Orange Belgium

Orange

Belgium

Annual report 2025

Orange

is here

Orange Belgium is one of the leading players in the

telecommunications market in Belgium and Luxem-

bourg (through its subsidiary Orange Communica-

tions Luxembourg).

Thanks to its own fixed and mobile networks, Orange

Belgium offers both residential and business cus-

tomers fixed and mobile connectivity services and

convergent offerings (internet, telephony, television,

including original TV content: Be tv, VOOsport, etc.).

Orange Belgium has 3.5 million mobile customers

and more than 1 million fixed broadband customers,

and operates top-quality mobile and fixed-line net-

works, which are constantly being invested in to re-

main at the cutting edge of technology in the sector.

We are the first telecom operator nationwide to offer

1 Gbps on the fixed network.

As a responsible operator, we invest to reduce our

ecological footprint and promote sustainable and in-

clusive digital practices.

Orange Belgium is also a wholesale operator, offer-

ing its partners access to its infrastructure as well

as a broad portfolio of connectivity and mobility ser-

vices, including offerings based on Big Data and the

Internet of Things (IoT).

Orange Belgium is a subsidiary of the Orange Group,

one of the leading European and African operators

in the mobile and internet access markets, and one

of the world leaders in providing telecommunication

services to corporate customers.

Orange Belgium is listed on the Brussels stock ex-

change.

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Orange Belgium

_

Annual report 2025

46

Management

report

72

Sustainability report

76

General information

118

Environmental information

144 Social information

188 Governance

197

Appendix

53

Corporate

Governance

Statement

03

Strategic report

03

Key ﬁgures

04

Chairman’s letter

06

CEO interview

10

General Secretary interview

13

Highlights 2025

14

Lead the Future

34

Orange Luxembourg

37

ESG Focus

220

Financial

Statements 2025

Contents

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Orange Belgium

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Annual report 2025

€

1,963.4

m

Revenues (-1.5 % yoy)

€

566.1

m

EBITDAaL (+4.0 % yoy)

€ 375.9

m

eCapex (excluding licence fees) (+2.1 %

yoy)

Key

ﬁgures

Financial

Operational

3.55

m

Mobile contracts excl. M2M (+2.5 % yoy)

+

86

k

Net adds - Mobile contracts excl. M2M

1.04

m

Cable customers (+1.8 % yoy)

+

18

k

Net adds - Cable customers

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Orange Belgium

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Annual report 2025

Johan

Deschuyﬀeleer

Dear team

members,

shareholders,

partners, and

customers,

Chairman’s letter

Orange is a company that stands for positive,

optimistic values, driven by a strong custom-

er-first mindset. You can see it at every level of

the organization, from our call centers and retail

shops to executive management. We feel it in

the goodwill our brand enjoys, both in the north

and the south of the country. This welcoming

spirit and drive to help customers, to meet

them where they are, understand their needs,

and respond to them, are part of our DNA and

remain a constant focus.

This positive attitude is also a key strength in

a highly competitive environment. At the end

of 2024, we prepared for the arrival of a fourth

entrant, and we came out stronger, thanks to

the remarkable work of the hey! teams. They

succeeded in building a strong and consistent

brand identity that clearly reflects the optimism

that defines us.

Optimism

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Annual report 2025

This assessment would not

be possible without a shared

and aligned vision. That is why

I want to thank the Orange

Group, the Board of Directors,

our shareholders, and all our

partners across the different

points of sale for supporting our

decisions. We are confident that

we can rely on their expertise

and that they contribute to the

climate of trust mentioned be-

fore.

More specifically, I would like to

express my sincere gratitude to

all managers and team mem-

bers at Orange Belgium for their

smooth collaboration, profes-

sionalism, positive attitude, and

individual contribution to the

successful harmonization this

year.

Last but not least, I want to

thank all Orange and hey! cus-

tomers for their trust and loyal-

ty. They are a powerful source

of motivation for our teams and

help create the conditions that

enable our continued progress

and this virtuous cycle of trust

and development.

Gratitude

Being part of a large interna-

tional group gives us a signifi-

cant advantage, both technical-

ly and in marketing. Customers

feel that, and it strengthens their

trust, which in turn reinforces

our own confidence in the future

and in our competitive position.

Through our different brands,

we can address the full range

of retail customer expectations,

while continuing to expand our

unique B2B offering.

While our mobile and fixed net-

works remain our core foun-

dation, cybersecurity and AI

are also key pillars that receive

ongoing focus and investment.

They will therefore be our priori-

ties for the year ahead.

Trust

Our customers are

a powerful source

of motivation

for our teams

and help create

the conditions

that enable

our continued

progress.

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Orange Belgium

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Annual report 2025

Xavier

Pichon

Interview

Chief Executive Oﬃcer

How do you look

back on 2025?

2025 was a dynamic year, and it helped us strengthen

several strategic directions that will shape the years

ahead. It built on our Lead the Future strategy and our

main transformation programs.

Our ambition remains unchanged: we want to play a

leading role across the entire Belgian telecom market.

To achieve that goal, we continued to roll out the three

pillars of our Lead the Future plan: leadership through

our assets, excellence in our operations, and the sus-

tainability of our business model.

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Annual report 2025

The first pillar of the

strategy focuses

on networks. What

progress did you make

on the fixed network?

In 2025, we modernized our Hybrid

Fiber Coaxial (HFC) network, a major

upgrade that enables 10 Gbps tech-

nologies, while also improving energy

efficiency and optimizing resource use,

in line with our sustainability approach.

These investments lay the foundation

for a more agile, reliable, and high-per-

forming network, capable of meeting to-

morrow’s requirements.

Beyond our high-performance HFC

network, fiber will become the core of

our infrastructure. Our goal is clear: by

2040, we will offer Fiber to the Premises

(FTTP) to two thirds of our footprint in

Wallonia and in six Brussels municipal-

ities, and HFC to one third of our foot-

print, to guarantee speeds of 10 Gbps

and above.

We formalized this ambitious goal

through a Memorandum of Understand-

ing with Proximus to extend fiber de-

ployment and promote access to giga-

bit networks in Wallonia. This agreement

reflects our shared commitment to mak-

ing fiber accessible to approximately

200,000 households and businesses in

lower-density areas.

Where do you stand on mobile

network development?

In 2025, we made significant progress on the Radio Ac-

cess Network (RAN) sharing project. We also modernized

our mobile network infrastructure to improve resilience,

while continuing our 5G rollout to reach 85 percent out-

door coverage nationwide. This included replacing out-

dated infrastructure with new towers made in Belgium.

We also deployed 5G coverage across all Brussels metro

stations, giving passengers seamless, reliable connectiv-

ity.

These efforts earned strong recognition. Ookla

®

con-

firmed Orange Belgium’s leadership in high performance

mobile connectivity by awarding us the prize for ‘Best 5G

Mobile Network’ in the market for the first half of the year,

as well as ‘Fastest 5G Network’ in Belgium in the second

and third quarters of 2025.

Our investments lay the

foundation for a more

agile, reliable, and high-

performing network,

capable of meeting

tomorrow’s requirements.

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Orange Belgium

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Annual report 2025

2025 was also a

turning point for

the B2B market

Since the acquisition of

VOO in June 2023, many

milestones have been

reached. What were the

highlights of 2025?

The integration of VOO was a large-scale and com-

plex project that required strong engagement from

our teams to ensure a smooth transition. 2025

played a decisive role in bringing the two organiza-

tions together.

Our ambition in the B2B market is clear: to

become the reference partner for telecom-

munications and ICT solutions for Belgian

companies.

That is why, in June, we launched a unified

B2B offering that brings together the ex-

pertise of Orange Belgium, Orange Busi-

ness, Orange Business Digital Services, and

Orange Cyberdefense. This unique value

proposition helps Belgian businesses ad-

dress major challenges: cloud adoption,

data and AI integration, stronger cybersecu-

rity, and high speed connectivity.

On

July 1, 2025

, we integrated all VOO employees

into Orange Belgium. This milestone aligned work-

ing conditions and created the right framework to

bring all team members together around a shared

vision.

On

October 1, 2025

, we completed the integration

process with the dissolution of the legal entity VOO

S.A. We transferred the assets and liabilities linked

to fixed network activities to Orange NetCo S.A., a

subsidiary fully owned by Orange Belgium. Orange

Belgium S.A. took over the remaining activities.

Finally, we began migrating VOO customers to our

Orange offers in 2025, on a voluntary basis. We sup-

port every customer throughout the process to en-

sure a seamless experience and offer solutions that

fit their needs.

Customer experience is a ma-

jor priority for Orange Belgium.

What initiatives have you im-

plemented to stand out?

This year, more than ever, we made customer ex-

perience excellence a central priority across the or-

ganization.

Since

July 2025

, we have integrated VOO stores

into Orange shops, so all customers can access

the best of both worlds in a single location: an even

warmer welcome, greater proximity, and a broader

range of services.

We adopted a proactive, multichannel approach,

using artificial intelligence to support our teams and

deliver differentiated solutions and a more person-

alized, seamless customer experience. In particular,

we automated certain customer service processes,

which allows our teams to spend more time on di-

rect interactions with customers.

Before developing a new offer or customer journey,

we now systematically create a digital prototype and

test it with a panel of customers. If we identify any

issues, we pause the project until we find a solution.

Our team members design the entire customer jour-

ney and all related processes, and they also test

them in real-life conditions. This helps us step back

from our actions, identify what works well, and im-

prove what does not.

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Annual report 2025

Our commitment

to a sustainable

future has two

dimensions

If you had to

summarize 2025 in

a few words, what

would you say?

2025 was a defining year as we

strengthened the leading position we

intend to hold in the Belgian market.

It was a year of major achievements

and successes. But nothing would

have been possible without the com-

mitment and professionalism of all our

people. I want to extend my sincere

thanks to them, because each of them

contributed, in their own way, to our

shared successes.

What are the main

objectives for 2026,

and how do you look

ahead to the new

year?

We will keep highlighting the quality of

our network and make the necessary

investments to modernize the HFC

network and deploy FTTP, so we can

offer customers seamless connectivi-

ty through ultra high performance net-

works.

We will strengthen our security ca-

pabilities through our comprehensive

‘Cyber Master Plan’ approach, so we

can provide customers with an opti-

mal level of cybersecurity.

Customer satisfaction will continue to

guide our priorities, with excellence in

customer experience serving as our

daily driver. We will also highlight our

capacity to innovate, relying on Gen-

erative AI, a true revolution for both

our customers and our employees.

Finally, we will maintain our commit-

ment to society by giving everyone the

tools to participate in a responsible

digital world.

Together with the management team

and all Orange Belgium employees,

we enter this new year with deter-

mination and enthusiasm, ready to

show the Belgian market that in 2026,

Orange is here.

The third pillar of the

strategy focuses on a

sustainable business

model. What are your

objectives in this

area?

First, Orange Belgium contributes to

the Group’s target to reach net zero

carbon by 2040. In 2025, we focused

on reducing emissions linked to our

own operations. We accelerated the

electrification of our fleet, ensured that

100 percent of our electricity consump-

tion came from renewable sources, de-

ployed energy saving features on the

mobile network, and decommissioned

outdated antennas. As a result, in 2025

our CO

2

emissions, scopes 1 and 2,

decreased by 16 percent compared

with 2024. When we include scope 3,

the reduction reaches 8 percent.

Second, we want to give everyone the

tools to participate in a responsible

digital world by acting through four

essential pillars: protection, employ-

ability, education, and entrepreneur-

ship. Under the #ForGoodConnec-

tions banner, Orange Belgium actively

works to protect young people from

digital abuse. In October, we launched

the ‘Smartphone Pass’, a free platform

that supports parents in guiding their

children’s digital education when they

receive their first smartphone. The

platform aims to encourage dialogue

between parents and children on top-

ics such as screen time, privacy, on-

line safety, and cyberbullying.

In 2026, we will

continue our

work to deliver

on our strategic

ambitions

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Orange Belgium

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Annual report 2025

Paul-Marie

Dessart

Secretary General

This year, we succeeded in maintaining the right bal-

ance between staying true to our strategic direction

and demonstrating the agility required in an ultra-com-

petitive and constantly evolving sector such as ours.

To highlight three major milestones from 2025: the

establishment of the foundations for Orange Netco,

which will be ready for roll out in 2026; the Memoran-

dum of Understanding signed with Proximus, enabling

us to ensure a rational and sustainable deployment

of our network; and the exemplary completion of the

VOO integration, particularly with regard to the harmo-

nization of working conditions.

I would especially like to commend the employee rep-

resentatives for their work on harmonizing working

conditions as part of the VOO integration. This required

in-depth effort and lengthy, pragmatic discussions that

did not shy away from addressing various constraints.

Today, all our teams benefit from the same conditions,

laying the groundwork for healthy collaboration and a

positive working environment.

What

achievements

from 2025

stand out to

you?

Interview

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Annual report 2025

2025 was a

year that was

both rich and

consistent

The creation of Orange Netco marks an im-

portant step in implementing our fixed net-

work strategy for the years ahead. By es-

tablishing this entity, we have laid out the

groundwork for fiber deployment, which will

allow us to accelerate our progress in fixed

networks, replicating the success we have

achieved in mobile, particularly with 5G this

year. Developed from assets previously held

by VOO and Orange Belgium, Orange Netco

now owns the HFC and fiber access network

of Orange Belgium and will manage its com-

mercialization. At the same time, we have

mobilized our teams to ensure maintenance

and adjustments for the cable network, and

we are working to clearly define resource al-

location and governance between Orange

Netco and Orange Belgium, particularly in

terms of commercialization and subcon-

tracting. This will enable the deployment of

technical and industrial network projects and

make 2026 a year of consolidation.

Is this ability to streamline

your processes what

sets you apart from the

competition today?

After such a significant

project as the VOO

integration, what are your

challenges for 2026?

Yes, absolutely. The decommissioning of 3G

during the year and the implementation of

RAN-sharing have enabled us to optimize our

network management, meeting the growing de-

mand for data while also achieving our sustain-

ability objectives. We intend to apply this same

thoughtful, measured, and efficient approach to

fiber deployment, using a passive deployment

model that streamlines the network for the ben-

efit of all.

This operational agility was also our greatest as-

set in overcoming the cyberattack summer 2025

with resilience. While the incident did not involve

sensitive data, it was nonetheless significant in

scale and left a lasting impression. While we are

aware of the crucial importance of this issue for

a telecommunications operator, and we ensure

that our IT teams remain fully trained in this area,

we also saw it as an opportunity to get even

more rigorously back on track, with the definition

of new processes and the establishment of a ful-

ly dedicated security division that brings togeth-

er the various IT and network forces.

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Annual report 2025

A genuine

commitment

from Europe

would enable us

to realize our full

potential

In 2024, you called

for a reform of

telecommunications

regulations in Europe.

Are you satisfied with

the progress made

this year?

We have begun working with various teams to

meet the initial deadlines of European regula-

tions related to the digitalization of the economy.

While awaiting further government measures,

we are already addressing major issues such as

cybercrime, cybersecurity, and data protection.

These are essential for consumer protection, but

I would have also welcomed stronger European

support to help us compete with countries like

China and the USA, where a less fragmented

market allows for economies of scale and great-

er competitiveness.

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Orange Belgium

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Annual report 2025

Highlights

2025

January

March

Ookla

®

recognizes Orange Belgium as the

operator oﬀering

the best 5G mobile

network in Belgium,

underscoring the company’s sustained

leadership in mobile experience and network

performance.

October

November

July

June

Orange uniﬁes its sales

front and strengthens its

B2B portfolio, combining

the expertise of Orange

Belgium, Orange Business,

Orange Business Digital

Services, and Orange

Cyberdefense.

This strategic move creates a market-leading

end-to-end oﬀering across connectivity, cloud,

AI, and cybersecurity, marking a key milestone

in the company’s ‘Lead the Future’ strategy.

Orange Belgium and Proximus

sign a Memorandum of

Understanding to

expand ﬁber

deployment

in Wallonia,

accelerating access to gigabit

connectivity for households and

businesses.

hey!

hosts a large-scale

AI Hackathon at

BeCentral

,

bringing together more than

90 students who developed

innovative AI concepts over

two days. Team 5 won with

an Intelligent Virtual Assistant

prototype designed to strengthen

hey! telecom services.

Orange Belgium modernizes

its 1 Gbps ﬁxed network by

deploying a Distributed Access

Architecture (DAA),

boosting

future-proof

connectivity

and enhancing performance

across its high-speed footprint.

VOO S.A. becomes

fully integrated into the

Orange Belgium Group

,

completing the ﬁnal step of the

cquisition. The VOO brand and oﬀers

remain unchanged, ensuring

full continuity for customers.

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Orange Belgium

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Annual report 2025

Lead the Future

2

Capitalizing

on our

infrastructure

1

PILLAR

Capitalizing

on our

core business

Nationwide gigabit

and multigigabit

networks

leadership

Mobile

- 5G frequencies (capacity and speed)

- 5G Core SA (reliability and B2B

services)

- RAN Sharing agreement (coverage)

Broadband

- South: powerful HFC & FTTH network

modernized towards state-of-the-art

standards

- North: HFC & FTTH Wholesale

agreements

Customer

experience

excellence

Multisegmented service offering

- Consumer Premium segment

- Consumer Access segment

- Business segment

(Re)internalization of major servicing assets

- Customer’s call servicing

- Mastering of IT skills and tools

Expand customer data and AI knowledge

capabilities

- Meaningful brand

- Tailored value propositions

- Local approach

We care

for People

& the Planet

Future proof ESG enterprise

model

- Net zero carbon operator

- Digital inclusion

Preferred tech & telco employer

- Attractive industrial project and

HR policy

- Tech talents development

- Diversity & inclusion

New

enterprise

model

PILLAR

3

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Orange Belgium

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Annual report 2025

Philippe

Toussaint

Chief Technology Oﬃcer

How has

Orange

Belgium’s

mobile

network

evolved in

2025?

Orange Belgium’s Lead the Future strategy is built around three

key pillars: developing ultra-high-performance multi-gigabit net-

works, creating an excellent customer experience, and establish-

ing a sustainable business model. 5G is a core element of these

pillars, reflecting our commitment to building networks that are not

only faster but also more reliable and sustainable, serving both

consumers and businesses.

This is why, in 2025, we made significant progress on the RAN-shar-

ing project, merging 4,000 of our 4,600 sites and achieving over

85% of 5G coverage. We also modernized our mobile network in-

frastructure to strengthen resilience and expand 5G capacity. This

included replacing outdated towers with new ones and completing

5G coverage across all metro stations in Brussels, which provides

passengers with seamless and reliable connectivity, even under-

ground.

The results were immediate: based on data from the first half of

2025, Orange Belgium was recognized by Ookla

®

as the Belgian

operator offering the best 5G mobile network, with a Speedtest

®

connectivity score of 69.60. This score reinforces key indicators

that most directly reflect user experience, from speed and re-

sponse time to browsing and streaming quality.

Interview

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Orange Belgium

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Annual report 2025

How will you

consolidate this

leadership?

Today, 5G primarily operates

in

Non-Standalone

(NSA)

mode, relying on the existing

4G core infrastructure. At the

end of 2025, we completed

our very first VoNR (Voice over

New Radio) call: a 5G phone

call on our 5G new core infra-

structure that does not require

fallback to 4G. The goal?

Faster call setup, superior

audio quality, lower latency,

no forced switch back to 4G

during calls, wider bandwidth,

multimedia capabilities, en-

hanced security, and greater

network flexibility. 5G core

functions pave the way for

major advances such as net-

work slicing, allowing us to di-

vide our 5G network into mul-

tiple ‘virtual’ networks, each

tailored to specific needs and

increased security.

In 2025, Orange Belgium, to-

gether with Nokia, completed

a joint test on our live net-

work, validating the upper 6

GHz band for future capacity

needs. Real-world measure-

ments confirmed this band as

a key enabler for 5G and fu-

ture 6G applications, deliver-

ing multi-gigabit speeds and

strong indoor coverage. This

concrete experiment demon-

strates our ability to anticipate

growing data traffic and fu-

ture-proof our network, pav-

ing the way for higher speeds,

greater capacity, and more

sustainable high-performance

connectivity in Belgium and

beyond.

Finally, the successful 3G

shutdown, executed by our

technical teams and part-

ners, freed up the spectrum

for smarter, faster, and more

sustainable

networks.

Fre-

quencies previously used for

3G were reallocated to more

efficient 4G/5G applications,

improving

network

perfor-

mance, reducing energy con-

sumption,

and

simplifying

operations, particularly main-

tenance.

Our mission is simple:

deliver the best

connectivity experience

for our customers,

across both mobile

and broadband. Faster

setup times, improved

audio and video quality,

lower latency, seamless

services, expanded

bandwidth, advanced

multimedia capabilities,

stronger security, and a

more ﬂexible network—

all working together

to redeﬁne everyday

connectivity.

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Orange Belgium

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Annual report 2025

What is the plan

for fixed network

development?

As outlined in our ‘Lead the Fu-

ture’

strategy,

by

2040

Orange

Belgium aims to cover two-thirds

of its fixed network in Wallonia and

six Brussels municipalities with Fib-

er to the Premises (FTTP) and one-

third with Hybrid Fiber Coaxial (HFC)

technology, preparing for speeds of 5

Gbps and 10 Gbps.

We are currently finalizing our FTTP pi-

lot in the municipality of Ixelles in the

Brussels region, enabling our teams

to validate their approach and select

the most suitable materials for the up-

coming large-scale rollout, which will

progressively replace part of our HFC

network to deliver improved perfor-

mance and greater efficiency.

Having

achieved 1 Gbps capability across our

fixed network, we are now consolidat-

ing it through the deployment of Dis-

tributed Access Architecture (DAA).

This key milestone decentralizes and

virtualizes core network functions,

enhances stability and efficiency, and

enables the evolution toward 10 Gbps

technologies.

We have driven

innovation

and delivered

new customer

experiences

What innovation are

you most proud of in

2025?

In 2025, Orange Belgium launched its

first Network APIs (Application Pro-

gramming Interfaces) on the Orange

Developer Portal. These APIs, includ-

ing KYC Match, SIM Swap, and Num-

ber Verification, establish and promote

common standards to provide univer-

sal access to operator networks for

developers and hyperscalers. They

also deliver secure digital identity and

verification solutions, key tools in com-

bating fraud and enhancing security.

Representing a strategic and trans-

formative opportunity for Orange,

these APIs boost innovation and

create new customer experiences

through programmable networks and

advanced features, highly sought after

by businesses who seek more secure,

data-driven solutions.

In retrospect, what

drove the success of

our mobile and fixed

network evolution

initiatives?

All these improvements, made possi-

ble by our teams, were reinforced by

the transition to a One Team techni-

cal approach —bringing together the

complementary strengths of Orange

Belgium and VOO telecom exper-

tise— enabling our teams to leverage

deep knowledge while benefiting from

the support of the Orange Group.

We have

prepared to

structurally

accommodate

increasing

network traffic

17

Orange Belgium

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Annual report 2025

Werner

De Laet

Chief Enterprise Oﬃcer

2025 truly marked

a turning point for

Orange Belgium’s

B2B strategy and

offerings, would you

not agree?

Interview

Indeed. The combined expertise of

Orange Belgium, Orange Business,

Orange Business Digital Services

and Orange Cyberdefense has cre-

ated a powerful synergy that no

other telecommunications operator

in Belgium can offer to SMEs, (mul-

ti)national companies, or public or-

ganizations. With a unified market

approach, this coalition is launching

a range of cutting-edge products

and services, aiming to capture the

Belgian B2B market by going be-

yond traditional connectivity solu-

tions.

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Orange Belgium

_

Annual report 2025

In 2025, we

established

ourselves as THE

leading partner

for connectivity

and cybersecurity

solutions for

Belgian businesses

With this new phase in our Lead the Future strategy, we are delivering a unique

B2B value proposition to meet both current and future needs in ICT, connectivity,

and cybersecurity. To achieve this, we have chosen to prioritize modular solutions

over fully bespoke ones, enabling us to meet the expectations of a broader audi-

ence, as these solutions address 90% of the needs expressed by the ICT industry.

In response to an increasingly fragmented ICT landscape, Orange now uniquely

offers and manages six industry-leading value propositions in the Belgian market

to ensure the digital success of businesses:

Cloud Avenue:

An end-to-end sovereign

cloud solution with data

hosted within the EU

Micro-SOC:

Enables SMEs to benefit from

a Security Operations Center

without the complexity of

managing it themselves,

while enjoying expert and

responsive protection

Contact Centre as a

Service:

A transparent, integrated

customer communication

platform with AI-driven

insights

Critical

Communication:

Reliable, priority-based

multichannel communication

platforms

Evolution Platform:

A simplified management

service for composing,

deploying, and adjusting

connectivity, cybersecurity,

and cloud services on

demand

Live Intelligence:

A secure, sovereign AI

platform for intelligent

business collaboration

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Orange Belgium

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Annual report 2025

We have a

responsibility to

communicate about

the sustainability

of digital tools and

to ensure their

sovereignty

We are entering an

unprecedented phase

of convergence

between the

telecommunications

and IT sectors

With the democratization of AI,

growing

geopolitical

pressures,

and the uncertainties they bring,

we are preparing for an even more

digital, ‘AI-delivered’ future. In this

matter, we have developed a range

of enabling solutions, along with a

unified interface that communi-

cates the use of these tools and

raises awareness of their risks.

This organizational transformation

brings us greater efficiency and

allows us to offer highly compre-

hensive solutions, significantly ex-

panding our portfolio.

Like every company, Orange Bel-

gium faces a substantial increase

in data, data exchanges, and the

use of energy-intensive technolo-

gies such as AI. It is therefore es-

sential for us to communicate on

these issues, to raise awareness

about their use, and to guide cli-

ents towards more energy-efficient

and secure products, such as Live

Intelligence, which we aim to make

available to our customers. At the

same time, we are migrating to-

wards European solutions to guar-

antee the highest levels of security,

protection, and sovereignty across

our B2B offerings.

What role do you

see for artificial

intelligence?

What are you most

looking forward to

in the coming year?

Building on the solid foundations established this year,

we are moving into a unique phase of strategic execu-

tion, with more modular ICT services, intensified col-

laboration with other Orange subsidiaries, an enhanced

B2B commercial approach, and the integration of AI into

our various working methods. These various initiatives

will strengthen our position, supported by a major group,

in the face of competition.

20

Orange Belgium

_

Annual report 2025

Orange

Business

21

Orange Belgium

_

Annual report 2025

A unified sales

front to conquer

leadership in

the Belgian B2B

market

In today’s rapidly evolving business landscape,

Orange recognizes that strong, strategic, and

integrated partnerships are crucial for B2B

success. Drawing on the Group’s innovation and

technical expertise, Orange therefore combines

the strengths of Orange Belgium, Orange

Business, Orange Business Digital Services,

and Orange Cyberdefense in Belgium. With a

unified go-to-market approach, the coalition

of these entities offers a range of new, cutting-

edge products and services to conquer the B2B

market in Belgium.

In order to tackle the complexities of cloud

adoption, data and AI integration, escalating

cybersecurity threats, and the demand for high-

speed connectivity, companies can now finally

find a partner that offers a streamlined approach

to secure innovative growth, elevate customer

interactions and empower employees, all

supported by an advanced digital infrastructure.

Multi-gigabit networks and added value servic-

es powered by Orange Belgium, ensuring supe-

rior connectivity as a frontrunner in 5G SA busi-

ness use cases in Belgium.

Digital transformation acceleration and cloud

infrastructure expertise from Orange Business,

offering sovereign cloud-networking solutions.

Innovation in data and AI from Orange Business

Digital Services, making the next technological

revolution a tangible reality for businesses: 450

data specialists in Belgium that can leverage on

pan-European teams of more than 4,000 spe-

cialists.

Superior cybersecurity services from Orange

Cyberdefense, with its Belgian based security

operation center (SOC), providing robust de-

fense against the growing number and com-

plexity of threats through global monitoring and

local handling.

It works

better

when it

works

together

22

Orange Belgium

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Annual report 2025

Cybersecurity:

responding to

rising threats

Cloud: meeting

growing concerns

around data

sovereignty

With ransomware attacks on SMEs ris-

ing by 53% in a year,

cybersecurity is

a central pillar of Orange Business’

strengthened portfolio

.

Through Orange Cyberdefense, Orange

Business provides advanced protec-

tion via a Belgian-based SOC, com-

bining

global threat intelligence with

local handling capabilities

.

The Micro-SOC solution offers 24/7

threat detection,

monitoring and ex-

pert assistance for Belgian organi-

zations

.

With 50% of businesses concerned

about their data in the cloud,

sov-

ereign and compliant cloud solu-

tions

became a major priority in

2025.

Orange Business strengthens its

cloud offering

with Cloud Avenue,

an end-to-end EU-hosted cloud

solution designed to meet strict Eu-

ropean data regulations.

Evolution Platform simplifies the

management of cloud, connec-

tivity and cybersecurity services,

supporting companies that want

more control and agility

.

23

Orange Belgium

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Annual report 2025

Our commitment to

accelerating digital

success is more than

just a statement, it’s a

fundamental framework

of our Lead the Future

strategy. Our seamlessly

integrated solutions

across connectivity,

cloud, and cybersecurity

form an unrivalled

client proposition on

the Belgian market.

Companies in Belgium

now finally have the

leading partner they were

seeking to thrive in the

digital age.

AI: enabling

secure and

sovereign AI

adoption

5G: preparing

businesses for

new applications

With an expected 32% annual growth

in applications built on 5G and net-

work infrastructure by 2027,

connec-

tivity remains a strategic priority

.

Orange Belgium’s multi-gigabit net-

works and leadership in 5G technology

provide the foundation for

next-gen-

eration business applications

.

The Critical Communication solution

delivers reliable, priority-based

mul-

ti-channel

communication

plat-

forms

.

With 51% of businesses now using AI,

twice as many as last year,

Orange

Business reinforces its AI capabil-

ities

to support organizations adopt-

ing these technologies securely.

The Live Intelligence platform pro-

vides a

secure and sovereign envi-

ronment

for AI-driven collaboration

and business applications.

Contact Centre as a Service enhanc-

es customer communication with

AI-driven insights, helping business-

es

modernize interactions across

multiple channels

.

24

Orange Belgium

_

Annual report 2025

Christophe

Dujardin

Chief Consumer Oﬃcer

How do you

evaluate the

telecom market

changes

and Orange

Belgium’s

strategic

approach in

2025?

The entry of a new competitor disrupted the market this year,

but the strategy we had carefully prepared well in advance

and swiftly implemented upon their arrival has proven its true

value and effectiveness. Faced with the challenge of a new

player with an aggressive price positioning, we had proac-

tively anticipated multiple strategic scenarios, which allowed

us to demonstrate exceptional agility, and the results speak

for themselves.

Our primary objective is always to anticipate market trends

and customer expectations, allowing us to stay ahead of

the curve. Rather than merely reacting to external pressures

or industry shifts, we focus on continuously enhancing the

overall consumer experience. This strategic mindset has

enabled us to deliver innovative solutions and personalized

services that truly meet the demands of our customers, fos-

tering long-term loyalty and satisfaction.

As we conclude the year, we are further strengthening this

forward-looking strategy, focusing on competition, techno-

logical advancements, and commercial innovations. By bal-

ancing reactivity with proactivity, short-term agility with long-

term vision, we are able to expand and improve our offers

and services, enhancing the overall customer experience

and reinforcing customer loyalty.

Interview

25

Orange Belgium

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Annual report 2025

‘Orange is here’

is a premium

experience that

supports the

daily lives of all

our customers

How has the company

distinguished itself in

the areas of customer

experience and offerings?

At Orange Belgium, we consistently adopt a pro-

active approach to ensure that our brands, ser-

vices and offerings are closely aligned with the

changing and evolving needs of our customers.

The position of our digital brand hey! remains a

key reference among budget friendly telecom-

munications offerings in Belgium. Its strength lies

in its ability to deliver uncompromising quality at

smart, accessible prices, along with ultra-clear

offers, proving that customers do not have to

choose between value and quality. I take this

opportunity to congratulate the hey! teams, who

keep pushing the boundaries with our ‘incredibly

smart’ brand, combining simple, generous and

reliable value propositions with impeccable ser-

vice quality.

The strength of the Orange brand lies in value

propositions that combine quality and meaning-

ful experience, at different price points, com-

plemented by flexible and tailored commercial

packages that span the entire value chain. This

approach is supported by a broad network of

physical stores and a comprehensive range of

premium services, such as Mobile Serenity, WiFi

Comfort or My Comfort Service, offering peace

of mind and personalized customer support. In

terms of customer experience, this commitment

is reflected in achieving the highest Net Promot-

er Score (NPS) in the market for both multi-ser-

vice customers and mobile-only users.

Furthermore, before developing any new offer

or customer journey, we systematically create a

digital prototype. This allows us to identify po-

tential improvements through a panel of testers.

Since this year, we have also been conducting

end-to-end real-life testing, which provides an

even finer analysis of areas for improvement, es-

pecially concerning the quality of fixed and mo-

bile services.

But what really sets Orange apart is how we bring

our promise, ‘Orange is here’, to life: we deliver a

genuinely premium experience that supports our

customers’ daily lives, providing them with the

best possible solutions – from mobile and inter-

net services to TV and cybersecurity.

Over the past year, we have again introduced

several services that add significant value for

our customers: a free six-month trial of ‘Le Chat

Pro’, the virtual assistant developed by French

company Mistral AI; the free addition of the Uni-

versal+ catalogue for Orange TV Family sub-

scribers; a revamped Orange Sport TV pack-

age dedicated

to international sports; and an

upgraded Prepaid Tempo mobile offer. We also

partnered with the Gezinsbond and La Ligue des

Familles, giving our customers the opportunity

to get a trial membership for multiple months,

with access to tips and advice on upbringing,

and discounts with over 2,000 businesses.

Embodying ‘Orange is here’ also means inte-

grating digital security into our product offerings.

That is why we created the Smartphone Pass, a

free platform enabling pre-teens and their par-

ents to test their digital knowledge via quizzes

and discover best practices and pitfalls to avoid.

Through the Orange Thank You loyalty program,

1,000 Orange customers received six months

of exclusive free access to the premium version

of DConnect, an innovative app helping families

limit daily screen time by suggesting practical al-

ternatives.

Lastly, we integrated the anti-spam app Orange

Telephone into the My Orange app. Based on

community data, it adapts in real time to inform

and protect our clients from phone scams and

unwanted calls.

26

Orange Belgium

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Annual report 2025

Clearly it is Artificial Intelligence. With this revolution-

ary technology making a strong entrance into our lives,

we are firmly committed to leveraging it in the service

of people. In 2025, we began integrating AI into the

automation of certain customer service processes,

which allowed us to increase the time spent directly

with customers and provide more personalized sup-

port. AI also enables us to conduct comprehensive

meta-analyses of call center satisfaction, helping us

identify areas for improvement and proactively ad-

dress customer concerns. During maintenance works,

it also allows us to communicate more effectively with

affected customers, keeping them informed and re-

assured. Additionally, AI helps us to better target mo-

bile network investments by analyzing and focusing

on areas experiencing congestion, ensuring a better

end-to-end quality of service for all users.

Beyond AI, we place an ever-greater importance on

delivering seamless, reliable connectivity and sup-

port that meet the highest standards of quality and

customer satisfaction. This includes first-rate fixed,

TV and mobile services, ensuring rapid, high-quality

installations, quick and effective repairs in case of out-

ages, and coverage in every room of our customers’

homes. To conclude, I can honestly say that in 2025

we again made significant progress and delivered on

overall experience and value.

What was the

most important

driver of customer

experience

innovation for the

company in 2025?

Our customer

service is

empowered by

cutting-edge

technologies

that enhance the

human touch

27

Orange Belgium

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Annual report 2025

Nathalie

Rahbani

Acting Chief Brand,

Communication & ESG Oﬃcer

What do you

think is the

societal role

of a telecom-

munications

operator?

Telecommunication is an integral part of our daily

lives, enriching us and providing innovative solutions

that simplify how we live, work, and connect. From

checking emails and browsing the news to using AI

to summarize a contract, finding a well-rated restau-

rant, or streaming a favorite show before bed, tech-

nology surrounds us and keeps us constantly con-

nected. Yet, while being ‘always on’ offers countless

benefits, it also highlights the importance of discon-

necting when needed, building a responsible digital

world and ensuring equal opportunities for all. Today,

the line between mobile and broadband is disappear-

ing—everything flows seamlessly, driving us forward.

However, not everyone has equal access to this con-

nectivity, and this is where our societal responsibility

as a telecommunications operator becomes essen-

tial. Promoting digital inclusion is a priority, ensuring

that no one is left behind and that everyone has ac-

cess to the transformative power of technology.

Interview

28

Orange Belgium

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Annual report 2025

Technology

must serve

everyone without

distinction

#ForGoodConnections

Making every

connection positive

Orange’s societal role goes beyond bridging the digital

divide. Our ambition is to maximize the positive impact

of access to telecommunications services by creating a

more inclusive and responsible online environment, giv-

ing everyone the keys to a safer and more equitable dig-

ital world. This role includes ensuring technology serves

all, protecting customers—especially younger users —

and helping everyone find a healthy balance between

being ‘always on’ and knowing when to disconnect.

To translate this ambition into concrete action, Orange

Belgium supports and develops programs and initiatives

that empower individuals with the knowledge and tools

to use technology safely, confidently, and responsibly.

In 2025 nearly 13,000 beneficiaries were supported—a

31% increase from the previous year—through initia

-

tives designed to assist the most vulnerable. Our own

employees can enrol in the ‘Digital Buddies’ program,

helping seniors to gain autonomy in using digital tools.

The year 2024 saw the launch

of the ambitious ‘For Good

Connections’ program. How did

you expand the project to meet

the scale of demand in 2025?

With our #ForGoodConnections program, we are com-

mitted to supporting young people and their parents

in the proper use of digital technology, promoting safe

and responsible online behaviors. The program raises

awareness about key issues such as cyberbullying,

excessive screen time, and inappropriate content. In

this context, we held conferences on cyberbullying for

nearly 6,000 students, featuring the Belgian film TKT

that tackles the impact of cyberbullying among teen-

agers. We also launched the Smartphone Pass, a free

platform designed to help parents and children to turn

the moment of getting a first smartphone into a shared

learning experience. The platform covers topics includ-

ing cyberbullying, data privacy, critical thinking about

AI, and managing screen time, helping families navigate

the digital world safely and confidently.

29

Orange Belgium

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Annual report 2025

For many years, you have allowed

your clients to exchange their

loyalty points for charitable

donations. How much was raised

in 2025?

We are proud to be able to count on the trust of many

customers who are loyal to the brand and its values,

and who are warmly rewarded through our ‘Orange

Thank You’ loyalty program. The program offers sur-

prise gifts on special occasions, as well as exclusive

benefits. Customers also have the option to choose to

donate their loyalty bonus to a charity of their choice.

Last summer, almost 25,000 customers donated a total

of €51,714, of which €10,246 to ‘La Ligue des familles’

and €20,328 to ‘Gezinsbond’, as well as various other

charities. ‘Orange Thank You’ really reflects our shared

commitment to sustainability, protecting nature, pro-

moting a digital world for all, and the well-being of fam-

ilies.

Sustainability is on

e of Orange

Belgium’s strategic pillars,

from equipment recycling to

responsible data management.

What goals were achieved in

2025

?

By strengthening our data management and combining

qualitative and quantitative information, we successfully

delivered our first CSRD report at the start of 2025. This

milestone provides stakeholders with clear and measura-

ble insights into our sustainability actions — an essential

pillar of the Group’s ESG strategy. In 2025, we also rein-

forced our commitments in line with Orange’s ‘net zero

emissions’ target by 2040, making measurable progress

in energy, emissions, circular economy, and data govern-

ance.

For example, we increased fleet electrification from 18%

to 38%, developed the Legal Mobility Budget, dismantled

obsolete antennas, and ensured that 100% of our elec-

tricity comes from renewable sources. We also enhanced

ESG criteria for our suppliers and collected 59,600 mo-

bile phones via our RE program, which promotes the

collection, refurbishment, recycling, and resale of mobile

phones and devices to extend their lifespan and support

the circular economy.

Looking ahead to 2026, we plan to further strengthen

decarbonization efforts, expand circular economy pro-

grams, and deepen purchases based on ESG criteria,

maintaining momentum toward the goal of ‘net zero

emissions’ by 2040.

What is your motto for 2026 and

beyond?

In a world of uncertainty, Orange remains a beacon

of trust and positivity. Our commitment goes beyond

connectivity; it is about creating meaningful connec-

tions. Through our positive power, we can ensure im-

pact, make a difference in our customers’ lives and

help them move forward. An inclusive, safe, and con-

nected world starts with trust and optimism.

Orange Thank

You: turning

customer

loyalty into

social impact

From

commitment

to action:

our CSRD

milestone

30

Orange Belgium

_

Annual report 2025

Jelle

Jacquet

The past years were

strongly marked by

extensive work to align

working conditions

between VOO and

Orange employees.

Did this succeed in

creating the expected

team spirit?

Chief People Oﬃcer

Our keyword for 2025 was

‘

Act as One

’

moving Orange Belgium from One team

to One employer. Historically, VOO grew

in a patchwork manner through several

acquisitions that were never unified, re-

sulting in the coexistence of up to eight

different systems. Our ambition there-

fore was to create internal fairness and

simplicity within teams, smoothening the

differences and strengthening a shared

culture of performance, whilst ensuring

our attractiveness and competitiveness

on the market. Discussions with the un-

ions were constructive, and we were able

to work step by step, taking into account

the implementation phase until mid-

2025.

Interview

31

Orange Belgium

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Annual report 2025

Can you concretely

illustrate the company’s

commitment to gender

equality and diversity?

What specific actions

are you taking?

We worked

on our

attractiveness

while

protecting the

organization’s

productivity

With the assurance of fair treatment of their

performance, the teams were able to engage

in healthy, calm, and equitable collaboration.

Put differently, we removed the frustrations that

could hinder the development of a true team

spirit, which is the primary driver of engagement

in any project. These results were confirmed by

solid scores showing from

‘

Your Voice

’

our major

internal engagement and pride survey, as well as

by our ability to attract new talent.

For the past 15 years, we have been GEEIS

certified (

Gender Equality European & Inter-

national Standard

), an international standard

that encourages us to implement concrete

tools to strengthen our inclusion and equal

opportunity strategy. At the end of 2025, fol-

lowing an in-depth audit, we were once again

certified for the next four years, with con-

tinued increasing scores. This recognition

reflects our ongoing commitment to gender

equality and diversity within our organization.

To give a few concrete examples we ensure

there are no gender pay gaps, we promote

the feminization of management, we support

initiatives aimed at increasing the number of

women in tech (Tech Academy, Women in

Tech, Girls in ICT Days, Summer Schools),

we run the Orange

‘Women Up

’

program,

and we participate in external networks such

as BeCode and Agoria.

We are

building a

corporate

culture that

integrates

our values

of equity,

particularly

gender equity

32

Orange Belgium

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Annual report 2025

You identified three corporate

values: to be caring,

responsible, and bold. How

did they evolve in 2025?

Identified through internal surveys, our three values

of being caring, responsible, and bold are the result

of a bottom-up process reflecting the strengths we

aspire to embody and promote. This co-creation,

true to Orange’s DNA, confirmed the Group’s values.

This year, with more than 90% of team members de-

claring they know and support the newly launched

values, we integrated

them for the first time into our

performance cycle, while continuing to develop them

through workshops that allow us to assess how well

we embody them and how we can do so even better.

The challenges

ahead of us

are profoundly

human

We use our

three values

as guiding

principles for

behavioral

outcomes

How can you remain

competitive as a tech

employer in a rapidly changing

world?

Facing a near future of work in which all jobs will be

redesigned - not eliminated - by AI-driven innovation,

we need to reinvent our continuous learning strate-

gies. We are working on our skills intelligence, allow-

ing individuals and teams to map and steer their skill

development. Not only to adopt AI and automation,

but also to cherish what is uniquely human, combin-

ing scalable productivity and human creativity and

critical thinking.

33

Orange Belgium

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Annual report 2025

Chief Executive Oﬃcer Orange Luxembourg

Orange

Luxembourg

Corinne

Lozé

Orange Luxembourg strengthened

its leadership in the telecom market

in 2025 through major investments

in next-generation connectivity and

digital innovation. The company

expanded its fiber offering and

completed the nationwide rollout

of its 5G network, enhancing

performance and reliability

for customers. Alongside new

digital services and strengthened

cybersecurity solutions, Orange

Luxembourg also focused on

customer satisfaction, partnerships

in sports and eSports, and initiatives

that promote digital inclusion and

sustainability.

Corinne Lozé, Chief Executive

Officer, shares her insights on

the new solutions offered.

We are reaffirming our position in fiber

optics in Luxembourg by offering ever

more innovative and high-performing

solutions. In 2025, we expanded our

Fiber Internet portfolio to better meet

the growing demands of our customers

and the evolving market. We now offer

packages at 1 Gbit/s and 8.5 Gbit/s,

along with the launch of our new tri-

band Livebox 7 and the rollout of WiFi

7. We are proud to currently be the

only provider offering this cutting-edge

technology, a distinction confirmed by

our victory at the Ookla’s Best Fixed

Network Awards™ last July, attesting

to the best fiber connectivity on the

Luxembourg market.

To go even further, at the end of the

year we launched Fiber to the Room

(FTTR), a first in the Grand Duchy. This

innovative solution allows fiber to be

deployed in every room without con-

struction work, even in complex envi-

ronments where thick walls can hinder

connectivity. These advances illustrate

our determination to maintain our lead-

ership and offer our customers an un-

paralleled fiber experience.

34

Orange Belgium

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Annual report 2025

A next-generation

mobile network

with Nokia,

strengthening our

network’s reliability

In the first half of 2025, we completed the renewal of

all our mobile antennas and rolled out 5G coverage

across the whole of Luxembourg. These investments

enhance the quality and reliability of our network, pro-

viding our customers with an ever smoother and more

connected experience.

Consolidated

customer

satisfaction,

verified by Kantar

More digital

services with

eSIM and an

innovative

app

According to a Kantar study, 4 out of 5 customers say

they are satisfied with Orange, thanks to the quality of

our offers, our loyalty program, and the customer ex-

perience we provide. We do everything possible to stay

close to our customers, whether in-store, via our multi-

lingual customer service, or through WhatsApp. For our

business customers, our dedicated service guarantees

efficient and tailored support.

At the beginning of 2025, we

launched the eSIM Transfer feature,

reinforcing our position as an innova-

tive operator. In the summer, we also

introduced the ‘Hello eSIM’ app, a

simple and flexible solution allowing

users to easily purchase and activate

multiple lines, including data plans

abroad, choosing from over 100

countries. This innovation confirms

our leadership in digital services.

35

Orange Belgium

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Annual report 2025

Over 1,700

beneficiaries

via our Orange

Digital Center

and numerous

mobile

collections with

the RE Program

To strengthen security and business continuity, we offer dedicated solu-

tions through Orange Cyberdefense. We also provide eSIM back-up, en-

suring uninterrupted connectivity in case of incidents or outages, thus en-

hancing our customers’ resilience.

In the spring, we inaugurated our Orange Dig-

ital Center in Bertrange, an innovation and

training hub open to the public and profes-

sionals. Through our ‘For Good Connections’

naworkshops, more than 1,700 young people

were educated about cyberbullying, helping

to build a safer and more responsible online

environment. Furthermore, our RE program,

dedicated to recycling and taking back smart-

phones, enabled us to collect over 2,000 de-

vices this year. These concrete actions illus-

trate our commitment to a more responsible,

inclusive, and sustainable digital world.

For over five years, we have been proud part-

ners of the Luxembourg Football Federation

(FLF). This collaboration demonstrates our

commitment to the development of football

and eSports in Luxembourg. Our Orange

eLeague

eSports

competition,

organized

with the FLF in partnership with EA Sports,

has seen remarkable growth, with 32 players

across two divisions and an ever-increasing

level of play. As every year, the national grand

winner represented Luxembourg at the FC Pro

World Championship Play-Ins, further raising

our country’s profile on the international stage.

Partnership

and

commitment

in eSports

and football

Security and

resilience for our

business customers

36

Orange Belgium

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Annual report 2025

Driving the future

with a sustainable,

responsible, and

ESG-focused

business approach

37

Orange Belgium

_

Annual report 2025

40

%

24

%

5

%

30

%

Gender gap:

Only

27

%

of Belgians are

facing diﬃculties

related to the use

or security of digital

services. Online

security is the

greatest danger.

1

of 12–17-year-

olds are victims of

cyberbullying.

2

of Belgians do not

have an internet

connection at home.

1

of tertiary

students in

STEM are

women.

3

Why

is this

essential?

of Belgians need

help to complete

essential formalities

online.

1

1 According to the Digital Inclusion Barometer based on the Belgian population aged 16 to 74.

Source:

https://media.kbs-frb.be/fr/media/11912/zoom_barometre_inclusion_numerique

2 EU Child Participation 2025 Survey.- Source:

https://eu-for-children.europa.eu/cyberbullying_en

3 Education and Training Monitor 2025 - Belgium Report (European Commission/EACEA, December 2024).

Source:

https://op.europa.eu/webpub/eac/education-and-training-monitor/en/country-reports/belgium.html

Orange Belgium operates in a rapidly

changing environment, marked by

growing expectations regarding

economic, social, and environmental

responsibility. In the face of geopolitical,

climate, digital sovereignty, and

resource-related challenges, the Group

has adopted a proactive approach to

anticipating and adapting to economic,

societal, environmental, and regulatory

developments, relying on structured

dialogue with its stakeholders.

Guided by its purpose –

to be a trusted

player that gives everyone the keys to

a responsible digital world

– Orange

Belgium asserts its role as a provider of

essential services, a creator of lasting

connections between people and re-

gions, and a driver of meaningful, sus-

tainable innovation.

In this context, the third pillar of the

‘Lead the Future’

strategy is built on a

sustainable business model that fully in-

tegrates ESG (environmental, social, and

governance) considerations at the heart

of the organization. This translates into

concrete commitments towards employ-

ees, customers, partners, and society at

large, as well as a deep transformation

of our processes and tools. By struc-

turing its actions in this way, Orange

Belgium asserts its role as a central

actor in driving the transition toward a

more responsible, inclusive, and resilient

future.

38

Orange Belgium

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Annual report 2025

1. Environment

Decreasing our environmental

impact and evolving our activities

2025 in figures

(compared to the previous year):

20

%

increase in ﬂeet electriﬁcation (scope 1)

100

%

of our electricity purchased from renewable

sources (scope 2)

78

%

coverage of smart meters, deployment of

energy features on the mobile network, and

decommissioning of obsolete antennas

(scope 2)

16

%

reduction in CO₂ emissions (scope 1&2)

8

%

reduction in CO₂ emissions (scope 1&2&3)

3 scopes

as indicators

1

Direct greenhouse gas emissions

(GHG) related to activities owned or

controlled by the company.

2

Indirect emissions related to the

consumption of purchased energy,

such as electricity, produced by a third

party.

3

Other indirect emissions upstream

or downstream of the company’s

value chain, such as the manufacture,

transport, or use of products.

39

Orange Belgium

_

Annual report 2025

Net Zero carbon

by 2040

To achieve the Group’s goal of carbon

neutrality by 2040, Orange Belgium

has defined a comprehensive strategy

to combat climate change.

Cutting its own CO₂

emissions by reducing

indirect emissions related

to energy use

To achieve its first objective, the company sources 100%

of its electricity from renewable resources and has installed

solar panels at two RAN sites. Orange Belgium is acceler-

ating its energy-saving initiatives on the radio access net-

work and hybrid fiber-coaxial network by deploying energy

features and smart meters, with a coverage target of 78%

now achieved, while dismantling sites and decommissioning

obsolete technologies.

In terms of mobility, while promoting the legal mobility

budget, Orange Belgium is rolling out an electric fleet for

its employees, with the aim of switching to an 84% electric

fleet by 2030. In one year, the electrified fleet has grown from

18% to 38%.

Additionally, Orange Belgium aims to reduce heating and is

exploring the use of heat pumps to minimize the environ-

mental impact of its buildings.

Reducing emissions

both upstream in its supply chain

and downstream in its customer

base

By integrating sustainability criteria into its procurement processes, Orange

Belgium encourages its suppliers to reduce their emissions. In addition, the

decarbonization of Orange Belgium’s value chain is advancing through the

rollout of the Group’s PTNZC (Partners to Net Zero Carbon) program.

The company

sources 100% of

its electricity from

renewable resources

and has installed

solar panels at two

RAN sites

40

Orange Belgium

_

Annual report 2025

Driving Circular Economy

with the RE Program

Promoting the circular economy for mobiles and devices

through the RE program and for our IT Network equip-

ment via the OSCAR program.

The company encourages more responsible use of de-

vices by:

•

collecting used phones so they can either be reused

when still functional or sent to proper recycling chan-

nels when they are obsolete.

•

promoting repair to extend the life of phones.

•

increasing the share of refurbished phones sold, to

limit the need for new raw materials.

In parallel, Orange Belgium is rolling out eco design ap-

proaches, a key pillar of its circular economy strategy. The

aim is to use fewer critical metals, make products more

durable and easier to recycle, and reduce waste from

electrical and electronic equipment (WEEE).

2025 in figures

13,000

people

beneﬁted from free digital training, an increase of 31% compared

to 2024 in Belgium - We have tripled the Group’s 2025 target of

training six million people between 2021 and 2030

.

132,202

hours

of training provided

61

%

of our beneﬁciaries are under 18

more than

600

beneﬁciaries received personalized support from

Care Corners and Care Agents in several Orange stores

more than

600

people looking for work or in career transition

beneﬁted from hackathons and NoCode courses

2. Social

Bridging the digital

divide for a more inclusive

digital society

41

Orange Belgium

_

Annual report 2025

Two fundamental approaches to

bridge the digital divide

The ﬁrst approach focuses on providing comprehensive training,

raising awareness by sharing best practices for healthy and

secure digital use, and oﬀering ongoing support.

The second focuses on deploying infrastructure to expand and

improve connectivity, enhance aﬀordability, and ensure device

access for all, fostering a more

inclusive digital environment.

Inform, educate, raise

awareness: empowering

people through digital skills

and resources

Aware of the opportunities brought by the

growing digitalization of society, Orange also

recognizes the associated risks, particularly

the exclusion of people affected by the digital

divide. Its ambition is therefore to maximize

the positive impact of access to telecom-

munications services by creating a more in-

clusive and tailored digital environment, and

by

giving everyone the keys to a more re-

sponsible digital world.

Orange is convinced that digital technolo-

gies can be powerful drivers of social and

economic development. To enable everyone

to fully exercise their rights and thrive in a

constantly evolving technological world, the

company is committed to providing people

with the knowledge and tools they need to

use digital services confidently, safely and

with full awareness.

complementary

pillars

3

Our action is structured around three pillars, each with

speciﬁc objectives and target audiences.

1

Better Internet for Kids

aims to protect

young people from the risks of the digital

world by raising their awareness of online

dangers and helping them adopt safe and

responsible behaviours.

2

With

Digital Basics for Seniors

, we

support older people in acquiring basic

digital skills and tools, to reduce the digital

divide and strengthen their autonomy in

everyday life.

3

Finally,

Tech Careers for Women

aims to

promote careers and employability in tech

to girls, inspire them, and remove barriers

that may prevent them from pursuing these

paths.

For each of these pillars, we rely on grassroots

partnerships with the non-proﬁt sector to ensure a

concrete, lasting impact that is tailored to the needs of the

people we support. As part of the Orange Belgium Fund

(hosted by the King Baudouin Foundation), we support

associations active in the ﬁeld of digital inclusion.

42

Orange Belgium _

Annual report 2025

Better Internet for Kids

Digital Basics

for Seniors

This year, the company strengthened its long-term

commitment to protecting young people online,

with a particular focus on cyberbullying.

Under the

#ForGoodConnections

initiative, Orange

Belgium has introduced a series of concrete, pre-

ventive actions to strengthen protection, security

and trust for children and their parents.

In partnership with

Pimento

and

Sors de ta bulle,

school conferences are organised to help pupils

understand major digital risks (such as cyberbul-

lying, excessive screen time and fake news) and

to encourage healthier, more responsible online

behaviour.

For

parents,

Orange

Belgium

offers

ded-

icated

sessions

on

parenting

and

on-

line

security,

in

collaboration

with

Ge-

zinsbond

and

La Ligue des Familles.

These con-

ferences provide practical guidance to build trust

with their children, set clear and balanced rules for

digital use at home, and create a safer online envi-

ronment for the whole family.

In addition, as part of the first purchase of

a phone for children Orange Belgium has

launched the

Smartphone Pass

, a practical

tool aimed at promoting responsible digital ha-

bits and helping parents and children navigate the

digital world more safely.

In collaboration with the association Bibliothèques

Sans Frontières, the company launched the inter-

generational

Digital Buddies

project, designed to

help 2,000 beneficiaries (mainly seniors) overcome

everyday digital challenges such as passwords,

updates, and banking apps.

Originally designed as an individual support pro-

gram, we decided to develop a version dedicated

to training Orange Belgium’s employees, who re-

sponded enthusiastically to becoming ambassa-

dors for digital inclusion, demonstrating a strong

commitment that we are delighted to see.

In less

than four months, 120 team members decided to

become Digital Buddies.

In practice, our members attended a one-day

training session to learn how to be digital support

companions, followed by a day of volunteering,

during which they were able to put their new skills

into practice.

1

2

43

Orange Belgium

_

Annual report 2025

Enhancing employability

in a connected world

Connecting

and equipping:

tackling the digital

divide through

infrastructure

deployment

Orange Belgium remains committed to

improving employability by strength-

ening skills and creating new job op-

portunities, while fostering innovation

and entrepreneurship to support eco-

nomic growth and social progress.

To this end, it collaborates with local

partners, notably BeCode, a train-

ing center offering a seven-month IT

program (AI, cybersecurity) for career

changers, with an 80% reintegration

rate (and a target of 50% women per

cohort). This school–industry collab-

oration also facilitates intern recruit-

ment and provides practical use cas-

es for students. BeCode also offers an

online NoCode program and a men-

toring program, in which professionals

support BeCode learners throughout

their journey. Special attention is giv-

en to encouraging girls to engage with

technology and to helping women

develop their digital skills through the

Tech Careers for Women axis.

Orange Belgium deploys and maintains high-speed networks, thereby im-

proving accessibility for many Belgians. The deployment of satellite con-

nectivity and the expansion of network coverage enable all communities

to benefit from high-speed access via our HFC, fiber-optic, or mobile net-

works.

To promote inclusion and ensure accessibility, the company has introduced

social tariffs for low-income seniors and beneficiaries of integration income,

while offering accessible services and products tailored to families, young

people, vulnerable seniors, people with disabilities, small businesses, and

associations.

In addition, customer support spaces are available in stores, where customer

service agents provide free one-on-one assistance with the use of digital de-

vices, including technical advice, data transfers, and device setup.

3

44

Orange Belgium

_

Annual report 2025

3. Governance

An example of integrity

and accountability

The governance structure includes several key bodies

that adopt a comprehensive approach to the govern-

ance, management, and supervision of ESG initiatives

within the organization, ensuring full transparency

both internally and externally.

To strengthen the management of ESG objectives, the

company is committed to standardizing its processes

and tools, while enhancing the organization and skills

of the ESG team in collaboration with other depart-

ments.

Orange Belgium has also implemented a double ma-

teriality matrix, engaged in stakeholder dialogue, and

established processes and tools to fulfill its due dili-

gence obligations. Finally, the company is consolidat-

ing its efforts to provide fair and integrated respons-

es to regulatory frameworks such as the CSRD and

the Taxonomy, ensuring a consistent approach to the

governance, management, and supervision of ESG in-

itiatives across the organization.

45

Orange Belgium

_

Annual report 2025

Management report

Orange Belgium is

one of the leading

telecommunication

operators on the Belgian

market, with over

3 million customers, and

in Luxembourg through

its subsidiary Orange

Luxembourg.

As a convergent actor, we provide mobile tel-

ecommunication services, internet and TV to

private clients, as well as innovative mobile

and fixed line services to businesses.

Orange Belgium is a subsidiary of the Orange

Group, one of the leading European and Af-

rican operators for mobile telephony and

broadband internet access, as well as one

of the world leaders for telecommunication

services to enterprises.

Orange Belgium is listed on the Brussels

Stock Exchange (OBEL).

The Management Report for the accounting

year ended on 31 December 2025, consist-

ing of pages 46 to 52 has been prepared

in accordance with Articles 3:6 and 3:32 of

the Belgian Code of Companies and Asso-

ciations and was approved by the Board of

Directors on 18 March 2026. It covers both

the consolidated accounts of the Orange

Belgium Group and the statutory accounts

of Orange Belgium S.A. The Corporate Gov-

ernance statement on pages 53 to 71 is an

integral part of this Management Report. The

Corporate Sustainability Reporting Directive

(CSRD) section can be found on pages 72

to 219.

1. Recent events

First Semester of 2025

Orange unified its sales front

and significantly strengthened

its connectivity, cloud, AI and

cybersecurity product and service

offering to conquer leadership in

the Belgian B2B market

Orange has launched a leading B2B solution

on the Belgian high-end market. The collec-

tive expertise of Orange Belgium, Orange

Business, Orange Business Digital Servic-

es, and Orange Cyberdefense is combined

to create a powerful synergy that no other

telco player in Belgium can offer to SMEs,

(multi) national corporates, and public organ-

isations. This marks another milestone in the

‘Lead the Future’ strategy, providing a unique

B2B value proposition for present and future

ICT, connectivity, and cybersecurity needs.

Team 5 won hey! hackathon to

shape the AI of tomorrow

On March 14

th

and 15

th

, Orange Belgium’s

brand hey! organised a hackathon dedicat-

ed to artificial intelligence at BeCentral in the

heart of Brussels. Over two intensive days,

more than 90 students, divided into ten

teams, worked on five technological chal-

lenges aimed at imagining the AI solutions

of tomorrow for hey! and Orange Belgium.

Team 5 won this edition, impressing the jury

with their well-executed project on an Intel-

ligent Virtual Assistant designed to enhance

hey! telecom offers. Their victory grants

them a personality test with a personalised

debriefing session, along with a specialised

workshop at Google and Amazon.

Orange Belgium modernised

its 1 Gbps fixed internet access

network to meet future connectivity

demands with Distributed Access

Architecture (DAA)

Building on its current deployment of DOC-

SIS 3.1 technology to deliver 1 Gbps Orange

Belgium is now upgrading its HFC network

to Distributed Access Architecture (DAA).

This transformation, which spans at least

34% of its Wallonia and Brussels footprint,

is powered by partnerships with Teleste,

Commscope, and Nokia. DAA represents a

significant evolution in Hybrid Fiber networks

by decentralising and virtualising headend

and network functions. Leveraging the ubiq-

uity of optical ethernet transport, it establish-

es the foundation for 10 Gbps technologies.

Second semester of 2025

In July, Orange Belgium signed

deal to broadcast Premier League

and Bundesliga via Play Sports

channels

Orange Belgium has reached an agreement

with Telenet group for the distribution of the

two Play Sports channels, starting from the

2025-2026 season. Both channels are avail-

able in French and Dutch.

Orange Belgium announced a new

Management Services Agreement

with Orange SA

Orange Belgium’s previous Strategic Part-

nership Agreement (“SPA”) with Orange SA

expired on 31 December 2024 . Under such

previous SPA, a fixed management fee of

€5 million was charged by Orange SA to Orange

Belgium in return for (1) access to the Orange

Group sourcing programme, (2) specific

know-how available within Orange SA and

(3) access to Orange Group roaming and in-

terconnect programs.

As of 2025, the SPA will be replaced by a new

Management Services Agreement (“MSA”),

covering more management services-ori-

ented type of activities, thereby transitioning

to a structure that includes a cross charge

of management fees, determined as a ratio

(based on Orange SA costs), multiplied by

Orange Belgium’s annual external turnover,

excluding taxes. Orange S.A. applies this ap-

proach to other members of the Orange SA

group.

The board of directors has instructed a com-

mittee of independent directors in the frame-

work of article 7:97 of the Companies and

Associations Code, with the assistance of

an independent expert, to assess the arm’s

length character of the new management

fee structure. The independent expert has

performed by proxy a transfer price analysis

based on applicable guidelines. Such meth-

odology was considered the best available

proxy in view of the extensive and detailed

regulations, guidelines and practices availa-

ble to assess intragroup relationships. In ad-

dition, for a duration of three years, the total

46

Orange Belgium

_

Annual report 2025

service fee charged by Orange SA to Orange

Belgium would not exceed €15.4 million per

annum.

Orange Belgium and Proximus

signed a Memorandum of

Understanding to expand fiber

deployment and increase access to

gigabit networks in Wallonia

This Memorandum of Understanding formal-

ised the operators’ shared commitment to

join forces to expand fiber deployment and

improving access to gigabit networks in less

densely populated areas of Wallonia. The

collaboration would also ensure that more

consumers benefit from the advantages and

high-speed of existing gigabit networks,

while reducing civil works.

In medium-density areas, Proximus, through

its joint venture Unifiber co-owned with Eu-

rofiber, will continue to roll-out Fiber-to-the

Home (FTTH) to 600,000 homes and busi-

nesses, and will gradually welcome Orange

Belgium customers.

In less densely populated areas, Orange Bel-

gium and Proximus will work together to make

Fiber-to-the-Home (FTTH) networks accessi-

ble to some 200,000 homes and businesses.

Volumes will be distributed evenly, favouring

the most cost-efficient deployment methods.

Proximus will gain access to Orange Bel-

gium’s fiber network, and Orange Belgium

will gain access to Proximus’ fiber networks.

Thanks to this collaboration, around 70% of

homes in Wallonia will be covered by a Fiber-

to-the-Home (FTTH) network.

In the most sparsely populated zones, Prox-

imus will start offering services using the

Hybrid Fiber Coax (HFC) network of Orange

Belgium for approximately 600,000 homes,

which will allow to offer gigabit speeds

throughout Wallonia.

In August, Orange Belgium

informed its customers about a

cyberattack

At the end of July, Orange Belgium detect-

ed a cyberattack on one of its IT systems,

resulting in unauthorised access to certain

data from 850,000 customer accounts. No

critical data was compromised: no pass-

words, email addresses, bank or financial

details were hacked. However, the hack-

er gained access to one of our IT systems

containing the following data: surname, first

name, telephone number, SIM card number,

PUK code, tariff plan.

In October, Orange Belgium

completed final step of VOO

acquisition: VOO S.A. is now fully

integrated in Orange Belgium

Group, VOO brand and offers

remains unchanged for customers

Orange Belgium announced the successful

completion of the final phase of its strategic

integration of VOO S.A. Following share-

holders’ unanimous approval at the extraor-

dinary general meeting, VOO S.A. has been

dissolved, completing a process that began

with the acquisition in June 2023 and the

subsequent integration of its staff and assets

into Orange Belgium.

Public announcement in

accordance with article 7:97, § 4/1

of the Belgian Code of Companies

and Associations (‘CCA’)

concerning the signing of a Pledge

Agreement and a Letter of Consent

and Release with Enodia

Following the acquisition of VOO by Orange

Belgium, VOO granted Enodia a mandate

under which Enodia is authorised to create

a first-rank pledge over VOO’s business, as

security for all amounts that may be owed by

VOO to Enodia under the Service Agreement,

up to a maximum amount of €250,000,000

(the “Mandate”).

In the context of the demerger of VOO, it was

proposed that, all VOO’s rights and obliga-

tions to Enodia, would be transferred from

VOO to Orange Belgium and that the Man-

date would be terminated and replaced by

a pledge agreement covering Orange Bel-

gium’s trade receivables and bank accounts

for the benefit of Enodia.

In November, Ookla

®

recognised

Orange Belgium as the Belgian

operator offering the best 5G

mobile network on the market

Based on first-half 2025 data, Orange Bel-

gium has been recognised by Ookla

®

as the

Belgian operator offering the best 5G mobile

network on the market. These achievements

have earned Orange Belgium the Ookla

®

Speedtest Award™ for Best 5G Network,

in which the company achieved a Speed-

test Connectivity Score of 69.60. The score

reflects the overall mobile user experience,

perfectly combining performance indicators

such as download and upload speed, web

experience, and video streaming quality.

2. Comments on the

consolidated accounts

prepared according to

IFRS standards

The scope of consolidation at 31 December

2025

includes the following companies: Orange

Belgium S.A. the parent company, the Lux-

embourgian company Orange Communi-

cations Luxembourg S.A. (100%), IRISnet

S.C.R.L. (28.16%), Smart Services Network

S.A. (100%), Walcom Business Solutions

S.A. (100%), A & S Partners S.A. (100%),

Orange NetCo S.A. (100%[NH1.1][LA1.2]

[NG1.3][NH1.4]-new in 2025), BeTV S.A.

(100%), Wallonie Bruxelles Contact Center

S.A (100%) and MWingz S.R.L. (50%).

Orange Belgium S.A.

(the company’s ulti-

mate majority shareholder is Orange S.A.) is

one of the main actors on the telecommuni-

cations market in Belgium and Luxembourg.

Orange Belgium is listed on the Brussels

Stock Exchange (OBEL).

Orange

Communications

Luxembourg

S.A.

, a company organised and existing un-

der the laws of Luxembourg, was acquired

as of 2 July 2007 by Orange Belgium S.A.

The purchase concerned 90% of the shares

of Orange Communications Luxembourg

S.A. The remaining 10% of shares were ac-

quired on 12 November 2008. The company

has consolidated the results of Orange Com-

munications Luxembourg S.A. for 100%, as

of 2 July 2007.

IRISnet S.C.R.L.

is a company constituted in

July 2012 in collaboration with the Brussels

authorities in order to take over the activi-

ties performed by the temporary association

IRISnet, and is responsible for the operation

of the Irisnet 2 optical fiber network and for

the provision of fixed telephony, data trans-

mission services (internet, e-mail) and other

network related services (video-conferenc-

ing, video surveillance, etc.). The take-over

of the activities took place on 1 November

2012. In this new legal structure, Orange Bel-

gium S.A. contributed in cash for €3,450,000

equivalent to 345,000 shares out of the

1,225,000 shares issued by the company.

Due to the deal structure, IRISnet S.C.R.L. is

accounted for in the accounts using the eq-

uity method.

Smart Services Network S.A.

(SSN) is a Bel-

gian company that distributes telecommuni-

cation and energy services including those of

Orange Belgium and Luminus. SSN’s route

to market is based on the principle of mul-

ti-level marketing. SSN’s network consists of

47

Orange Belgium

_

Annual report 2025

more than 1,000 independent consultants.

Smart Services Network S.A., a company

organised and existing under the laws of Bel-

gium, was created as of 30 September 2014.

Orange Belgium S.A. contributed in cash for

€999,900 equivalent to 9,999 shares out of

the 10,000 shares issued by the company.

Atlas Services Belgium S.A. contributed in

cash for €100 equivalent to 1 share. In 2016,

Orange Belgium S.A. contributed in cash in

the capital increase of Smart Services Net-

work S.A. for €700,000, equivalent to 7,000

shares. On 25 March 2022, the carried for-

warded losses have been integrated in the

capital of the company for an amount of

€1,041,610.41 and a capital increase of

€341,610.41 has been funded. After these

transactions, the capital of the company

amounts to €1,000,000.00.

Walcom Business Solutions S.A.

, a com-

pany organised and existing under the laws

of Belgium, was created as of 13 July 2017.

Walcom Business Solutions S.A. specialises

in the sales of telecommunication products

and services for the professional market.

Orange Belgium S.A. contributed in cash for

€60,885 equivalent to 99 shares of the 100

shares issued by Walcom Business Solu-

tions S.A. Walcom S.A., liquidated during the

accounting year 2020, contributed in cash

for €615 equivalent to 1 share. The results

of Walcom Business Solutions S.A are fully

consolidated by the company since 13 July

2017.

A&S Partners S.A.

also an existing Orange

Belgium agent, provides telecommunications

services to B2B customers within the Brus-

sels region via a dedicated sales team of 35

professionals under the name of AS Mobility.

A&S Partners S.A., a company organised and

existing under the laws of Belgium, was ac-

quired as of 30 September 2017 by Orange

Belgium S.A. The purchase concerned 100%

of the 620 shares of A&S Partners S.A. The

results of A&S Partners S.A. are fully consoli-

dated by the company since 1 October 2017.

MWingz S.R.L.

is a joint operation between

Orange Belgium S.A. and Proximus S.A.,

each owning 50% of the company that will

manage the unilateral and shared mobile

radio access network of both shareholders.

In 2019 both companies decided to build a

shared mobile radio access network with the

objective to meet customers’ increasing de-

mand for mobile network quality and deep-

er indoor coverage. The agreement will also

allow a faster and more comprehensive 5G

roll-out in Belgium. While sharing the com-

mon part of their mobile radio access net-

works, both companies will continue to have

full control over their own core network and

spectrum assets ensuring differentiated ser-

vices. MWingz S.R.L. is a company organ-

ised and created under the laws of Belgium

and was created as of 6 December 2019.

Orange Belgium S.A. contributed in cash for

€1 equivalent to 1 share out of the 2 shares

issued by the Company. Proximus S.A. con-

tributed in cash for €1 equivalent to 1 share.

In April 2020, Orange Belgium did participate

in the capital increase of MWingz S.R.L. for

€1,599,999. Orange Belgium holds 50% of

the shares of MWingz S.R.L. This compa-

ny started the operational activities as from

1 April 2020.

VOO S.A.

is a telecommunication operator

organised and created under the laws of

Belgium, with the following purposes: de-

velopment and maintenance of optical fiber

network, provision of all services to custom-

ers, design-creation and production of any

audiovisual goods or services. On 2 June

2023, Orange acquired VOO S.A and its

100% subsidiaries. On the 1st October 2025,

the dissolution of VOO S.A. marks the end

as a legal entity with retroactive effect on the

1st July 2025.

Assets and liabilities related

to its fixed network activities are transferred

to the public limited company Orange NetCo,

a direct subsidiary wholly owned by Orange

Belgium. All other activities, such as custom-

er services and commercial operations, are

transferred to Orange Belgium S.A.

Orange NetCo S.A.

now owns and man-

ages the fixed access networks (due to the

demerger of VOO SA). This move aligns with

Orange Belgium’s long-term vision to build

a modern, efficient, and future-proof net-

work infrastructure, supporting Belgium’s

digital ambitions and the European Union’s

Digital Decade 2030 objectives. Orange Net-

Co was created on 17 April 2025 with cap-

ital of 61,500.00 € fully paid up by Orange

Belgium (100% - 123,000 shares).

Follow-

ing the demerger of VOO and the contri-

bution to Orange NetCo via a capital in-

crease of 621,364,532.39 € represented by

1,328,244,383 new shares. Orange NetCo is

a fully owned subsidiary of Orange Belgium.

WBCC S.A.

is VOO’s subsidiary, organised

and created under the laws of Belgium.

Main purposes: providing customers sever-

al telephone services, as assistance or help;

providing also marketing and telemarketing

services. On 2 June 2023, Orange acquired

VOO S.A. and its 100% subsidiaries.

BeTV S.A.

is VOO’s subsidiary organised

and created under the laws of Belgium, with

the following purposes: television broadcast

service intended for the public, by ensuring

the programming, production, promotion,

exploitation of these broadcasts. The ex-

ploitation concerns both the direct or indirect

exploitation of the right to access the service,

the marketing, publication or other, of the

broadcast time, the exploitation of all derived

rights or even any production or publishing

operation. On 2 June 2023, Orange acquired

VOO S.A. and its 100% subsidiaries.

48

Orange Belgium

_

Annual report 2025

2.1

Consolidated statement of comprehensive income

In €m

FY 2024

FY 2025

Change

Revenues

1 993.7

1 963.4

-1.50%

Retail service revenues

1 600.8

1 577.5

-1.50%

Equipment sales

197.6

214.4

8.50%

Wholesale revenues

164.4

158.7

-3.50%

Other revenues

30.9

12.7

-58.80%

EBITDAaL

544.3

566.1

4.00%

% of Revenues

27.30%

28.80%

153 bp

Net proﬁt (loss) for the period

17.2

41.3

139.50%

Earnings (Loss) per share (€)

0.33

0.61

eCapex

1

-368

-375.9

2.10%

% of Revenues

18.50%

19.15%

65 bp

Adjusted Operating cash ﬂow

2

176.3

190.2

7.90%

Organic cash ﬂow

41.8

90.8

117.22%

Net ﬁnancial debt

1 904.9

1815.1

-4.70%

1. eCapex excluding licence fees

2. Adjusted Operating cash ﬂow deﬁned as EBITDAaL – eCapex excluding licence fees

Revenues

Group revenues reached €1,963.4 million in

2025, down by 1.5% in comparison to last

year. Retail service revenues amounted to

€1,577.5 million, down by 1.5%, explained

by convergent service revenues (+3.8%) and

fixed revenues (-6.7%). Additionally, equip-

ment sales increased, while IT & Integration

service revenues, other revenues, wholesale

and mobile service revenues decreased.

Result of operating activities

before depreciation and other

expenses

EBITDAaL increased by 4% to €566.1 million

driven by tough cost control despite inflation

impacts. The margin increased 1.5pt as it

reached 28.8%.

Total operational expenses for the full year

decreased by 3.6% to €1,391.9 million. The

following provides an overview of the differ-

ent expenses:

•

Direct costs decreased by 3.8% to

€635.6 million

•

Labour costs grew by 2.5% to €257.7 mil-

lion

•

Indirect costs decreased by 6.2% to

€498.6 million .

In €m

FY 2024

FY 2025

Change

Direct costs

-660.4

-635.6

-3.80%

Labour costs

-251.4

-257.7

2.50%

Indirect costs including RouA

-531.8

-498.6

-6.20%

of which RouA

-61.2

-58.3

-1 443.6

-1 391.9

-3.60%

Depreciation and amortization

Depreciation and amortization increased

from €411.5 million in 2024 to €418.4 million

in 2025, representing an increase of €6.9 mil-

lion or +1.7%.

Impairment of goodwill

Goodwill is tested for impairment each year.

Our testing in 2025 did not reveal any need

to impair goodwill.

EBIT

EBIT increased from €118.8 million in 2024 to

€136.3 million in 2025.

Financial result

Net financial expenses decreased from

-€114.6 million in 2024 to -€97.0 million in

2025. The decrease is mainly due to lower

interest rates year-over-year.

Taxes

Full-year tax expense decreased from €12.9

million profit in 2024 to a profit of €2.0 million

in 2025 mainly explained by an income tax

expense of €7.2 million and a deferred tax

expense of €3.7 million due to the increase

of the earnings before income tax from 4.3

million in 2024 versus 39.4 million in 2025.

Net profit and earnings per share

The full-year net profit increased from

€17.2 million to €41.3 million in 2025. Earn-

ings per share was €0.33 in 2024, compared

to a profit per share of €0.61 in 2025.

49

Orange Belgium

_

Annual report 2025

2.2

Consolidated statement

of financial position

Assets

Goodwill

remained stable during 2025. No

impairment losses were recorded in 2025.

The carrying year-end value is €751.2 million,

same as it was as at the end of 2024.

Intangible assets

mainly relate to mobile li-

censes and spectrum fees. The net carrying

value at year-end was €813.3 million com-

pared to €861.9 million at the previous year-

end. The decrease comes mainly from the

amortization expense.

Property, plant and equipment

mainly com-

prises network facilities and equipment. The

net book value at year-end was €1,812.4 mil-

lion compared with €1,803.9 million at 2024

year-end.

Rights-of-use assets

relate to the applica-

tion of IFRS 16 and increased from €172.4

million to €182.7 million as of 31 December

2025 essentially due to changes during the

year (updates, new contracts…).

Inventories

increased from €34.8 million to

€38.3 million, mainly due to new network pol-

icy following the demerge VOO and Orange

NetCo creation.

Trade receivables

increased from €220.8

million to €245 million in 2025 (increase of

11% versus 31 December 2024).

Other assets related to contracts with

customers

totalled €127.5 million, an in-

crease of €9.6 million compared to 2024.

This variation is due to the evolution of the

number of subsidised contracts and the in-

creased in value of the subsidised offers.

Other current assets and prepaid expens-

es

decreased by €6.7 million to €30 million

in 2025.

Cash and cash equivalents

increased from

€58.2 million to €80.6 million at the end of

2025. More details on cash flows can be

found in the cash flow statement.

Total equity and liabilities

Total equity

increased from €959.2 million

to €1,008.5 million. The change in retained

earnings stems essentially from the result of

the period (+ €41.8 million) and the variation

of OCI (+ €7.4 million).

Non-current

liabilities

decreased

from

€2,344.4 million at the end of 2024 to

€2,137.6 million at the end of 2025. The main

drivers are: the reimbursement of long-term

financing (- €196.3 million) combined with a

decrease in deferred taxation (- €3.6 million).

Current liabilities

increased to €957.4 mil-

lion at the end of 2025 from €772.8 million

at the end of 2024. This increase is mainly

the result of increase short-term financing

(+128.9 million), fixed assets payable (+ €7.7

million) and trade payable (+ €49.6 million).

Dividends

The Orange Belgium Group aims to balance

the appropriate cash returns to equity hold-

ers maintaining a balanced and sound finan-

cial position, while leaving sufficient leeway

to continue to invest in its convergent strat-

egy, the expansion of its network and oth-

er growth opportunities. Orange Belgium’s

Board of Directors will not propose a divi-

dend for the financial year 2025 to preserve

cash for future capital requirements.

2.3

Liquidity and capital

resources

Cash flows

Orange Belgium uses Adjusted Operating

cash flow and Organic cash flow as the main

performance metrics for analyzing cash gen-

eration. The table below shows the reconcili-

ation to EBITDAaL.

Operating cash flow

is defined as EBIT-

DAaL less eCapex (excluding license fees).

Operating cash flow increased by +€13.9

million mainly due to a higher EBITDAaL

(+€21.8 million compared to 2024), partially

offset by increased investments versus last

year (+€7.9 million compared to 2024).

Organic cash flow

measures the net cash

provided by operating activities less eCapex

and the repayment of lease liabilities, in-

creased by proceeds from sale of property,

plant and equipment and intangible assets

and adjusted for the payments for acquisi-

tion of telecommunications licenses. Organic

cash flow increased from + €41.8 million to

+ €90.8 million, mainly explained by higher

cash provided by operating activities and a

decrease in fixed assets payable (- €22.7 mil-

lion).

Organic cash flow from telecom activities

corresponds to the organic cash flow ad-

justed for the spectrum license acquisition.

In 2025 this KPI amounted to €101.5 million

compared to €51.9 million for the year ended

31 December 2024.

in €m

FY 2024

FY 2025

EBITDAaL

544.3

566.1

eCapex

1

-368

-375.9

Adjusted Operating cash ﬂow

2

176.3

190.2

Net proﬁt (loss) before the period

17.2

41.3

Adjustments to reconcile net proﬁt (loss) to cash generated from operations

619.6

581.6

Changes in working capital requirements

-8.9

11.8

Other net cash out

-125.0

-109.1

Net cash provided by operating activities

502.8

525.6

eCapex and license fees

-368.5

-375.9

Prepayments on investment grants

-8.5

0.5

Increase (decrease) in ﬁxed assets payables

-27.5

-4.8

Repayment of lease liabilities

-57.0

-54.7

Organic cash ﬂow

41.8

90.8

Elimination of telecommunication licenses paid

10.2

10.7

Organic cash ﬂow from telecom activities

51.9

101.5

1. eCapex excluding license fees

2. Adjusted Operating cash ﬂow deﬁned as EBITDAaL – eCapex excluding license fees

50

Orange Belgium

_

Annual report 2025

Net debt

Net debt at year-end was €1,895.8 million,

compared to €1,904.9 million at the end of

2024.

The decrease is the combined effect

of: (i) net increase in cash of 22.4 million

euros, (ii) decrease of 20.7 million euros in

borrowings from third-party

following the re-

payment of maturing financing, (iii) decrease

of 46.7 million euros in our intra-group loans

following the repayment of loans as a result

of our increase in cash (organic cash flow).

€m, period ended

31.12.2024

31.12.2025

Cash & cash equivalents

Cash

-58.2

-80.6

Cash equivalents

0

Total cash and cash equivalents

-58.2

-80.6

Financial liabilities

Intercompany short-term borrowing

54.7

186.7

Third parties short-term borrowing

21.4

18.3

Third parties long-term borrowing

40.3

22.7

Intercompany long-term borrowing

1 846.7

1 668.0

Total borrowings

1 963.1

1 895.8

Net debt (Financial liabilities minus cash and cash equivalents)

1 904.9

1 895.8

3. Orange Belgium S.A.’s

statutory accounts 2025

The statutory income statement and bal-

ance sheet are presented on pages 282 to

284. As for the exhaustive annual accounts

of Orange Belgium S.A., please refer to the

Orange Belgium website (https://corporate.

orange.be/en/financial-information/share-

holders-investors).

Versus 31 December 2025, the main fluc-

tuations can be described as follows:

Goodwill

increased by 96 million euros fol-

lowing the demerger of VOO which was

merged into Orange Belgium S.A.

Financial fixed assets – participations

de-

creased significantly versus year-end 2024

(- 147.9 million euros) following the demerger

of VOO S.A., part of which was merged into

Orange Belgium S.A. and the other part into

a new entity Orange NetCo S.A.

Financial fixed assets – receivable:

the

amount of receivable did not change (80

million euros); however, during the demerg-

er, the receivable from VOO S.A. was trans-

ferred to the new entity Orange NetCo S.A.

Shareholders’ equity

decreased by 10.2

million euros following current year’s pro-

posed result appropriation corresponding to

the

decrease in retained earnings.

Third parties loans:

Financial loans of

22 million euros are recognised following the

incorporation of the liabilities of VOO S.A.

(Demerger).

Financial income

decreased by 111.7 mil-

lion euros during 2025. This decrease was

largely explained by the exceptional gains

realised on the mergers of BKM NV and

VOO Holding S.A. with Orange Belgium S.A.

(€ 107.9 million) in 2024.

Financial charges

decreased by € 13.9 mil-

lion due to the reduction in our financial debt,

which began last year.

4. Events after the

reporting period

Based on crowdsourced Speedtest™ data

collected by Ookla

®

in Q2–Q3 2025, Orange

Belgium has been named the fastest 5G net-

work in Belgium, achieving a Speed Score™

of 48.66 and reflecting real-world consumer

experience.

Antoine Chouc, Chief Financial Officer (CFO),

will step down from his position effective

1 April 2026 to assume the role of Chief

Financial and Strategy Officer at Orange

France. Until that date, he will continue to

fully perform his duties and work closely with

the teams to ensure a smooth and orderly

transition. Matthieu Bouchery has been ap-

pointed as the next CFO and will start his role

from 1 July 2026.

5. Outlook

The Company targets an EBITDAaL growth

of circa 3.5% yoy. Total eCapex in 2026 is

expected to be circa € 360 million.

6. Legal disputes

The following section summarizes Orange

Belgium’s legal disputes.

Telecom masts

Since 1997, certain municipalities and prov-

inces have adopted local taxes, on an annual

basis, on pylons, masts or antennas erect-

ed within their boundaries. Orange Belgium

continues to file fiscal objections against tax

assessment notices received concerning

these taxes. These taxes are currently being

contested in Civil Courts (Courts of First In-

stance - Tax Chamber and Courts of Appeal).

On June 6, 2024, the Walloon government

and the mobile operators Proximus, Telen-

et, Orange Belgium, and Insky signed an

agreement regarding the tax on pylons in

the Walloon region for the period 2023-2026,

extendable to 2027 if agreed by all parties.

The operators commit to paying, as a sec-

tor, €2.5 million for 2023 and €6 million per

year in 2024, 2025, and 2026 to the Walloon

region. Local taxes, which municipalities and

provinces may levy during these years, are

deductible up to certain annual ceilings.

The allocation key, to determine the share of

these annual amounts to be borne by each

operator, is determined annually by the mo-

bile operators based on a mutual agreement,

according to the number of pylons and masts

owned by each operator and the presence of

each operator on sites in the Walloon terri-

tory. For 2023, the allocation key for Orange

Belgium was 37.24% and for 2024 34.74%.

Exchanges to determine this allocation key

for 2025 are ongoing via Agoria.

Between January 1, 2023, and December 31,

2026, Orange Belgium will also invest an ad-

ditional amount of €15 million in telecommu-

nications infrastructure in the Walloon region.

There is an agreement not to establish Wal-

loon regional taxes on telecommunications

infrastructure during the period 2023-2026.

Moreover, municipalities and provinces will

be discouraged from imposing taxes on

telecommunications

infrastructure

during

2023-2026. In August 2025, an amount of

€1,334,000.00 was paid by Orange Belgium

to the Walloon Region for the years 2023 and

2024.

51

Orange Belgium

_

Annual report 2025

Access to Coditel Brabant

(Telenet)’s cable network

After Orange Belgium paid the provision

for the cable wholesale access set-up fees,

Coditel Brabant (Telenet) failed to provide

such access within the regulatory 6-month

period. This, in combination to the lack of

progress on the development of an effective

wholesale service, prompted Orange Bel-

gium to initiate legal action against Coditel/

Telenet for breach of its regulatory obliga-

tions end of December 2016. Due a combi-

nation of several elements (covid, intermedi-

ary court decisions, expert assessment) the

case was very significantly delayed. It is ex-

pected that the case will be closed H1 2026.

7. Justification of the

application of the going

concern accounting

principles

In view of Orange Belgium Group’s financial

results of the financial year ending 31 De-

cember 2025, the company is not subject

to the application of article 3:6 §1 (6°) of the

Belgian Code of Companies and Associa-

tions relating to provision of evidence of the

application of the going concern accounting

rules.

8. Other disclosures

required in accordance

with art. 3:6 and 3:32

of the Belgian Code

of Companies and

Associations

Art 3:6 §1.1

– To anticipate, prevent and ad-

dress major risks, Orange Belgium has put

in place a structure, procedures and systems

with the aim of implementing measures and

if necessary dedicated action plans. The goal

is to provide reasonable assurance in front

of the Audit Committee about the company’s

resilience and its ability to meet its objectives

and fulfill its commitments.

Therefore, the corporate risk map has been

updated in 2025 taking into account the

external context (worldwide geopolitical sit-

uation, macro-economic/industrial factors

such as cyber criminality, energy prices and

inflation, legal and regulatory market condi-

tions), as well as internal factors (integration

of VOO, major business interruptions, health

and safety of our people, among others). For

an exhaustive list of our risk clusters, please

refer to Risk Management section in the Cor-

porate Governance chapter of this Annual

Report.

Art 3:6 §1.3

– We can expect some market

evolutions during the course of 2026 and

beyond that may influence the competitive

landscape. The evolutions expected are

amongst others the progressive introduction

of new technologies such as artificial intelli-

gence in various services.

Art 3:6 §1.4

– Research and development:

activities are carried out in this respect and

especially in the field of the cable. Orange

Belgium developed a patent and benefits

from fiscal deductions due to its R&D activ-

ities.

Art 3:6 §1.5

– Info on branches not applica-

ble as we have subsidiaries and no branches.

Art 3:6 §1.7

– Treasury shares: absence of

Treasury shares.

Art 3:6 §1.8

– Use of financial instruments:

reference should be made to note 9 of the

IFRS financial statements.

52

Orange Belgium

_

Annual report 2025

Corporate Governance

Statement

1. Introduction

Orange Belgium adopted the 2020 Belgian

Corporate Governance Code (the “CGC”) as

its compulsory reference code as defined by

the Belgian Code of Companies and Associ-

ations. It is available on the Corporate Gov-

ernance Committee website (http://www.

corporategovernancecommittee.be/en). The

application of the principles of the CGC

takes into account the company’s specifici-

ties, its size, needs and ownership structure.

Orange Belgium’s Corporate Governance

Charter (the “Charter”), in its current version,

has been approved by the Board of Directors

on 17 October 2025 and became effective

on the same date. It is available on Orange

Belgium’s website (https://corporate.orange.

be/en/financial-information/corporate-gov-

ernance). This Charter describes the main

aspects of the company’s corporate govern-

ance, including its governance structure and

the internal rules of the Board of Directors,

the Executive Management, and committees

set up by the Board of Directors.

The Company considers that its Charter as

well as this Corporate Governance State-

ment reflect both the spirit and the provisions

of the CGC and the relevant provisions of the

Belgian Companies and Associations Code,

with the exception of the three following de-

viations, as detailed in Appendix VI of the

Charter:

a. Remuneration of

Non-Executive Directors

Article 7.6 of the CGC stipulates that each

non-executive director receives a part of his

remuneration under the form of shares of the

Company. The Board believes nonetheless

that it is in the best interest of the company

and its stakeholders to deviate from this

provision for the following reason:

The remuneration policy of the non-executive

directors is in first instance based on the

will to attract, motivate and keep qualified

directors having the profile and experience

required for business administration. In

order to achieve that, the company applies

a transparent remuneration policy in line

with market standards and taking into

account the scale, the organization and the

complexity of the company. No performance

related remuneration in connection with the

performance of the company is foreseen for

non-executive directors, in accordance with

article 7.5 of the CGC.

In order to avoid that the non-executive

directors, among which the independent

directors, would be overly influenced by the

stock market price of the company’s share,

the company has decided not to grant a part

of their remuneration under the form of shares

of the company. The company believes that

this deviation to the CGC allows the non-

executive directors to be the guardians of

the legitimate interests of all stakeholders of

the company and to focus on its long-term

perspectives. The company underlines that

the directors (executive and non-executive)

belonging to Orange Group as well as the

directors proposed by Nethys SA exercise

their mandate free of charge and that the

latter act as well in the best interests of the

company and in a perspective of sustainable

value-creation for the shareholders and

the stakeholders as a whole. Moreover, the

remuneration policy (as described in the

Remuneration Report that is submitted to the

approval of the General Meeting) has never

generated any issues or has never resulted

in arbitration or adverse behaviour. It allows

to achieve a balance between the various

underlying objectives of the CGC as a whole.

b. Shareholding Threshold for

Executive Management

Article 7.9 of the CGC stipulates that the

Board determines a minimal shareholding

threshold that the managers (i.e. the mem-

bers of the Executive Management) should

hold. The Board believes nonetheless that it

is in the best interest of the company and its

stakeholders to deviate from this provision

for the following reason :

The remuneration policy of the Executive

Management is in first instance based on the

will to attract, motivate and keep qualified

executive managers having the profile and

experience required to successfully manage

the operational direction of the company. In

order to achieve that, the company applies a

transparent remuneration policy in line with

market standards and taking into account

the scale, the organization and the complex-

ity of the company. The various components

of the remuneration of the Executive Man-

agement are described in the Remuneration

Report. In accordance with article 7.7 of the

CGC, the Board ensures that there is an ap-

propriate balance between fixed and variable

remuneration, and cash and deferred remu-

neration.

In order to match the interests of the exec-

utive managers to the objectives of sustain-

able value-creation, the variable part of the

remuneration of the executive managers is

structured to link reward to individual per-

formance and to the overall performance of

the company. As the remuneration policy

of the Executive Management already had

the ambition to remunerate the members

of the Executive Management in relation to

the short-term performance and the reali-

zation of the long-term strategic ambitions

of the company, the Board has decided not

to impose to the members of the Executive

Management to keep, in addition, a minimal

amount of shares. Such an obligation would

only add little added value compared to the

remuneration policy already put in place and

53

Orange Belgium

_

Annual report 2025

the monitoring hereof could in addition cre-

ate useless administrative burden.

The Board believes therefore that the current

remuneration policy (as described in the Re-

muneration Report that is submitted to the

approval of the General Meeting) already

encourages

the

Executive

Management

sufficiently to act in the best interests of the

company and in a perspective of sustainable

value-creation and that it allows to achieve

a good balance between the various under-

lying objectives of the concerned provision

and of the CGC as a whole.

c. Appointment of

independent members of

the Board

Article 3.5 of CGC stipulates that in order to

be appointed as an independent member of

the Board, a director must satisfy a number

of criteria, of which:

a) not have served for a total term of more

than twelve years as a non-executive

board member (article 3.5.2);

b) not maintain, nor have maintained in the

past year before their appointment, a

significant business relationship with the

company or a related company or person,

either directly or as partner, sharehold-

er, board member, member of the senior

management of a company or person

who maintains such a relationship (article

3.5.6).

At the General Meeting of 3 May 2023, the

Board nevertheless considered that it was

in the best interests of the Company and its

stakeholders to deviate from these provi-

sions for the following reasons:

a) the candidacy of an independent direc-

tor has been presented for renewal for a

term that resulted in the twelve-year term

being exceeded for one year. The Board

has considered that this extension was

justified by the need to ensure continuity

among the independent directors during

a complex integration period. The inde-

pendent director’s mandate was renewed

by the shareholders, with full knowledge of

the facts and in full transparency.

b) the candidacy of an independent director

has been presented for appointment even

though this candidate was a director of

Orange S.A. during the previous year. The

Board has considered that his experience,

his sector expertise and the independ-

ence of mind that he has demonstrated

in the exercise of his mandates would

make a useful contribution to the work of

the Board. The independent director was

appointed by the shareholders, with full

knowledge of the facts and in full trans-

parency.

2.

Risk Management and

Internal Control

A comprehensive, consistent and integrat-

ed risk management approach is in place

to capitalize on synergies between Audit,

Control and Risk functions at all levels of the

organization. This approach aims to provide

reasonable assurance that operating and

strategic targets are met, that current laws

and regulations are complied with, and that

the financial information is reliable.

Risk management

The framework and the process of risk man-

agement, as well as the organization and the

responsibilities relating to it, are formalized

in a charter as well as a corporate risk map,

validated by the Executive Management and

then approved by the Audit Committee and

the Board of Directors. Business and op-

erational key players in all different depart-

ments are responsible for the identification,

analysis, assessment, as well as treatment

and coverage of the risks. The company or

corporate risk map is approved at least once

a year by the Executive Management and

submitted to the Audit Committee for overall

assessment of approach and methodology.

Today, this risk map includes -but is not lim-

ited to- the following risk clusters:

•

Geopolitics (including international sanc-

tions)

•

Competition

•

Image and reputation

•

Major business interruption

•

Information security and cybersecurity

•

Corruption

•

Frauds

•

Regulatory, tax and legal pressure

•

Health and safety of people

•

Skills and competences management

•

Transformation related to Artificial Intelli-

gence

•

Key partnership underperformance

•

Climate change and environmental tran-

sition

•

Non-compliance with laws or regulations

•

Governance and subsidiaries manage-

ment

In the context of mergers and acquisitions,

a specific focus on risk and opportunities

linked to VOO was presented in 2025 to the

Audit Committee as well as to the Board of

Directors, until the official demerging of VOO.

Internal control environment

and control activities

To address and manage risks, an internal

control approach and framework has been

deployed for many years at Orange Bel-

gium. It covers aspects such as governance,

delegations of powers and signatures, poli-

cies, processes, procedures, segregation of

duties and controls to ensure selected risk

treatments (retain, reduce, transfer, avoid)

are effectively carried out.

Through its vision, its mission and its values,

Orange Belgium Group defines its corporate

culture and promotes ethical values that are

reflected in all its activities. There is a charter

of professional ethics at company level and a

section of the company’s intranet, accessible

to all employees, that is dedicated to compli-

ance, ethics, corporate social responsibility

and to the company culture and values in

general. Within the framework of promoting

ethical values, a professional warning system

allows for reporting confidential information

intended to strengthen the control environ-

ment.

The human resources management and the

social responsibility of the company are de-

scribed in the corporate brochure of the an-

nual report and the Corporate Sustainability

Reporting Directive (CSRD) section included

in this annual report. The management and

control of the company and the function-

ing of the management bodies are detailed

in the declaration of corporate governance

contained in the annual report as well as in

the company’s articles of association. This

corporate governance covers particularly the

responsibilities of these governance bodies,

their internal regulations as well as the main

rules to be respected in the management of

the company.

The control activities are carried out firstly by

the functional or operational managers under

the supervision of their supervisors. All major

processes and the controls that they encom-

pass are formalized. As part of the Orange

Group, this internal control environment en-

sures compliancy with relevant regulations

including [NH1.1]the Sapin II law require-

ments that must be complied with, at Orange

group level.

All documentation is regularly reviewed and

duly updated. Specific functions of assur-

54

Orange Belgium

_

Annual report 2025

ance (i.e. fraud, revenue assurance, data pri-

vacy, security, business continuity and crisis

management), compliance and audit (i.e. ‘In-

ternal Audit’) have also been set up.

The budget control covers not only the

budget aspects, but also key performance

indicators. In order to ensure adequate finan-

cial planning and follow-up, a financial plan-

ning procedure which describes planning,

quantification, implementation and review of

the budget in alignment with the periodical

forecasts, is closely followed up.

Information and communication

The company maintains transparent commu-

nication towards its employees, in conform-

ity with its values and based on a variety of

communication channels integrating in par-

ticular its intranet, internal communication

emails and periodical presentations by the

Executive Management at different levels.

Advanced data processing and control pro-

cesses ensure reliable information is made

available in a timely manner, in particular fi-

nancial reporting.

Orange Belgium Group aspires to be open

and transparent in its disclosure to the pub-

lic, shareholders, customers, employees and

other stakeholders. The company publishes

detailed financial reports providing a com-

prehensive set of key performance indicators

and financial statements for each business

segment. These results are made available

to the press and to the investor and financial

analyst community during dedicated meet-

ings

(conference

calls/webcasts/physical

meetings). The provided information is ac-

cessible to all and available on the compa-

ny’s website (https://corporate. orange.be).

Monitoring

In addition to the front-line control activities,

specific functions of assurance, compliance

and audit are in place to ensure internal con-

trol is constantly assessed. Internal Audit re-

ports to the Audit Committee to ensure it can

carry out its assignments with independence

and impartiality.

The Audit Committee monitors the respon-

siveness to audit engagements and the fol-

low-up of action plans and, if any, of correc-

tive recommendations. The Audit Committee

also monitors and controls the reporting pro-

cess of the financial information disclosed by

the company and its reporting methods. To

this effect, the Audit Committee discusses all

financial information with the Executive Man-

agement and with the external auditor and,

if required, examines specific issues with re-

spect to this information.

3.

Shareholders

The following table shows Orange Belgium’s

shareholder structure as at 31 December

2025, as evidenced by the notifications re-

ceived pursuant to article 14, al. 4 of the law

of 2 May 2007:

Atlas Services Belgium SA – an Orange

SA wholly-owned subsidiary – is Orange

Belgium’s main shareholder.

In compliance with Belgian legal regulations

on transparency as regards notification of

shareholding thresholds of listed companies,

Orange Belgium sets notification thresholds

at 3%, 5% and multiples of 5%.

Situation on 31.12.2025 (based on

Transparancy Notifications)

Shareholders’ structure based on notiﬁcations

date

notiﬁcation

# voting

rights notiﬁed

% owned

ASB

06/10/2025

51 427 221

76.29%

TFG Asset Management UK LLP *

31/10/2025

8 766 407

13.00%

UBS Group AG**

20/03/2025

3 046 592

4.52%

Nethys

06/10/2025

2 986 979

4.43%

Free ﬂoat

1 185 006

1.76%

Total

67 412 205

100.0%

*

TFG Asset Management owns 2,019,604 shares and

6,746,803 equivalent ﬁnancial instruments

** UBS Group AG owns 3,046,574 shares and 18 equivalent

ﬁnancial instruments

Notification in compliance with the

law on takeover bids

On 24 August 2009, the company received a

notification from its ultimate parent company

Orange SA pursuant to article 74 §7 of the

law of 1 April 2007 concerning takeover bids.

This notification detailed Orange SA’s owner-

ship in Orange Belgium.

As at 24 August 2009, Orange SA held in-

directly 31,753,100 Orange Belgium shares.

The chain of control was reconfirmed on

1 July 2013 after an internal restructuring of

the Orange Group.

As a result of a public takeover bid launched

in 2021, Orange SA increased its indirect

ownership to 46,191,064 Orange Belgium

shares and notified Orange Belgium thereof

on 26 May 2021. In the meantime, its owner-

ship has increased to 51.427.221.

The organization chart below illustrates

Orange Belgium’s shareholding structure as

at 31 December 2025.

55

Orange Belgium

_

Annual report 2025

Orange Netco

(Belgium)

Smart Services network

(Belgium)

MWingz

(Belgium)

Irisnet

(Belgium)

OCL

(Luxembourg)

Belgian Mobile ID

(Belgium)

A&S Partners

(Belgium)

CommuniThings

(Belgium)

Walcom Business Solutions

(Belgium)

BeTV

(Belgium)

WBCC

(Belgium)

Orange SA

(France)

Orange

Belgium

(Belgium)

Atlas

Services

Belgium

(Belgium)

100%

50%

28.16%

100%

6.59%

100%

14.29%

100%

76.29%

4. Relevant information

as provided by Article

34 of the Royal Decree

of 14 November 2007

Capital structure – special

control rights

The capital of Orange Belgium is represented

by 67,412,205 shares without nominal value,

each representing an equal share of the capi-

tal. The shares are registered or dematerialised.

There are no specific categories of shares

and all shares have the same voting rights

and obligations with no exceptions.

The principle within the company has al-

ways been to respect the rule “one share,

one vote”. The company has decided not to

make use of the option offered by article 7:53

of the Code of Companies and Associations

to grant a double voting right to fully paid-up

shares that are registered in the share regis-

ter for at least two years without interruption

in the name of the same shareholder.

Transfer of shares

There are no specific restrictions on the free

transfer of shares other than those set out by

the law or in the shareholders’ agreement re-

ferred to below.

Control mechanism provided

in a potential employee

shareholding system

when voting rights are not

exercised directly by the

personnel

Not applicable.

Exercise of voting rights

There are no legal or statutory restrictions on

the exercise of voting rights as regards the

company’s shares.

Shareholder agreements

Orange Belgium is aware of a sharehold-

er’s agreement entered into between Atlas

Services Belgium SA and Nethys SA which

could restrict the transfer of shares and/or

the exercise of voting rights.

Appointment, renewal,

resignation and dismissal of

directors

The directors are appointed or re-appointed

by the General Meeting upon proposal by the

Board of Directors, which takes into consid-

eration the proposals made by the Remu-

neration and Nomination Committee and by

those shareholders holding at least 3% of the

capital. The directors are generally appointed

for a period that does not exceed four years

in accordance with the recommendation of

article 5.6 of the CGC; their mandate can be

renewed by a resolution of the General Meet-

ing. Any renewal is analysed in accordance

with the principles set out in the CGC.

If the mandate of a director becomes vacant

during the term of office, the remaining direc-

tors have the right to appoint a replacement

director, based on the recommendation of

the Remuneration and Nomination Commit-

tee. The mandate of the co-opted director

is submitted to the first General Meeting for

confirmation.

The directors may be dismissed at any time

by the General Meeting.

56

Orange Belgium

_

Annual report 2025

Modification of the Articles of

Association

The General Meeting may only deliberate

on and decide to amend the articles of as-

sociation when the changes proposed are

set out specifically in the notice convening

the General Meeting, and when the share-

holders present or represented, represent at

least half the capital. If the latter condition is

not met, a second General Meeting must be

convened which shall validly deliberate and

decide, regardless of the portion of the cap-

ital represented by the shareholders present

or represented.

The modification shall only be adopted if ap-

proved by three quarters of the votes cast,

not counting abstentions in both the numer-

ator and the denominator. A modification of

the object of the company shall only be ac-

cepted if approved by four fifths of the votes

cast.

Powers of the Board of

Directors, in particular to

issue and buyback shares

The Board of Directors is not empowered to

issue new shares as long as the company

does not make use of the authorised capital

procedure.

The Extraordinary General Meeting of 2 May

2024 has, in accordance with and within the

limitations set out in the Code of Companies

and Associations, authorised the Board of

Directors to acquire own shares of the com-

pany, by purchase or exchange, on or out-

side the regulated market.

The company may only acquire shares of the

company if it does not hold more than 20%

of its own shares. The purchase price shall

not be less than eighty-five per cent (85%) or

more than one hundred and fifteen per cent

(115%) of the average closing price on the

regulated market on which the shares were

admitted during the 5 working days preced-

ing the purchase or exchange. This authori-

sation shall remain valid for a period of five

(5) years as from 2 May 2024.

This authorisation extends to the acquisition

(by purchase or exchange) of shares of the

company by a direct subsidiary company, in

accordance with article 7:221 and following

of the Code of Companies and Associations

and under the conditions laid down in those

provisions.

The Board of Directors is also authorised to

alienate or to cancel the own shares. This

authorisation extends to the cancellation of

the shares of the company acquired by a

direct subsidiary as well as to the alienation

of the company’s shares by a direct subsid-

iary company at a price determined by the

Board of Directors of the latter. The Board of

Directors of the company is also authorised

to have the cancellation of own shares of the

company recorded by a notary public, and to

coordinate the articles of association in order

to bring them in line with the decisions taken.

Significant agreements that

may be impacted by a change

of control of the company

Agreements to which the company is a party

and which are covered by Article 7:151 of the

Code of Companies and Associations, where

applicable, are presented and approved by

the Special General Shareholders Meeting.

Agreements providing for

compensation in the event of

a public takeover bid

There are no specific agreements between

the company and the members of the Board

of Directors or the personnel which provide

for compensation in the event of a public

takeover bid.

5.

Composition and

functioning of the

Board of Directors and

its Committees

The rules governing the structure, composi-

tion, functioning role and assessment of the

Board of Directors and of its committees are

set out in the Charter. The internal rules of the

Board of Directors (Appendix I), the Audit and

Risk Committee (Appendix III) and the Remu-

neration and Nomination Committee (Appen-

dix IV) are attached to the Charter.

The company opts for a one-tier governance

structure: the Board of Directors has the pow-

er to accomplish all required or useful acts in

order to achieve the object of the company,

except for those acts that are reserved by

law to the General Meeting. The operation-

al management of the company, including

without limitation the daily management, is

carried out by the Executive Management

(see section 6 below).

Board of Directors

Structure and composition

The Board of Directors is composed of a

reasonable number of directors to ensure its

proper functioning,, while taking into account

the specificities of the company.

As at 31 December 2025, the Board of Direc-

tors consisted of 14 members:

•

13 of the 14 members of the Board of

Directors are non- executive directors;

•

among

the

non-executive

directors

4 directors are independent;

•

5 members of the Board of Directors are

women;

•

there is no age limit within the Board of

Directors.

The composition of the Board of Directors is

determined based on the diversity and com-

plementary of competencies, experiences

and knowledge of its members, as well as

on the basis of gender and age diversity and

diversity in general. In particular, the compo-

sition of the Board of Directors must be such

that the Board of Directors, as a whole, pos-

sess the following competencies:

(i) “generic competencies”, namely in the

field of finance, accounting, governance,

management and organization; and

(ii) “industry specific competencies”, namely

in the field of operations, technology, dis-

tribution, marketing, etc.

During the year 2025, the following changes

occurred within the Board of Directors:

•

The mandate of Mrs. Sara Puigvert (who

was co-opted by the Board of Directors

during its meeting on 18 July, 2024, with

effect from 19 July, 2024, replacing Mrs.

Clarisse Heriard Dubreuil, who resigned)

was confirmed by the Ordinary and

Special General Meeting of Shareholders

held on 7 May, 2025. Her mandate will

expire at the end of the Ordinary General

Meeting of Shareholders in 2027.

•

The company “From the Factory” (F.T.F.)

SComm., represented by Mr. Philippe

Delusinne, resigned as a director with

effect from 1 October 2025 (at 11:59 PM).

As of 31 December 2025, the Board of Direc-

tors is composed as follows:

57

Orange Belgium

_

Annual report 2025

Name

Function

Main function

Born

Nationality

End of mandate

The House of Value – Advisory & Solutions BV

(5)

Director/ Chairman

Director of companies

NA

Belgian

AGM 2027

X. Pichon

(1)(2)

Executive director

CEO - Orange Belgium

1967

French

AGM 2027

K2A Management and Investment Services (K2A Services) BV

(3)(6)

Independent director

Director of companies

NA

Belgian

AGM 2027

S. Puigvert

(1)

Director

Executive VP of Global Operations - Orange SA

1972

French

AGM 2027

Ch. Luginbühl

(1)

Director/ Vice-chairman

Senior VP ESG & Large Projects - Orange SA

1967

Swiss

AGM 2027

J.-M. Vignolles

(1)

Director

Director of companies

1953

French

AGM 2027

M.-N. Jégo-Laveissière

(1)

Director

Executive VP / CEO Orange in Europe (outside France) - Orange SA

1968

French

AGM 2027

M. Bouchery

(1)

Director

Head of Group Finance and Treasury - Orange SA

1978

French

AGM 2027

Leadership and Management Advisory Services (LMAS) SRL

(3)(4)

Independent director

Director of companies

NA

Belgian

AGM 2027

C. Guillaumin (Haddad)

(1)

Director

Executive VP of Communication for the Group - Orange SA

1965

French

AGM 2027

I. Mertens

(3)

Independent director

Director of companies

1974

Belgian

AGM 2027

B. Demonceau

(1)

Director

CEO - ECETIA

1971

Belgian

AGM 2027

L. Orsini

(1)

Director

Head of Grand Public

1970

Belgian

AGM 2027

B. Ramanantsoa

(3)

Independent director

Director of companies

1951

French

AGM 2027

(1) Directors who represent the majority shareholder (Atlas Services Belgium SA).

(2) Director in charge of the daily management since 1 September 2020.

(3) The independent directors have signed a declaration stating that they comply with the criteria of independence mentioned in the Code of Companies and Associations.

(4) The company Leadership and Management Advisory Services (LMAS) SRL is represented by Mr Grégoire Dallemagne.

(5) The company The House of Value - Advisory & Solutions is represented by Mr Johan Deschuyﬀeleer.

(6) The company K2A Management and Investment Services (K2A Services) is represented by Mr Wilfried Verstraete.

(7) Director who represents Nethys SA.

Functioning and role

The Board of Directors meets at least four

times a year.

Non-executive directors meet at least once

a year without the CEO and the other exec-

utive directors (where applicable), in compli-

ance with Article 3.11 of the CGC.

The Board of Directors may only deliberate

validly if at least half its members are present

or represented. The decisions are adopted

by a simple majority of the votes cast.

The Board of Directors met 8 times in 2025.

Each director’s individual attendance rate is

presented in the table below. During the year,

the Board of Directors’ discussions, reviews

and decisions focused on:

•

the company’s strategy and structure

•

the budget and its financing

•

the operational and financial situation

•

the commercial results

•

the

harmonization

of

the

working

conditions and remuneration

•

the demerger of VOO S.A. and the

application of the conflict of interests

procedure

of

article

7:97

of

the

Companies and Associations Code prior

to its implementation, concerning the

conclusion of a pledge agreement and a

letter of consent and release with Enodia

•

the incorporation of Orange NetCo SA

and the transfer of personnel from the

company dedicated to the “Wholesale”

activity to Orange NetCo SA

•

the new management services agree-

ment with Orange SA, as well as the

finalization of the application of the

conflict of interests procedure of article

7:97 of the Companies and Associations

Code prior to its conclusion

•

the evolution of the regulatory and

geopolitical framework

•

the risk management

•

the development of the B2B division

within the framework of the launch of

“Orange Business”

•

the entry of a new operator on the B2C

market

•

the fixed and mobile network and the

deployment of the fiber network

•

the competition

•

the artificial intelligence

•

the Information security, cyberattack,

cybersecurity, and compliance with the

NIS2 Directive (IT security master plan)

•

the various brands, their development,

and communication

•

the

composition

of

the

Board

(resignation), the Executive Management

(succession and development plans for

its members and departures), and the

Audit and Risk Committee (replacement)

•

the modification of the remuneration

policy

•

the delegation of powers

•

the (exit of) SOX certification and ESG/

CSRD reporting

There were no transactions or contractual

relationships in 2025 between the company

and the members of the Board of Directors

that gave rise to a conflict of interests within

the meaning of Article 7:96 of the Code of

Companies and Associations.

58

Orange Belgium

_

Annual report 2025

Members of the Board of Directors

Function

06-Feb

19-Mar

17-Apr

23-Jul

18-Aug

30-Sept

16-Oct

11-Dec

The House of Value - Advisory & Solutions BV (J. Deschuyﬀeleer)

Director/ Chairman

P

K2A Management and Investment Services (K2A Services) BV (W. Verstraete)

Independent director

P

R

P

X. Pichon

Executive Director

P

J.M. Vignolles

Director

P

Leadership and Management Advisory Services (LMAS) SRL (G. Dallemagne)

Independent director

P

S. Puigvert

Director

P

From the Factory (F.T.F.) Scomm (Ph. Delusinne) (resignation 01.10.2025)

Director

P

R

P

NA

B. Demonceau

Director

P

R

P

L. Orsini

Director

P

R

P

R

P

M-N. Jégo-Laveissière

Director

P

R

P

M. Bouchery

Director

P

C. Luginbühl

Director/Vice-chairman

P

R

C. Guillaumin (Haddad)

Director

P

R

P

R

I. Mertens

Independent director

P

B. Ramanantsoa

Independent director

P

P: present (in person or by call)

R: validly represented

E: excused

59

Orange Belgium

_

Annual report 2025

Johan

Deschuyffeleer

Chairman

Xavier

Pichon

Director

Grégoire

Dallemagne

Independent

director

Wilfried

Verstraete

Independent

director

Jean-Marc

Vignolles

Director

Sara

Puigvert

Director

Bertrand

Demonceau

Director

Mari-Noëlle

Jégo-Laveissière

Director

Laetitia

Orsini

Director

Matthieu

Bouchery

Director

Caroline

Guillaumin

Director

Bernard

Ramanantsoa

Independent

director

Christian

Luginbühl

Director/

Vice-chairman

Inne

Mertens

Independent

director

Members of the Board of Directors

60

Orange Belgium

_

Annual report 2025

Evaluation

The Board of Directors is responsible for a

periodic evaluation of its own effectiveness

with a view to ensure a continuous improve-

ment in the governance of the company.

In this respect, and under the lead of the

Chairman of the Board of the Directors, the

Board of Directors must regularly assess (at

least once every three years) its size, compo-

sition, performance and interaction with the

Executive Management.

This evaluation process has four objectives:

•

assessing the operation of the Board of

Directors;

•

verifying that the important issues are

thoroughly prepared and discussed;

•

assessing the actual contribution of

each director to the work of the Board

of Directors, by his or her attendance at

the Board of Directors and Committee

meetings and his or her constructive in-

volvement in discussions and the deci-

sion-making process;

•

comparing the Board of Directors’ cur-

rent composition against the Board of

Directors’ desired composition.

In order to enable periodic individual as-

sessments, the directors must give their full

assistance to the Chairman of the Board of

Directors, the Remuneration and Nomination

Committee and any other persons, whether

internal or external to the company, entrust-

ed with the assessment of the directors. The

Chairman of the Board of Directors, and the

performance of his or her duties within the

Board of Directors, must also be carefully

assessed.

The non-executive directors must assess, on

an annual basis, their interaction with the Ex-

ecutive Management and, if necessary, make

proposals to the Chairman of the Board of

Directors with a view to facilitating improve-

ments.

Based on the results of the assessment, the

Remuneration and Nomination Committee,

where appropriate and possibly in consulta-

tion with external experts, submits a report

commenting the strengths and weaknesses

of the Board of Directors and makes pro-

posals to appoint new members or not to re-

elect certain members.

Board Committees

In order to effectively fulfill its duties and re-

sponsibilities, and without prejudice to its le-

gal missions, the Board of Directors has set

up specialized committees to analyse spe-

cific issues and to advise and report to the

Board of Directors on those matters. These

committees have an advisory role.

The Charter foresees 2 special committees:

•

Audit and Risk Committee

•

Remuneration and Nomination Commit-

tee

These two committees are also foreseen in

the company’s articles of association.

The Board of Directors pays particular at-

tention to the composition of each of its

committees to ensure that in appointing the

members of each committee, the needs and

qualifications that are required for the opti-

mal operation of that committee are taken

into account.

Members of the Audit Committee

Function

05-Feb

16-Apr

22-Jul

15-Oct

10-Dec

B. Ramanantsoa

Independent Director/ Chairman

P

Leadership and Management Advisory Services (LMAS) SRL (G. Dallemagne)

Independent director

P

E

P

I. Mertens

Independent director

P

E

P

From the Factory (F.T.F.) SComm (Ph. Delusinne) (resignation 01.10.2025)

Director

P

E

P

NA

B. Demonceau (appointment 02.10.2025)

Director

NA

E

P

P: present (in person or by call)

R: validly represented

E: excused

Under the lead of its Chairman, the Board

must regularly assess (at least once every

three years), the operation of each commit-

tee and, in particular, its size, composition

and performance. This assessment serves

the same four objectives as those set out

above to assess the Board of Directors.

Audit and Risk Committee

The Audit and Risk Committee (the “Audit

Committee”) is composed of at least three

directors at all times. All members of the Au-

dit Committee must be exclusively non-ex-

ecutive directors and the majority of them

must be independent directors.

As at 31 December 2025, the Audit Commit-

tee is comprised of four directors: Mr. Ber-

nard Ramanantsoa, the company Leadership

and Management Advisory Services (LMAS)

SRL (represented by Mr. Grégoire Dalle-

magne), Mrs. Inne Mertens and Mr. Bertrand

Demonceau.

Pursuant to Article 3:6, §1 (9°) of the Code of

Companies and Associations, the company

must justify the independence and exper-

tise, in both accounting and audit matters,

of at least one of the members of the Audit

Committee. The company Leadership and

Management Advisory Services (LMAS) SRL

represented by Mr. Grégoire Dallemagne, in-

dependent director, is the Audit Committee

member who meets the independence cri-

teria defined in article 3.5 of the CGC. His

expertise in audit and financial matters is

endorsed by an extensive career in the tel-

ecoms industry as well as the energy sector.

The Audit Committee is responsible for pre-

paring a long-term audit program covering all

company activities. Without prejudice to ad-

ditional roles that the Board of Directors may

entrust to the Audit Committee, its role is to

assist the Board of Directors in its responsi-

bilities with respect to:

•

the monitoring of the financial reporting

process

•

the monitoring of the effectiveness of the

internal control and risk management

systems

•

the review of the budget proposals pre-

sented by the Executive Management

•

the monitoring of internal audit and its

effectiveness

•

the monitoring of the statutory audit of

the (consolidated) annual accounts

•

the monitoring of the financial relations

between the company and its sharehold-

ers

•

the review and monitoring of the inde-

pendence of the statutory auditor

The Audit Committee must convene when-

ever necessary for the proper operation of

the Committee, and in any event at least

four times a year and regularly reports to the

Board of Directors. The Committee met 5

times in 2025.

61

Orange Belgium

_

Annual report 2025

In 2025, the main subjects discussed by the

Audit Committee were:

•

the annual evaluation of the committee’s

functioning

•

the periodical financial, budget and ac-

tivity reports

•

the internal control

•

the internal audit (plan, activities, reports

and conclusions)

•

the assessment of the external audit and

report of the statutory auditor

•

the evolution of the regulatory and geo-

political framework

•

the risk management (cartography of

important risks and events, the new US

regulations and compliance action plan

•

the review and monitoring of the inde-

pendence of the statutory auditor

•

the annual report on “Fraud & Revenue

Assurance”

•

GDPR and data security

•

the (exit of) SOX certification, the “CFO

Guide” and “SMRs”

•

the integration of VOO, the demerger of

VOO and the incorporation of Orange

NetCo SA

•

the ESG/CSRD reporting

•

the Information security, cyberattack,

cybersecurity, and compliance with the

NIS2 Directive (IT security master plan)

Remuneration and Nomination

Committee

The Remuneration and Nomination Commit-

tee is composed of at least three directors at

all times. All members of the Remuneration

and Nomination Committee must be exclu-

sively non-executive directors and the major-

ity of them must be independent directors.

As at 31 December 2025, the Remuneration

and Nomination Committee is composed of

five directors: the company The House of

Value – Advisory Solutions BV (represented

by Mr. Johan Deschuyffeleer), Mrs. Inne

Mertens,

Mr.

Christian

Luginbühl,

the

company

K2A

Management

Investment

Services (K2A Services) BV (represented by

Mr. Wilfried Verstraete) and the company

Leadership

and

Management

Advisory

Services (LMAS) SRL (represented by Mr.

Grégoire Dallemagne).

The Remuneration and Nomination Commit-

tee, which has the necessary competencies

in respect of remuneration policy, is respon-

sible for assisting the Board of Directors in

defining a remuneration policy for the com-

pany’s directors and Executive Management.

Every year, it prepares a remuneration report

for the Board of Directors. The Remuner-

ation and Nomination Committee ensures

that procedures regarding the appointment

and renewal of directors, the CEO and oth-

er members of the Executive Management

are followed as objectively as possible. It

provides the Board of Directors with recom-

mendations on the appointment and remu-

neration of the directors, the CEO and other

members of the Executive Management.

The Remuneration and Nomination Commit-

tee must convene whenever necessary for

the proper operation of the committee, and

in any event at least twice a year. The com-

mittee met 6 times in 2025.

Members of the Audit Committee

Function

05-

Feb

16-

Apr

22-

Jul

22-

Sept

15-

Oct

10-

Dec

The House of Value - Advisory & Solutions BV

(J. Deschuyﬀeleer)

Director/

Chairman

P

K2A Management and Investment Services

(K2A Services) BV (W. Verstraete)

Independent

director

P

Leadership and Management Advisory Services

(LMAS) SRL (G. Dallemagne)

Independent

director

P

E

P

C. Luginbühl

Director

P

I. Mertens

Independent

director

P

R

P

P: present (in person or by call)

R: validly represented

E: excused

In 2025, the main subjects discussed by the

Remuneration and Nomination Committee

were:

•

the drafting and analysis of the remuner-

ation report

•

the remuneration policy (analysis and ap-

proval of the proposed modifications)

•

the validation of the performance bonus

and the objectives for 2025

•

the granting of a remuneration to any

independent

director

who

chairs

a

(non-statutory) committee of directors as

part of an analysis mission required by

article 7:97 of the Companies and Asso-

ciations Code

•

the resignation of the Chief Communica-

tion, Brand, and CSR Officer”

•

the appointment of a “Director Brand and

Sustainability, acting chief Brand, Com-

munication and ESG Officer”

•

the composition (succession and devel-

opment plans for its members and de-

partures), remuneration (analysis and val-

idation of proposed modifications) and

group disability insurance (analysis and

validation of proposed modifications) of

the members of the Executive Manage-

ment

•

the harmonization of working and sala-

ry conditions between the employees of

VOO SA and that of the company

•

the EU pay transparency directive

Committee of independent directors

created in the framework of the pro-

cedure of Article 7:97 of the Code of

Companies and Associations

The committee of independent directors has

been created in the framework of the appli-

cation of the conflict of interests’ procedure

of article 7:97 of the Code of Companies and

Associations. Reference is made to section

10 below of this corporate governance state-

ment for further detail.

This committee met 6 times in 2025.

Members of the committee

of independent directors

Function

09-

Jan

14-

Jan

22-

Jan

31-

Jan

19-

Sept

23-

Sept

K2A Management and Investment Services

(K2A Services) BV (W. Verstraete)

Independent

director (Chairman)

P

Leadership and Management Advisory Services

(LMAS) SRL (G. Dallemagne)

Independent

director

P

I. Mertens

Independent

director

P

P: present (in person or by call) R: validly represented E: excused

62

Orange Belgium

_

Annual report 2025

Xavier

Pichon

CEO

Paul-Marie

Dessart

General Secretary

Antoine

Chouc

Chief Financial Officer

Jelle

Jacquet

Chief People Officer

Javier

Diaz

Chief IT Officer

Werner

De Laet

Chief Enterprise

& Innovation

Officer

Philippe

Toussaint

Chief Technology

Officer

Christophe

Dujardin

Chief Consumer

Officer

Members of the Management Committee

63

Orange Belgium

_

Annual report 2025

6. Composition and

functioning of the

Executive Management

The rules governing the structure, compo-

sition, functioning, role and assessment of

the Executive Management are detailed in

the Charter. The Executive Management’s in-

ternal rules are presented in the appendices

(Appendix II).

Executive Management

Structure and composition

The Executive Management of the company

comprises the CEO and all persons who di-

rectly report to him and that head a depart-

ment of the company. The appointment of

the members of the Executive Management

is submitted to the Board of Directors for pri-

or approval, on the recommendation of the

Remuneration and Nomination Committee.

As at 31 December 2025, the Executive

Management is comprised of 8 members:

Executive

Management 2025

Function

Xavier Pichon

Chief Executive Oﬃcer

Antoine Chouc

Chief Financial Oﬃcer

Werner De Laet

Chief Enterprise &

Innovation Oﬃcer

Paul-Marie Dessart

Secretary General

Javier Diaz Sagredo

Chief IT Oﬃcer

Christophe Dujardin

Chief Consumer Oﬃcer

Jelle Jacquet

Chief People Oﬃcer

Philippe Toussaint

Chief Technology Oﬃcer

Functioning and role

The Executive Management is responsible

for managing the company by supporting the

CEO in the daily management of the compa-

ny and in the performance of his or her other

duties. Generally, the Executive Management

meets weekly, or whenever necessary for the

proper operation of the Executive Manage-

ment and the company.

7. Diversity Policy

Orange Belgium values diversity, equity and

inclusion and implements various criteria in

its selection processes to account for age,

gender, educational background as well as

professional experience.

The composition of the Board of Directors

and of the Executive Management is de-

termined on the basis of diverse and com-

plementary competencies, experience and

knowledge.

With respect to gender diversity, when a di-

rectorship is available, the company makes

the best effort to present candidates of both

genders to ensure that at least one-third of

the Board members are of a different gender

than the other members. The Board of Direc-

tors currently has five female directors out of

a total of 15.

In the framework of the legislation regarding

the publication of information with respect

to DEI (Diversity, Equity and Inclusion), the

company’s DEI policy will be further devel-

oped and monitored by the Board of Direc-

tors.

Our DEI ambitions are part of our Lead the Fu-

ture strategic pillar ‘care for people’. Orange

Belgium aims at being the preferred tech &

telco employer in Belgium by proposing an

attractive Lead the Future industrial pro-

ject and HR policy, developing tech talents

through internal learning programs and cap-

italizing on external partnerships such as the

Tech Academy by Orange. Valuing diversity

& inclusion highly and putting those values at

the heart of our company.

In 2025 we continued to focus on the VOO

integration. This year the major project was

the harmonization of the working conditions

and salary packages with the aim to provide

an attractive salary package to all the em-

ployees, based on their role level. To do this

we performed a prior grading exercise with

the objective to determine updated grading

for the whole organization to ensure all em-

ployees having the same role have the same

grade (independently from gender, age, …).

The new harmonized payroll was implement-

ed in July 2025.

To effectively tackle team-specific challeng-

es, we continued to deploy the approach we

initialized in 2023 with internalized coaching

and the promotion of team development as

a pathway to self-improvement, fostering a

holistic and diverse wellbeing approach. We

have a

well established & inclusive Learn-

ing & Development

approach to boost em-

ployee skills, retain talent and ensure legal

compliance. It is in this framework that we

launched our new training policy.

Through the Tech Academy and our part-

nership with the ULB, which we launched

in 2023, we continued to bring this strategic

pillar into action which resulted in enhanced

visibility,

attractiveness,

and

(youngster)

traineeship and recruitment. By investing in

specialized education and together with our

Orange labs, we are preparing students for

tomorrow’s Telecom challenges. During the

Academic year 2024-2025, 81 students fol-

lowed the Orange Chair co-created by Or-

ange tech experts and ULB Professors, we

created visibility towards 660 students from

EPB. Furthermore 14 students did an in-

ternship, we received 151 applications from

Tech students for young graduate positions,

student jobs or traineeships, 120 students

attended a seminar on 5G whilst 32 of our

team members received extra Telco Trainings

form the ULB. During the month of July, our

Orange Summer School, a key initiative of

the Tech Academy by Orange, offered tech

students, trainees and young graduates in

engineering a unique opportunity to engage

in a practical, personalized learning journey.

Just like the 2 previous years, this edition

was eye-opening for 10 young tech enthusi-

asts, but also a refreshing experience for our

Orange team.

We continued our partnership with Wom-

enInTech, a student association forming

a community of women engineers/Techs

& students from ULB who aim to promote

gender diversity in engineering studies and

to raise awareness around its importance in

STEM fields and more specifically in schools

and at university. We participated in 1 Speed

Networking session where several female

professionals from Orange were present, al-

lowing the students – both men and women

- to discuss and exchange with them. On 14

th

and 15

th

March 14, we invited WomenInTech

members to join our Hackathon, bringing

together 90 students from different back-

grounds to co-create innovative solutions.

Our collaboration is based on shared values

and mutual trust.

During the year we continued to publish en-

gaging and diverse ‘inside’ stories on our

Proud to be Orange website to promote our

employer brand.

To build bridges with future tech talent, during

the spring, close to 100 students from

EPB

(

ULB

/

VUB

),

HEPL

and

UMONS

left the class-

room and stepped into the telecom world at

Orange Belgium over the course of three sep-

arate visits. On different sites and in different

groups, they got a rare look at what telecom

looks like in practice: how networks are built,

tested, and monitored, and what it takes to

keep Belgium connected. 6 of our female

employees as well as 1 mentor and 1 coach

participated in the Group’s European Woman-

Up talent program involving CEOs, Executives

and Leaders from across the Group. The ob-

jective of this program being to prepare wom-

en for a bold next step on their professional

path, develop their leadership skills, develop

64

Orange Belgium

_

Annual report 2025

European business perspective and build a

community of talented female.

In October we launched our 2

nd

joint well-

being week as part of our overall Wellbeing

plan 2026, offering a wide array of activities,

while taking into account our multi-site and

multi-profile environment, as well as a range

of online and onsite trainings to taste from. In

October we launched our 2

nd

joint wellbeing

week as part of our overall Wellbeing plan

2026, offering a wide array of activities, while

taking into account our multi-site and mul-

ti-profile environment, as well as a range of

online and onsite trainings to taste from. This

year we included subjects as menopause and

neurodiversity. Of course we continued to of-

fer different types of wellbeing benefits, such

as: 20 km of Brussels, Bike to work challenge,

Biking challenge, Ekiden marathon, summer

party, EOY celebrations, all aimed at fostering

engagement.

In November we re-certified GEEIS or “Gen-

der Equality European International Stand-

ard”) for the 5

th

time in a row since 2011. This

recognition reflects our ongoing commitment

to gender equality and diversity within our or-

ganization and allows us to put in place tools

and processes to further progress. The audi-

tors were particularly impressed by our talent

development and wellbeing approach and our

long-time tradition of permanent dialogue &

qualitative labor relations.

The Orange Group diversity policy aims at fos-

tering talents and encouraging the inclusion

of all employees based on two pillars: gen-

der equality and equal opportunities. Orange

Belgium focuses on developing all available

talents for a unique experience by:

•

Offering a diverse and inclusive work

environment that encourages all our em-

ployees to progress and to develop their

talents for a unique experience;

•

Focusing on diversity in the broad sense:

promoting team diversity;

•

Ensuring well-being as a key component

of our equity and inclusion strategy.

Orange Group has defined

3 pillars for developing an

inclusive environment and

management

Whilst combatting discrimination by raising

awareness of stereotypes and banning all

forms of violence from the workplace. These

3 pillars are:

Gender equality

•

gender balance in all job lines, particular-

ly technical and digital professions

•

access for women to management posi-

tions at all levels of the hierarchy

•

work-life balance

•

equal pay between men and women

•

combatting sexism, sexual harassment,

and violence

Equal opportunities

•

age; Integration of young people and

multi-generational management

•

disability; Employment and integration of

people with disabilities

•

origins; Ethnic, socio-economic and cul-

tural diversity within the company

•

identity; Gender identity, sexual orienta-

tion and physical appearance

•

personal

opinions;

Religion,

political

opinion, trade-union membership

Digital Equality

•

gender balance in digital teams

•

increasing the numbers of women in the

digital sector

•

inclusive Artificial Intelligence Develop-

ment of responsible and inclusive AI

•

accessibility: Ensuring our digital appli-

cations are accessible for all

•

digital inclusion: Combatting the digital

divide, supporting seniors, integration

through employment

8. Remuneration Report

Introduction

This remuneration report concerns the 2025

financial year. Remuneration relating to the

2025 financial year complies with the remu-

neration policy that was applicable to that fi-

nancial year, as explained in the remuneration

report of the previous year, and as henceforth

explained in the Remuneration Policy, that

will be submitted for approval to the General

Meeting of Shareholders on 6 May 2026, and

to be found on the Orange Belgium website.

As far as needed, the remuneration policy is

incorporated into this remuneration report.

Orange Belgium Group delivered resilient

profitability in a transforming market en-

vironment. Revenues decreased by 1.5%

to €1,963.4m (2024: €1,993.7m), partly re-

flecting the non-renewal of Belgian football

broadcasting rights in H2 and a reduction in

low-margin activities. Despite this, EBITDAaL

grew by 4% to €566.1m (2024: €544.3m),

driven by the successful integration of VOO,

the realization of acquisition synergies, and

sustained operational efficiencies. This per-

formance highlights the Group’s focus on

value creation and disciplined cost manage-

ment.

You will find a comprehensive overview of

Orange Belgium major achievements in 2025

in the management report chapter.

Total remuneration

The tables below contain each individual di-

rector’s total remuneration split by component

and including any remuneration from any un-

dertaking belonging to the same group. Fur-

thermore, the tables below present the relative

proportion of fixed and variable remuneration.

In accordance with Article 3:6 §3, of the Bel-

gian Code of Companies and Associations,

amounts of remuneration for the members of

the Board of Directors are disclosed individu-

ally (table 1), and amounts of remuneration for

the other members of the Executive Manage-

ment are disclosed globally (table 2).

Independent directors receive a basic fee for

their mandate at the board of directors and

specific fees for their participation on other

committees (both are included in table below).

The remuneration policy of non-executive

directors is established in line with market

standards taking into consideration the scale,

organization and complexity of the Company.

Their remuneration is set at a level to enable

the Company to attract, motivate and retain

individuals with the profile and necessary ex-

perience for the role. No performance relat-

ed remuneration in connection with the per-

formance of the Company is anticipated for

non-executive directors, in accordance with

article 7.5 of the CGC.

In order to avoid that the non-executive direc-

tors, among which the independent directors,

would be overly influenced by the stock mar-

ket price of the Company’s share, the Com-

pany has decided not to grant a part of their

remuneration under the form of shares of the

Company. The Company believes that this

deviation to article 7.6 of the CGC allows the

non-executive directors to be the guardians of

the legitimate interests of all stakeholders of

the Company and to focus on its long-term

perspectives.

65

Orange Belgium

_

Annual report 2025

Name of director, position

Finan-

cial year

1. Fixed remuneration

2. Variable remuneration

3. Extra-

ordinary

items

4. Pension

expense

5. Total

Remune-

ration

6. Proportion

of ﬁxed and variable

remuneration

Base

salary

Fees

Fringe

beneﬁts

One-year

variable

Multi-year

variable

The House of Value - Advisory & Solutions

(1)

2025

89 400

2024

89 400

Leadership and Management Advisory Services (G. Dallemagne)

(2)

2025

69 600

2024

67 200

Inne Mertens

(3)

2025

69 600

2024

55 200

Bernard Ramanantsoa

(4)

2025

51 000

2024

53 400

K2A Management and Investment Services (W. Verstraete)

(5)

2025

65 400

2024

52 800

TOTAL

2025

345 000

2024

318 000

(1) as President of the Board of Directors and President of the Remuneration and Nomination Committee

(2) as member of the Audit Committee and member of the Remuneration and Nomination Committee

(3) as member of the Audit Committee and Remuneration and Nomination Committee

(4) as President of the Audit Committee

(5) as member of the Remuneration and Nomination Committee

Other members

of the management

Financial

year

1. Fixed remuneration

2. Variable remuneration

3. Extra-

ordinary items

4. Pension

expense

5. Total

Remuneration

6. Proportion

of ﬁxed and variable

remuneration

Base

salary

Fees

Fringe

beneﬁts

One-year

variable

Multi-year

variable

CEO

2025

499 319

358 681

(4)

438 256

252 341

95 191

1 643 788

Fix: 58%

Variable: 42%

2024

479 639

215 724

(4)

210 628

(3)

171 798

0

91 901

1 169 690

Fix:67%

Variable: 33%

(3)

Executive Committee (excl. CEO)

2025

2 215 351

142 433

1 238 107

1 221 606

411 637

5 229 135

(2)

Fix: 53%

Variable: 47%

2024

2 080 262

146 655

611 548

(3)

985 775

(1)

0

411 506

4 235 747

(1) (2) (4)

Fix: 62%

(1)

Variable: 38%

(3)

(1) The initial amount has been corrected from the 2024 remuneration report.

(2) The allowance provided by the Income Tax Code 92 for inpatriate executives is not included in the table.

(3) As of 2024, the performance cycle is measured on a yearly basis and no more on a semestrial basis. The variable remuneration in 2024 includes in the above table refers only to the achievement of the second semester of 2023 (a half year and not a full year).

(4) The fringe beneﬁts amount includes expat advantages according to the Orange Group Mobility policies including but not limited to relocation, home leave and schooling for children.

66

Orange Belgium

_

Annual report 2025

The details of the structure and components

of the remuneration of the members of the

Executive Management are explained here-

under.

Structure of the remuneration of

the members of the Executive

Management

The remuneration of the members of the Ex-

ecutive Management consists of the follow-

ing elements:

•

Yearly base remuneration (around 39% of

total remuneration)

•

Variable remuneration which is designed

to motivate the executive team to reach

company objectives on a yearly basis

and on a long-term basis. The variable

part is supposed to represent a substan-

tial part of the executive remuneration.

Both the short-term and the long-term

variable remunerations are linked to spe-

cific performance metrics and strategic

goals that drive the executive team to fo-

cus on sustainable growth and profitabil-

ity. The yearly and long-term targets are

validated by the remuneration committee

as well as the results.

- Short-term variable remuneration called

“performance bonus”.

- Long-term variable remuneration called

“Long-term Incentive Plan 2022-2024”,

“Long-term Incentive Plan 2023-2025”,

“Long-term Incentive Plan 2024-2026”

and “Long-term Incentive Plan 2025-

2027”.

•

According to Article 20 of the Orange Ar-

ticles of Association the Company may

deviate from the stipulations of article

7:91 (as the case may be in combination

with Article 7:121) of the Companies and

Associations code and which is the case

in relation to the variable remuneration

performance criteria. Orange considers

that the three-year recurring Long Term

Incentive plan for Executive Management

provides sufficient orientation for the cre-

ation of long-term value for the Company

in this respect.

•

Other elements of remuneration (around

15% of total remuneration)

- Group insurance consisting of four

parts: life – death – disability and waiver

of premiums

- Hospital insurance

- Employee profit sharing plan

- Company car/car allowance/Federal

Mobility Budget

- Meal vouchers

- Allowance for inpatriates which don’t

fall within the scope of the Income Tax

Code 92 for inpatriate executives.

Components of the remuneration

of the members of the Executive

Management

The remuneration policies concerning the

Executive Management are assessed and

discussed by the Remuneration and Nomi-

nation Committee that submits its proposals

for approval to the Board of Directors.

The yearly base remuneration

The yearly base remuneration is intended to

remunerate the nature and extent of individu-

al responsibilities.

It is based on market benchmarks while re-

specting internal equity within the company.

The variable remuneration

1) The Performance bonus

The short-term variable remuneration con-

sists of a proportion to encourage individual

performance and another part aimed at at-

taining company objectives.

In order to incentivize Executive Manage-

ment, to overachieve company targets, the

collective part includes the possibility for Ex-

ecutive Management to receive an additional

collective part payout (“collective boost”) on

a “Hit or Miss” principle (i.e. all or nothing),

the objective(s) are reached or not and must

be reached to receive the collective boost

payment depending on the achievement of

results against stretched financial targets de-

termined annually.

The targets for the individual part are set

against the main business priorities aligned

with the company strategy. The progress

against those priorities is assessed based on

a number of indicators. The quality of man-

agement and leadership behaviour is also

taken into consideration during the evalua-

tion.

The targets for the collective part were as

follows:

•

Organic Cash Flow

•

Revenue

•

EBITDAaL (Earnings before Interest, Tax-

es, Depreciation and Amortization, after

Lease)

•

Operating Cash Flow (EBITDAaL minus (i)

investments in property, plant and equip-

ment and intangible assets and (ii) less

the price on disposal of fixed assets))

•

C-Sat cocktail, a KPI grouping Indicators

of the customer satisfaction throughout

the customer journey on a number of key

products and services in our major mar-

ket segments.

•

Mean Recommendation Score (average

customer recommendation score calcu-

lated for B2C and B2B markets)

•

CO

2

emissions (as set out in the GHG

Protocol (Green House Gas Protocol)

covering the greenhouse gases of the

Kyoto Protocol)

•

Social performance (participation rate

and engagement score in the employee

barometer campaigns)

The performance bonus has been granted in

cash, in warrants, in options on shares which

are not connected to the company or bene-

fits available in the Flex Income Plan.

More specifically:

•

A first portion (the collective part) has

been paid in cash under the form of a

collective bonus CLA90 (up to the ceiling

free of taxes and normal social security

charges)

•

A second portion has been paid in war-

rants or options on shares which are not

connected to the company (up to the tax

ceiling of 20% of the yearly remunera-

tion);

•

A third portion has been paid in the Flexi-

ble Income Plan, resulting in cash or ben-

efits in kind.

The

performance

criteria,

their

relative

weighting and the actual outcome in 2025

can be summarized as follows:

67

Orange Belgium

_

Annual report 2025

Name of director,

position

1.

Performance criteria

2.

Relative

weighting of the

performance

criteria

3.

Information on Performance Targets

[optional]

4.

a) Measured performance

b) Actual award outcome

a) Minimum target

/ threshold

performance

b) Corresponding

award

a) Maximum target /

performance

b) Corresponding

award

CEO

Individual target:

Progress against business priorities aligned with the business strategy as well as management

attitude and quality of Leadership.

40%

a) overachieved

b) 125%

Collective target: Revenue

6%

a) below target

b) 69.1%

Collective target: Organic Cash Flow

12%

a) overachieved

b) 150%

Collective target: EBITDA(aL)

18%

a) overachieved

b) 124%

Collective target: C-Sat cocktail / MRS

12%

a) below target

b) 93%

Collective target: Social performance

6%

a) below target

b) 75%

Collective target: CO

2

Reduction (scope 1&2)

6%

a) overachieved

b) 146.2%

Collective Boost target(s): EBITDAL(al)

Operating Cash Flow

-

a) both targets achieved jointly

b) 100%

Executive Committee

Individual target:

Progress against business priorities aligned with the business strategy as well as management

attitude and quality of Leadership.

40%

a) overachieved

b) 113%

Collective target: Revenue

6%

a) below target

b) 69.1%

Collective target: Organic Cash Flow

12%

a) overachieved

b) 150%

Collective target: EBITDA(aL)

18%

a) overachieved

b) 124%

Collective target: C-Sat cocktail / MRS

12%

a) below target

b) 93%

Collective target: Social performance

6%

a) below target

b) 75%

Collective target: CO

2

Reduction (scope 1&2)

6%

a) overachieved

b) 146,2%

Collective Boost target(s): EBITDAL(al)

Operating Cash Flow

-

a) Both targets achieved jointly

b) 100%

68

Orange Belgium

_

Annual report 2025

2) The long-term variable remuneration

The long-term variable consists of recurring

long-term Incentive Plans (2022-2024, 2023-

2025, 2024-2026 and 2025-2027) which rep-

resents 30% of yearly fixed remuneration of

executive members after three years.

The LTIP is a “rolling plan” over three-year

performance periods with awards consid-

ered and decided annually by the Remunera-

tion and Nomination Committee.

The Remuneration and Nomination Com-

mittee decided on three company KPI’s and

targets to apply to each annual LTIP award

for the three-year performance period at the

beginning of the financial year.

For long-term Incentive Plans (2022-2024,

2023-2025 and 2024-2026), company targets

are weighted independently 50%/50%/50%,

with a maximum possible achievement for

each LTIP award of 150%. Subject to the

achievement of at least one company target

in any three-year performance period, indi-

vidual contribution by the executive member

can add an additional 25% to the final result

subject to an overall maximum LTIP potential

of 175% of the target award.

For long-term Incentive Plan (2025-2027),

company targets are weighted independent-

ly 1/3 /1/3 /1/3, with a maximum possible

achievement for each LTIP award of 100%.

LTIP awards will vest subject to company

performance measured over each three-

year period with plan payments paid in cash,

in warrants or in the form of non-company

share options, or benefits available in the

Flex Income Plan (possibly pension benefits).

In the case of payment in the form of options,

these options are frozen for one year.

In 2022, the company KPI’s decided for the

2022-2024 LTIP award were as follows:

•

EBITDA(al)

•

Organic Cash Flow (OCF)

•

Growth in Mobile Convergence: number

of B2C convergent mobile customers at

the end of the relevant period compared

to the strategic plan approved by the

Board of Directors.

In 2023, the Growth in Mobile Convergence

has been replaced by an ESG target that is

composed of two elements weighing 50%

each:

•

The number of women in management

positions

•

The energy efficiency

In 2024, the energy efficiency has been re-

placed by reduction in CO2 (Scope 1&2)

In 2025, the company KPI’s have remained

the same as 2024.

The long term Incentive Plan 2022-2024

has vested with results assessed at 150%

achievement and been paid in March 2025.

Long term Incentive Plans (2023-2025, 2024-

2026 and 2025-2027) awards are anticipated

to vest and become payable in respectively

March 2026, March 2027 and March 2028

respectively subject to results.

Other elements of the

remuneration

1) Group insurance - additional pension

plan

The additional pension plan is a plan with

predefined contributions. The acquired re-

serve consists of employers’ contributions

solely.

The amounts paid into the pension plan are

specified in table 1 above (total reward).

2) Employee profit sharing plan

In accordance with the law of 22 May 2001,

Orange Belgium shares 1% of the net con-

solidated profit under certain circumstances

with the members of the personnel including

the members of the Executive Management.

In the event the conditions are fulfilled, the

amount granted to each employee, including

the members of the Executive Management,

is identical regardless of the position is held.

In 2025, the General Meeting of Sharehold-

ers approved the award of a profit sharing

scheme resulting in an amount of €116.98

per employee working full-time (including

members of the Executive Management),

paid in June 2025 (based on the number of

months performed in 2024).

3) Other benefits

The members of the Executive Management

benefit from other advantages, in accord-

ance with the practices of the sector and

their level of function, such as hospital insur-

ance, availability of/disposal over a vehicle or

the ‘Federal Mobility Budget”, meal vouch-

ers, mobile phone, internet connection, etc.

Members of the Executive Management

when on international assignment within

Orange may also receive additional advan-

tages under Orange Group Mobility policies

including but not limited to relocation, hous-

ing allowances, home leave and schooling

for children.

2. Share-based remuneration

In 2025, the Board of Directors of Orange

S.A. decided to implement a share award for

the 3-year period 2025-2027 approved pur-

suant to the provisions of the seventeenth

resolution of the General Meeting of Share-

holders of 21 May 2025.

The aim of the Orange S.A. Long Term In-

centive Plan is to develop corporate loyalty

amongst employees who perform key func-

tions in the Group and to align the interests

of beneficiaries, the Group and shareholders.

As part of the implementation of the ‘Lead

the future’ strategic plan, the Board of Direc-

tors of Orange S.A. decided on 28 July 2025

to award rights over Orange S.A shares to

eligible executive members of the company

and certain other key employees according

to the terms and conditions of the 2025-2027

award. Shares will only vest at the end of the

vesting period for the award on or after 31

March 2028, subject to the presence condi-

tions and achievement of the performance

conditions as assessed by the Board of Di-

rectors of Orange S.A.

3. Severance payments

All members of the Executive Management

have an employment contract. The Chief

Consumer Business Officer who joined the

company in January 2020 and the Chief Ex-

ecutive Officer who joined the company in

September 2020, benefit from a 12-month

exit guarantee. For the other members of the

Executive Management, labour law applies

and no specific severance clauses have been

agreed.

No severance indemnity was paid during

2025.

4. Use of the right to reclaim

No circumstances justified any reclaim in

2025.

5. Derogations and deviations

from the remuneration

policy

In 2025, there was no deviation from the re-

muneration policy.

69

Orange Belgium

_

Annual report 2025

6. Comparative information - evolution of remuneration and performance

2021

2022

2023 Reported

2023 Comparable

2024

2025

Directors/Executive Remuneration

CEO total remuneration (in €)

810 523

1 069 046

1 150 449

1 169 690

1 643 788

Executive committee (excluding CEO) total remuneration (in €)

4 003 050

3 890 280

4 424 650

4 235 747

(1) (2)

5 229 135

(2)

Orange Belgium Group performance

Net Proﬁt (in m€)

39.7

58.2

-10.8

-18.5

17.2

41.3

Total Revenues (in m€)

1 363.50

1 391.2

1 749.5

1 961.1

1 993.7

1 963.4

EBITDAal (in m€)

353.0

373.7

451.34

494.3

544.3

566.1

Organic Cash Flow (Social View) (in m€) from Telecom activities

126.6

105.3

19.3

51.9

101.5

Organic Cash Flow (Social View) (in m€)

104.8

-115.2

-182.1

41.8

90.8

Brand NPS*

121.3% vs target

113.6% vs target

100.9% vs target

97.8% vs target

-

eNPS*

113.2% vs target

112.5% vs target

115% vs target

109.1% vs target

-

Voice-Up Engagement***

-

77.0

Voice-Up Participation***

-

79.0

CSAT (/MRS)**

-

93.0% vs target

Average remuneration on a full-time basis of employees

Average remuneration per employee (in €)

71 304

73 357

79 805

79 816

79 289

76 207

(1) The initial amount has been corrected from the 2024 remuneration report.

(2) from

(*)

for Brand NPS (meanwhile C-Sat Cocktail) and eNPS, the table shows the achievement vs target at the end of the 1st semester of the relevant year to be consistent with payment dates of the performance bonus. The performance bonus paid in 2024

relates to semester 2 of 2023.

(**)

CSAT (/MRS) has been applicable since 2025.

(***)

Voice-Up has been applicable since 2025 & replaces the eNPS. 2 dimensions are evaluated: Voice-Up Participation & Voice-Up Engagement. The goal is to increase the participation rate in the Voice Up survey and to measure employee satisfaction and

engagement with their employer. Satisfaction is measured on a scale from 1 to 5. Workers giving a score of 4 and 5 are called ‘promoters’. The scores of 4 and 5 are added together, and the proportion of these scores relative to the total responses is

translated into an «engagement percentage».

The methodology used to calculate the

average

remuneration

on

a

full-time

equivalent basis of employees considers:

sum of the yearly base pay (monthly base

salary of December 2025 * 13.92) and sum

of the actual variable remuneration paid in

2025 for all employees of Orange Belgium

excluding CEO and Executive Management.

All the elements that have been considered

to calculate the CEO and Exco remuneration

on a yearly basis have been included in the

calculation: employer contribution in the

meal vouchers, profit sharing, employer

contribution in the group insurance, employer

contribution in the hospitalization insurance,

company car (benefit in kind), car allowance,

Legal Mobility Budget, benefit in kind for

mobile phone and consumption vouchers if

applicable.

The retail employees are included in the

analysis of the remuneration ratio since 2024,

which was not the case in the editions of the

remuneration report before 2024.

Ratio between the highest

remuneration and the lowest

remuneration

The ratio between the total remuneration

of Orange Belgium’s CEO and the total re-

muneration of the lowest paid employee is

equivalent to 48.

70

Orange Belgium

_

Annual report 2025

9.

Contractual relations

with directors,

managers and

companies of the

Orange Group

Every contract and every transaction between

a director or a member of the Executive

Management and the company requires

prior approval from the Board of Directors,

after informing and consulting with the Audit

Committee in that respect. Such contracts

or transactions should be concluded at

commercial conditions, in accordance with

the prevailing market circumstances. The

prior approval of the Board of Directors is

required, even if articles 7:96 and 7:97 of the

Code of Companies and Associations are

not applicable to the said transaction or the

said contract. However, services delivered

by the company in its normal course of

business and at normal market conditions

(i.e. a normal “customer relationship”) are not

subject to such prior approval.

There

are

agreements

and/or

invoices

regarding the performances of the staff

members and/or delivery of services or

goods between the company and several

companies of the Orange Group. These

contracts and invoices are reviewed by the

Audit Committee.

10. Application of article

7:97 of the Code

of Companies and

Associations during the

2025 financial year

The procedure foreseen in article 7:97 of the

Code of Companies and Associations has

been applied in 2025 :

•

The procedure launched in 2024 as part

of the conclusion of a new management

services agreement with its indirect

shareholder Orange SA was finalized and

formalized in Q3 2025. A favorable opin-

ion was issued by the committee of inde-

pendent directors. The public announce-

ment relating to the transaction can be

consulted on the Company’s website

(under “Financial news”).

•

The procedure launched in Q3 2025 in

the framework of the demerger of VOO

S.A. with regard to the conclusion of a

pledge agreement and a letter of consent

and release with Enodia was finalized

and formalized in Q3 2025. A favorable

opinion was issued by the committee of

independent directors. The public an-

nouncement relating to the transaction

can be consulted on the Company’s

website (under “Regulated information”).

11. Information concerning

the tasks entrusted to

the auditors

The audit of Orange Belgium’s consolidated

and statutory financial statements is entrust-

ed to Deloitte Bedrijfsrevisoren BV / Révi-

seurs d’Entreprises SRL.

During 2025, the statutory auditor and linked

companies provided services for which the

fees were as follows:

Audit services €1,097,140, of which €563,100

for the parent company.

Non-audit services €209,045, of which

€157,545 for the parent company.

71

Orange Belgium

_

Annual report 2025

Sustainability

Report

72

Orange Belgium

_

Annual report 2025

73

T

A

B

L

E

O

F

C

O

N

T

E

N

T

1

.

G

E

N

E

R

A

L

I

N

F

O

R

M

A

T

I

O

N

.

7

6

1.1

G

ENERAL DISCLOSURES

(ESRS

2)

.........................................................................................................................................

76

1.1.1

Basis for preparation

......................................................................................................................................................

76

1.1.1.1

General basis for preparation of the sustainability statement (BP-1)

.......................................................................

76

1.1.1.2

Disclosures in relation to specific circumstances (BP-2)

.........................................................................................

77

1.1.2

Governance

....................................................................................................................................................................

79

1.1.2.1

The role of the administrative, management and supervisory bodies (GOV-1)

........................................................

79

1.1.2.2

Information provided to and sustainability matters addressed by the undertaking’s administrative, management

and supervisory bodies (GOV-2)

................................................................................................................................................

86

1.1.2.3

Integration of sustainability-related performance in incentive schemes (GOV-3)

.....................................................

87

1.1.2.4

Statement on due diligence (GOV-4)

.......................................................................................................................

88

1.1.2.5

Risk management and internal controls over sustainability reporting (GOV-5)

........................................................

89

1.1.3

Strategy

..........................................................................................................................................................................

91

1.1.3.1

Strategy, business model and value chain (SBM-1)

.................................................................................................

91

1.1.3.2

Interests and views of stakeholders (SBM-2)

...........................................................................................................

99

1.1.3.3

Material impacts, risks and opportunities (IROs) and their interaction with strategy and business model (SBM-3)

102

1.1.4

Impact, risks and opportunities management

...............................................................................................................

114

1.1.4.1

Description of the process to identify and assess material impacts, risks and opportunities (IRO-1)

....................

114

2

.

E

N

V

I

R

O

N

M

E

N

T

A

L

I

N

F

O

R

M

A

T

I

O

N

.

1

8

2.1

C

LIMATE

C

HANGE

(E1)

........................................................................................................................................................

118

2.1.1.

Environmental strategy

.................................................................................................................................................

118

2.1.1.1

Transition plan for climate change mitigation (E1-1)

..............................................................................................

118

2.1.2

Management of impacts, risks and opportunities related to climate change mitigation and energy

.............................

119

2.1.2.1

Policies related to climate change mitigation and energy (E1-2)

............................................................................

119

2.1.2.2

Targets related to climate change mitigation and energy (E1-4)

............................................................................

121

2.1.2.3

Energy consumption and mix (E1-5)

......................................................................................................................

123

2.1.2.4

Gross scopes 1, 2, 3 and total GHG emissions (E1-6)

...........................................................................................

124

2.1.2.5

GHG removals and GHG mitigation projects financed through carbon credits (E1-7)

...........................................

127

2.1.2.6

Taking actions on climate change mitigation and energy (E1-3)

............................................................................

127

2.1.3

Management of impacts, risks and opportunities related to climate change adaptation

..............................................

130

2.1.3.1

Policies related to climate change adaptation (E1-2)

.............................................................................................

130

2.1.3.2

Targets related to climate change adaptation (E1-4)

.............................................................................................

131

2.1.3.3

Taking actions on climate change adaptation (E1-3)

.............................................................................................

131

2.2

R

ESOURCE

U

SE AND

C

IRCULAR

E

CONOMY

(E5)

....................................................................................................................

132

2.2.1

Management of impacts, risks and opportunities related to resource use and circular economy

................................

132

2.2.1.1

Policies related to resource use and circular economy (E5-1)

...............................................................................

132

2.2.1.2

Targets related to resource use and circular economy (E5-3)

................................................................................

133

2.2.1.3

Taking actions on resource use and circular economy (E5-2)

................................................................................

133

2.2.2

Management of impacts, risks and opportunities related to resource outflows / waste

...............................................

137

2.2.2.1

Policies related to resource outflows / waste (E5-1)

..............................................................................................

138

2.2.2.2

Targets related to resource outflows and waste (E5-3)

..........................................................................................

138

2.2.2.3

Metrics related to resource outflows and waste (E5-5)

..........................................................................................

138

2.2.2.4

Taking actions on resource outflows and waste (E5-2)

..........................................................................................

140

2.3

T

HE

EU

T

AXONOMY

............................................................................................................................................................

142

3

.

S

O

C

I

A

L

I

N

F

O

R

M

A

T

I

O

N

.

1

4

3.1

H

UMAN RIGHTS

..................................................................................................................................................................

144

3.1.1

Orange Group human rights

.........................................................................................................................................

144

3.1.1.1

Human Rights Policy

.............................................................................................................................................

144

3.1.1.2

Focus on human trafficking, forced labour or compulsory labour and child labour

...............................................

146

3.1.2

Human rights for own workforce

...................................................................................................................................

147

3.1.3

Human rights for consumers and end users

.................................................................................................................

148

3.1.4

Human rights for workers in the value chain

.................................................................................................................

150

3.1.5

Human rights incidents (S1-17)

.....................................................................................................................................

150

3.2

O

RANGE

’

S OWN WORKFORCE

(S1)

.......................................................................................................................................

151

3.2.1

Management of impacts, risks and opportunities for the own workforce

.....................................................................

151

3.2.1.1

Processes for engaging with own workers and workers’ representatives about impacts (S1-2)

...........................

151

73

Orange Belgium

_

Annual report 2025

74

3.2.1.2

Processes to remediate negative impacts and channels for own workers to raise concerns (S1-3)

......................

153

3.2.2

Management of impacts, risks and opportunities related to training and skills development

.......................................

155

3.2.2.1

Policies related to training and skills development (S1-1)

......................................................................................

155

3.2.2.2

Targets related to training and skills development (S1-5)

......................................................................................

157

3.2.2.3

Training and skills development metrics (S1-13)

...................................................................................................

158

3.2.2.4

Taking actions on training and skills development (S1-4)

......................................................................................

159

3.2.3

Management of impacts, risks and opportunities related to diversity

...........................................................................

160

3.2.3.1

Policies related to diversity (S1-1)

..........................................................................................................................

160

3.2.3.2

Targets related to diversity (S1-5)

..........................................................................................................................

163

3.2.3.3

Diversity metrics

....................................................................................................................................................

163

3.2.3.4

Taking actions on diversity (S1-4)

..........................................................................................................................

166

3.2.4

Management of impacts, risks and opportunities related to health and safety

.............................................................

168

3.2.4.1

Policies related to health and safety (S1-1)

............................................................................................................

168

3.2.4.2

Targets related to health and safety (S1-5)

............................................................................................................

169

3.2.4.3

Health and safety metrics (S1-14)

..........................................................................................................................

170

3.2.4.4

Taking actions on health and safety (S1-4)

............................................................................................................

170

3.2.5

Additional metrics related to own workforce

.................................................................................................................

173

3.3

O

RANGE

’

S CONSUMERS AND END

-

USERS

(S4)

.......................................................................................................................

176

3.3.1

Management of impacts, risks and opportunities with end users

.................................................................................

176

3.3.1.1

Processes for engaging with consumers and end-users about impacts (S4-2)

.....................................................

176

3.3.1.2

Processes to remediate negative impacts and channels for consumers and end-users to raise concerns (S4-3). 177

3.3.2

Management of impacts, risks and opportunities related to digital inclusion

................................................................

178

3.3.2.1

Policies related to digital inclusion (S4-1)

..............................................................................................................

178

3.3.2.2

Target related to digital inclusion (S4-5)

................................................................................................................

178

3.3.2.3

Taking actions on digital inclusion (S4-4)

...............................................................................................................

179

3.3.3

Management of impacts, risks and opportunities related to psychological health of end-users

...................................

182

3.3.3.1

Policies related to psychological health of end-users (S4-1)

.................................................................................

182

3.3.3.2

Targets related to psychological health of end-users (S4-5)

..................................................................................

182

3.3.3.3

Taking actions on psychological health of end-users (S4-4)

..................................................................................

182

3.3.4

Management of impacts, risks and opportunities related to data privacy and cybersecurity

.......................................

184

3.3.4.1

Policies related to data privacy and cybersecurity (S4-1)

......................................................................................

184

3.3.4.2

Targets related to data privacy and cybersecurity (S4-5)

......................................................................................

185

3.3.4.3

Taking actions on data privacy and cybersecurity (S4-4)

......................................................................................

185

4

.

G

O

V

E

R

N

A

N

C

E

.

1

8

4.1

B

USINESS

C

ONDUCT

(G1)

...................................................................................................................................................

188

4.1.1

Management of impacts, risks and opportunities related to business ethics

................................................................

188

4.1.1.1

Business conduct policies and corporate culture (G1-1, G1-3)

.............................................................................

188

4.1.1.2

Incidents of corruption or bribery (G1-4)

................................................................................................................

193

4.1.2

Management of impacts, risks and opportunities related to suppliers’ relations

..........................................................

193

4.1.2.1

Management of relationships with suppliers, lowering late payment impact on suppliers’ liquidity (G1-2)

............

193

4.1.2.2

Management of relationships with suppliers, building trust and secure responsible supply (G1-2)

.......................

194

5

.

A

P

E

N

D

I

X

.

1

9

7

5.1

N

OTE ON CARBON FOOTPRINT ASSESSMENT METHODOLOGY

..................................................................................................

197

5.2

D

ISCLOSURES ON THE MATERIALITY ASSESSMENT PROCESS

(ESRS

2

IRO-2)

..........................................................................

201

5.2.1

List of complied disclosure requirements

.....................................................................................................................

201

5.2.2

List of datapoints in cross-cutting and topical standards that derive from other EU legislation

...................................

206

5.3

L

IMITED ASSURANCE REPORT OF THE STATUTORY AUDITOR ON THE CONSOLIDATED SUSTAINABILITY STATEMENT OF

O

RANGE

B

ELGIUM

………………………………………………………………………………………………………………………………………….214

74

Orange Belgium

_

Annual report 2025

75

L

I

S

T

O

F

T

A

B

L

E

S

Table 1: Members of the boards’ distribution

............................................................................................................................

79

Table 2: References to core elements of due diligence in this report

........................................................................................

89

Table 3: Orange energy consumption mix

...............................................................................................................................

123

Table 4: Orange energy production mix

..................................................................................................................................

124

Table 5: Orange Belgium and Orange Communications Luxembourg’s carbon footprint

.......................................................

125

Table 6: Orange’s economic carbon intensity

.........................................................................................................................

126

Table 7: Waste breakdown by hazardous and non-hazardous waste and treatment type

......................................................

139

Table 8: Taxonomy KPI of Orange Belgium and Orange Communications Luxembourg

........................................................

143

Table 9: Orange employees’ training and skills development

.................................................................................................

158

Table 10: Orange’s gender distribution at top management level

...........................................................................................

164

Table 11: Orange’s employee distribution by age group

.........................................................................................................

164

Table 12: Orange number of discrimination incidents and complaints

....................................................................................

164

Table 13: Gender pay gap of Orange

......................................................................................................................................

165

Table 14: Number of accidents and fatalities that are work-related within Orange

.................................................................

170

Table 15: Orange’s employees’ distribution by gender

...........................................................................................................

173

Table 16: Orange’s employees’ distribution by country

..........................................................................................................

173

Table 17: Orange’s employees’ distribution by contract type and gender

..............................................................................

174

Table 18: Orange’s employee departures and turnover rate

...................................................................................................

174

Table 19: Orange’s collective bargaining coverage

.................................................................................................................

175

Table 20: Orange’s social dialogue coverage

..........................................................................................................................

175

Table 21: Orange’s annual remuneration ratio

.........................................................................................................................

175

Table 22: Coverage of the compliance training per functions within Orange

..........................................................................

193

Table 23: Number of convictions and amount of fines for violation of anti-corruption and anti- bribery laws within Orange . 193

75

Orange Belgium

_

Annual report 2025

76

1.

General information

1.1

General disclosures (ESRS 2)

1.1.1

Basis for preparation

1.1.1.1

General basis for preparation of the sustainability statement (BP-1)

Reporting scope

The 2025 sustainability statement covers O

O

r

a

n

g

e

B

e

l

g

i

u

m

’

s

own

activities and all its f

f

u

l

y

c

o

n

s

o

l

i

d

a

t

e

d

s

u

b

s

i

d

i

a

r

i

e

s

i

n

B

e

l

g

i

u

m

a

n

d

L

u

x

e

m

b

o

u

r

g

(together referred to in this report as “

“

O

r

a

n

g

e

”

),

namely:

•

VOO, currently consolidated at 100%, has undergone a

demerger

effective

01/10/2025

with

retroactive

application from 01/07/2025. The assets and liabilities

have been transferred to Orange Belgium and to a

newly established entity named Netco. Netco is thereby

included in the scope in this sustainability statement,

just like its predecessor VOO. This transaction does not

affect the consolidated financial statements, as both

transferee entities are fully consolidated.

•

Be tv, consolidated at 100%

•

WBCC, consolidated at 100%

•

Orange Communications Luxembourg, consolidated at

100%

The report always covers information from all these entities

unless specified otherwise. Throughout this report, the term

'

O

r

a

n

g

e

G

r

o

u

p

'

o

r

'

t

h

e

G

r

o

u

p

'

refers to the parent company,

O

r

a

n

g

e

S

.

A

., headquartered in France.

This 2025 statement specifically e

e

x

c

l

u

d

e

s

subsidiaries that are

jointly controlled by Orange Belgium but over which it has no

direct control, or a low material impact or high administrative

burden as regards the value of the data. This includes Irisnet

(consolidated using the equity method at 28.12%), Mwingz (joint

venture at 50%), A&S Partners (consolidated at 100% but with

negligible impact on revenues, i.e. 0.05% of total revenues),

Smart Service Network (consolidated at 100% but negligible

impact

on

revenues);

and

Walcom

Business

Solutions

(consolidated at 100% but with negligible impact on revenues,

i.e. 0.0% of total revenues).

Joint-ventures and other entities under significant influence are

not included in the reporting scope.

This

sustainability

statement

c

o

v

e

r

s

i

t

s

u

p

s

t

r

e

a

m

a

n

d

o

w

n

s

t

r

e

a

m

v

a

l

u

e

c

h

a

i

n

. It is particularly the case regarding

indirect emissions (scope 3)

including emissions stemming from

our business partners and clients, as well as business conduct

(G1) disclosures that cover governance-related aspects of

upstream supplier relationships in Orange Belgium. In addition, a

stakeholder’s dialogue, where various stakeholders from the

upstream and downstream value chain have been consulted,

was performed to identify and prioritise the company's effects on

the value chain. As part of its double materiality exercise, an in-

depth analysis of the impacts, risks,

and opportunities (IRO) has

been conducted, focusing on Orange Belgium’s and Orange

Communications Luxembourg's own operations as well as its

upstream and its downstream value chain. This information is

detailed in section

1.1.4.1 Description of the process to identify

and assess material impacts, risks and opportunities (IRO-1)

. The

same applies to the policies and action plans to address them.

For each metric, a methodological note indicates the scope of

the information presented.

Information omitted

Orange did not use the option to omit a specific piece of

information corresponding to intellectual property, know-how or

the results of innovation.

The company has exercised its right to omit certain information

relating to impending developments or matters currently in the

course of negotiation, where disclosure could seriously prejudice

the company’s commercial position or result in misleading

information. The decision to apply this option has been made on

a case-by-case basis and is limited to specific elements, based

on the following considerations.

S

t

r

a

t

e

g

i

c

a

n

d

c

o

m

e

r

c

i

a

l

y

s

e

n

s

i

t

i

v

e

i

n

f

o

r

m

a

t

i

o

n

: Certain

disclosures relate to information that is closely linked to strategic

decision-making, internal assessments and capital allocation

processes. Disclosing such information could seriously prejudice

the company’s commercial position and therefore does not meet

the conditions for publication at this stage.

U

n

c

e

r

t

a

i

n

t

y

a

n

d

f

o

r

w

a

r

d

-

l

o

k

i

n

g

n

a

t

u

r

e

o

f

i

n

f

o

r

m

a

t

i

o

n

: Some

information relates to forward-looking developments that remain

subject to significant uncertainty and ongoing decision-making.

The

disclosure

of

such

information

could

lead

to

misinterpretation or provide a misleading view of the company’s

expected performance, as assumptions and timelines may

change.

M

a

t

u

r

i

t

y

o

f

m

e

t

h

o

d

o

l

o

g

i

e

s

,

d

a

t

a

n

d

i

n

t

e

r

n

a

l

p

r

o

c

e

s

e

s

: Other

disclosures depend on methodologies, data collection processes

or analytical frameworks that are still under development or being

aligned at Group level. In their current state, these elements do

not yet allow for sufficiently robust, consistent or reliable

disclosure.

G

r

o

u

p

-

l

e

v

e

l

g

o

v

e

r

n

a

n

c

e

a

n

d

s

c

o

p

e

o

f

r

e

s

p

o

n

s

i

b

i

l

i

t

y

: Certain

targets, plans and analyses are defined, managed and monitored

at Group level. Local-level disclosure of these elements would

not reflect the actual governance framework and would not

provide meaningful or decision-useful information at this stage.

76

Orange Belgium

_

Annual report 2025

77

The relevance and availability of the omitted information will be

reassessed in future reporting periods, where appropriate.

Based on the considerations above, the main disclosures

omitted in this reporting period relate in particular to:

•

The current and future financial effects of material

sustainability-related risks and opportunities on the

company’s

financial

position,

which

the

Group

considers to constitute strategic information;

•

Information on the resilience of the company’s strategy

and business model, as well as the underlying analysis

of physical and transition risks, as this analysis is under

development, steered at Group level, and pending

communication on the update of the Group’s strategic

plan;

•

The climate target, the climate transition plan, and the

financial resources allocated to the climate transition

plan, which are defined and managed at Group level;

•

The current and future resources required to implement

sustainability-related action plans, as the related

calculation methodologies are still under development

in coordination with the Group;

•

Forward-looking information on carbon sinks and

projected carbon credit needs, which are managed at

Group level as part of the Net Zero Carbon strategy;

•

Targets related to circular economy (E5) and digital

inclusion (S4), which form part of the Group’s strategic

plan and not representative at local level;

•

Targets related to psychological health of end users

(S4), as methodology and data of efficiency of actions

are too difficult to implement at this stage;

•

Targets related to data privacy and cybersecurity (S4)

are not disclosed due to information sensitivity.

1.1.1.2

Disclosures in relation to specific circumstances (BP-2)

In preparing its 2025 sustainability statement, Orange assessed

the materiality of the information to be disclosed, considering the

European Sustainability Reporting Standards (ESRS) application

requirements, and in particular the general elements of ESRS 2

and the list of sustainability matters covered by the thematic

issues, classified by topics, sub-topics in the ESRS, from the

perspective of financial materiality and/or impact materiality.

Material topics identified through the double materiality exercise

were matched with underlying quantitative and qualitative data

points defined by the ESRS framework. Within material ESRS,

some data points were assessed as not relevant for its industry

or business model. In addition, the relevance of the information

in terms of stakeholders’ expectations and Orange's ability to

respond to them was considered. A list of disclosure

requirements published can be found in the appendices of this

report.

In addition, the list of data points in cross-cutting and thematic

standards derived from other European Union legislation and

their correspondence with sections of the sustainability

statement is set out in the appendices of this report.

In preparing its sustainability statement, Orange has adhered to

several key legislations, reporting standards, or international

frameworks that guide Orange’s sustainability efforts and

enhance its commitment to responsible business practices.

These legislations, standards or frameworks include:

•

S

c

i

e

n

c

e

B

a

s

e

d

T

a

r

g

e

t

s

I

n

i

t

i

a

t

i

v

e

(

S

B

T

i

): Orange Group

aligned its emissions reduction targets with climate

science to ensure accountability and transparency,

Orange

Belgium

and

Orange

Communications

Luxembourg, as subsidiaries, contribute to this target.

•

G

r

e

n

h

o

u

s

e

G

a

s

e

s

(

G

H

G

)

P

r

o

t

o

c

o

l

:

Orange’s

emissions

reporting

follows

the

GHG

Protocol

standards, providing a comprehensive framework for

measuring and managing greenhouse gas emissions.

•

E

U

T

a

x

o

n

o

m

y

: Orange assesses its activities against

the EU Taxonomy to ensure they contribute to

environmental sustainability.

1

As defined in ESRS 1 section 6.4: “(a) for the short-term time horizon: the period adopted by the undertaking as the reporting period in its financial statements;

(b) for the medium-term time horizon: from the end of the short-term reporting period defined in (a) up to 5 years; and (c) for the long-term time horizon: more

than 5 years.

•

F

r

e

n

c

h

L

o

i

S

a

p

i

n

I

: Orange Belgium compliance

programme is designed to meet the requirements of the

French Loi Sapin II, promoting transparency and ethical

business practices.

•

D

u

t

y

o

f

v

i

g

i

l

a

n

c

e

: Orange implements measures to

identify and mitigate risks related to human rights and

environmental impacts in its value chain.

•

I

S

O

Norms 22301 and 27001: The company adheres to

ISO 22301 for business continuity management and

ISO 27001 for information security management,

ensuring resilience and data protection.

•

N

I

S

2

D

i

r

e

c

t

i

v

e

: Its practices comply with the NIS 2

Directive,

enhancing

cybersecurity

and

network

resilience.

•

B

e

l

g

i

a

n

C

o

d

e

o

n

W

e

l

b

e

i

n

g

a

t

W

o

r

k

: Orange Belgium

follows the Belgian Code to promote employee

wellbeing and ensure a safe working environment.

These frameworks guide the sustainability efforts and enhance

the company’s commitment to responsible business practices.

Standards are generally applied and mentioned with no reference

to specific paragraphs.

Estimation and uncertainty management

Orange has not deviated from the medium- or long-term time

horizons defined by the ESRS

1

.

Metrics in this report do include estimated data, in particular

related to the carbon footprint presented in

section 2.1.2.4 Gross

1, 2, 3 and total GHG emissions (E1-6)

in chapter 2 on the

Environmental information.

Orange Belgium and Orange Communications Luxembourg base

the measurement of GHG emissions in part on estimates. To

finalise this reporting exercise, some values of the last quarter

2025 have been estimated, when no primary data was available,

or evidence was not yet available from provider sources. For

emissions-related information, scope 1 and scope 2 greenhouse

gas emissions are based on actual data available up to

November, with December figures estimated to complete the

77

Orange Belgium

_

Annual report 2025

78

reporting year. For Orange Communications Luxembourg, a

limited number of estimations were also required for grid energy

consumption in November. Scope 3 emissions, taking into

consideration information related to our partners in our value

chain, rely partly on estimations due to data availability

constraints. For categories not directly linked to scope 1 and

scope 2 emissions, as well as for waste-related emissions at

Orange

Belgium

in

particular,

fourth-quarter

data

were

estimated. In addition, employee commuting and business travel

data were collected only for the first semester for all entities and

were extrapolated to cover the full year. Regarding waste,

Orange Belgium data is based on actual data up to November

with December estimated, while Orange Communications

Luxembourg waste data is fully based on actual figures for the

entire reporting period.

As explained in the GHG calculation methodological note part of

this report, the gradual replacement of GHG emission estimates

using the methodology based on monetary values by physical

values, as well as collaboration with its suppliers to refine

emission factors by category of equipment, contribute to

improving the quality of estimates. Further information regarding

the methodologies to calculate the carbon footprint can be found

in appendix

5.1 Note on carbon footprint assessment

methodology

.

In 2025, substantial efforts were made to improve the quality of

scope 3 value chain data, including refining calculation

methodologies and enhancing data collection processes. In

parallel, monitoring processes and tools for learning &

development and health and safety metrics were also

strengthened to enable more effective monitoring and reporting.

These efforts will continue in 2026, with a focus on further refining

data collection processes, methodologies, and internal controls

to continue to ensure ever more accurate and reliable KPI

reporting in future periods.

Looking ahead to 2026, major initiatives include moving as many

network equipment data points within scope 3 GHG emissions

as possible from monetary-based reporting to physical activity-

based collection for GHG calculations, in order to improve

precision, facilitate action planning, and make emission

reduction efforts more tangible for the Tech department. Further

planned improvements include enhancing the quality of waste

data by reconciling treatment percentages with supplier

evidence, and improving forecasts of electricity consumption of

the mobile network shared with other telecom providers.

Environmental data will be complemented by trend analyses and

performance insights shared with teams, providing guidance and

inspiration for continuous improvement.

To ensure transparency and comparability, each KPI that

includes estimated data is accompanied by a dedicated

methodological note describing the scope of the calculations, as

well as the applicable definitions, methodologies, assumptions

and limitations. These methodological notes also clarify the

resulting level of accuracy and certainty related to the source of

measurement of the reported metrics.

Historical changes

In 2025, the structure of the sustainability statement was revised

to enhance readability and coherence compared to the 2024

sustainability statement. All data points building on the general

disclosures presented under ESRS 2 have been consolidated in

this chapter, providing, where relevant, additional details on

specific sustainability-related matters. Furthermore, data points

have been reorganised by material sub-topic, bringing together

the corresponding policies, targets, metrics, and action plans.

Policies related to workers in the value chain and human rights

due diligence were previously addressed in a separate chapter

and are now grouped under section

3.1 Human rights

referring to

the rights of different stakeholders. In 2025, these disclosures

have been integrated into a transversal human rights chapter,

presenting specific information for each stakeholder group (own

workers (S1), workers in the value chain (S2), and consumers and

end-users (S4)) to further improve clarity and consistency.

A mapping of all disclosure requirements is available in the

appendices under section

5.2.1 List of complied disclosure

requirements

.

Compared to the 2024 sustainability statement, corrections

relating to comparative information have been identified:

•

The number of executive and non-executive board

members under the governance chapter (ESRS2 Gov-

1) has been corrected for 2024 and restated to ensure

comparability;

•

No variable remuneration linked to ESG KPIs was due

in 2024 (ESRS2 Gov-3). The first payment linked to ESG

KPIs will be paid in 2026;

•

The 2024 Gross location-based scope 2 GHG

emissions included a typo that did not affect the total

emissions and has been corrected this year;

•

The number of work-related accidents disclosed under

Health and Safety Metrics (S1-14) has been corrected

and restated to ensure comparability, following the

identification of an error in the 2024 sustainability

statement. The corrected figures had been subject to

verification as part of the 2024 assurance process.

No other material prior period errors were identified.

As a general principle, where the adjustment of comparative

information is not practicable, the reasons are disclosed through

the

relevant

methodological

explanations.

Where

the

comparability of metrics with prior periods is affected by

methodological changes, improvements in data quality, or

refinements in scope, these differences are explained in the

relevant methodological notes accompanying the affected KPIs.

For

example,

in

the

remuneration

metrics

for

Orange

Communications Luxembourg (S1-16), estimated 2024 data

have been replaced by actual 2025 remuneration data. Similarly,

certain scope 3 GHG categories (E1-6) that were not previously

calculated by Orange Communications Luxembourg are now

included. Details of these changes, including the underlying

assumptions and methodological adjustments, are provided in

the methodological notes for the respective KPIs.

In the English version of this statement, quantitative figures use

a comma as the thousand’s separator and a dot as the decimal

separator; while in the French and Dutch versions, a comma is

used as the decimal separator.

78

Orange Belgium

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Annual report 2025

79

1.1.2

Governance

1.1.2.1

The role of the administrative, management and supervisory bodies (GOV-1)

1.1.2.1.1

Composition and diversity of the members of the administrative, management and

supervisory bodies

Board of Directors

The s

s

u

p

e

r

v

i

s

o

r

y

b

o

a

r

d

s

of Orange Belgium and Orange Communications Luxembourg are composed in the following way:

M

e

m

b

e

r

s

o

f

t

h

e

b

o

a

r

d

s

2

0

2

4

2

0

2

5

Executive

12

13

Non-Executive

7

6

G

e

n

d

e

r

d

i

s

t

r

i

b

u

t

i

o

n

Female

32%

Male

68%

Not reported

N/A

Other

N/A

T

a

b

l

e

1

:

M

e

m

b

e

r

s

o

f

t

h

e

b

o

a

r

d

s

’

d

i

s

t

r

i

b

u

t

i

o

n

Compared to 2024, changes mainly reflect the integration of VOO and the natural evolution of the Board composition. Following the

restructuration, Philippe Delusinne left the Board of VOO and a new board was created for NetCo with three members in 2025.

The board gender diversity ratio is 0.5 in 2025 (as in 2024), reflecting an improvement in female representation on the board.

Independent members account for 21% of the boards (as in 2024), which are responsible for overseeing the activities of the mentioned

entities.

2

Note that an error has been identified in the 2024 statement (3 executive members and 16 non-executive members) and has been corrected in the present

table.

79

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Annual report 2025

80

Orange Belgium

_

Annual report 2025

81

Orange Belgium

_

Annual report 2025

82

Employee representation

Orange Belgium

The representation of employees within the company is

facilitated through three main bodies for consultation with the

Unions. These bodies are the Trade Union Delegation (TUD), the

Committee for Prevention & Protection at Work (CPPW) and the

Works Council (WoCo). Each of these bodies has both effective

and substitute members.

•

The TUD is a platform of concertation concerning the

conclusion of the Collective Labour Agreement (CLA),

reg. individual cases, the remuneration or employment

conditions. The TUD has eight effective and eight

substitute members and meets twice per month.

•

The members at CPPW give advice or suggestions on

each subject linked to the wellbeing at work, work

environment, security, health, hygiene. The CPPW has

10 effective and 10 substitute members and meets

once a month.

•

The WoCo's role includes communication of economic

& financial information, giving advice or suggestions on

subjects linked to work organisation, controlling the

application of social legislation, and making decisions

on the update of the Working Rules. The WoCo has 12

effective and 12 substitute members and meets once a

month.

These members are nominated by unions and elected during

social elections (except the delegates within the Trade Union

Delegation who are nominated by their permanent, employee

from the Union). The Chief People Officer and the General

Secretary represent the Direction in those platforms.

Some of Orange Belgium’s representatives are also members of

the European committee (‘Comité de Groupe Européen

d'Orange’) and of the World Committee (‘Comité de Groupe

Monde’), two international social dialogue bodies specific to the

Orange Group. The unions are also represented within the

International Trade Union Federation UNI Global Union, which

represents more than 20 million workers in 150 countries in the

services sector.

Orange Communications Luxembourg

The employee representation for Orange Communications

Luxembourg is organised in such a way as to ensure effective

and balanced representation. It includes five permanent

representatives of employees, as well as five alternates to ensure

continuity in representation. One representative is specifically

responsible for health and safety, to ensure the wellbeing and

safety of all employees. In addition, another representative is

responsible for Diversity, Equity and Inclusion (DEI) initiatives, to

promote an inclusive and diversity-friendly work environment.

Employees are represented by other employees from the

company who are voting for employee representatives during the

professional elections every five years. Employee representation

is an autonomous body. There is no direct or indirect employee

representation in the administrative or management body in the

Luxembourgish branch.

The

main

mission

of

employee

representation

is

the

representation and communication between employees and

management, while ensuring health and safety monitoring within

the company to ensure a safe working environment. It also

participates in the consultation on terms and conditions of

employment to defend their rights and interests, while playing an

active role in participating in social and economic discussions,

thus contributing to the development of policies favourable to

employees. The resolution of disputes and conflicts between

employees and employers is also part of its responsibilities. The

term of office for representing employees is five years, with legal

protection ensuring their independence and integrity during this

period.

82

Orange Belgium

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Annual report 2025

83

1.1.2.1.2

Roles and responsibilities of the administrative, management and supervisory

bodies

The governance

structure

for

the

management

of

the

Environment Social and Governance (ESG) and the Corporate

Sustainability Reporting Directive (CSRD) related activities

consists of several key bodies, each with distinct roles and

responsibilities:

•

The E

E

S

G

T

e

a

m

a

n

d

E

S

G

p

o

i

n

t

s

o

f

c

o

n

t

a

c

t

w

i

t

h

i

n

t

h

e

c

o

m

p

a

n

y

are responsible for ensuring that business

conduct aligns with ESG standards. This transversal

team includes the ESG team and key contacts from all

involved departments of the company (Finance, Human

resources, General Secretary, Marketing, Tech, etc.).

•

E

S

G

&

C

S

R

D

S

t

e

r

i

n

g

C

o

m

i

t

e

:

This specific

committee oversees both the overall ESG activities all

year long and the yearly sustainability statement

exercise, including business conduct topics. This

committee is composed of several contributors and five

members from the Executive Committee, i.e. the

Communication Brand & ESG Officer, the Chief Finance

83

Orange Belgium

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Annual report 2025

84

Officer, the Chief People Officer, the Chief Technology

Officer, and the General Secretary/Compliance Officer.

They convene quarterly to monitor a selection of key

ESG KPIs and the progress on yearly sustainability

statement exercise, and they provide guidance.

•

The D

D

i

v

e

r

s

i

t

y

,

E

q

u

i

t

y

a

n

d

I

n

c

l

u

s

i

o

n

(

D

E

I

)

C

o

m

i

t

e

oversees the implementation of actions related to the

zero-tolerance policy on discrimination and harassment

and monitors DEI performance.

•

Ad-hoc sessions are organised with the E

E

x

e

c

u

t

i

v

e

C

o

m

i

t

e

to focus on specific ESG topics which

needs strategic decisions.

•

The A

A

u

d

i

t

a

n

d

R

i

s

k

C

o

m

i

t

e

plays a crucial role in

reviewing updates on yearly sustainability statement.

This committee meets on a quarterly basis to assess

the effectiveness and compliance of these initiatives.

•

The N

N

o

m

i

n

a

t

i

o

n

a

n

d

R

e

m

u

n

e

r

a

t

i

o

n

C

o

m

i

t

e

advises

the

Board

on

remuneration

for

directors

and

executives, ensuring alignment with strategy, risk,

market norms and in line with Belgian corporate

governance best practices (including the Long-Term

Incentive Plans which entail ESG criteria)

•

Finally, the B

B

o

a

r

d

o

f

D

i

r

e

c

t

o

r

s

includes the ESG

Director of Europe from the Orange Group, who

provides insights on ESG matters. The Board receives

at least once a year and on ad hoc basis presentations

on ESG topics, including business conduct.

For more general information, please refer to

the corporate

governance statement chapter

of the Management Report:

Composition and functioning of the Board of Directors and its

Committees.

B

o

d

i

e

s

a

n

d

i

n

d

i

v

i

d

u

a

l

s

’

r

e

s

p

o

n

s

i

b

i

l

i

t

i

e

s

regarding i

i

m

p

a

c

t

s

,

r

i

s

k

s

a

n

d

o

p

o

r

t

u

n

i

t

i

e

s

(

I

R

O

)

are reflected in the Orange Belgium

Internal Audit, Internal Control and Risk Management Charter.

The control framework is based on a cross-functional,

collaborative structure, organised into three control lines, in

accordance with the standards of the Institute of Internal Auditors

(IIA):

•

T

h

e

f

i

r

s

t

l

i

n

e

o

f

c

o

n

t

r

o

l

(

O

p

e

r

a

t

i

o

n

s

)

manages

operational risks in line with the requirements of the

second line;

•

T

h

e

s

e

c

o

n

d

l

i

n

e

(expertise, surveillance and animation

of the overall r

r

i

s

k

c

o

n

t

r

o

l

s

y

s

t

e

m

) defines, deploys,

coordinates

and

evaluates

the

Group's

risk

management and internal control systems, providing

expertise and support;

•

T

h

e

t

h

i

r

d

l

i

n

e

(

i

n

d

e

p

e

n

d

e

n

t

v

a

l

u

a

t

i

o

n

)

provides

independent and objective assurance.

The Group Audit, Control and Risk Management Department

(DACRG in French) reports to the Group’s Executive Vice

President Finance, Performance and Development. It combines

key Group functions including risk management, internal control,

fraud & revenue assurance, general control, credit management

and internal audit. Its mission is to anticipate, define, deploy, lead

and evaluate the Group's approach to risk management and

business control, on behalf of General Management and the

Group Audit Committee.

The DACRG is a key player in the project to implement the

requirements of the CSRD and ESRS. The appointment of a

Group

Audit

Control

Risk

ESG

Director

dedicated

to

sustainability issues is intended to support, over the long term,

the design and deployment of a control framework adapted to

the challenges of transformation, steering, publication and

auditability of sustainability information.

The key components of the existing risk management and

internal control system are:

•

The Audit Control Risks (ACR) Charter defines the

framework of the ACR community's missions and the

integrated assurance approach, leveraging synergies

between local and central ACR functions and

operational

departments,

aiming

to

meet

the

company's objectives.

•

The risk management operating rules strengthen the

Group's resilience and apply to all areas.

•

The internal control procedures, which are deployed

through the existing ACR network.

•

The annual audit plan, which incorporates ESG

considerations through standard entity reviews and

thematic audits.

Under EU Directives 2006/43/EC and 2014/56/EU, the Group

Audit

Committee

annually

ensures

the

existence

and

effectiveness of internal control and risk management systems,

particularly for financial purposes, and approves the Group’s risk

map, including exposure to social and environmental risks and

the

associated

methodology

to

their

identification

and

assessment.

Within Orange Belgium, m

m

a

n

a

g

e

m

e

n

t

'

s

r

o

l

e

s

in governance

processes, controls and procedures used to monitor, manage

and oversee impacts, risks, and opportunities related to ESG are

reflected

through

several

mechanisms.

O

v

e

r

s

i

g

h

t

o

v

e

r

m

a

n

a

g

e

m

e

n

t

-level positions and committees responsible for

ESG governance is exercised through a structured framework

that ensures accountability and effective monitoring of impacts,

risks, and opportunities. Together, these bodies ensure a

comprehensive approach to governance, management, and

oversight of ESG priorities within the organisation and with

regards to the law of 2 December 2024 transposing the

Corporate

Sustainability

Reporting

Directive

(CSRD),

incorporated into the Belgian Code of Companies and

Associations.

•

Regarding r

r

i

s

k

s

, the internal control system, led by

management, ensures the achievement of operational,

reporting,

legal,

and

strategic

objectives

while

managing risks. Risks are identified, assessed, and

addressed through acceptance, mitigation, transfer, or

elimination strategies, with the risk culture promoted

across the organisation. Roles and responsibilities are

clarified and coordination with stakeholders and

auditors ensures effective oversight.

•

The duty of vigilance provides the overarching

framework ensuring that i

i

m

p

a

c

t

s

are controlled and

managed proactively.

•

O

p

o

r

t

u

n

i

t

i

e

s

are systematically analysed, particularly

in relation to risks and impacts identified within the

CSRD framework by the ESG team in coordination with

business owners.

84

Orange Belgium

_

Annual report 2025

85

Governance mechanisms are implemented to ensure continuous

oversight, enabling management to make informed decisions

and uphold accountability in managing sustainability and

operational risks.

Orange Communications Luxembourg's local ESG and ACR

teams are responsible for IROs operational monitoring and

management. It is then Orange Belgium’s Management that is

responsible for overseeing these IRO's.

In Belgium,

r

e

p

o

r

t

i

n

g

l

i

n

e

s

to administrative, management, and

supervisory bodies within the governance structure notably for

overseeing impacts, risks, and opportunities related to the CSRD

or ESG performance are clearly defined to ensure effective

communication and accountability. The ESG team reports to a

Steering Committee, which includes members of the Executive

Committee. Reporting is then done to the Audit Committee and

the Board of Directors.

Orange Belgium

a

p

l

i

e

s

d

e

d

i

c

a

t

e

d

c

o

n

t

r

o

l

s

a

n

d

p

r

o

c

e

d

u

r

e

s

for

the management of impacts, risks and opportunities and are

integrated with other internal functions:

•

Risk management

and vigilance plan related activities

are under the scrutiny of the Executive Committee

members. Key processes and controls are documented

with Risk and Control Matrices and in Entity Level

Controls questionnaires, reviewed annually to maintain

robustness and accountability. The Orange Belgium

Risk Manager, with the support of the ACR team,

interviews

Executive

Committee

members

and

discusses main corporate risks and incidents. The risk

map is approved at least once a year by the Executive

Committee and by the Audit Committee.

•

Regarding the vigilance plan, Orange Belgium ESG

team with support of internal experts and domain

owners map the impacts and communicate to Orange

Group and internal steerco and audit Committee at

least once a year.

•

Within Orange Belgium, an ESG team and a network of

ESG correspondents in various departments have been

set up to initiate the necessary transformations. They

are responsible for monitoring IRO's and associated

targets

and

action

plans.

This

enables

the

implementation of a governance system with E

E

S

G

s

i

n

g

l

e

p

o

i

n

t

s

o

f

c

o

n

t

a

c

t

c

o

r

d

i

n

a

t

e

d

b

y

A

C

R

a

n

d

E

S

G

d

e

p

a

r

t

m

e

n

t

s

for impacts.

•

Within Orange Communications Luxembourg, an ESG

Officer

was

appointed

in

2024

within

the

Communication Department, under the responsibility of

the Head of Communication, who is part of the

Directors’ Committee. The ESG Officer coordinates the

implementation of the sustainability strategy within

Orange

Communications

Luxembourg

with

the

different relevant departments with the required skills.

In 2025, the exercise related to IROs identification and

double materiality update have been coordinated

between both ESG and ACR teams.

O

r

a

n

g

e

G

r

o

u

p

'

s

E

S

G

o

b

j

e

c

t

i

v

e

s

are set out in a letter of

commitment

signed

by

the

Group

Corporate

Social

Responsibility Executive Director and the divisional Executive

Director. At local level, targets at Orange Belgium are monitored

by the ESG teams in conjunction with their ESG correspondents

in the various departments, under the supervision of the ESG

Officer

of

Orange

Belgium,

Orange

Communications

Luxembourg and the Executive Committee. Some specific

ambitions are directly managed and monitored by responsible

teams such as health and safety and data privacy &

cybersecurity.

Orange Belgium and Orange Communications Luxembourg

participate in the quarterly performance review organised by

Orange Group ESG Europe Team. Best practices are shared

among

different

geographies,

the

reported

metrics

are

challenged, and areas of improvements are suggested and

implemented where feasible according to local reality.

1.1.2.1.3

Focus on business conduct

The governance structure related to the ESG and Corporate

Sustainability Reporting Directive described above also includes

topics

b

u

s

i

n

e

s

c

o

n

d

u

c

t

s

.

Administrative,

management and supervisory bodies have e

e

x

p

e

r

t

i

s

e

i

n

b

u

s

i

n

e

s

c

o

n

d

u

c

t

and continuously receive further information and

training.

In Belgium, business conduct matters are overseen by the

General Secretary, who is also Chief Compliance Officer and is

responsible for ethics, compliance, and business conduct. He

brings extensive legal expertise, with significant experience in

regulatory

and

compliance

functions

within

the

telecommunications sector, both in Belgium and in international

contexts. At Orange Communications Luxembourg, such

presentations have been done to the Compliance Officer

specifically. The Group also regularly communicates on

sustainability topics to subsidiaries in all regions where it is

active. Also, a yearly mandatory training on compliance and

business conduct must be followed by all Orange management

and team members in Belgium and Luxembourg.

At Orange Communications Luxembourg, the Compliance officer

controls all contracts with third parties, which are then validated

by the CEO. This person is also in charge of performing the due

diligence. No other specific body is in place for follow-up matters

related to business conduct. The Chief Financial Officer oversees

business

conduct.

He

joined

Orange

Communications

Luxembourg in 2011, dedicating his efforts to management

control and finance development. He became part of the

management team in 2023, leveraging over a decade of financial

expertise to support the company’s operations and governance.

1.1.2.1.4

Skills and expertise to oversee sustainability matters

The Orange Group's sustainability commitment is a cornerstone

of its integrated business model, with the ambitious goal of

achieving Net Zero Carbon operations by 2040. This objective

requires active contributions from Orange Belgium, supported by

both internal and external expertise.

85

Orange Belgium

_

Annual report 2025

86

At the Group level, the Environmental and Energy Transition

department, established in 2023, consolidates the Group’s c

c

o

r

e

c

o

m

p

e

t

e

n

c

i

e

s

i

n

e

n

v

i

r

o

n

m

e

n

t

a

n

d

e

n

e

r

g

y

m

a

n

a

g

e

m

e

n

t

,

including strategic planning, policy development, reporting, and

performance analysis. This department collaborates with Orange

Belgium and Orange Communications Luxembourg ESG

correspondents, ensuring regular interaction and the consistent

application of ESG initiatives.

K

n

o

w

l

e

d

g

e

s

h

a

r

i

n

g

is further facilitated through e-learnings,

conferences, and quarterly ESG meetings.

More broadly, s

s

k

i

l

s

a

n

d

e

x

p

e

r

t

i

s

e

r

e

l

a

t

e

d

t

o

s

u

s

t

a

i

n

a

b

i

l

i

t

y

are

primarily identified based on the needs expressed by team

members and the strategic requirements of the organisation. To

ensure ongoing development and alignment with business

objectives, a comprehensive training catalogue created by

Orange Group is available in the corporate Learning Management

System “Orange Learning”. This catalogue is organised

according to job categories and will specify the necessary skills,

notably on sustainability competencies. This approach enables

management and supervisory bodies to ensure that employees

are equipped to oversee sustainability matters effectively.

In Orange Belgium, an E

E

S

G

t

e

a

m

with experts well skilled on

environmental, social and governance matters takes the lead and

works alongside a network of ESG correspondents in various

departments

to

drive

necessary

adaptations

and

transformations. Reporting to the ESG and Brand Director, this

team is responsible for defining, deploying, communicating, and

refining the sustainability strategy at local level, as well as leading

sustainability-related projects.

The S

S

e

c

u

r

i

t

y

t

e

a

m

does not only manage cybersecurity but also

plays a critical role in addressing other sustainability IROs,

particularly related to potential climate change impact on

infrastructure. Orange Belgium further benefits from a dedicated

D

a

t

a

P

r

i

v

a

c

y

O

f

i

c

e

r

, ensuring robust data governance in

alignment with sustainability objectives.

In Orange Communications Luxembourg, an E

E

S

G

O

f

i

c

e

r

was

appointed in 2024 within the Communication Department, under

the responsibility of the Head of Communication, who is part of

the Directors’ Committee. The ESG Officer coordinates the

implementation of the sustainability strategy within Orange

Communications

Luxembourg with the different relevant

departments with the required skills.

Both entities also have other roles supporting ESG initiatives

through their respective functions. These include h

h

e

a

l

t

h

a

n

d

s

a

f

e

t

y

l

e

a

d

s

, e

e

x

p

e

r

t

o

n

d

i

g

i

t

a

l

i

n

c

l

u

s

i

o

n

and responsible for

technological awareness through the Orange Digital Center,

training and development leads, and compliance officers.

The ESG team encompasses expertise in digital inclusion and

user health, which are critical to addressing material impacts

related to social inclusion and wellbeing of clients and end-users.

The H

H

u

m

a

n

R

e

s

o

u

r

c

e

s

d

e

p

a

r

t

m

e

n

t

contributes specialised

knowledge in diversity, training, and skills development,

supporting workforce resilience and talent development.

Additionally, the G

G

e

n

e

r

a

l

S

e

c

r

e

t

a

r

y

a

n

d

P

u

r

c

h

a

s

i

n

g

t

e

a

m

s

bring

expertise in business ethics, human rights in the value chain, and

suppliers’ ESG scorecards, helping to mitigate risks and ensuring

responsible supply chain management.

Together, these teams collaborate to identify and manage

material impacts, risks, and opportunities, reinforcing the

Group’s commitment to sustainability and responsible business

practices.

1.1.2.2

Information provided to and sustainability matters addressed by the

undertaking’s administrative, management and supervisory bodies (GOV-2)

The governance structure of Orange Belgium for overseeing

ESG-related impacts, risks and opportunities (IRO), including

compliance with the Corporate Sustainability Reporting Directive

(CSRD) and European Sustainability Reporting Standards

(ESRS), implementation of due diligence, and results and

effectiveness of policies, actions, metrics and targets adopted to

address them, is supported by several key bodies. These include

the CSRD and ESG Steering Committees, the Executive

Committee, the Audit Committee, and the Board of Directors (see

above section

1.1.2.1.2 Roles and responsibilities of the

administrative, management and supervisory bodies

for more

details about the meeting frequency).

At Orange Communications Luxembourg, ESG issues are

discussed at meetings of the Directors Committee, although

there is no set frequency. They are discussed based on

upcoming issues, internal initiatives and the creation of

partnerships.

Additionally, quarterly ESG performance reviews are conducted

with the ESG Europe Group team and the ESG Belgium and

Orange Communications Luxembourg teams to monitor actions,

metrics, and targets aligned with the Group ESG strategic plan

and evaluate their effectiveness.

These administrative, management and supervisory bodies

consider and oversee strategy, decisions on major transactions

and risk management process on a regular basis in the different

committees described above. Decisions are taken in these

committees and recorded with minutes and reports to adopt

necessary actions.

While the overall strategy is defined at Orange Group level,

Orange Communications Luxembourg contributes to and

oversees its implementation locally. In this context, impacts, risks

and opportunities are considered as part of strategic and

decision-making discussions within the relevant governance

bodies. The level of formalisation of these considerations may

vary depending on the nature of the decisions.

All identified material impacts, risks and opportunities have been

presented and approved by management and supervisory

bodies and relevant committees. Operational committees are set

up for the continuous supervision of material IROs with the aim

to report and ensure supervision by management bodies.

86

Orange Belgium

_

Annual report 2025

87

1.1.2.3

Integration of sustainability-related performance in incentive schemes (GOV-3)

The members of the management of O

O

r

a

n

g

e

B

e

l

g

i

u

m

a

n

d

O

r

a

n

g

e

C

o

m

u

n

i

c

a

t

i

o

n

s

L

u

x

e

m

b

o

u

r

g

b

e

n

e

f

i

t

f

r

o

m

s

u

s

t

a

i

n

a

b

i

l

i

t

y

-

r

e

l

a

t

e

d

i

n

c

e

n

t

i

v

e

s

c

h

e

m

e

s

in the remuneration

policies.

However,

there

are

no

sustainability-related

performance metrics included in the incentive and variable

remuneration systems for neither WBCC nor Be tv.

The long-term variable remuneration scheme of Orange Belgium

operates through r

r

e

c

u

r

i

n

g

L

o

n

g

-

T

e

r

m

I

n

c

e

n

t

i

v

e

P

l

a

n

s

(

L

T

I

P

)

,

spanning three-year performance periods (e.g. 2023-2025, 2026-

2028…). The LTIP is a “rolling plan” over three-year performance

periods with awards considered and decided annually by the

N

o

m

i

n

a

t

i

o

n

a

n

d

R

e

m

u

n

e

r

a

t

i

o

n

C

o

m

i

t

e

.

In Belgium, incentive schemes are approved and updated in the

Remuneration Committee of the Orange Belgium entity. It can

represent up to 30% of the yearly fixed remuneration of the Board

of directors, the CEO and the other management members who

are head of department. Further information on the methodology

behind the calculation of this incentive can be found in the

management report under the remuneration report section.

In

Luxembourg,

the

incentive

scheme

at

Orange

Communications Luxembourg, the LTIP 2023-2025 concerns

only the CEO.

The Nomination and Remuneration Committee decided on t

t

h

r

e

c

o

m

p

a

n

y

K

P

I

’

s

a

n

d

t

a

r

g

e

t

s

t

o

a

p

l

y

to each annual LTIP award

for the three-years performance period at the beginning of the

financial year. Company targets are weighted independently

(50%/50%/50%), with a maximum possible achievement for

each LTIP award of 150% for the 2023-2025 plan

3

. Subject to the

achievement of at least one company target in any three-year

performance period, individual contribution by the executive

member can add an additional 25% to the final result subject to

an overall maximum LTIP potential of 175% of the target award.

LTIP awards will be subject to company performance measured

over each three-year period with plan payments paid in cash, in

warrants or in the form of non-company share options or benefits

available in the Flex Income Plan (possibly pension benefits). In

the case of payment in the form of options, these options are

frozen for one year.

In 2023, an ESG target was introduced that is composed of two

elements weighing 50% each. Indeed, the LTIP in which

members of Executive Committee in Orange Belgium participate,

includes an ESG objective linked to the p

p

e

r

c

e

n

t

a

g

e

o

f

w

o

m

e

n

i

n

m

a

n

a

g

e

m

e

n

t

p

o

s

i

t

i

o

n

s

and the u

u

n

d

e

r

t

a

k

i

n

g

’

s

e

n

e

r

g

y

e

f

i

c

i

e

n

c

y

,

defined as the total electricity consumption of the Radio Access

Network (in GWh) in relation to the total data consumption (in

GB). The aim is to reach 35% of women in management by the

end of 2025 and -20% year on year of the energy intensity of the

network by the end of 2025. In 2025, neither target has been

reached. Therefore, no payments are due in 2025 for either

Orange Belgium, nor Orange Communications Luxembourg.

4

As of the LTIP 2024-2026, the ESG target continues to be

composed of two elements weighing 50%, yet the energy

efficiency objective has been replaced by a GHG reduction

scope 1 and 2 objective. As of the LTIP 2025-2027, the combined

weight of the two elements of the ESG target is reduced to 33%,

as the weight of the other two KPIs of the LTIP, aiming to reduce

the payout potential from 150 to 100%.

3

As of the LTI 2025-2027, the weight of the company targets are reviewed to 33%33%33%, with a maximum possible achievement of 100% and without the

possibility to add an additional individual 25% to the pay-out. These changes are documented in the remuneration report section.

4

Note that an error has been identified in the 2024 report (stating that the percentage of variable remuneration depending on the sustainability related target

reached 3.82%). No variable remuneration linked to ESG KPIs were due in 2024. The first payment linked to ESG KPIs will be paid in 2026.

87

Orange Belgium

_

Annual report 2025

88

1.1.2.4

Statement on due diligence (GOV-4)

Orange has ensured that it exercises reasonable diligence by

identifying the p

p

o

t

e

n

t

i

a

l

o

r

a

c

t

u

a

l

i

m

p

a

c

t

s

of its activities within

its value chain, considering their severity (scope, scale and

degree of irremediability), as well as the means available to

Orange to act within its value chain. The nature of the material

negative impacts is based on the double materiality exercise

analysis according to the criteria defined by EFRAG and the

OECD Due Diligence Guidance for Responsible Business

Conduct. The assessment of these impacts is an integral part of

Orange’s duty of vigilance, in accordance with the French duty

of vigilance law, which mandates proactive identification and

mitigation of impacts to ensure responsible corporate conduct.

Core Elements of Due Diligence

Paragraphs

a) Embedding due diligence in

governance, strategy and business

model

1.1.2.2 Information provided to and sustainability matters addressed by the undertaking’s

administrative, management and supervisory bodies (GOV-2)

1.1.2.3 Integration of sustainability-related performance in incentive schemes (GOV-3)

1.1.3.3 Material impacts, risks and opportunities (IROs) and their interaction with strategy and

business model (SBM-3)

2.1.1.1 Transition plan for climate change mitigation (E1-1)

3.1.1 Orange Group human rights

b) Engaging with affected

stakeholders in all key steps of the

due diligence

1.1.3.2 Interests and views of stakeholders (SBM-2)

1.1.3.3 Material impacts, risks and opportunities (IROs) and their interaction with strategy and

business model (SBM-3)

1.1.4.1 Description of the process to identify and assess material impacts, risks and opportunities

(IRO-1)

3.2.1.1 Processes for engaging with own workers and workers’ representatives about impacts (S1-

2)

3.3.1.1 Processes for engaging with consumers and end-users about impacts (S4-2)

4.1.2.2 Management of relationships with suppliers, building trust and secure responsible supply

(G1-2)

c) Identifying and assessing adverse

impacts

1.1.3.3 Material impacts, risks and opportunities (IROs) and their interaction with strategy and

business model (SBM-3)

1.1.4.1 Description of the process to identify and assess material impacts, risks and opportunities

(IRO-1)

3.2.1.2 Processes to remediate negative impacts and channels for own workers to raise concerns

(S1-3)

3.3.1.2 Processes to remediate negative impacts and channels for consumers and end-users to

raise concerns (S4-3)

d) Taking actions to address those

adverse impacts

2.1.1.1 Transition plan for climate change mitigation (E1-1)

2.1.2.6 Taking actions on climate change mitigation and energy (E1-3)

2.1.3.3 Taking actions on climate change adaptation (E1-3)

2.2.1.3 Taking actions on resource use and circular economy (E5-2)

2.2.2.4 Taking actions on resource outflows and waste (E5-2)

3.2.2.4 Taking actions on training and skills development (S1-4)

3.2.3.4 Taking actions on diversity (S1-4)

3.2.4.4 Taking actions on health and safety (S1-4)

3.3.2.3 Taking actions on digital inclusion (S4-4)

3.3.3.3 Taking actions on psychological health of end-users (S4-4)

3.3.4.3 Taking actions on data privacy and cybersecurity (S4-4)

88

Orange Belgium

_

Annual report 2025

89

T

a

b

l

e

2

:

R

e

f

e

r

e

n

c

e

s

t

o

c

o

r

e

l

e

m

e

n

t

s

o

f

d

u

e

d

i

l

i

g

e

n

c

e

i

n

t

h

i

s

r

e

p

o

r

t

1.1.2.5

Risk management and internal controls over sustainability reporting (GOV-5)

Risk management and internal control systems relating to

sustainability information published in this statement are an

integral part of Orange Group's overall control framework. It aims

to provide reasonable assurance of achieving strategic, financial

and operational objectives, complying with applicable laws and

regulations, and ensuring the reliability of information provided to

the market.

The Group Audit Committee is entrusted with monitoring the

process

of

preparation

of

extra-financial

information

(sustainability reporting). This consideration also applies to the

local statutory “Audit Committee” within Orange Belgium.

The information management framework is based on the internal

control systems deployed in the areas audited to meet the

reliability and transparency requirements of market information.

It is supplemented by the internal control elements needed to

reinforce and demonstrate the quality of information specific to

sustainability reporting. The framework will be further enriched

by information systems (IS) and organisational transformation

projects.

Orange Group applies the internationally recognised Committee

of Sponsoring Organisations of the Treadway Commission

(COSO framework), structured into:

•

Control environment with governance committees,

global policies and procedures;

•

Operational control in flows and processes.

The sustainability reporting approach is complemented by the

COSO Internal Control over Sustainability Reporting (ICSR)

framework and the ‘Institut Français de l'audit interne et du

contrôle interne’ (IFACI)-PWC methodological guide published in

November 2023.

Risk assessment a

a

p

r

o

a

c

h

f

o

r

t

h

e

C

S

R

D

sustainability reporting

process covers two main risks categories.

The first main risk relates to the definition of the scope of

sustainability reporting covering the process of defining the

relevant

information

to

be

published

(double

materiality/identification of IROs, definition of the qualitative &

quantitative data to be published) and the scope of the entities

concerned. This risk could lead Orange to fail in complying with

the expectations of the standards and stakeholders. Orange has

therefore focused on:

•

Analysing and documenting the scope of reporting

entities.

•

Defining the framework for controlling the double

materiality exercise, covering aspects of governance,

process and documentation of the work leading to the

identification of material IROs. Consideration has been

given to ensuring that this exercise is properly

coordinated

with

the

company's

overall

risk

management process and in alignment with Orange

Group.

•

Documenting the method used to define the repository

to produce 2025 information, and the reasons for any

absence or postponement of publication.

The second most important risk is related to Orange's ability to

produce information with the expected quality and auditability

Core Elements of Due Diligence

Paragraphs

e) Tracking the effectiveness of

these efforts and communicating

1.1.4.1 Description of the process to identify and assess material impacts, risks and opportunities

(IRO-1)

2.1.2.2 Targets related to climate change mitigation and energy (E1-4)

2.1.2.3 Energy consumption and mix (E1-5)

2.1.2.4 Gross 1, 2, 3 and total GHG emissions (E1-6)

2.1.2.5 GHG removals and GHG mitigation projects financed through carbon credits (E1-7)

2.2.1.2 Targets related to resource use and circular economy (E5-3)

2.2.2.2 Targets related to resource outflows and waste (E5-3)

2.2.2.3 Metrics related to resource outflows and waste (E5-5)

3.1.5 Human rights incidents

3.2.2.2 Targets related to training and skills development (S1-5)

3.2.2.3 Training and skills development metrics (S1-13)

3.2.3.2 Targets related to diversity (S1-5)

3.2.3.3 Diversity metrics

3.2.4.2 Targets related to health and safety (S1-5)

3.2.4.3 Health and safety Metrics (S1-14)

3.3.2.2 Target related do digital inclusion (S4-5)

3.3.3.2 Targets related to psychological health of end-users (S4-5)

3.3.4.2 Targets related to data privacy and cybersecurity (S4-5)

89

Orange Belgium

_

Annual report 2025

90

objectives. With a view to convergence with the financial

information control framework, the following assertions have

been

retained:

completeness,

quality,

transparency,

management validation. This risk could lead to inconsistencies

and failure in complying with the expectations of the standards.

Orange has therefore focused on:

•

Enhancing data quality and strengthening internal

control on sustainability reporting process by:

o

Defining the production/validation procedures for

sustainability reporting.

o

Framing and disseminating, where necessary,

expectations

concerning

estimates

using

methodological document.

o

Aligning and standardising the repository for

collecting

and

producing

quantitative

data

(including definitions, calculation methods).

•

Structuring the expected evidence to support the

Minimal Disclosure Requirement (MDR) related to

policies and action plans, targets and associated

metrics.

•

Strengthening supervision of data collected and

produced at Orange Belgium level.

•

Increasing Orange Belgium ownerships:

o

Enhancing data owners’ ownership (e.g. human

resources, ethics & anti-corruption, security,

personal data management, health and safety,

marketing, etc.).

o

On top of existing environmental data collections

of Greenhouse gases (GHG) emissions of scope 1

and 2, adding and setting up in 2025 a sound and

recurring local data collection around the scope 3

emissions with physical flows related data.

o

Engaging and empowering management by

involving them in sustainability report content

validation.

The focus for its second year, was to enhance the reliability and

compliance of the sustainability statement, with a focus on

strengthening internal controls following auditor’s remarks,

specifically for 2025 on 3 aspects:

•

Enhance environmental data quality and reliability;

•

Raise ownership regarding scope 3 GHG emissions at

Orange Belgium level;

•

Enhance internal control on sustainability reporting

process.

As the non-financial reporting is consolidated by Orange

Belgium, these functions are mainly born by this entity rather than

within Orange Communications Luxembourg.

Integrated Governance and Control Framework

for 2025

To ensure the integrity, reliability, and transparency of this

sustainability statement, a comprehensive governance and

control

framework

has

been

implemented

for

2025,

encompassing clear responsibilities and robust monitoring

processes.

90

Orange Belgium

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Annual report 2025

91

•

D

a

t

a

o

w

n

e

r

s

(

l

e

v

e

l

1

)

:

Responsible for accurate data

collection and validation at the source, ensuring initial

data integrity.

•

E

S

G

t

e

a

m

(

l

e

v

e

l

2

)

:

Handles data consolidation,

verification, and control. For the environment, this is

supported by a new collection process and a dedicated

dashboard for scope 1,2 and 3 emissions. A new team

member has been recruited to focus on data quality

and environmental reporting.

•

M

a

n

a

g

e

m

e

n

t

r

e

v

i

e

w

(

l

e

v

e

l

3

)

:

Conducts reviews to

ensure data consistency, reliability, and compliance,

with a focus on addressing auditor remarks and internal

control improvements.

Control and monitoring processes reinforce the reliability of the

information gathered:

•

I

n

t

e

r

n

a

l

c

o

n

t

r

o

l

f

r

a

m

e

w

o

r

k

:

An integrated control

process within the ESG team, including quarterly

reviews

via

a

comprehensive

dashboard,

to

continuously monitor scope 1 and 2 emissions data

accuracy and completeness.

•

A

u

d

i

t

o

r

e

m

a

r

k

s

f

o

l

o

w

-

u

p

:

Systematic tracking and

incorporation of auditor recommendations into the

control framework, ensuring timely and effective

corrective actions.

•

S

c

o

p

e

3

d

a

t

a

o

v

e

r

s

i

g

h

t

:

Enhanced management of

scope 3 emissions data, focusing on physical and

monetary information, identifying key financial sources,

evaluating emission factors, and prioritising high-

impact accounts for detailed control.

This approach ensures rigorous environmental data governance,

continuous monitoring, and proactive management of audit

feedback, strengthening the overall reliability of the sustainability

reporting process.

Periodic reporting of findings of risk assessment and internal

controls to administrative, management and supervisory bodies

are done as explained with more detailed supra in section

1.1.2.1.2 Roles and responsibilities of the administrative,

management and supervisory bodies

. Steering committee

(consulted on quarterly basis) and Audit Committee (at least once

a year) play a crucial role in the oversight of risk assessment and

internal controls related to the production of the sustainability

report.

The structure of the 2025 sustainability statement has been

updated compared to 2024 to improve readability and ensure a

more coherent presentation of each material sub-topic.

Additionally, the former chapter on human rights in its value chain

has been replaced with a broader explanation of how Orange

Group’s human rights policy is applied across all relevant

stakeholder groups, including value chain workers, as an

introduction to Chapter

3 Social information

(see infra in section

3.1 Human rights

)

.

1.1.3

Strategy

1.1.3.1

Strategy, business model and value chain (SBM-1)

Description of major products and services

Orange offers the following products and services:

B

r

o

a

d

b

a

n

d

:

For over 10 years, Orange has made the strategic

choice to invest in Gigabit infrastructure. Following the

acquisition of VOO, the company has accelerated the activation

of Gigabit on almost all VOO networks. Thanks also to a deal with

Wyre, more than 95% of the Belgian population can have access

to Gigabit. The creation of Orange NetCo, the signature of a MoU

with Proximus to cover less densely populated areas and the

previous activation of the Wyre network (incl. fibre) in the north

are aimed at accelerating deployment in the coming years.

Starting from the end of 2025, Orange Belgium will also be able

to connect 100% of the population thanks to the Orange Satellite

offer distributed by the company’s partner Nordnet (part of

Orange Group). In addition, the company is finalising the

modernisation of the VOO unidirectional network in underserved

areas (“white zones”), upgrading it to Gigabit speeds with the

support of public subsidies. Thanks to its own fixed and mobile

networks, Orange Belgium offers both residential and business

customers fixed and mobile broadband services.

M

o

b

i

l

e

:

In the mobile segment, 5G coverage will reach 98% of

the population by 2026 (based on outdoor 5G coverage using

both low-band (coverage) and mid-band (capacity/speed)

frequencies NR21/NR35), with enhanced mobile network

performance. Orange Belgium’s 5G equipped customer base has

now reached more than 1 million clients (B2C + B2B), meaning

that 1 in 3 Orange customers owns a 5G-compatible device. This

includes devices such as smartphones, tablets, connected

objects, etc. that are compatible with and can support 5G

frequencies.

T

e

l

e

v

i

s

i

o

n

:

Thanks to international partnerships (e.g. Netflix),

Orange offers a television service with a wide range of content.

A

d

i

t

i

o

n

a

l

p

r

o

d

u

c

t

s

a

n

d

s

e

r

v

i

c

e

s

:

Orange offers a wide set of

value-added services covering various areas like for example

cyber security solutions, home connectivity solutions, roaming

options,

smartphone

insurance

and

commercialised

smartphones.

W

h

o

l

e

s

a

l

e

:

Orange Belgium is also a wholesale operator, offering

its partners access to its infrastructure as well as a broad

portfolio of connectivity and mobility services, including offerings

based on big data and the Internet of Things (IoT).

Orange Communications Luxembourg offers the same range of

products and services as Orange Belgium.

The main customer segments of Orange are the following:

•

C

o

n

s

u

m

e

r

p

r

e

m

i

u

m

s

e

g

m

e

n

t

:

Benefiting from a full

range premium servicing through physical and digital

customer

touchpoints,

focusing

on

multi-gigabit

convergent connectivity and value-added services

propositions, such as rich TV content, Cybersecurity

solutions etc.

•

C

o

n

s

u

m

e

r

a

c

e

s

e

g

m

e

n

t

: Efficient digital servicing

with appealing and evolutive multiproduct value

propositions.

91

Orange Belgium

_

Annual report 2025

92

•

B

u

s

i

n

e

s

e

g

m

e

n

t

:

Tailor-made

B2B

value

propositions through Orange Belgium’s best of breed

strategy, putting cyber security and Information and

Communication Technology (ICT) expertise at the heart

and enriched with multi-gigabit network speeds and 5G

enabled servicing, serving all business segments in all

regions.

In 2025, Orange Belgium and Orange Communications

Luxembourg counted 2,912 employees for the entities in the

scope of this sustainability statement (for further information,

please see section

3.2.5. Additional metrics related to own

workforce

).

In line with its financial statement, the company reports with

regards to fiscal year 2025, a consolidated total net revenue of

+€1,963.3M

Elements of the general strategy relating to

sustainability

and

objectives

regarding

stakeholders’ relations

In alignment with its purpose - “as a trusted partner, Orange

gives everyone the keys to a responsible digital world” - and its

strategic plan, Orange Belgium has i

i

n

t

e

g

r

a

t

e

d

s

u

s

t

a

i

n

a

b

i

l

i

t

y

i

n

t

o

i

t

s

b

u

s

i

n

e

s

t

r

a

t

e

g

y

.

The third pillar of its “Lead the Future”

strategy emphasises building a sustainable business model that

prioritises the wellbeing of employees, the company, and

stakeholders.

With this goal in mind, Orange Belgium commits to a

a

c

t

a

s

a

t

r

u

s

t

e

d

p

a

r

t

n

e

r

b

y

e

s

t

a

b

l

i

s

h

i

n

g

c

l

e

a

r

c

o

m

i

t

m

e

n

t

s

o

n

s

u

s

t

a

i

n

a

b

i

l

i

t

y

a

n

d

a

d

o

p

t

i

n

g

a

n

’

E

S

G

b

y

d

e

s

i

g

n

’

m

o

d

e

l

, while

pursuing major ambitions. This involves making internal

transformational changes while helping its customers and

partners to make changes as well. The company considers

environmental, social and governance (ESG) key strategic

commitments, i.e.:

•

E

n

v

i

r

o

n

m

e

n

t

: Contribute to the Group net zero carbon

ambition by 2040;

•

S

o

c

i

a

l

: Digital inclusion and empowerment for all,

valuing diversity, inclusion developing tech talent for

employees;

•

G

o

v

e

r

n

a

n

c

e

: An example of integrity and responsibility.

Regarding governance, the company strives to improve

responsibility and transparency inside and outside the

organisation.

Integrating

ESG

principles

in

the

processes and tools of all organisations is also a

priority.

Sustainability is embedded in the other two pillars of the “Lead

the Future” strategy, including efforts to integrate sustainability,

environmental and inclusion considerations into infrastructure

deployment and customer offerings. Orange Communications

Luxembourg also follows the ‘Lead the future’ strategy and

therefore has the same objectives and priorities.

In response to the expectations of stakeholders, the major

impacts, risks and opportunities identified for Orange and in line

with its purpose (i.e. "to be the trusted player that gives everyone

the keys to a responsible digital world") and its strategic plan,

Orange has defined its areas of commitment contributing to

greater sustainability.

Orange's main environmental objectives

Orange's main environmental objectives are to contribute to the

fight against global warming, by reducing the environmental

footprint of its products and services and by enabling emissions

reductions for customers. The ambition is to contribute to the

Orange Group’s target to reach Net Zero Carbon operations by

2040.

In this perspective, Orange has set intermediate objectives:

•

To reduce its carbon footprint on scopes 1 and 2, by

reducing its energy consumption and deploying

renewable energies (e.g. Green ITN programme in

infrastructures:

network

&

IT,

software

and

architectures);

•

To reduce its scope 3 carbon footprint by leveraging

circular economy practices, reducing the carbon

footprint of its purchases and suppliers and rolling out

a scope 3 action plan by country (e.g. "Partners to net

zero carbon" programme);

•

To extend the use of circular economy principles to its

customers. To achieve this, Orange is developing the

collection and sale of reconditioned handsets, as well

as the eco-design of Orange-branded products.

Orange's main social objectives

Orange's ambition is to make digital technology accessible to all

and to promote inclusion through digital technology in its

connectivity and service offerings for the public, with the

following objectives:

•

To promote the use of Internet services through free

workshops and digital trainings, notably through the

Orange Digital Centers deployed in all the countries

where Orange is the operator, dedicated places to

promote inclusion through digital technology, and by

offering its support to digital entrepreneurship.

•

To facilitate access to essential networks and services

for information, communication and work, thanks to

affordable mobile handsets, combined with appropriate

payment methods in all the Group's regions, or social

services in Europe.

Sustainability objectives regarding stakeholder

relations

For its employees and customers alike, Orange is committed to

using digital technology to promote development and equal

opportunities and seeks to be an increasingly inclusive player. To

be an ever more inclusive employer and to strengthen human

rights within the company and its value chain, Orange aims to

create long-term value for its employees and stakeholders by

conducting its business in line with responsible human resources

management practices. These practices focus on maintaining

employee employability, developing skills, promoting diversity,

and improving the representation of women in management

positions. Orange promotes respect for human rights and

fundamental freedoms and responsible use of data by

businesses and has defined an ethical artificial intelligence (AI)

charter to provide a framework for its own activities.

Detailed actions and levers to achieve these ambitions are

outlined in the company’s sustainability action plans.

92

Orange Belgium

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Annual report 2025

93

Orange Group has recently adopted a new strategic plan for 2030

with the aim of creating a positive impact and sustainable value

for its stakeholders:

•

for its customers, with reliable connectivity and digital

services;

•

for society, by enabling everyone to take action through

digital technology and making digital technology a lever

for inclusion and equal opportunities;

•

and for the planet, by reducing Orange's environmental

impact and aiming for net zero carbon by 2040 at group

level.

The success of this transition depends on building this value

creation model with its employees, suppliers, investors and other

stakeholders.

Orange sustainability-focused products, services and

initiatives

Orange sustainability-focused products and services include,

notably, a large range of r

r

e

f

u

r

b

i

s

h

e

d

m

o

b

i

l

e

a

n

d

f

i

x

e

d

e

v

i

c

e

s

d

e

s

i

g

n

e

d

to minimise environmental impacts throughout their

lifecycle through eco-design and waste management.

Regarding d

d

i

g

i

t

a

l

s

k

i

l

s

&

i

n

c

l

u

s

i

o

n

p

r

o

g

r

a

m

e

s

, Orange

operates the Digital Center in Belgium, providing training and

annual programmes to supports local digital inclusion projects

annually, complemented by the Orange Foundation Group’s local

initiatives. In 2025, "Care Corners" deployed in Brussels shops,

offering free digital support such as data transfer, device

configuration, and tips. Additionally, donations from the Orange

Thank You loyalty programme support NGO partners like “Ligue

des Familles / Gezinsbond”, facilitating digital inclusion

workshops.

In the realm of i

i

n

o

v

a

t

i

o

n

a

n

d

i

n

c

l

u

s

i

o

n

, Orange Fab in Belgium

promotes gender inclusion through the Elle Active Forum,

supporting women startup founders via mentorship and

expertise, with opportunities to secure contracts with Orange.

Orange also develops accessible offers, such as the

“

C

o

u

p

d

e

P

o

u

c

e

”

s

o

c

i

a

l

o

f

e

r

i

n

L

u

x

e

m

b

o

u

r

g

, to address affordability

needs.

Development of the #

#

F

o

r

G

o

d

C

o

n

e

c

t

i

o

n

s

p

r

o

g

r

a

m

e

in

Belgium also focuses on cyberbullying, online hate, and

hyperconnectivity notably with its

S

m

a

r

t

p

h

o

n

e

p

a

s

l

a

u

n

c

h

.

There is also Orange M

M

o

b

i

l

e

S

e

r

e

n

i

t

y

enabling users to block

adult content, gambling, or specific online usages, screen time

management, and secure online browsing designed to reduce

exposure to potential cyberattacks.

In addition, initiatives such as e

e

x

p

a

n

d

i

n

g

n

e

t

w

o

r

k

c

o

v

e

r

a

g

e

,

rolling out very high-speed (1 Gbps) fixed network in Walloon

w

h

i

t

e

z

o

n

e

s

aim to reach underserved communities and

populations.

Through these efforts, Orange promotes digital inclusion in

Belgium and Luxembourg and supports local economic

development through partnerships with associations and

startups.

93

Orange Belgium

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Annual report 2025

94

The company also offers c

c

y

b

e

r

s

e

c

u

r

i

t

y

o

f

e

r

i

n

g

s

with tailored

security

packages

by

customer

segment

(i.e.

families,

individuals, businesses). In addition, it provides Business-to-

Business

(B2B)

customer

protection

tools

through

the

development of security services adapted to clients’ cyber

maturity and sector, including managed services, security

packages, managed firewalls, Security Operations Center (SOC)

services and IT Care for IT management.

To know more about these products and services explore action

plans in 2.2.1.3 Taking actions on resource use and circular

economy (E5-2), 2.2.2.4 Taking actions on resource outflows and

waste (E5-2), 3.3.2.3 Taking actions on digital inclusion (S4-4),

3.3.3.3 Taking actions on psychological health of end-users (S4-

4),

and

3.3.4.3 Taking actions on data privacy and cybersecurity

(S4-4).

Orange’s value chain

The business model and value chain are the same in Belgium and

Luxembourg. Orange Belgium and Orange Communications

Luxembourg are operating as leading telecommunications

providers, transforming inputs such as network infrastructure,

technology, and human resources into a range of digital services,

including mobile and fixed-line communications, to address

societal challenges. The company aims t

t

o

e

n

h

a

n

c

e

c

o

n

e

c

t

i

v

i

t

y

a

n

d

i

g

i

t

a

l

i

n

c

l

u

s

i

o

n

,

c

r

e

a

t

i

n

g

v

a

l

u

e

f

o

r

c

u

s

t

o

m

e

r

s

,

s

h

a

r

e

h

o

l

d

e

r

s

,

a

n

d

s

o

c

i

e

t

y

o

v

e

r

t

h

e

s

h

o

r

t

,

m

e

d

i

u

m

,

a

n

d

l

o

n

g

t

e

r

m

,

g

u

i

d

e

d

b

y

i

t

s

"

L

e

a

d

T

h

e

F

u

t

u

r

e

"

s

t

r

a

t

e

g

y

, which emphasises leadership

through core assets, operational excellence, and sustainability in

its enterprise model.

O

r

a

n

g

e

’

s

b

u

s

i

n

e

s

m

o

d

e

l

is characterised by the following

elements:

•

Orange

Belgium

and

Orange

Communications

Luxembourg have built out and expanded a mobile

network over the whole territory. These two entities

d

e

s

i

g

n

a

n

d

o

p

e

r

a

t

e

t

h

e

i

r

o

w

n

f

i

x

e

d

a

n

d

m

o

b

i

l

e

i

n

f

r

a

s

t

r

u

c

t

u

r

e

s

(such as antennas, cables and switches)

or use the networks of third-party operators under the

technical, economic and regulatory conditions in force,

in compliance with interoperability requirements. To do

so it has procured hardware components and software

solution to build out and expand its network. For the

mobile network Orange Belgium is implementing a

Shared Radio Access Network (RAN) together with

Proximus.

For

the

fixed

network,

through

the

94

Orange Belgium

_

Annual report 2025

95

acquisition of VOO in 2023, Orange Belgium has a

Hybrid Fibre Coaxial (HFC) network in the south of the

country. In the north of the country, Orange Belgium

has an agreement with Wyre for the usage of its HFC

network. IT platforms facilitate proactive m

m

a

n

a

g

e

m

e

n

t

o

f

n

e

t

w

o

r

k

s

, customer service, and data collection,

ensuring compliance with international interoperability

standards. Finally, for third-party operators, Orange

Belgium offers enabling interconnection at different

points on its network and meeting different service

specificities according to needs.

•

Orange

Belgium

and

Orange

Communications

Luxembourg

focus

on

p

r

o

d

u

c

t

d

e

v

e

l

o

p

m

e

n

t

,

constantly innovating to meet customer needs with

mobile, fixed-line, Internet, television, and cloud

services. Orange develops n

n

e

w

p

r

o

d

u

c

t

s

a

n

d

s

e

r

v

i

c

e

s

to meet the needs of its customers in line with

technological advances. Orange favours an open

innovation approach. Its experts and researchers work

with an ecosystem of partners, companies, start-ups,

public and private laboratories.

•

M

a

r

k

e

t

i

n

g

a

n

d

s

a

l

e

s

activities focus on promoting

services such as mobile plans, internet packages, and

innovative solutions like IoT and 5G, cybersecurity

solutions and guidance against digital risks to attract

and retain customers. Orange Belgium and Orange

Communications Luxembourg have their own physical

(shops, sales engineers, etc.) or digital (call centres,

website, applications) d

d

i

s

t

r

i

b

u

t

i

o

n

e

t

w

o

r

k

s

. The

delivery of telecom services to customer channels

includes

physical

stores,

online

platforms,

and

partnerships with resellers, catering to both individual

consumers and businesses.

Orange Belgium’s and Orange Communications Luxembourg's

m

a

i

n

f

e

a

t

u

r

e

s

o

f

u

p

s

t

r

e

a

m

v

a

l

u

e

c

h

a

i

n

include:

•

Orange

Belgium

and

Orange

Communications

Luxembourg participate in obtaining l

l

i

c

e

n

s

e

s

f

r

o

m

r

e

g

u

l

a

t

o

r

y

a

u

t

h

o

r

i

t

i

e

s

,

ensuring

compliance

with

obligations such as geographical coverage. They

operate their own infrastructure or use third-party

networks. In particular, the o

o

p

e

r

a

t

i

o

n

o

f

m

o

b

i

l

e

n

e

t

w

o

r

k

s

involves taking part in frequency allocation

procedures, which may be accompanied by specific

obligations, relating to network security and territorial

coverage.

•

The company i

i

n

v

e

s

t

s

i

n

p

h

y

s

i

c

a

l

i

n

f

r

a

s

t

r

u

c

t

u

r

e

,

including antennas, cables, and switches, to guarantee

extensive coverage and high-quality service, as well as

the purchase of the terminals required to provide the

service. Much of the equipment is sourced from very

large, global suppliers common to the various

operators, and local teams are employed to support

operations. The components used to make up this

equipment may contain rare natural resources and are

sourced from best-in-class suppliers, aiming to ensure

compliance

with

technical

and

environmental

standards.

Key actors

•

S

u

p

l

i

e

r

s

:

These include hardware manufacturers,

software developers, and service providers that

contribute essential components and technologies for

Orange

Belgium

and

Orange

Communications

Luxembourg's offerings.

•

N

e

t

w

o

r

k

p

r

o

v

i

d

e

r

s

:

Orange has established a mobile

radio access network–sharing joint venture with

Proximus that covers the whole of Belgium. In the

northern part of the country, Orange leases the Wyre

cable network. In the southern region, Orange operates

using its own HFC and fibre infrastructure.

D

o

w

n

s

t

r

e

a

m

,

Orange Belgium and Orange Communications

Luxembourg provide a wide range of connectivity services to

consumers, businesses and other telecoms operators, covering

fixed and mobile communications and data transmission.

•

U

s

a

g

e

a

n

d

a

f

t

e

r

-

s

a

l

e

s

e

r

v

i

c

e

s

:

The after-sales service

resolves technical issues and ensures continuity of

service and maximise the customer experience, relying

on both internal resources and external service

providers. These services are based partly on Orange

Belgium's own resources and partly on a network of

external service providers or subcontractors, both local

and global.

•

E

n

d

-

o

f

-

l

i

f

e

m

a

n

a

g

e

m

e

n

t

:

Customers'

equipment

(mobiles, SetTopBox, etc.) is reconditioned for a

second life or recycled through partnerships with

specialist companies. Collection is based on the

Orange

Belgium

and

Orange

Communications

Luxembourg network, as well as through partnerships,

in particular those concluded with associations

specialising in social economy.

Key actors

•

D

i

s

t

r

i

b

u

t

o

r

s

:

Retail partners and online platforms that

facilitate the sale of Orange Belgium and Orange

Communications Luxembourg's services.

•

C

u

s

t

o

m

e

r

s

:

End-users who benefit from the telecom

services provided, including individuals, businesses,

and organisations.

95

Orange Belgium

_

Annual report 2025

96

Orange’s value creation model

96

Orange Belgium

_

Annual report 2025

97

For Orange, c

c

r

e

a

t

i

n

g

s

u

s

t

a

i

n

a

b

l

e

v

a

l

u

e

means acting with the aim

of sharing this value with all its stakeholders. To this end, the

Group develops its activities as a fixed and mobile infrastructure

operator, and marketing connectivity services as well as

financial, IT and cybersecurity services. To enable the personal

and professional development of its employees, Orange

anticipates changes in professions, ensures the development of

skills and implements a policy of talent management, diversity

and equal opportunities. To offer its customers better

connectivity and put digital technology at the service of

businesses and local communities, Orange Belgium and Orange

Communications Luxembourg are modernising their networks

and supporting the development of their digital skills.

The Group’s global procurement network allows Orange Belgium

to access cutting-edge IT and network infrastructure, ensuring

sustainability

criteria

in

supplier

selection

to

minimise

environmental impact. In Belgium and Luxembourg in particular,

m

a

j

o

r

i

n

p

u

t

s

n

e

d

e

d

t

o

d

e

v

e

l

o

p

O

r

a

n

g

e

’

s

t

r

a

t

e

g

y

i

n

c

l

u

d

e

:

Industrial & technological

•

Orange

Belgium's

and

Orange

Communications

Luxembourg’s m

m

o

b

i

l

e

n

e

t

w

o

r

k

is constructed through

the installation of antennas on rooftops and pylons.

These antennas are equipped with hardware radio

equipment that enables the transmission and reception

of signals. To ensure the availability of suitable sites for

antennas, the two entities have entered into long-term

and

framework

agreements

with

landlords.

Additionally, there a long-term agreement has been

entered into with the equipment supplier to ensure a

reliable supply of necessary equipment. To optimise the

usage of resources, Orange Belgium has entered into a

Radio Access Network sharing agreement (called

Mwingz) with Proximus, a major telecommunications

company.

•

In addition to the mobile network, Orange Belgium and

Orange Communications Luxembourg also own a f

f

i

x

e

d

n

e

t

w

o

r

k

. In Belgium, this network has been established

through the acquisition of VOO, and through long-term

agreements

with

other

network

owners.

These

agreements cover both the current fixed network,

which utilises hybrid fibre-coaxial (HFC) technology, as

well as the future access and roll-out of fibre-to-the-

home (FTTH) technology.

Energy

•

Orange

Belgium

and

Orange

Communications

Luxembourg have entered into an agreement with the

main energy supplier to ensure a c

c

o

n

s

i

s

t

e

n

t

a

n

d

r

e

l

i

a

b

l

e

s

u

p

l

y

o

f

e

n

e

r

g

y

. Furthermore, they have established a

forward-looking pricing mechanism to ensure price

stability and mitigate the impact of fluctuations in

energy costs. To optimise energy consumption, Orange

Belgium has implemented various e

e

f

i

c

i

e

n

c

i

e

s

within

the network. One example is the RAN sharing

agreement with Proximus, which allows to share radio

access network infrastructure, reducing the overall

energy consumption.

Human

•

Orange

Belgium

and

Orange

Communications

Luxembourg recognise that skilled workforce and

technical expertise are the most valuable asset.

Partnerships

•

Orange

Belgium's

and

Orange

Communications

Luxembourg’s seal partnerships with technology

providers,

and

subcontractors

to

deploy

the

infrastructure and support operations. The company

develops innovative solutions by securing inputs

through strategic partnerships, wholesale agreements,

and procurement processes.

Orange’s p

p

r

o

d

u

c

t

s

a

n

d

s

e

r

v

i

c

e

s

p

r

o

v

i

d

e

t

h

e

f

o

l

o

w

i

n

g

b

e

n

e

f

i

t

s

t

o

i

t

s

t

a

k

e

h

o

l

d

e

r

s

:

Customers

•

I

m

p

r

o

v

e

d

c

o

n

e

c

t

i

v

i

t

y

:

Enhanced network coverage

and reliability, resulting in superior communication and

internet services. Orange Belgium has become the first

telecoms provider in Belgium and Luxembourg to offer

a nationwide gigabit network, allowing Belgian citizens

to enjoy very high broadband speeds up to 1 Gbps on

its powerful Hybrid Fibre Coaxial (HFC) network.

•

I

n

o

v

a

t

i

v

e

s

e

r

v

i

c

e

s

:

Launch of advanced technologies

such as 5G and IoT, providing customers with

enhanced user experiences and new functionalities.

Orange also proposes cybersecurity solutions to

support and guide their customers against digital risks.

•

C

u

s

t

o

m

e

r

s

u

p

o

r

t

:

Enhanced

customer

service

initiatives leading to higher satisfaction and loyalty

among users and General Data Protection Regulation

(GDPR) compliance.

Investors

•

R

e

l

i

a

b

l

e

r

e

t

u

r

n

s

:

Consistent financial performance and

a strong market position contribute to reliable returns

on investment.

•

G

r

o

w

t

h

p

o

t

e

n

t

i

a

l

:

Opportunities for expansion into new

markets and the introduction of innovative services that

can drive future revenue.

•

O

p

e

r

a

t

i

o

n

a

l

t

r

a

n

s

p

a

r

e

n

c

y

: Clear and transparent

financial reporting fosters trust and confidence among

investors.

Employees

•

C

o

m

p

e

n

s

a

t

i

o

n

p

a

c

k

a

g

e

s

:

Orange

Belgium

remuneration policy has been implemented to ensure

that the employees are fairly compensated for their

contributions. This policy considers factors such as job

responsibilities, experience, and market rates to

provide competitive compensation packages. By

valuing employees and providing them with fair

compensation, the company aims to foster a motivated

and dedicated workforce.

•

L

i

f

e

-

l

o

n

g

l

e

a

r

n

i

n

g

:

Orange Belgium and Orange

Communications

Luxembourg

are

committed

to

developing and retaining talent, particularly in technical

roles, and prioritise employee growth by offering

97

Orange Belgium

_

Annual report 2025

98

training opportunities, including initiatives to support

digital literacy and leadership development.

•

S

a

f

e

w

o

r

k

e

n

v

i

r

o

n

m

e

n

t

:

The two entities place a strong

emphasis on employee wellbeing and ensure health

and safety at work by integrating comprehensive

measures to maintain secure, supportive, and healthy

workplaces.

•

I

n

c

l

u

s

i

v

e

w

o

r

k

p

l

a

c

e

:

Additionally, Orange ensures

diversity within its workforce by implementing goals

such as increasing the representation of women in

managerial and technical positions.

Partners & suppliers

•

L

o

n

g

-

t

e

r

m

t

r

u

s

t

f

u

l

p

a

r

t

n

e

r

s

h

i

p

s

:

Engagement in fair

trade practices and the establishment of long-term

partnerships that benefit both parties.

Society & environment:

•

D

i

g

i

t

a

l

i

n

c

l

u

s

i

o

n

: Contributions to local communities

through corporate social responsibility initiatives, such

as digital literacy programmes and infrastructure

improvements.

•

E

n

v

i

r

o

n

m

e

n

t

a

l

r

e

s

p

o

n

s

i

b

i

l

i

t

y

: Orange Belgium and

Orange

Communications

Luxembourg

emphasize

environmental sustainability through among others,

energy efficiency, product recovery and recycling

initiatives, partnering with specialised companies to

minimise environmental impact. Orange Belgium and

Orange Communications Luxembourg are involved in

the collection, reconditioning and recycling of end-of-

life

products,

thereby

helping

to

reduce

the

environmental impact of their activities.

98

Orange Belgium

_

Annual report 2025

99

1.1.3.2

Interests and views of stakeholders (SBM-2)

1.1.3.2.1

Engagement with stakeholders

In 2024, Orange Belgium conducted a comprehensive double

materiality analysis, rooted in the methodology established by

the Group and based on the European Financial Reporting

Advisory Group (EFRAG) guidelines. Within this framework,

Orange Belgium engaged with a range of stakeholders. A

dialogue was initiated in 2024 to gather stakeholder views on

defined sustainability topics and associated impacts, risks and

opportunities. This process has been structured around several

key

moments.

The

engagement

process

with

external

stakeholders involved conducting targeted interviews, as well as

surveys for B2C customers. To collect views of internal

stakeholders and experts, the company organised workshops

with business matter experts to evaluate and score key

sustainability topics and internal interviews. The description

99

Orange Belgium

_

Annual report 2025

100

below contains information about stakeholders’ engagement as

part of Orange Belgium’s double materiality exercise.

The first step consisted in conducting a comprehensive mapping

of stakeholders impacted and concerned by its activities.

Stakeholders were mapped by their influence on Orange

Belgium's activities and their interest in the company’s

operations, receiving scores to prioritise their input. They were

categorised into five profiles (authorities, businesses, civil

society, customers and internal Orange profiles).

Stakeholders’

engagement

assumed

that

the

selected

individuals and groups represented a balanced view across ESG

themes and representatives of both external experts and

potentially affected stakeholders. The exercise was not

conducted by Orange Communications Luxembourg.

The second phase was the stakeholder engagement initiated in

2024 to gather their views on defined sustainability topics and

associated impacts, risks and opportunities. This process has

been structured around several key moments, including

interviews and workshops as describe below:

Eight external interviews were then conducted with the external

stakeholders from various categories (authorities, civil society,

and businesses).

1

.

I

n

t

e

r

n

a

l

s

t

a

k

e

h

o

l

d

e

r

s

include all employees from

Orange. These can include, amongst other, C-level

management, general secretary, union representatives,

other Orange Group directors, thematic experts and

business representatives or other team members were

interviewed including:

o

Two Executive Committee members from the

Group, including the Chief Financial Officer and

the General Secretary;

o

The Orange Group Director in charge of Europe;

o

And one union representative.

2

.

A

u

t

h

o

r

i

t

i

e

s

including regulators and supervisors, and

particularly those dedicated to the telecommunication

industry were interviewed such as:

o

Belgian

Institute

for

Postal

Services

and

Telecommunications (BIPT)

o

Federal Public Service Economy (SPF) Economy,

particularly the new Telco department focusing on

social tariffs and 5G subsidies.

3

.

C

i

v

i

l

s

o

c

i

e

t

y

including

Non-Governmental

Organisations

(NGOs),

Foundation

were

also

interviewed:

o

Belgian Responsible Digital Institute (ISIT)

o

King Baudouin Foundation, which focuses on

social issues and community development.

4

.

B

u

s

i

n

e

s

e

s

Includes representatives of strategic

partners,

suppliers,

sector

federations,

capital

providers, B2B customers. Orange Belgium and

Orange Group interviewed notably in 2024:

o

Chief Executive Officer (CEO) of Luminus, an

energy company.

o

President of Audit Committee Orange Belgium

(independent).

o

Representatives from Microsoft and Huawei, who

are

involved

in

technology

and

telecommunications.

5

.

C

u

s

t

o

m

e

r

s

include

Business-to-Consumers (B2C)

customer base: A s

s

u

r

v

e

y

has also been distributed to

the B2C customer base, gathering 3,000 responses to

gather data on customer perspectives regarding

sustainability issues.

Orange Belgium organised specific w

w

o

r

k

s

h

o

p

s

focused on

different

ESG

areas.

Internal

experts

and

stakeholders

participated to discuss and score 27 sustainability topics.

In 2025, internal stakeholders targeted for their expertise within

Belgium and Luxembourg were consulted to make minor

adjustments to better align the analysis to peers’ benchmark and

with the Orange Group.

These various engagement methods gathered qualitative and

quantitative data to assess the relevance and weight of specific

sustainability-related topics for Orange Belgium.

Stakeholders’ dialogues, workshops, and surveys provide crucial

input to refine Orange Belgium’s identification of most relevant

sustainability topics. The dialogue with stakeholders is seen as

an opportunity to improve the understanding of the most relevant

sustainability issues and adjust strategies accordingly. Feedback

collected from this dialogue plays a pivotal role in scoring

sustainability topics based on their significance, directly

influencing the prioritisation of initiatives and actions to tackle

these issues. The stakeholder dialogues also enable discussions

about the solutions to transform Orange’s business model to

embed ESG principles into its core operations.

This dialogue therefore enables Orange to:

•

G

a

t

h

e

r

i

n

s

i

g

h

t

s

: To collect diverse perspectives and

insights from stakeholders regarding sustainability

topics, impacts, risks, and opportunities (IROs)

associated with operations.

•

N

u

r

t

u

r

e

m

a

t

e

r

i

a

l

i

t

y

a

s

e

s

m

e

n

t

: To nurture the double

materiality analysis by understanding the magnitude

and scope of risks and opportunities (financial

materiality) as well as the extent and irreversibility of

impacts (impact materiality).

•

E

n

h

a

n

c

e

t

r

a

n

s

p

a

r

e

n

c

y

: To enhance transparency and

build trust with stakeholders by involving them in the

sustainability dialogue and decision-making processes.

•

A

l

i

g

n

b

u

s

i

n

e

s

t

r

a

t

e

g

y

: To align the company's

sustainability strategy with stakeholder expectations

and concerns, ensuring that the business model

evolves to meet societal and environmental needs.

•

D

r

i

v

e

c

o

n

t

i

n

u

o

u

s

i

m

p

r

o

v

e

m

e

n

t

: To facilitate continuous

improvement

in

sustainability

practices

by

incorporating stakeholder feedback into the company's

sustainability initiatives and reporting.

•

S

u

p

o

r

t

s

u

s

t

a

i

n

a

b

i

l

i

t

y

o

b

j

e

c

t

i

v

e

s

: To support the

overall Environmental, Social, Governance (ESG)

objectives of the company by ensuring that stakeholder

voices are heard and considered in shaping policies

and practices.

The insights and feedback gathered from stakeholders during the

engagement process are integrated into the double materiality

assessment, helping to identify and prioritise material topics that

reflect

both

stakeholder

concerns

and

the

company's

sustainability impacts. Feedback from stakeholders was used to

100

Orange Belgium

_

Annual report 2025

101

enrich the assessment of impacts, risks, and opportunities (IROs)

associated with sustainability topics performed at Group level.

The output of this dialogue and double materiality analysis has

been presented in the Work Council in 2024 and 2025 and

validated in CSRD Steering Committee and Audit and Risk

Committee.

This stakeholder dialogue is therefore directly reflected in the

company's

sustainability

statement,

demonstrating

how

stakeholder input has shaped the company's approach to

sustainability and the actions taken in response to their concerns.

1.1.3.2.2

Outcome of stakeholder engagement

These stakeholder interactions facilitated discussions on how to

transform Orange’s business model to embed ESG principles

into its core operations. T

T

h

e

t

o

p

i

c

s

t

h

a

t

g

a

r

n

e

r

e

d

t

h

e

m

o

s

t

i

n

t

e

r

e

s

t

from stakeholders include:

•

C

i

v

i

l

s

o

c

i

e

t

y

r

e

p

r

e

s

e

n

t

a

t

i

v

e

s

:

Customers emphasised the

importance of cybersecurity and data protection as top

priorities. Environmental concerns, particularly climate

change, natural resource depletion, and electronic waste,

were identified as second-tier issues. Digital inclusion,

especially for elderly populations, was also highlighted.

Associations

expect

concrete

actions

addressing

environmental impacts and reducing the digital divide in

Belgium.

•

E

x

t

e

r

n

a

l

s

t

a

k

e

h

o

l

d

e

r

s

(

a

u

t

h

o

r

i

t

i

e

s

a

n

d

b

u

s

i

n

e

s

p

a

r

t

n

e

r

s

)

:

Insights from interviews underscored the importance of

energy management, climate change adaptation, GHG

emissions reduction, waste management, and circular

economy initiatives. Topics such as gender equality, skills

development, physical and mental health, accessibility of

products and services, ethics compliance, and responsible

business conduct are areas where Orange is expected to

act.

•

I

n

t

e

r

n

a

l

s

t

a

k

e

h

o

l

d

e

r

s

(

e

x

e

c

u

t

i

v

e

c

o

m

i

t

e

,

O

r

a

n

g

e

G

r

o

u

p

,

a

n

d

u

n

i

o

n

r

e

p

r

e

s

e

n

t

a

t

i

v

e

s

)

:

Key focus areas include energy

management, GHG emissions, climate adaptation, equal

treatment and opportunities, health and safety, skills

development,

innovation,

responsible

research,

and

adherence to compliance and ethical standards.

•

E

m

p

l

o

y

e

s

: The main concerns highlighted were employee

health and safety, cybersecurity and data protection,

business ethics and compliance, followed by circular

economy, energy efficiency, and GHG emissions.

The stakeholder engagement process was designed to ensure a

balanced representation of perspectives across ESG themes,

including external experts and potentially impacted stakeholders.

It is important to note that this exercise was conducted by

Orange

Belgium

and

not

by

Orange

Communications

Luxembourg.

A

s

a

r

e

s

u

l

t

,

t

h

e

c

o

m

p

a

n

y

s

t

r

a

t

e

g

y

h

a

s

b

e

n

a

d

j

u

s

t

e

d

to place a

greater emphasis on sustainability initiatives. Several initiatives

have been adopted and form core elements of the company

strategy:

•

E

n

v

i

r

o

n

m

e

n

t

a

l

c

o

m

i

t

m

e

n

t

:

Orange Belgium has its specific

targets to contribute to the Group’s target to reach net-zero

greenhouse gas emissions by 2040.

•

D

i

g

i

t

a

l

i

n

c

l

u

s

i

o

n

p

r

o

g

r

a

m

e

s

: Orange Belgium is expanding

its digital inclusion initiatives, such as the Orange Digital

Center, which aims to provide digital skills training and

access to technology for underserved communities.

•

U

s

e

r

h

e

a

l

t

h

a

n

d

s

a

f

e

t

y

i

n

i

t

i

a

t

i

v

e

s

: The company is

implementing specific measures to address the health and

safety of users, particularly youth. This includes launching

campaigns to raise awareness about cyberbullying and

promoting responsible digital usage with For Good

connection Programme. Orange Belgium is establishing

partnerships with civil society organisations to co-create

solutions that address societal challenges.

•

D

a

t

a

p

r

o

t

e

c

t

i

o

n

a

n

d

c

y

b

e

r

s

e

c

u

r

i

t

y

:

Implementing ISO

certification

27001

(information

security)

and

22301

(business continuity) in Orange Belgium processes and

offering customer protection tools. This is complemented at

the end of 2025 by an upgraded security plan to

continuously adapt to new emerging risks in this field and

ensure data security and trust for all.

The strategy includes a focus on collaborating with stakeholders

to address societal challenges and enhance sustainability efforts.

In the last years, the risk management framework has been

revised to better incorporate stakeholder insights into the

identification and assessment of environmental and social risks.

In addition, enhancements have been made to performance

measurement systems to track progress on sustainability

initiatives more effectively. The overall approach aims to create

long-term value for the company while addressing sustainability-

related impacts.

I

n

t

h

e

f

u

t

u

r

e

,

Orange Belgium aims to deepen its engagement

with stakeholders by increasing the frequency and depth of

dialogues. Orange Belgium plans to systematically incorporate

stakeholders feedback into its strategic planning. Orange

Belgium intends to establish a regular communication channel to

update stakeholders on progress related to sustainability

initiatives and how their feedback has been implemented. This

means that insights gathered from stakeholders will directly

influence the development of new initiatives and the refinement

of existing strategies. It should allow stakeholders to have a

better view and feel included in the process of informing strategy

and business model. The purpose is also to build a relationship

based on trust with stakeholders and gather their points of view.

Moreover, Orange Belgium will further enhance its performance

measurement systems to track progress and impact of

sustainability initiatives more effectively. Therefore, the company

anticipates that the thresholds and scales used for materiality

assessments may be revised in future reviews and adjustments.

The methodology and findings will also be updated in response

to upcoming revisions of the regulations by the legislator, or any

other new regulations applicable to the company.

The outcome of the stakeholder engagement process is

communicated to the administrative and management bodies, as

the results of these dialogues are shared with the relevant bodies

described supra in section

1.1.2.2 Information provided to and

sustainability

matters

addressed

by

the

undertaking’s

administrative, management and supervisory bodies (GOV-2).

101

Orange Belgium

_

Annual report 2025

102

1.1.3.3

Material impacts, risks and opportunities (IROs) and their interaction with

strategy and business model (SBM-3)

When updating the 2025 materiality, no major changes have

been identified compared to the 2024 impacts, risks and

opportunities. Some simplification in wording and aggregation

have been made where possible. To enhance clarity, diversity

and suppliers’ relationships have been highlighted as material

topics, while in the previous exercise they were integrated into

training and skills development accessible to all, and into

business ethics, good governance and compliance respectively.

It is important to note that some new impacts have been

identified to align with duty of vigilance impacts mapping. New

IRO's are identified with a star in the different tables below

presenting the material IROs with their relevance in the value

chain and time horizon.

The topic of workers in the value chain (ESRS S2) has not been

assessed as material, but it is nevertheless addressed in

Orange’s human rights policy (see

section 3.1.4 Human rights for

workers in the value chain (S2-1)

), as well as in the company’s

governance policy, which covers due diligence and the

whistleblowing system (see section

4.1.1.1 Business conduct

policies and corporate culture (G1-1, G1-3)

), and supplier

relations within the value chain (see

section 4.1.2.2 Management

of relationships with suppliers, building trust and secure

responsible supply (G1-2)

).

102

Orange Belgium

_

Annual report 2025

103

1.1.3.3.1

Overview of Orange’s material Impacts, Risks and Opportunities related to climate

change

E

1

-

C

l

i

m

a

t

e

c

h

a

n

g

e

I

R

O

V

a

l

u

e

c

h

a

i

n

T

i

m

e

h

o

r

i

z

o

n

C

l

i

m

a

t

e

c

h

a

n

g

e

m

i

t

i

g

a

t

i

o

n

Impact of GHG emissions associated with Orange's activities and its

value chain

Actual negative

impact

  

Short, medium

and long term

Reputational risk associated with failure to meet GHG emission reduction

commitments

Transition Risk



Opportunity to support customers in decarbonising and increasing the

resilience of their activities

Opportunity

 

E

n

e

r

g

y

m

a

n

a

g

e

m

e

n

t

Impact of energy consumption linked to Orange's activity due to

increasing digitalisation among Orange's customers and end users.

Actual negative

impact

 

Short and

medium-term

Risk of energy supply constraints leading to higher costs and possible

temporary supply disruptions.

Transition risk

  

C

l

i

m

a

t

e

a

d

a

p

t

a

t

i

o

n

Financial and operational risk and risk of increased costs related, on the

one hand, to adapting infrastructure and activities to climate change and,

on the other hand, to the deterioration of infrastructure, services, and

people's health and safety as a result of climate hazards.

Physical risk

 

Impact in the event of failure to adapt to climate hazards, leading to

deterioration of network and IT infrastructure.

Potential negative

impact

 

Medium and long

term



New in 2025



Upstream value chain



Own operations



Downstream value chain

In 2025, due to the incompleteness of its adaptation plan, Orange

did not carry out a resilience analysis of its strategy and business

model with regard to climate change. The year 2025 has marked

a period of capacity building to develop analyses of critical sites

exposure and prepare the vulnerability analyses that will then

lead to climate

‑

change adaptation plans site by site and territory

by territory, as part of a broader effort to strengthen overall

resilience.

Climate mitigation

Negative impact due to the company contribution to

the increase in GHG emissions, due to Orange’s

activities and its value chain

Orange’s activities contribute to greenhouse gases (GHG)

emissions across scopes 1, 2 and 3, contributing to global

warming. The resulting GHG emissions place pressure on the

environment, forcing ecosystems to adapt to a changing climate.

Global warming also affects human health and wellbeing and has

broader socio-economic consequences. By contributing to these

emissions, Orange’s operations play a role in the increase of

greenhouse gases in the atmosphere, which drives climate

change and its associated impacts on nature and human

populations.

These emissions arise primarily from the energy consumed in

Orange’s own operations, as well as from upstream and

downstream activities across the value chain, including the

manufacture and use of devices and infrastructure.

Orange recognises its role in supporting decarbonisation efforts

and acknowledges that evolving regulations increasingly require

businesses to reduce their climate impact. In response, Orange

Group has set ambitious targets, validated by the Science Based

Targets initiative (SBTi), aiming to achieve net-zero emissions by

2040.

Orange

Belgium

and

Orange

Communications

Luxembourg actively contribute to these targets across

emissions of scopes 1, 2 and 3.

Reputational

risk

linked

to

inability

to

meet

greenhouse gas (GHG) reduction commitments

A significant portion of Orange’s climate footprint is linked to its

value chain, including suppliers and service providers, as well as

the development of new uses and technologies. Failure to

achieve Net Zero Carbon objectives by 2040, whether due to

Orange’s own activities or those of its business relations, could

have reputational consequences, potentially affecting customer

and market confidence, employer attractiveness.

Civil society and regulators are increasingly monitoring corporate

efforts to reduce emissions, with potential disqualification

against companies not advancing on climate commitments.

Orange’s ability to meet its Net Zero Carbon target may be

influenced by challenges faced by suppliers and subcontractors

in reducing the footprint of products and equipment supplied, as

well as by rising digital traffic driven by the development of new

uses.

If Orange’s environmental action plans, particularly during

technological transitions on fixed and mobile networks, are

insufficient or constrained by unavailable resources, the Group’s

103

Orange Belgium

_

Annual report 2025

104

commitment could be jeopardised. This could have a significant

negative impact on Orange’s reputation, potentially leading to a

loss of stakeholder confidence, reduced customer base,

decreased attractiveness as an employer, and higher financing

costs. Beyond the company, insufficient action in the telecom

sector could slow the development of a sustainable digital

society.

As mentioned above, by actively contributing to achieve the

Orange Group net-zero emissions by 2040, both Orange Belgium

and Orange Communications Luxembourg aim to proactively

avoid the cause of this reputational risk.

Opportunity to support customers in decarbonising

and increasing the resilience of their businesses

Orange identifies an opportunity to support its customers in

decarbonising and increasing the resilience of their businesses

by using digital technologies. As a telecommunications service

provider, Orange can offer connectivity service, particularly via

Orange Business, that help to reduce customers’ environmental

footprints and enhance their resilience to climate-related risks.

This opportunity aligns with Orange’s strategic focus on

positioning Orange Business as a leader in next-generation

connectivity solutions.

Energy management

Negative impact of energy consumption linked to

Orange's activity

The increase in the number of customers, their equipment, and

their usage leads to higher energy and equipment requirements

for both Orange and its customers. Orange accounts for a

significant share of the sector's energy consumption. For

Orange, and in line with its business model and growth strategy,

this requires scaling infrastructures accordingly. For customers,

additional energy is needed to operate their equipment and

access telecommunications services. As a result, there is an

upward trend in greenhouse gas emissions in the short, medium,

and long term, generating a tangible negative impact on the

environment. This material impact arises from Orange’s own

activities and from those of its business relations, which together

contribute to the Group’s GHG emissions.

Orange’s activities contribute to increasing energy demand in a

context where rapid decarbonisation is required and where

demand for low-carbon energy is high. In addition, in an

environment of increasing geopolitical tensions, Orange faces

the risk of rising energy costs, which weigh on its margins, as

well as occasional supply disruptions that could affect the

continuity of its activities. The entire value chain is affected by

this material impact and upstream risk. Energy consumption

stems mainly from the operation of Orange’s infrastructures (data

centre, Radio Access Network (RAN) infrastructure, etc.), with

comparatively smaller consumption associated with offices and

shops. Energy is also required upstream and downstream in the

value chain, including for manufacturing products used in

Orange’s activities, for operating the infrastructure made

available to society, and for the use of devices purchased or used

by customers.

To address these challenges, Orange has developed a strategy

to cover its energy needs based on supply sustainability, cost

efficiency, and the nature of energy sources, positively

influencing its business model. Energy consumption and GHG

emissions are key factors integrated into investment decisions.

Several initiatives have been implemented to better monitor and

manage the energy efficiency of operations and the broader

value chain (digital counters, smart meters combined to internet

of things (IoT) with energy management system (EMS), etc.).

Orange commits to using electricity sourced entirely from

renewable energy and analyses the feasibility of producing its

own electricity through solar or wind energy, or of purchasing it

via Green Power Purchase Agreements (PPAs).

Risk of strain on energy supply, costs and availability,

potentially leading to service disruptions

Orange faces risks related to energy supply, costs, and

availability, which could potentially lead to service disruptions.

The company’s significant energy consumption exposes it to

fluctuations in energy prices and investment costs for energy

efficiency measures. Inability to manage this energy demand

effectively could disrupt service provision and create operational

and financial risks.

To address these risks, Orange has implemented initiatives to

monitor and improve energy efficiency across its operations and

along its value chain.

Climate change adaptation

Financial and operational risks linked to increased

adaptation

costs

and

physical

damage

to

infrastructure and services due to climate hazards

Physical risks from climate hazards primarily affect network

infrastructures, buildings, and people. Orange may incur

increased costs due to the deterioration of its infrastructure,

which could also have a negative impact on its financial results.

Inadequate adaptation to these risks could lead to potential

litigation or affect the company’s access to insurance.

Extreme climate events are becoming more frequent and may

damage Orange’s IT systems, network infrastructure, buildings,

and other assets. Such events can also threaten the health and

safety of employees, suppliers, clients, and the public, potentially

resulting in the loss of customers, partners, or workforce, thereby

affecting business operations. In addition, regulators are

increasingly imposing requirements on managing these risks,

and failure to comply could result in legal or regulatory

consequences.

To mitigate these financial and operational risks, Orange invests

in strengthening the resilience of its assets and infrastructure and

implements measures to ensure business continuity under

existing and new sorts of adverse climate conditions (e.g. fire,

storm, flood, and now on, high temperature and landsliding).

Negative impact in the event of failure to adapt to

climate hazards, leading to deterioration of network

and IT infrastructure

Negative impacts may arise if Orange fails to adapt to climate

hazards, leading to deterioration of network and IT infrastructure.

Maladaptation to climate risks can negatively affect the quality

104

Orange Belgium

_

Annual report 2025

105

and continuity of services, even though Orange’s activities are

essential to the proper functioning of today’s society. These

impacts may be amplified by Orange’s interdependency with vital

service operators, such as energy providers.

Climate change has a material impact on customers, as the

interdependency of vital services with telecommunication

services can have serious consequences for society. In the short

term, and potentially in the medium and long term, climate

hazards may lead to service discontinuity or deterioration, which

is particularly damaging given that service continuity enables

public authorities to organise relief efforts during natural

disasters.

After having assessed and identified all Orange’s sites exposed

to such climate hazards (including formerly VOO’s critical assets

in 2025), the focus now shifts to the development of an optimised

adaptation plan for the most vulnerable sites, and beyond, to

carry out a resilience analysis of its strategy and business model

with regard to climate change.

1.1.3.3.2

Overview of Orange’s material Impacts, Risks and Opportunities related to circular

economy

E

5

-

R

e

s

o

u

r

c

e

u

s

e

a

n

d

c

i

r

c

u

l

a

r

e

c

o

n

o

m

y

I

R

O

V

a

l

u

e

c

h

a

i

n

T

i

m

e

h

o

r

i

z

o

n

R

e

s

o

u

r

c

e

s

u

s

e

a

n

d

C

i

r

c

u

l

a

r

e

c

o

n

o

m

y

Impact on natural resource depletion (e.g., critical metals)

Actual negative

impact



Short and medium term

Risk of pressure on the supply of essential resources, resulting in

higher costs and possible temporary supply disruptions.

Risk



R

e

s

o

u

r

c

e

s

o

u

t

f

l

o

w

s

a

n

d

W

a

s

t

e

m

a

n

a

g

e

m

e

n

t

Impact of waste production and treatment at the end of the life

cycle of equipment and infrastructure

Actual negative

impact



Short, medium and

long-term



New in 2025



Upstream value chain



Own operations



Downstream value chain

Resource use and circular economy

Negative impact due to the company contribution to

the depletion of resources and raw materials used to

manufacture

network

equipment,

terminals

and

products

This impact stems from Orange’s reliance on the manufacturing

of network equipment, terminals, and products that require raw

materials, including critical and finite resources such as metals.

These materials are essential to the telecommunications sector,

forming the backbone of the infrastructure and products that

support Orange’s services. Orange sources equipment and

materials from a wide range of global suppliers, a relationship

that often involves procuring rare and critical materials further

upstream in the value chain for the manufacturing of electronic

devices and network components used by Orange.

Orange’s activities have a negative impact through their

contribution to the depletion of resources and raw materials used

to manufacture network equipment, terminals, and products. The

company recognises the importance of managing this impact,

particularly regarding the depletion of rare and critical materials

used in telecommunications and IT equipment.

Orange’s service offering relies on the production of network

equipment and customer devices that require metals with limited

planetary stocks. This pressure on natural resources has a real

negative impact in the short and medium term.

The

extraction

of

rare

and

critical

materials

used

in

telecommunications equipment contributes to environmental

harm, including deforestation, biodiversity loss, and water and

soil pollution. Mining and processing activities often take place in

regions with insufficient safety standards, leading to hazardous

working conditions, exposure to toxic substances, and health

risks for workers and nearby communities.

By embedding circular-economy principles into its operations

and into the products and services it offers, Orange aims to

extend product lifecycles and reduce the need for continuous

extraction of raw materials. The company also collaborates with

industry partners to improve transparency and sustainability in its

supply chain.

Risk of pressure on the supply of essential resources

Orange’s service offering relies on the production of network and

customer equipment, which requires metals with limited global

stocks. This creates operational, economic, and financial risks,

including potential long-term shortages of critical resources. As

Orange’s business model partially depends on the sale of

equipment to customers, these risks could affect its operations.

To mitigate these risks, Orange implements policies to extend the

lifespan and usage of equipment, helping to alleviate resource

constraints while making digital services more affordable. For

network equipment, the company has established an internal

marketplace and processes for purchasing refurbished materials.

More broadly, Orange applies circular economy principles,

including reconditioning and repair of equipment, reducing

reliance on newly extracted raw materials, and promoting

recycling. These measures support a more sustainable use of

resources and help maintain continuity in the supply of essential

materials.

105

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106

Resources outflows and waste management

Negative impact due to the production of significant

waste, particularly if these materials are not recyclable

or biodegradable

Negative impacts arise from the production of significant waste,

particularly when materials are not recyclable or biodegradable.

End-of-life of electronic equipment that cannot be reused

constitutes hazardous waste, and its treatment relies on

dedicated channels that are not always operational at waste-

generation sites.

This impact originates directly from Orange’s business model,

which is based on providing telecommunication services and

selling electronic equipment to customers. These activities

generate

substantial

quantities

of

end-of-life

electronic

equipment, including network components and customer

devices, which require appropriate waste treatment. Orange’s

impact therefore stems both from its products and services, by

providing electronic devices to clients, and from its own

operations and infrastructure, which generate waste when

decommissioned.

Waste Electrical & Electronic Equipment (WEEE) and batteries

are classified as hazardous waste by environmental regulations.

If not managed properly, they can release toxic substances,

posing serious risks to ecosystems and human health. This can

have negative impacts in the short, medium, and long term on

the environment and on people’s health. Within the Orange value

chain, the company’s own operations for network waste and the

collection and downstream treatment of customer equipment are

the most affected.

In response, Orange’s strategy and action plan integrate

supplier-engagement initiatives to foster eco-design, reparability,

waste collection, and increased product longevity. The company

prioritises extending the lifecycle of its equipment and its

customers’ equipment and adopting circular-economy practices

to mitigate negative impacts, minimise waste generation, and

maximise recovery through dedicated channels.

1.1.3.3.3

Overview of Orange’s material Impacts, Risks and Opportunities related to own

workforce

All people in the company’s own workforce who can be materially

impacted were included in the scope of the double materiality

analysis. Orange has identified v

v

a

r

i

o

u

s

m

a

t

e

r

i

a

l

i

m

p

a

c

t

s

on its

own employees (own payroll), nevertheless these impacts may

also extend to non-employees in the value chain, working in

Orange’s premises.

•

The only material negative impact identified is on health

and safety. This impact is mainly related to individual

incidents rather than being widespread or systemic in

Orange's industry. There is another negative impact

associated to data privacy of employees from the own

workforce, which is addressed in a generic way

together with the same issue extended to consumers

and end-users (see following section on the Overview

of Orange’s material Impacts, Risks and Opportunities

related to customers and end-users, on

Data privacy

and cybersecurity within section 1.1.3.3.4 Overview of

Orange’s material Impacts, Risks and Opportunities

related to customers and end-users

for more details).

•

Diversity, Equity and inclusion policies and skills

development actions deployed by the company would

positively affect employee employability notably as

regards women in tech jobs, or management position

and persons with disabilities or not in education,

employment or training in accessing jobs and furthering

their career progression.

R

i

s

k

s

identified by Orange relate to employees' health and safety,

absence of certain skills, and security.

•

Health and safety and security related events can lead

to a decrease in employee motivation and efficiency or

to an increase of absenteeism.

•

The unavailability of certain skills and knowledge may

lead to business interruptions or operating losses. In

specific cases, Orange could also be fined, asked for

compensation or indemnity if preventive measures are

considered inefficient or in case of regulatory breaches.

•

When related to data protection, the risk of penalties

and compliance cost is addressed simultaneously

when addressing this risk for consumers and end-users

(see following

section Data privacy and cybersecurity

within section 1.1.3.3.4 Overview of Orange’s material

Impacts, Risks and Opportunities related to customers

and end-users

for more details).

There are also s

s

k

i

l

s

d

e

v

e

l

o

p

m

e

n

t

o

p

o

r

t

u

n

i

t

i

e

s

. Orange evolves

in a fast-paced market regularly requiring new skills. This calls for

continuous investment in skills development and knowledge

capitalisation which requires significant financial resources to

implement.

•

Orange sees an opportunity in recruiting, developing

and retaining talents via career paths enabling

employees to progress and grow. In Orange’s strategy,

a strong focus is set on ensuring these opportunities

are accessible to all, with a specific focus on access for

women to technical professions.

To Orange knowledge, n

n

o

m

a

t

e

r

i

a

l

i

m

p

a

c

t

a

r

i

s

i

n

g

f

r

o

m

t

r

a

n

s

i

t

i

o

n

p

l

a

n

s

for reducing the company's negative impacts on

environment and achieving greener operations has been

identified as regards its workforce.

Orange Belgium and Orange Communications Luxembourg have

not identified any significant risks regarding incidents of c

c

h

i

l

d

o

r

f

o

r

c

e

d

l

a

b

o

u

r

or compulsory labour. Within Vigilance plan risk

map, slavery or child or forced labour within the framework of a

known established contractual relationship has a low probability

but would have a dramatic impact.

To support the identification of Orange’s impacts on its own

workforce and potentially vulnerable groups harmed by its way

of working, Orange c

c

o

n

s

u

l

t

e

d

w

o

r

k

e

r

s

'

u

n

i

o

n

r

e

p

r

e

s

e

n

t

a

t

i

v

e

s

as

part of the materiality assessment stakeholder consultations in

2024. In addition, the feedback received during annual surveys

feeds the company’s understanding of particularly vulnerable

groups within its own workforce and their concerns.

106

Orange Belgium

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107

The w

w

h

i

s

t

l

e

b

l

o

w

i

n

g

p

r

o

c

e

s

also enables Orange to better

understand grievances of those affected by its way of working

and therefore whether some groups are more vulnerable.

Nevertheless, Orange has developed action plans to mitigate

potential risks linked to commonly accepted vulnerable groups

as part of its work with the health and safety department.

Although the company has not identified any negative impact on

diversity as part of the double materiality exercise, the Diversity,

Equity and Inclusion Committee, which oversees potential

negative impacts has adopted a zero-tolerance policy on

d

i

s

c

r

i

m

i

n

a

t

i

o

n

based on ethnic and social origin, age, disability

and neurodiversity, sexual orientation and gender identity, as well

as religious and trade union views. The following analysis did not

focus on specific groups of people.

S1-Own workforce

IRO

Value chain

Time horizon

Training and skills development

Risk of not having the skills needed to ensure business continuity

and the rollout of Orange Belgium's strategy

Risk



Medium and long term

Opportunity to attract and retain talent by offering attractive career

paths that are accessible to all, particularly in technical professions.

Opportunity



Short and medium term



Impact of developing and strengthening skills, improving

employee employability and career development towards new

professions

Actual positive

impact



Short and medium term

Diversity, equity and inclusion



Impact of policies and practices that promote an inclusive and

equitable work environment.

Potential positive

impact



Short and medium term

Health and safety



Impact on the physical and mental health of employees

(workplace accidents, conflict zones, adverse weather conditions,

etc.).

Potential negative

impact



Short and medium term

Operational and financial risks linked to health and safety at work

Risk



Short-term

Data privacy and cybersecurity

Financial penalties and compliance costs associated with non-

compliance with data protection regulations

Risk



Short-term

Impact on the privacy of employees resulting from a breach of the

security of their personal data

Potential negative

impact



Short and medium term



New in 2025



Upstream value chain



Own operations



Downstream value chain

Training and skills development

Risk of not having the right skills to ensure business

continuity and the deployment of Orange Belgium's

strategy

In a dynamic and rapidly evolving technological environment, the

need for new skills poses a risk to Orange Belgium’s business

continuity and the implementation of its strategy. The risks and

opportunities r

r

e

l

a

t

e

d

t

o

t

r

a

i

n

i

n

g

a

n

d

s

k

i

l

s

primarily concern

e

m

p

l

o

y

e

s

i

n

t

e

c

h

n

i

c

a

l

a

n

d

s

p

e

c

i

a

l

i

s

e

d

r

o

l

e

s

whose

competencies must evolve to meet changing technological and

market requirements. The risk of skill obsolescence may

particularly affect workers whose profiles are less aligned with

emerging needs, including s

s

o

m

e

o

l

d

e

r

e

m

p

l

o

y

e

s

.

This risk can result in a loss of in-house knowledge and generate

significant costs related to recruiting specialised profiles, as well

as implementing skills development programmes. Maintaining

attractiveness as an employer is particularly important for roles

requiring rare or highly sought-after skills. Insufficient employer

appeal or training initiatives could reduce Orange’s capacity to

operate effectively, potentially affecting its results and strategic

objectives.

To address this risk, Orange has developed a business model

that integrates strategic workforce planning, anticipates future

skills needs, particularly in areas such as data, and emphasises

organisational agility, simplification, and a strong corporate

culture.

Opportunity to attract and retain talent by offering

attractive career paths that are accessible to all,

particularly in technical professions

Orange identifies an opportunity to attract, develop, and retain

talent by offering career paths that are accessible to all,

particularly in technical and digital professions. By promoting

diversity, equity, and inclusion, Orange enables access to

positions of responsibility and supports the development of

technical

skills

across

its

workforce.

Structured

career

development and skill-building initiatives help enhance the

company’s attractiveness to talent, foster innovation, and

encourage diverse teams to collaborate creatively. The

opportunity to attract and retain talent through accessible and

attractive career paths mainly benefits employees in technical

and managerial positions, as well as those transitioning toward

new or emerging roles.

107

Orange Belgium

_

Annual report 2025

108

Orange has established career paths for a broad range of profiles

and implements ambitious policies to increase the representation

of women in management, leadership, and technical roles.

Recruitment initiatives target young talent, and the company

monitors progress on diversity, equity, and inclusion, including

metrics such as gender pay gap and the percentage of women

in management positions. This opportunity mainly benefits

employees interested in technical and managerial positions.

Positive

impact

of

skills

development

and

enhancement, improving employee employability and

career development towards new professions

Policies and practices that promote an inclusive and developing

work environment, as part of Orange Belgium’s strategy, have a

positive impact on employees. The focus on skills development

and enhancement improves employee employability and

supports

career

progression

towards

new

professions,

strengthening workforce capabilities, fostering innovation, and

enhancing competitive advantage. The ongoing and anticipated

effects of these initiatives are expected to have a positive impact

on the business model, value chain, strategy, and decision-

making processes.

In response to these effects, Orange has integrated continuous

learning programmes into its strategic planning to ensure that

employees acquire skills aligned with evolving industry demands.

The company is also exploring new opportunities for talent

development and strategic partnerships to support workforce

growth and adaptability, reinforcing its commitment to increasing

sustainable business practices and long-term value creation.

This approach positively affects employee employability and

career progression towards new professions.

Learning and development form a key component of Orange

Belgium’s strategy through the “We care for people” pillar, which

focuses notably on skills development. As an employer aiming to

become the leading telco-tech and telco-first employer, the

Orange Group has developed human-resources policies that

include learning and talent development, generating a positive

impact on employees.

Diversity, equity and inclusion

Positive impact of policies and practices that promote

an inclusive and equitable work environment

Policies and practices that promote an inclusive and equitable

work environment have a positive impact on employees. As part

of Orange Belgium’s strategy, these initiatives help foster a sense

of belonging, motivation, and overall wellbeing. They contribute

to building a more diverse and engaged workforce, enhancing

employee satisfaction, collaboration, and innovation, in line with

the company’s strategic objectives.

In response to these positive effects, Orange Belgium continues

to prioritise inclusivity and equity within its organisational culture.

The company is implementing targeted programmes and

practices to ensure ongoing progress in diversity and inclusion,

reinforcing its commitment to a supportive and fair workplace

that contributes to sustainable growth and long-term success.

These initiatives positively affect employee employability, notably

for women in tech roles or management positions, and for

persons with disabilities or those not in education, employment,

or training, by improving access to jobs and career progression.

Diversity, Equity and Inclusion form an integral part of Orange

Belgium’s strategy through the “We care for people” pillar, which

focuses notably on diversity.

Health and safety

Negative impact on employees' physical and mental

health (workplace accidents, conflict zones, climatic

hazards, etc.)

Damage to employees’ physical and mental health can have

serious consequences for both individuals and organisations.

Workplace accidents, exposure to conflict zones, and climatic

hazards can result in injuries, chronic health conditions, and

psychological stress. In the telecom sector, this mainly includes

field

technicians

and

employees

performing

installation,

maintenance or network interventions, who may face physical

risks linked to on-site activities, technical equipment or outdoor

working conditions. These impacts reduce employees’ wellbeing

and quality of life, while also affecting productivity, increasing

absenteeism, and raising healthcare costs.

At Orange Belgium, the negative impact on employees’ physical

and mental health is a key concern. Employees working in high-

risk environments may be exposed to specific dangers, including

working at height, handling electrical currents, or encountering

toxic or hazardous materials, such as lead cables. Non-

compliance with safety rules can exacerbate the occurrence of

such negative impacts. Additionally, roles subject to high

workload or sustained operational pressure may be more

exposed to stress-related impacts on mental health.

To address these challenges, Orange Belgium is committed to

strengthening health and safety protocols, implementing

preventive measures, and providing comprehensive support

systems. The company continuously reviews and enhances its

safety practices and mental health initiatives to protect

employees, promote resilience, and ensure a safe and healthy

work environment.

Operational and financial risks linked to health and

safety at work

Health and safety at work are critical factors for Orange Belgium,

as incidents such as workplace accidents, sick leave, and other

occupational

risks

can

decrease

productivity,

generate

significant costs, and affect the company’s reputation as an

employer. Mismanagement of employee health and safety can

also lead to risks of business interruptions, operational losses,

and financial penalties or compliance costs resulting from

regulatory breaches. This could also damage Orange’s image as

an employer and increase staff turnover.

In the context of increased teleworking, employees may face

risks linked to new working conditions, including social isolation,

which can impact their health and safety. Psychosocial risks

discrimination,

harassment,

or

physical

and

psychological violence are also considered. Additionally, the

rapid expansion of digital tools and virtualisation of work can

create further psychosocial risks, potentially leading to physical

or psychological incapacity. These risks could hinder the

108

Orange Belgium

_

Annual report 2025

109

deployment of Orange’s strategy, affect its operations and

reputation, and generate financial implications.

The risks primarily concern employee groups whose roles involve

higher exposure to operational health and safety constraints. In

the telecom sector, this mainly includes f

f

i

e

l

d

t

e

c

h

n

i

c

i

a

n

s

a

n

d

e

m

p

l

o

y

e

s

p

e

r

f

o

r

m

i

n

g

i

n

s

t

a

l

a

t

i

o

n

,

m

a

i

n

t

e

n

a

n

c

e

o

r

n

e

t

w

o

r

k

i

n

t

e

r

v

e

n

t

i

o

n

s

,

who may face physical risks linked to on-site

activities, technical equipment or outdoor working conditions.

Additionally, roles subject to high workload or sustained

operational pressure may be more exposed to stress-related

impacts on mental health. As a result, the material risks

associated with accidents, illness and reduced wellbeing relate

particularly to employees in operational and field functions, as

well as those in positions with heightened psychosocial

demands.

Health and safety at work is central to Orange Belgium’s “Lead

the Future” strategy under the “We care for people” pillar, which

aims to make the company a preferred tech and telecom

employer, develop talent, and promote diversity and inclusion.

To mitigate these risks, Orange is implementing an occupational

health and safety management system across all geographies

including Belgium and Luxembourg, incorporating prevention,

monitoring, and employee support measures.

Data privacy and cybersecurity

As these topics may affect its own workforce as much as

consumers and end-users, these impacts risks and opportunities

are described together below in section

1.1.3.3.4 Overview of

Orange’s material Impacts, Risks and Opportunities related to

customers and end-users

.

1.1.3.3.4

Overview of Orange’s material Impacts, Risks and Opportunities related to

customers and end-users

In the framework of Orange’s strategy “Lead the future”, actual

and potential impacts on consumers and end-users are

addressed in the third pillar "We care for people" from which

feeds into Orange Belgium’s societal strategy which mainly

addresses d

d

i

g

i

t

a

l

i

n

c

l

u

s

i

o

n

and p

p

r

o

t

e

c

t

i

o

n

o

f

i

t

s

c

u

s

t

o

m

e

r

s

a

n

d

e

n

d

-

u

s

e

r

s

.

All consumers who can be materially impacted by Orange’s

activities are included in this analysis and report. Orange's

consumers and end-users comprises both individuals and

businesses.

A potential n

n

e

g

a

t

i

v

e

i

m

p

a

c

t

arises when users experience service

degradation or network outages during technical or climatic

crises, as such disruptions can temporarily limit access to

essential digital services and undermine user confidence in

network reliability. This negative impact highlights Orange’s

dependency on the continuity and quality of its connectivity

services. It also reinforces the importance of maintaining resilient

infrastructure, as interruptions can affect users’ ability to

communicate, access information, or benefit from digital services

that support socio-economic participation.

•

As regards the negative impact Orange's products and

services can have on customers' psychological health,

particular attention is paid to vulnerable groups with an

emphasis on younger generations who may be even

more vulnerable (e.g. bullying and discrimination,

inappropriate content, screen time limits, or else).

World Health Organisation

5

notably highlights the

importance of balanced digital use and guidelines for

healthy digital habits.

•

Orange has identified the protection of personal data

and privacy as a material issue, given that its business

model relies on transmitting and storing sensitive

information

while

ensuring

the

integrity

and

confidentiality of communications. A breach of end

users’ personal data security constitutes a potential

negative impact, as it may infringe on individuals’

privacy and affect their personal or professional

activities. Both individuals as well as businesses can be

affected by the misuse of their data in case of data

5

WHO's Global Strategy on Digital Health

https://www.who.int/health-topics/digital-health#tab=tab_1

privacy breaches. However, it is proven that online

security is the g

g

r

e

a

t

e

s

t

d

a

n

g

e

r

f

o

r

p

e

r

s

o

n

s

w

h

o

h

a

v

e

l

i

m

i

t

e

d

i

g

i

t

a

l

s

k

i

l

s

as they often lack the knowledge

and awareness needed to recognise and respond to

cyber threats such as phishing, malware, and scams.

This vulnerability makes them more susceptible to data

breaches, identity theft, and financial loss. Additionally,

limited digital skills can hinder their ability to implement

basic security measures like strong passwords or

recognising suspicious links, increasing their risk

exposure.

While data privacy impacts are related to individual incidents or

specific business relationships, other impacts on access to

products and services and the health of its consumers are more

widespread or systemic.

When considering the p

p

o

s

i

t

i

v

e

i

m

p

a

c

t

Orange can have on digital

inclusion, Orange mainly identified populations with limited

digital skills, who could be limited in their access to information

and essential online services. Orange also identified a positive

impact of its products and services on marginalised groups who

suffer from economic and social exclusion and women.

•

Orange generates positive impacts t

t

h

r

o

u

g

h

a

c

t

i

v

i

t

i

e

s

t

h

a

t

e

x

p

a

n

d

e

q

u

i

t

a

b

l

e

a

c

e

s

to telecommunications

services and essential digital tools. By extending

network coverage to rural and remote areas and

offering affordable, accessible digital solutions, the

company supports local socio-economic development,

strengthens

social

cohesion,

and

facilitates

professional integration. Its digital inclusion initiatives

specifically benefit consumers and end-users who face

economic vulnerability, irregular income, precarious

employment status, or disabilities. These actions help

reduce digital divides, enhance autonomy, and enable

vulnerable and underserved populations to participate

more fully in economic and social life.

109

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_

Annual report 2025

110

Orange’s business model, built on reliable connectivity and

digital inclusion, creates both risks and o

o

p

o

r

t

u

n

i

t

i

e

s

linked to its

dependencies on consumers and end-users. For instance, the

negative impact related to data privacy and cybersecurity gives

rise to a m

m

a

t

e

r

i

a

l

r

i

s

k

for Orange:

•

A breach of data could damage its reputation and

erode customer trust, both essential for a

telecommunications operator and could also result in

financial consequences, including regulatory fines.

But these considerations also come with opportunities:

•

A m

m

a

t

e

r

i

a

l

o

p

o

r

t

u

n

i

t

y

consists in the expertise,

technologies, and resources that Orange deploys to

prevent such breaches. It positions the company to

strengthen its cybersecurity offerings and develop new

data-protection solutions for all types of customers. By

building on its existing capabilities, Orange can expand

trust-based services on the market and support end

users in addressing growing cybersecurity threats.

•

Orange’s sustained investments in network quality,

rural coverage, and accessible offers generate material

o

p

o

r

t

u

n

i

t

i

e

s

. By ensuring strong local roots and

delivering inclusive, reliable digital service, even in

remote or underserved areas, Orange can enhance its

brand image and strengthen customer trust and loyalty.

These factors support the company’s ability to expand

and retain its customer base, while contributing

positively to the economic and social integration of

populations distant from digital access.

The 2024 Digital Inclusion Barometer of the Foundation Roi

Baudouin helps to identify the target group for digital inclusion.

According to this barometer, 30% of Belgians need assistance

to carry out essential online actions (such as e-banking, e-health,

e-commerce, e-admin, etc.).

S

4

-

C

o

n

s

u

m

e

r

s

a

n

d

e

n

d

-

u

s

e

r

s

I

R

O

V

a

l

u

e

c

h

a

i

n

T

i

m

e

h

o

r

i

z

o

n

D

i

g

i

t

a

l

i

n

c

l

u

s

i

o

n

a

n

d

a

c

e

s

t

o

p

r

o

d

u

c

t

s

a

n

d

s

e

r

v

i

c

e

s



Impact on users due to service degradation or network outages in

the event of a crisis (technical, climatic).

Potential negative

impact



Short and medium term

Impact related to access to telecommunications services, promoting

local socio-economic development, support for local stakeholders,

social cohesion, and professional integration.

Actual positive impact



Short, medium and long-

term



Opportunities for operators with strong local roots (accessible

offers, connectivity in rural areas, multi-service offers, etc.) to increase

and retain customers thanks to a better brand image linked to inclusive

digital services.

Opportunity

 

Short term

P

s

y

c

h

o

l

o

g

i

c

a

l

h

e

a

l

t

h

o

f

e

n

d

-

u

s

e

r

s

Impact on mental health of end users, particularly among vulnerable

groups (addiction, use of and exposure to inappropriate content,

cyberbullying, etc.).

Actual negative impact



Short, medium and long-

term

D

a

t

a

p

r

i

v

a

c

y

a

n

d

c

y

b

e

r

s

e

c

u

r

i

t

y

Impact on end users' privacy in the event of a breach of their personal

data security

Potential negative impact



Short and medium term

Reputational and financial risk in the event of a breach of end users'

personal data security

Risk



Short, medium and long

term

Possibility to strengthen cybersecurity offerings on the market and

develop new technologies to protect data.

Opportunity

 

Short term



New in 2025



Upstream value chain



Own operations



Downstream value chain

Digital inclusion and access to products and

services

Negative impact on users due to service degradation

or network outages in the event of a crisis (technical,

climatic)

Service degradation or network outages during crises, such as

technical failures or climatic events, can have a negative impact

on users. Digitalisation can amplify these effects, as individuals

may be excluded from communications, including emergency

services, public services such as health and education, banking,

and other essential activities. Such disruptions can undermine

user experience, trust, and satisfaction, while also affecting

operational resilience and strategic decision-making.

The negative impact on users is directly linked to Orange’s

network infrastructures and its business activities, which

prioritise reliable connectivity and service quality. Outages or

service degradations can affect user trust, brand reputation, and

may lead to potential financial consequences.

To address these risks, Orange is investing in resilient network

infrastructure, advanced technologies, and robust contingency

planning.

This

includes

deploying

redundant

systems,

implementing

disaster

recovery

protocols,

continuous

monitoring, and comprehensive crisis management procedures.

110

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111

Proactive communication strategies are also used to ensure

transparency and provide support to users during disruptions.

By integrating these resilience measures into its strategic

framework, Orange aims to minimise service interruptions,

maintain high-quality customer experiences, and uphold its

commitment to reliable connectivity even under adverse

conditions.

Positive impact on digital inclusion by contributing to

network access and information for all

Orange has a positive impact on digital inclusion by contributing

to network access and information for all, supporting economic

and social development, and helping reduce the digital divide.

The company contributes to strengthening social ties and

fostering social and professional integration. This positive impact

is achieved through investment in expanding network coverage

to remote or economically disadvantaged areas and through

digital literacy initiatives that enable effective use of digital tools.

Orange’s business model is based on connectivity and inclusion,

with the usefulness of its services increasing as users are able to

reach a broader network of contacts. Its strategy is to capitalise

on its leadership in network deployment to generate value and

promote digital inclusion and empowerment through technology.

In addition to connectivity, Orange provides essential services,

such as access to energy, health, education, and financial

activities, which support socio-economic development and

empower populations far from infrastructure, including in favour

of professional integration.

Through these offers, Orange has a positive impact on

populations distant from digital technologies in the short,

medium, and long term by promoting economic and social

integration, job creation, and support for local actors and

initiatives contributing to territorial development. These impacts

occur mainly in the downstream value chain. Digital inclusion

enhances access to information, communication, and essential

services,

reinforcing

socio-economic

development

and

improving opportunities for people far from infrastructures. In

Belgian territories, Orange’s activities help drive economic and

social development and digital inclusion.

Orange’s mission is to be a trusted digital partner, providing

reliable and inclusive connectivity. Promoting digital inclusion

directly supports this mission, notably through the Orange

Belgium

Fund

and

the

Orange

Belgium

and

Orange

Communications Luxembourg’s digital centers. Orange invests

in expanding telecommunications infrastructure, such as mobile

networks and broadband, to reach remote and underserved

areas, bridging the digital divide and ensuring wider access to

digital services. Products and services are also tailored to

vulnerable groups, including affordable offers and digital literacy

programmes. The digital centers and the Orange Fund provide

training in digital skills, entrepreneurship, and innovation, helping

individuals acquire the knowledge and tools required to

participate in the digital economy.

In addition, Orange collaborates with governments and non-

governmental

organisations

to

develop

and

implement

programmes that promote digital literacy and connectivity. These

partnerships often focus on community-based initiatives that

facilitate internet access and provide digital education.

To address impacts on consumers, Orange Belgium launched in

2024 the

For Good Connections

initiative, aligned with its

purpose: “As a trusted partner, Orange gives everyone the keys

to a responsible digital world.” The company is strengthening its

long-standing commitment to protecting young people against

digital abuse, first addressing cyberbullying before tackling

online hate and hyperconnectivity. Under

For Good Connections

,

Orange is initiating preventive and educational actions to help

children and parents adopt good practices and use digital tools

responsibly and safely.

Opportunity to be an operator with strong local roots

Orange identifies an opportunity to strengthen its position as a

locally rooted operator by providing accessible and inclusive

services, improving connectivity in rural areas, and offering multi-

services solutions. These initiatives support customer acquisition

and retention while enhancing Orange’s brand image through

inclusive digital services.

As a locally based operator, Orange delivers services that

complement

connectivity,

including

access

to

energy

management,

healthcare

services,

education

to

tech

competences, and financial services. These benefits contribute

to the socio-economic development of regions and empower

populations that are remote from infrastructure, including by

supporting professional integration.

Orange’s business model is built on connectivity and the

inclusion it enables. Its strategy leverages leadership in network

deployment to generate value, promote digital inclusion,

particularly through its “We Care for People” pillar and empower

people through digital technologies.

Psychological health of end users

Negative impact on psychological health of end-users

Orange has identified a potential impact in the short, medium,

and long term on the psychological health of its users, particularly

children, in cases of excessive or inappropriate use of online

products or services. Such use may lead to screen addiction,

resulting in attention issues and cognitive delegation, and may

expose users, especially children, considered a vulnerable

population, to inappropriate content. Consequently, within the

value chain, this impact concerns primarily the downstream

segment.

Orange’s services, while central to digital connectivity, may have

negative health impacts on customers, notably regarding digital

dependence and cognitive issues. The main impacts identified

on

children’s

psychological

health

include

access

to

inappropriate content, hyper-connection and screen addiction,

misuse of personal data and advertising, online harassment by

peers, the presence of cyber-predators, and exposure to cyber-

attacks or fraud. The company’s provision of continuous internet

and mobile services facilitates constant access to digital content,

which can increase screen time and lead to potential digital

addiction, particularly among younger users who may be more

susceptible to overuse. Orange’s activities contribute to this

impact through its service provision, expanding network access,

developing content (either directly or with content providers),

creating apps and digital services integrated into daily life, and

through marketing and customer engagement.

111

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112

To address these risks, Orange has implemented a policy of

responsible digital use for children for several years, structured

around three components:

•

P

r

o

v

i

d

i

n

g

c

h

i

l

d

r

e

n

w

i

t

h

a

s

e

c

u

r

e

d

i

g

i

t

a

l

e

n

v

i

r

o

n

m

e

n

t

through parental control on household screens,

enabling the control of time slots and access to age-

inappropriate content, and informing households and

caregivers about online risks via country websites.

•

O

f

e

r

i

n

g

o

n

l

i

n

e

r

e

s

o

u

r

c

e

s

, in partnership with relevant

stakeholders, which help parents and caregivers

understand digital risks for children, access tools and

advice for protection, and obtain external assistance or

support services dedicated to children and parents.

•

T

r

a

i

n

i

n

g

p

a

r

e

n

t

s

,

f

a

m

i

l

i

e

s

,

a

n

d

c

h

i

l

d

r

e

n

in good

practices to ensure safe, autonomous, and responsible

digital use. Orange also organises activities for children

to help them critically assess online content (e.g., fake

news, the role of algorithms in social networks),

become autonomous and skilled in digital tools (e.g.,

coding), and understand the environmental impact of

their equipment and digital practices.

Orange’s strategy, particularly through the launch of

For Good

Connections

, designs service offerings tailored to users’ needs,

including parental-control tools, public guides on responsible

digital use, and awareness-raising and training initiatives.

Data privacy and cybersecurity

Negative impact on customers’ privacy in case of

cybersecurity issues

Orange’s activities can have a negative impact on customers’

privacy and economic situation in the event of cybersecurity

incidents or breaches of personal data that lead to misuse. Data

security, cybersecurity, and the protection of personal data and

privacy are among the most important issues for Orange, given

that the company’s business model relies on the transmission of

customer information while preserving the integrity and

confidentiality of correspondence.

Orange’s operations involve transmitting personal data over its

networks and storing it on its infrastructures, both for customers

and the general public. In case of data breaches, data owners

could suffer loss, including from malicious acts such as

cyberattacks. Orange’s responsibility extends to all data

entrusted to it by employees, customers, and, as an essential

infrastructure provider, the broader population. The negative

impacts of data loss or disclosure include infringements on

privacy, potential effects on business operations, and the risk of

ransom demands.

Orange is committed to fostering a trusted digital society and

aims to be a leader in cybersecurity and a key player in digital

trust. To support this, the company is developing Orange

Cybersecurity, reaffirming its policies for protecting personal

data, promoting the ethical use of artificial intelligence (AI) and

data through its ethical charter, and raising awareness of

responsible digital practices.

At the core of its operations, Orange’s business relies on

transmitting information on behalf of its customers while ensuring

the integrity and secrecy of that correspondence.

Reputational, financial and operational risk stemming

from

cybersecurity

and

data

privacy

breaches

affecting Orange end users and own workforce

Orange’s activities involve transmitting and storing the personal

data of customers, employees, and the general public across its

networks and infrastructures. Despite measures to protect its

infrastructure, these activities expose Orange to risks of loss,

unauthorised disclosure, inappropriate modification, or improper

communication of personal data, particularly when introducing or

updating services and applications. The deployment of new

technologies, increased use of cloud services, outsourcing of

digital services, and development of new activities, such as

connected objects, can heighten these risks.

Potential causes of data breaches include malicious acts (e.g.,

cyberattacks), errors or negligence by Orange or its partners, and

government requests that do not comply with legal or regulatory

requirements. When these risks materialise, individuals whose

data is disclosed or modified could suffer loss and Orange’s

reputation

could

be

significantly

affected.

Financial

consequences may include fines of up to 4% of turnover under

regulations such as the EU General Data Protection Regulation

(GDPR, 2016/679).

Orange recognises its responsibility in safeguarding personal

data and contributing to a trusted digital environment. The

company pursues this through the development of cybersecurity

solutions, a reaffirmed policy on data protection, promotion of

ethical use of AI and data via an ethical charter, and initiatives to

raise awareness of responsible digital practices.

Opportunity to develop cybersecurity offering

Orange has an opportunity to develop its cybersecurity offerings

and provide new technologies for data protection, generating

potential revenue across markets. Given the importance of

cybersecurity as a risk with significant potential impacts due to

Orange’s business model, the company leverages its expertise

and resources in securing its infrastructures and protecting

personal data to offer cybersecurity and trust services,

particularly to business clients.

Orange sees this as an opportunity to strengthen its

cybersecurity solutions and develop new technological assets.

The company is committed to promoting a trusted digital

environment, with the ambition of being a leader in cybersecurity

and digital trust. This includes developing Orange Cybersecurity

offerings, reaffirming its personal data protection policies,

promoting the ethical use of AI and data through its ethical

charter, and raising awareness of responsible digital practices.

112

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Annual report 2025

113

1.1.3.3.5

Overview of Orange’s material Impacts, Risks and Opportunities related to

governance

G

1

-

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

Financial and reputational risk in the event of corruption and regulatory

non-compliance with business ethics.

Risk



Short and

medium term

S

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r

s

’

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By strengthening its culture of ethics and compliance, Orange can earn the

trust of its partners throughout the value chain, differentiate itself, and

stimulate growth, while opening up new sustainability-related business

opportunities.

Opportunity



Medium term



New in 2025



Upstream value chain



Own operations



Downstream value chain

Business ethics and corporate culture

Financial and reputational risk in the event of

corruption/bribery and non-compliance with business

ethics regulations

Orange is exposed to financial and reputational risks in the event

of corruption/bribery or non-compliance with business ethics

regulations.

Breaches

of

business

ethics,

including

corruption/bribery by or involving employees, could result in the

loss of customers, suppliers, or business partners, as well as

financial sanctions.

Given that Orange’s business model is based on the marketing

of services and equipment, instances of corruption/bribery could

directly impact revenue. They could also undermine the

company’s strategic objectives, affecting its leadership in

network services, the quality of its offerings, and its socially

responsible business practices.

Hence, a whistleblowing system allows the report of conduct or

situations that go against the Group’s anti-corruption policy,

Code of Ethics, or policies and procedures relating to

accounting, internal control and auditing, that represent a clear

and serious violation of laws or regulations, or that seriously

infringe human rights and fundamental freedoms, the health and

safety of individuals or the environment.

Suppliers’ relationships management

Opportunity

to

establish

long-term,

trust-based

relationships with suppliers

Orange identifies an opportunity to establish long-term, trust-

based relationships with its suppliers. The company’s business

model relies in part on suppliers and partners, and building

relationships grounded in trust within a responsible contractual

framework supports operational stability and ethical practices.

Orange’s approach includes adherence to the United Nations

Global Compact principles on human rights, labour, the

environment, and anti-corruption, as well as supplier evaluations,

risk assessments, and on-site audits, both independently and

collaboratively with peers. By fostering a culture of ethics and

compliance, Orange can strengthen partner trust across its value

chain, enhance supply chain reliability, and open new

sustainability-related

business

opportunities.

Strategic

partnerships are prioritised to promote knowledge-sharing and

joint development initiative.

113

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Annual report 2025

114

1.1.4

Impact, risks and opportunities management

1.1.4.1

Description of the process to identify and assess material impacts, risks and

opportunities (IRO-1)

1.1.4.1.1

Double materiality methodology

Orange Belgium conducted in 2024 a comprehensive double

materiality analysis, rooted in the methodology established by

the Group and based on the European Financial Reporting

Advisory Group (EFRAG) guidelines, which is refined along the

years. As described in

section 1.1.3.2 Interests and views of

stakeholders (SBM-2)

, to ensure a correct understanding of

these impacts, risks and opportunities, Orange Belgium engaged

dialogues with a range of stakeholders, including authorities, civil

society representatives, business partners, clients, and internal

stakeholder groups.

Amongst the dialogues, Orange Group launched one with

stakeholders on "ESG by Design" or "How to transform Orange's

business model to become ESG By Design", which was also

launched by Orange Belgium. The dialogue consisted of three

key discussions: a part for scoring double materiality topics

(double

materiality

framework),

a

part

questioning

the

sustainability of topics regarding the company’s strategy and

business model, and a part on the solutions and changes Orange

should implement to become ESG by Design.

In 2025, the scoring of individual IROs was primarily based on

the 2024 input from Group IRO scoring system data.

.

114

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Annual report 2025

115

U

p

d

a

t

e

s

h

a

v

e

b

e

n

i

n

t

r

o

d

u

c

e

d

b

a

s

e

d

o

n

i

n

f

o

r

m

a

t

i

o

n

b

e

l

o

w

to

identify, assess, and manage material impacts, risks, and

opportunities:

•

2025 contextual changes (e.g., evolution of the scope

of legal entities, major events, etc.);

•

2025 corporate risk mapping: Orange Belgium’s

existing corporate risk mapping acted as a foundational

input for evaluating the probability and magnitude of

risks, supporting a comprehensive review of financial

materiality;

•

2025

negative

impacts

from

duty

of

vigilance

supporting the review of the impact materiality;

•

Group and local sectorial benchmark on IRO’s

(comparative data from sector-specific references,

such as Sustainability Accounting Standards Board

(SASB), Morgan Stanley Capital International Index

(MSCI), United Nations Environment Programme

Finance Initiative (UNEP-FI), and the not-for-profit

organisation

for

Exploring

Natural

Capital

Opportunities, Risks and Exposure (ENCORE), were

used to supplement and validate the analysis. These

benchmarks provided external context to enhance the

assessment of impacts and ensure alignment with

industry standards.

To ensure the relevance and accuracy of updates, targeted

dialogues were held with the risk department, HR teams, and

other internal topic-specific referents. As a result, a simplification

was performed, leading to the splitting or regrouping of some

items for the sake of clarity. No entity-specific IRO has been

identified as they could all be linked to topics and sub-topics of

the ESRS.

The highest IRO’s notes define the topic materiality, except when

topic was not material in 2024. In such case, the 2024 topic-level

notation

remained

the

same.

Orange

Communications

Luxembourg inputs were included in the analysis of 2025 material

IRO's identified.

This methodology supports the company’s approach to identify

and assess its sustainability impacts, risks and opportunities

aligning with regulatory expectations and best practices in

corporate sustainability reporting. The management of impacts

and risks is integrated in Orange risk management process

through its corporate risk mapping and its duty of vigilance

impact mapping, covering a screening of all its assets and

activities in own operations and upstream and downstream value

chain. IROs have also been integrated in Orange Belgium ESG

strategic plan exercise.

Orange has not conducted any different methodology or

consultation related to resources use and circular economy from

those already described in this section and in section

1.1.3.2

Interests and views of stakeholders (SBM-2)

.

1.1.4.1.2

Impact materiality process

Impact materiality focuses on Orange’s impact severity, which is

assessed through the scale, scope and irremediable character of

its effects on the environment and society. These are thoroughly

reviewed at least once a year in collaboration with HR

department, the chief compliance officer, purchasing and the

health and safety managers, who are consulted to inform on

alerts raised and inform impacts identification. In the duty of

vigilance, ESG-related topics covered are labelled as “serious

violation of human rights or fundamental freedoms, human health

and safety, and damage to the environment/climate”. In 2025, a

new methodology has been defined by Orange Group to align

impact analysis of the vigilance plan with CSRD and ESRS

impact analysis method. This method has been improved and will

be fully implemented in order to prepare the 2026 statement.

Risks of adverse impacts associated with the Group's operations

across various geographies were deemed immaterial in Belgium

and Luxembourg, which share very local and similar realities,

leading

to

differences

from

the

Group-wide

materiality

assessment. Industry-specific factors relevant to Orange's local

operations were assessed by comparing its materiality results

with those of local peers.

Orange Belgium, as subsidiary of the Orange Group, must deploy

all the regulatory mechanisms included in the French law on duty

of vigilance. Therefore, Orange Belgium considers impacts which

are linked to own operations or result from business

relationships.

Orange’s process prioritises impacts based on their relative

severity and likelihood. A first selection of material topics was

based on the scores obtained during stakeholder’s dialogues,

where double materiality topics were scored on both dimensions,

i.e. impact materiality and financial materiality along the value

chain. Impacts, both positive and negative ones, were scored

considering their scale, their scope and their remediability,

considering also the part of the value chain concerned by the

impact. Trends were also analysed to give a perspective of time

by reflecting how the topics have evolved recently.

1.1.4.1.3

Financial materiality process

Financial materiality considers how risks and opportunities could

influence the undertaking’s financial performance and is

assessed based on the magnitude of the financial effects posed

by various sustainability topics and their likelihood. The nature of

identified sustainability risks and opportunities has been defined

during workshops and further enriched by feedback from

external stakeholders’ consultations. Then, the likelihood and

magnitude of risks are aligned with Orange's corporate risk

mapping by taking the score of the risk cluster that best

represents the specific impact described.

Orange Belgium corporate risk map process provides a

foundation for identifying, assessing and prioritising r

r

i

s

k

s

and

their financial effects. As sustainability related risks have been

integrated within the corporate risk map, they follow the same

risk assessment methodology. Sustainability related risks include

climate change, health and safety, information security &

cybersecurity, non-compliance with ESG laws and regulations,

corruption, and ethical breaches.

O

p

o

r

t

u

n

i

t

i

e

s

are identified through a stakeholder dialogue and

are based on Orange Group materiality analysis. To strengthen

115

Orange Belgium

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Annual report 2025

116

the analysis of opportunities, a benchmark is performed against

Orange Group analysis and sectorial standards such as SASB,

MSCI, UNEP-FI, and ENCORE. These benchmarks were

assumed to provide reliable, sector-specific insights that were

crucial for refining IRO scores.

Connection between impacts and dependencies with risks were

considered when aligning impact and risks identified with duty of

vigilance and corporate risk map. Opportunities will gradually be

integrated in this process.

1.1.4.1.4

Climate impacts, risks and opportunities process

The process for the evaluation of climate-related IROs is the

same as the one described above.

Analysis of physical risks

In 2023, Orange launched a project in conjunction with a

specialised firm with climate expertise and equipped with an

analysis tool to estimate change scenarios per main climatic

hazards in the countries where the Group operates and to

accurately

qualify

the

exposure

of

the

Group's

main

infrastructures to each of these hazards. The c

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t

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c

h

a

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a

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d

s

e

l

e

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t

e

d

relate to the four areas of study recommended in the

ESRS: temperature (including heat stress, heat wave, forest fire),

wind (tropical cyclone, extratropical storm), water (including

coastal/river/surface flooding, snow, frost), soil structure

(including landslide, subsidence). The assessment enabled the

establishment of a risk index based on each of these specific

hazards for each site. Additional indicators enable the analysis to

be refined a

a

c

o

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d

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n

g

t

o

l

o

c

a

l

c

o

n

d

i

t

i

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n

s

(e.g. hydric stress,

drought) or changes in the relevance of available models (e.g.

clay shrinkage and swelling not available in all regions). To carry

out the analyses, three Intergovernmental Panel on Climate

Change

(IPCC)

scenarios

were

selected,

including

the

pessimistic scenario SSP5 8.5, and t

t

h

r

e

t

i

m

e

f

r

a

m

e

s

:

2

0

3

0

,

2

0

4

0

a

n

d

2

0

5

0

. Orange thus has a vision of the climate risks and

impacts over the short, medium and long term.

Climate analyses consider two complementary approaches:

•

A detailed site-by-site approach f

f

o

r

t

h

e

m

a

i

n

‘

s

t

r

a

t

e

g

i

c

’

s

i

t

e

s

(as defined in the Group's physical security

policy), based on the detailed reports indicated above;

•

A geographical approach b

b

a

s

e

d

o

n

c

l

i

m

a

t

e

m

a

p

s

,

allowing for a more comprehensive approach by

superimposing all assets in a given area. Beyond

assessing exposure, this approach is useful for

understanding the risks specific to future locations.

These analyses make it possible to measure risks for each of the

relevant hazards over three time-horizons, and to deduce

potential vulnerabilities of sites and infrastructures. These results

inform Orange risk matrix and thereby are directly i

i

n

t

e

g

r

a

t

e

d

i

n

t

h

e

d

o

u

b

l

e

m

a

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e

r

i

a

l

i

t

y

a

s

e

s

m

e

n

t

.

Following an initial pilot, the tool is gradually being rolled out

across the Group's entities. The exposure of most of Orange

Belgium’s critical sites’ to climate change was assessed in 2024.

In 2025, this exposure analysis has been extended to the critical

assets of the former entity VOO and of Orange Communications

Luxembourg.

The link between the impact identified for the different horizons

and the residual useful life of assets and the capital allocation

plan will be established later in 2026. To complement its short-

term analysis, Orange considers frequent and probable

contingencies in the management of its operations.

As part of its continuous improvement process, Orange is

d

e

v

e

l

o

p

i

n

g

a

c

l

i

m

a

t

e

c

h

a

n

g

e

a

d

a

p

t

a

t

i

o

n

p

l

a

n

aimed at

strengthening the resilience of its infrastructure and organisation.

The results of these first analysis on Orange assets and business

activities sensitive to climate-related hazards are being

progressively integrated in an adaptation plan at Group level.

Where deemed necessary, Orange is gradually drawing up

adaptation plans to c

c

o

u

n

t

e

r

p

h

y

s

i

c

a

l

r

i

s

k

s

b

y

r

e

i

n

f

o

r

c

i

n

g

i

n

f

r

a

s

t

r

u

c

t

u

r

e

s

and/or s

s

e

r

v

i

c

e

r

e

s

t

o

r

a

t

i

o

n

p

r

o

c

e

d

u

r

e

s

.

The analysis of vulnerabilities to specific assets and business

activities of past climate events and future expected events

based

on

different

climate

scenarios

will

provide

an

understanding of the financial implications, in terms of both repair

costs and investment.

Analysis of transition risks

Orange has started to assess how its activities are exposed to

transition risks, thereby creating gross transition opportunities or

risks following the methodology presented in this section under

the title

1.1.4.1.3 Financial materiality process

. However, the

process of identifying transition risks and opportunities did not

include a climate scenario limiting global warming to 1.5°C over

the short, medium and long-term.

To manage transition risks, Orange has set itself the priority of

meeting its GHG reduction targets as part of its environmental

strategy. In addition, Orange is developing a responsible

purchasing policy and seeking to secure its supply chains.

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117

1.1.4.1.5

Decision-making processes and integration in corporate risk management and

internal control procedures

As described in section

1.1.2 Governance

, periodic reporting are

in place to involve these supervisory bodies in strategic decisions

and for further integration in risk management and internal

control procedures.

When material IROs are re-assessed, the related policies, action

plans and targets for each material topic are reviewed

accordingly. This review helps clarify the residual risks and

impacts, as well as the actions still required to address them and

to update the continuous improvement roadmap. Where this

leads to the identification of new risk types to be integrated into

the risk management framework, or to the need for updates to

internal

control

procedures,

the

relevant

managers

are

responsible for implementing these changes within their

respective scopes of responsibility.

As reminder from

section 1.1.2.1.2 Roles and responsibilities of

the administrative, management and supervisory bodies

, bodies’

and individuals’ responsibilities regarding IRO’s are reflected in

the Orange Belgium Internal Audit, Internal Control and Risk

Management Charter.

•

Regarding risks, the internal control system, led by

management, ensures the achievement of operational,

reporting,

legal,

and

strategic

objectives

while

managing risks. Risks are identified, assessed, and

addressed through acceptance, mitigation, transfer, or

elimination strategies, with the risk culture promoted

across the organisation. Roles and responsibilities are

clarified and coordination with stakeholders and

auditors ensures effective oversight.

•

The duty of vigilance provides the overarching

framework for this oversight, ensuring that impacts are

controlled and managed proactively.

•

Opportunities are systematically analysed, particularly

in relation to risks and impacts identified within the

CSRD framework. Nevertheless, a formal process to

identify, assess and manage opportunity has to be

improved to reach the same maturity as the impacts

and risks assessment.

Governance mechanisms are implemented to ensure continuous

oversight, enabling management to make informed decisions

and uphold accountability in managing sustainability and

operational risks.

Orange Communications Luxembourg's local ESG and Audit,

Control and Risk teams are responsible for IROs operational

monitoring and management. It is then the Orange Belgium

management bodies responsible for overseeing these IRO's.

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118

2.

Environmental information

2.1

Climate Change (E1)

2.1.1.

Environmental strategy

2.1.1.1

Transition plan for climate change mitigation (E1-1)

Orange Group has adopted a proactive approach to manage

environmental risks and impacts in a context of strong growth in

digital usage. This proactive management consists of a

comprehensive t

t

r

a

n

s

i

t

i

o

n

p

l

a

n

6

based on two pillars: mitigation

and adaptation.

•

The company has implemented a m

m

i

t

i

g

a

t

i

o

n

s

t

r

a

t

e

g

y

aimed at reducing its greenhouse gas (GHG) emissions

across its entire value chain (covering emissions of

scopes 1, 2 and 3), with a Net Zero Carbon target by

2040.

•

At the same time, a climate change a

a

d

a

p

t

a

t

i

o

n

s

t

r

a

t

e

g

y

aims to strengthen the resilience of its infrastructure and

organisation (see infra in section

2.1.3 Management of

impacts, risks and opportunities related to climate

change adaptation

for more details).

This transition plan is aligned with the Paris Agreement and the

c

a

r

b

o

n

t

r

a

j

e

c

t

o

r

i

e

s

established by the Intergovernmental Panel on

Climate Change (IPCC). It includes three scenarios depending on

whether or not the average temperature increase is limited to +1.5

°C, and three-time horizons: 2030, 2040 and 2050.

The transition plan is broken down into a g

g

o

v

e

r

n

a

n

c

e

with

integration into the company's strategic plan and aligned with

financial planning; an environmental and energy p

p

o

l

i

c

y

; annual

t

a

r

g

e

t

s

and monitoring throughout the period validated by the

Science-Based Targets initiative (SBTi); and a

a

n

a

c

t

i

o

n

p

l

a

n

and

resources at group level. So, as such combined together with the

strategic plan, this transition plan enters in a regular approval

process by administrative, management and supervisory bodies.

Efforts to reduce to the Group’s carbon footprint are based around

two main areas of action, in order to reach the digital sector target

of “Net Zero Carbon by 2040”: r

r

e

d

u

c

i

n

g

t

h

e

v

o

l

u

m

e

o

f

s

e

r

v

i

c

e

s

u

s

e

d

by Orange to perform its activities (energy, equipment,

services) and r

r

e

d

u

c

i

n

g

t

h

e

c

a

r

b

o

n

i

n

t

e

n

s

i

t

y

o

f

i

t

s

p

r

o

d

u

c

t

s

a

n

d

s

e

r

v

i

c

e

s

all throughout the value chain (suppliers, sub-

contractors, customer uses).

In addition, considering the activities performed by the company,

Orange is not excluded from the EU Paris-aligned benchmarks.

6

Orange Group Climate Transition plan can be found here:

https://mastermedia.dam-broadcast.com/medias/domain12751/media101611/483387-gqohn4qd8t-75.pdf

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Mitigation of GHG emissions

The company has modelled the impact of its activities, including

energy consumption, supplier engagement, and equipment

circularity, to define its decarbonisation actions.

The strategy is based on controlling emissions by reducing

energy consumption, increasing the use of renewable energies,

engaging suppliers, and developing circular economy models.

The decarbonisation of the electricity mix in its various

geographical areas of activity also contributes to an additional

reduction.

Orange Group plans

•

to reduce its GHG emissions by 33% by 2030

compared to 2020 with part of this reduction already

achieved (reduction of24% at the end of 2025) and

actions underway;

•

and

to

reach

-45%

by

2030

with

additional

decarbonisation opportunities that are being identified

and quantified in terms of financial, GHG and

operational impacts in order to inform the decision on

whether or not to implement them. This initiative is

collectively referred to as the 'Nursery' programme.

The Orange Group divisions that contribute most to GHG

emissions (France, as well as the other European countries

including

Orange

Belgium

and

Orange

Communications

Luxembourg, Africa and the Middle East, Orange Business,

Orange Wholesale) have each been given specific GHG emission

targets for 2026 as part of the expected budget and for 2030 as

part of the strategic plan, along with their financial targets for

these periods. These targets for each division, once consolidated

all together, reflect the above detailed modelled figures.

The Group defines the climate-transition plan at Orange SA level.

Its alignment with overall business strategy and financial planning

is therefore assessed and steered by the Group. The company

applies this framework in its own planning processes, ensuring

that strategic decisions and investments remain consistent with

the Group’s climate targets and long-term priorities.

Orange Belgium and Orange Communications Luxembourg are

committed to supporting the Group in achieving its emissions

reduction targets through a comprehensive sustainability

strategy (see also infra section

2.1.2 Management of impacts,

risks and opportunities related to climate change mitigation and

energy

for more details about derived policies, actions, targets,

and metrics).

Beyond 2030

•

Several actions will continue beyond 2030 and enable

further progress to be made. New actions will need to

be identified through the Nursery programme, but also

potentially through sectoral pooling initiatives that are

yet to be identified and implemented. The ambition is

to reach a 90% reduction in emissions in 2040 as

compared to 2020.

•

It is also foreseeable that by 2040 there will be an

unavoidable level of residual emissions (currently

targeted at 10%) for which offsets will be necessary via

carbon sink storage.

To date, Orange Group has not carried-out a formal analysis of

its locked-in emissions.

In

recent

years,

there

has

been

an

increase

in

telecommunications usage driven by Artificial Intelligence (AI),

fibre and 5G deployment, as well as the increase of streaming

services. This surge has led to higher data traffic, greater

demands on network infrastructure, and increased energy

consumption in mobile and fixed network to absorb traffic

increase and at data centres for processing and cooling. As

demand for these services continues to rise, the energy

consumption of the network and data centres increase as well,

which in turn indirectly increases the energy-related emissions

associated with telecommunications operations. To mitigate this

risk, Orange Group deploys efforts to decarbonise the energy use

of its mobile and fixed network and data centres and adopts

more energy efficient technology.

Explanation on the current progress of the implementation of the

transition plan can be found in the action plans described in

section

2.1.2.6 Taking actions on climate change mitigation and

energy (E1-3)

below.

2.1.2

Management of impacts, risks and opportunities related to

climate change mitigation and energy

2.1.2.1

Policies related to climate change mitigation and energy (E1-2)

At Orange Belgium, the commitment to the planet is at the heart

of its strategic vision, "Lead the Future”. Orange recognises the

urgent need to address climate change and is dedicated to

making a meaningful impact following the Group environmental

policies. To implement its transition plan and mitigation strategy,

the Group published t

t

h

e

n

v

i

r

o

n

m

e

n

t

a

n

d

e

n

e

r

g

y

p

o

l

i

c

y

,

and

t

h

e

p

u

r

c

h

a

s

i

n

g

p

o

l

i

c

y

(internal document only) as described below,

as well as guidelines that apply to all Orange entities to manage

their GHG emissions, and energy efficiency.

7

The Group Environment and Energy Policy:

https://mastermedia.dam-broadcast.com/medias/domain12751/media101367/410206-099fde5djo-75.pdf

Environment and energy policy

The Orange Group environment and energy policy, which is

published on its website

7

, reflects the Group’s commitment to

play its part in the fight against climate change under the Paris

Agreement on climate change. With this policy, Orange Group

aims to implement its above explained mitigation strategy and

achieve Net Zero emissions by 2040 through programmes to

reduce scope 1, 2 and 3 GHG emissions by tackling volumes

(energy, equipment, services) and the carbon intensity of those

119

Orange Belgium

_

Annual report 2025

120

volumes (decarbonisation of energy supply, equipment, circular

economy). Residual emissions of the Group will be offset by 2040

by sequestration in natural carbon sinks

This policy applies to all of Orange’s activities. It is implemented

in all the geographical regions where the Group operates and is

adapted to the regions’ specific characteristics. It targets

employees,

customers,

suppliers,

partners,

industry

organisations and local communities. The policy can be broken

down into three sets of operational guidelines. Orange has

shared these guidelines with the relevant entities, outlining the

goals, challenges and selection criteria, as well as how to

account for carbon credits from these projects.

•

G

u

i

d

e

l

i

n

e

s

f

o

r

t

h

e

n

e

r

g

y

c

o

m

p

o

n

e

n

t

:

In addition to the

environment and energy policy, Orange Group shares

its guidelines on energy purchases with all its telecom

operator entities in the Europe region. These guidelines,

which

are

regularly

updated

to

account

for

developments in the electricity market, define the

electricity purchasing policy regarding the twofold

challenge of controlling costs and decarbonising the

Group’s electricity consumption, under the supervision

of the Group Energy Sourcing Committee.

•

G

u

i

d

e

l

i

n

e

s

f

o

r

t

h

e

p

r

i

n

c

i

p

l

e

s

r

e

g

a

r

d

i

n

g

“

e

n

v

i

r

o

n

m

e

n

t

a

l

c

l

a

i

m

s

”

:

Orange Group seeks to continuously improve

the environmental performance of its products and

services in line with its environmental targets, and to

report on that performance in a fair, transparent and

open manner. At the end of 2023, Orange defined

seven principles for environmental claims, aimed at the

Group’s marketing and communication communities.

The principles are designed to enhance the value

proposition of the Group’s products and services, while

avoiding the reputational, legal and judicial risks related

to greenwashing. They aim to improve the consistency

of environmental communication across all entities. The

principles provide the marketing and communication

communities

with

a

clear,

practical

guide

to

understanding and complying with the regulations and

the Group’s commitments. The communication and

legal business lines were involved in drafting these

principles and are tasked with monitoring them.

•

A

Group

a

n

t

i

-

g

r

e

n

w

a

s

h

i

n

g

C

o

m

i

t

e

was

established in early 2025 to ensure compliance with

Orange's principles on environmental claims across all

entities. It also ensures that these principles are

regularly updated in line with changes in regulations

and the Group's commitments. This Committee,

composed

of

representatives

from

the

communications, legal and CSR departments, as well

as from the various divisions (France, Europe, Africa

and the Middle East, and Orange Business), meets on

an ad hoc basis as needed and formally at least twice

a year.

•

G

u

i

d

e

l

i

n

e

s

f

o

r

t

h

e

c

a

r

b

o

n

s

i

n

k

c

o

m

p

o

n

e

n

t

:

These

guidelines detail Orange Group commitment to finance

natural projects that, beyond carbon sequestration,

offer

co

‑

benefits

for

biodiversity

and

the

socio

‑

economic development of local communities.

The financing of the funds and projects that will help

generate carbon credits has been approved by the

Group Investment Committee.

The Group’s environmental objectives are set out in a letter of

commitment signed by the Executive Director of Corporate

Social Responsibility and the Executive Director of the division.

The Group Environmental Strategy Committee makes the

decisions required to effectively implement these guidelines for

the Group. As an integral part of the budget and strategic plan

processes, they are monitored by the Group’s Executive

Committee, under the control of the Group Audit Committee, the

Internal control of CSR and the Group Board of Directors.

The Environment and energy policy applies to the Group and its

affiliates including Orange Belgium and Orange Communications

Luxembourg.

At

Orange

Belgium,

the

Chief

Brand,

Communication & ESG Officer leads the commitment, supported

by the entire executive committee. At Orange Communications

Luxembourg, the Head of Communications and ESG leads the

commitment.

In defining the policy, the following s

s

t

a

k

e

h

o

l

d

e

r

s

were considered

at Group level:

•

S

u

p

l

i

e

r

s

: The policy recognises the need for suppliers

to adopt more sustainable practices and recognises

their role in the supply chain. Further information on the

suppliers’ Code of conduct can be found under chapter

4.1 Business Conduct (G1)

.

•

C

u

s

t

o

m

e

r

s

: Customers’ interests are prioritised by

ensuring product reliability and transparency in

sourcing. Feedback from customers is actively sought

to

understand

their

expectations

regarding

sustainability and resource management.

•

R

e

g

u

l

a

t

o

r

s

: The policy is aligned with regulatory

standards and reflects the importance of compliance

and

ethical

sourcing.

Orange

actively

monitors

regulatory developments and works with regulators to

ensure that its practices meet or exceed legal

requirements.

•

I

n

d

u

s

t

r

y

P

a

r

t

n

e

r

s

: Collaboration with industry partners

is essential in fostering recycling and substitution

strategies. Orange Group consults with these partners

to share best practices and develop innovative

solutions to tackle resource depletion together.

•

I

n

t

e

r

n

a

l

T

e

a

m

s

: The interests of internal teams are

considered by involving senior managers and aligning

policies

with

sustainability

objectives.

Regular

consultation and discussion with internal stakeholders

ensure that policies reflect the company’s values and

objectives.

Orange Group and its subsidiaries interact with these

stakeholders, including electricity distribution companies, when

drawing up prevention or repair plans. This engagement helps to

ensure that the policies developed are practical and effective in

addressing the environmental impacts associated with energy

consumption and waste.

Policies are published on its official website, making them

accessible to the public and ensuring that all potentially affected

stakeholders, including customers, suppliers, and community

organisations, can review them. Regular c

c

o

m

u

n

i

c

a

t

i

o

n

through

newsletters, reports, and updates, highlights key policy elements

and any modifications, keeping stakeholders informed about the

company’s commitments and progress.

120

Orange Belgium

_

Annual report 2025

121

Orange

Group

also

prioritises

capacity-building

among

stakeholders

involved

in

policy

implementation.

T

r

a

i

n

i

n

g

sessions and w

w

o

r

k

s

h

o

p

s

are organised for suppliers and

employees, providing them with detailed information about the

policies, their objectives, and the roles they play in achieving

desired outcomes. F

F

e

d

b

a

c

k

mechanisms, such as surveys,

direct communication channels, and stakeholder meetings,

ensure that concerns and suggestions are heard and addressed,

fostering a culture of continuous improvement.

Group purchasing policy

The Group purchasing policy is an internal document that takes

account of the issues of environmental transformation and

incorporates the decarbonisation of activities into its missions,

with a section titled “Contributing to the implementation of

Orange’s social and environmental commitments”. This section

requires that environmental criteria be incorporated upstream

into purchasing and procurement decisions, and that the

relevance of the purchase be questioned by considering

alternatives (internal solution, reuse, use of refurbished

equipment, etc.) and, in the case of energy, by increasing

purchases of decarbonised and renewable energy. Further

information on this policy can be found in section

4.1.2.2

Management of relationships with suppliers, building trust and

secure responsible supply (G1-2)

.

2.1.2.2

Targets related to climate change mitigation and energy (E1-4)

Orange Group has made the commitment to become N

N

e

t

Z

e

r

o

C

a

r

b

o

n

i

n

t

h

e

d

i

g

i

t

a

l

s

e

c

t

o

r

b

y

2

0

4

0

a

n

d

has set an interim target

reducing GHG emissions in a

a

l

t

h

r

e

s

c

o

p

e

s

b

y

4

5

%

i

n

2

0

3

0

compared with the 2020 level. These relative targets are based

on absolute figures (in kt

C

O

2

eq) and reflected in above carbon

trajectory (see section

2.1.1.1 Transition plan for climate change

mitigation (E1-1)

). Orange Belgium and Orange Communications

Luxembourg contribute to this goal but have not defined entity-

specific targets.

These targets were developed i

i

n

l

i

n

e

w

i

t

h

i

n

t

e

r

n

a

t

i

o

n

a

l

s

e

c

t

o

r

a

l

m

e

t

h

o

d

o

l

o

g

y

for digital technology: estimates of the global

climate

impact

of

the

Information

and

Communication

Technology sector are based on work carried out by the

International Telecommunication Union (ITU), in conjunction with

the Science-Based Targets Initiative (SBTi), GSM Association

(GSMA), Global e-Sustainability Initiative (GeSI) and the

International Energy Agency (IEA), to which Orange Group has

contributed. This work has resulted in the publication of a

document that sets out the GHG emission reduction trajectories

to be followed by the sector to align with scientific

recommendations and keep the temperature rise to +1.5°C

compared to pre-industrial levels. Orange's objectives are also in

line with national climate policies, supporting the use of

renewable energy, implementing circular economy practices,

demonstrating social responsibility, engaging with stakeholders,

and

ensuring

transparency

and

accountability

through

monitoring mechanisms.

Orange Group is not only committed to reducing its own GHG

emissions, but also indirect ones related to its electricity

consumption and those generated upstream by its suppliers and

downstream by its customers, and to sequestering residual

emissions by financing carbon sink projects. The Group targets

are based on reducing the gross GHG emissions. Therefore, they

must be achieved with effective emissions reduction in priority,

without considering negative emissions from carbon sink

projects. These will only take into account the calculation of net

emissions (for a quantity not representing more than 10% of total

gross emissions in the reference year).

Regarding the critical assumptions for setting GHG emission

reduction targets, Orange Group has considered future

developments such as changes in sales volumes, shifts in

customer preferences and demand, regulatory factors, and new

technologies. These elements are integrated into the modelling

of GHG emissions and reductions, allowing the Group to

anticipate potential impacts on its emissions and adjust its

strategies accordingly.

121

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_

Annual report 2025

122

On top of alignment with the various specialised international

actors and initiatives involved to define this target, i

i

n

t

e

r

n

a

l

s

t

a

k

e

h

o

l

d

e

r

s

within Orange Belgium have been consulted to

gather insights on their expectations and needs regarding energy

consumption and thus scope 1 and 2 emissions and challenge

the feasibility of the emissions reduction ambition. Forecasts are

based on several assumptions. For instance, consumption

estimates were based on analyses of current trends and growth

forecasts, considering stakeholder feedback on technical

advancements and requirements and planned activities aligned

with the strategy. The results of consultations and the

methodologies used to establish consumption forecasts are

shared with all involved stakeholders, ensuring transparency and

feedback consideration in the target-setting process. All the

communicated views are based on current known information

and will need to be reviewed year by year. Thus, Orange Group

actively engages with stakeholders and experts to ensure their

targets are informed by the latest research and best practices.

Here is a summary of the performance against the disclosed

targets:

•

At Orange Belgium, scope 1 emissions mainly come

from its vehicle fleet, accounting for about 80% of

scope 1 emissions. The electrification of the fleet and

the installation of charging stations for electric vehicles

are underway, supported by exclusively electric orders

for all new vehicles. Orange Belgium plans to electrify

84% of its fleet by 2030, with the remaining 16% being

technical vehicles for which a feasibility study still

needs to assess risks and opportunities without

impacting the quality of service.

•

Scope 2 emissions, covering indirect emissions from

purchased electricity, purchased heating from other if

any, and from cooling, have been entirely sourced from

renewable energy for several years in Orange Belgium.

Orange Communications Luxembourg strives to collect

information and collaborate with property owners to

transition remaining technical sites to renewable

energy. In addition, energy efficiency initiatives, such as

deploying smart meters and decommissioning obsolete

sites, are underway. Orange Belgium is also investing

in solar panels on RAN, core sites and facilities.

•

Scope 3 emissions, encompassing other indirect

emissions throughout the value chain, represent the

greatest challenge. Orange Belgium focuses its efforts

on

reducing

upstream

emissions

by

rigorously

selecting suppliers based on sustainability criteria and

adopting circular practices, particularly for IT and

telecom equipment (including CPEs). The Orange

Sustainable & Circular Ambition for Recertification

(OSCAR) programme, dedicated to IT and telecom

assets, and the RE programme, focused on mobile and

fixed devices, play a key role in addressing the impact

linked to these products.

Orange Belgium has identified a first indicative list of

k

e

y

d

e

c

a

r

b

o

n

i

s

a

t

i

o

n

l

e

v

e

r

s

l

o

w

e

r

i

n

g

v

o

l

u

m

e

s

a

n

d

i

n

t

e

n

s

i

t

y

that are

expected to contribute quantitatively to achieving its greenhouse

gas (GHG) emission reduction targets. These levers include:

1.

U

s

e

o

f

r

e

n

e

w

a

b

l

e

n

e

r

g

y

: The company is committed

to increasing its use of renewable energy sources. As

of 2023, Orange Belgium covered 100% of its

electricity consumption with renewable energy backed

by Guarantee of Origin (GOs) from producers. It is also

a goal to balance more and more with green Power

Purchase Agreements (PPAs) and the installation of

solar panels at its sites. Orange Communications

Luxembourg aims to procure entirely renewable

electricity by 2030.

2.

E

n

e

r

g

y

e

f

i

c

i

e

n

c

y

i

m

p

r

o

v

e

m

e

n

t

s

: Energy efficiency

initiatives are being implemented to reduce overall

energy consumption, including adopting efficient

technologies, deploying energy management systems,

and optimising energy use in buildings and operations.

These initiatives are implemented across its operations,

particularly in its networks and IT systems. This

includes optimising the energy consumption of mobile

access networks (RAN) through advanced energy-

saving

features,

modernising

equipment,

and

enhancing the efficiency of data centres. These actions

are projected to reduce energy consumption and

associated emissions.

3.

M

a

t

e

r

i

a

l

e

f

i

c

i

e

n

c

y

w

i

t

h

s

u

p

l

i

e

r

s

a

n

d

c

o

n

s

u

m

p

t

i

o

n

r

e

d

u

c

t

i

o

n

w

i

t

h

c

u

s

t

o

m

e

r

s

: Orange Group is focusing on

reducing material consumption and improving the

efficiency of its resource use. This includes optimising

supply chain processes and encouraging responsible

consumption among customers, notably through the

deployment of customer premises equipment (CPEs)

designed to reduce energy consumption and integrate

eco-design principles, which can lead to lower

emissions across the value chain.

4.

C

i

r

c

u

l

a

r

e

c

o

n

o

m

y

p

r

a

c

t

i

c

e

s

:

The

company

is

committed to promoting circular economy principles,

which include extending the lifespan of products

through repair and refurbishment, increasing the use of

reconditioned equipment, and implementing eco-

design (see also details infra in section

2.2.1.3 Taking

actions on resource use and circular economy (E5-2)

).

These actions not only reduce waste but also lower the

emissions associated with the production of new

equipment.

5.

P

h

a

s

i

n

g

o

u

t

o

r

s

u

b

s

t

i

t

u

t

i

n

g

p

r

o

d

u

c

t

s

a

n

d

p

r

o

c

e

s

e

s

:

Orange Group is evaluating its product offerings and

processes to identify opportunities for substitution with

lower-carbon

alternatives.

This

includes

the

development with suppliers of energy-efficient devices

and services that align with sustainability goals.

Overall, these decarbonisation levers are expected to play a role

in helping Orange Group achieve its GHG emission reduction

targets, contributing to a more sustainable and low-carbon

future. The quantification of the contribution of these levers to

achieving the company’s ambition is currently still being

assessed together with Orange Group. The company is

committed to continuously monitoring and reporting on the

effectiveness of these initiatives to ensure progress towards its

climate goals.

122

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Annual report 2025

123

METHODOLOGICAL NOTE

The company ensures that its GHG emission reduction targets are consistent with its GHG inventory boundaries, and in line with

the scope of entities part of this sustainability statement.

Orange has set the year 2020 as its base year for measuring greenhouse gas (GHG) emission reductions. This baseline covers all

scopes and relevant categories of the GHG Protocol enabling a comprehensive assessment of all activities. The table below

presents 2020 emissions for the entities covered within this report.

As the 2020 baseline predates VOO’s acquisition in 2023, it has been adapted to include emissions on the new scope of activities

for the sake of comparability. Due to the lack of some specific scope 1 and scope 2 data for VOO for 2020, some emissions for

that year were approximated using ratios derived from 2023 data. Further information on the emissions reduction progress can be

found under section

2.1.2.4 Gross scopes 1, 2, 3 and total GHG emissions (E1-6)

.

A s

s

y

s

t

e

m

a

t

i

c

m

o

n

i

t

o

r

i

n

g

f

r

a

m

e

w

o

r

k

has been set in place for GHG emissions calculations, including data collection processes, key

performance indicators (KPIs), and reporting schedules. The process to collect data has been strengthened in 2025 with clear data

governance, thereby more closely monitoring progress towards the target . GHG emissions data of scope 1, scope 2 and waste

undergo a quarterly validation by Environmental, Social, and Governance (ESG) teams in Belgium and Luxembourg, complemented

by regular audits to ensure accuracy and compliance. Progress towards the target is based on available information and process

owners’ data input, ensuring that forecasts remain relevant and aligned with expectations of progress towards the target.

Data becomes more and more reliable following the 2025 reporting exercise. However, the 2024 data remain globally consistent

with what was reported last year.

In consultation with the Group, the GHG inventory is regularly updated to reflect operational changes, evolutions of emissions

factors and the availability of more granular data, maintaining alignment with the established targets. The Group continuously

monitors and makes data-driven adjustments to their plans and initiatives based on scientific findings and operational performance.

Orange Belgium actively engages with stakeholders through consultative dialogues, collaborations with experts, and transparent

reporting, to ensure their targets are informed by the best practices and latest knowledge.

By committing to Net Zero Carbon by 2040 and accordingly

setting targets consistent with the Science-Based Targets

initiatives (SBTi) framework and the sectoral decarbonisation

pathways for the telecommunications sector, Orange Group has

considered a diverse range of climate scenarios, including a

scenario compatible with limiting global warming to +1.5°C. The

Group has conducted analysis to identify relevant environmental,

societal, technological, market, and policy-related developments

that may impact its operations and inform its decarbonisation

strategies.

2.1.2.3

Energy consumption and mix (E1-5)

Orange does not operate in a high climate impact sector. The table below represents Orange energy consumption:

E

n

e

r

g

y

c

o

n

s

u

m

p

t

i

o

n

a

n

d

m

i

x

2

0

2

4

2

0

2

5

Total fossil energy consumption (MWh)

23,576 MWh

25,479 MWh

Share of fossil sources in total energy consumption (%)

11 %

12 %

Total energy consumption from nuclear sources (MWh)

0 MWh

Share of consumption from nuclear sources in total energy consumption (%)

0 %

(1) Fuel consumption from renewable sources, including biomass (also comprising industrial

and municipal waste of biologic origin, biogas, renewable hydrogen, etc.) (MWh)

0 MWh

(2) Consumption of purchased or acquired electricity, heat, steam, and cooling from renewable

sources (MWh)

182,553 MWh

182,758 MWh

(3) Consumption of self-generated non-fuel renewable energy (MWh)

806 MWh

687 MWh

Total renewable and low carbon energy consumption (MWh) (sum of (1) to (3))

183,359 MWh

183,445 MWh

Share of renewable and low carbon sources in total energy consumption (%)

89 %

88 %

Total energy consumption (MWh)

206,936 MWh

208,924 MWh

T

a

b

l

e

3

:

O

r

a

n

g

e

n

e

r

g

y

c

o

n

s

u

m

p

t

i

o

n

m

i

x

In 2025, fossil-fuel energy use fell by 16% at Orange Belgium, yet total fossil-fuel consumption increased due to a reduced share of

electricity covered by renewable certificates at Orange Communications Luxembourg. Meanwhile, total renewable electricity

consumption stayed flat overall; it increased at Orange Belgium but decreased at Orange Communications Luxembourg.

123

Orange Belgium

_

Annual report 2025

124

Orange Belgium produces electricity with renewable technologies that is entirely self-consumed.

E

n

e

r

g

y

p

r

o

d

u

c

t

i

o

n

2

0

2

4

2

0

2

5

Renewable (MWh)

806 MWh

687 MWh

Non-renewable (MWh)

0 MWh

Total Energy Production (MWh)

806 MWh

687 MWh

T

a

b

l

e

4

:

O

r

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m

i

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M

E

T

H

O

D

O

L

O

G

I

C

A

L

N

O

T

E

To identify renewable electricity sources in scope 2, the company uses the share of electricity covered by Guarantees of Origin

(GOs). This means that it only considers GWh for which an equivalent is covered by a certificate: Quantity of electricity consumed

under Guarantee of Origin and self-produced / Total quantity of electricity consumed to obtain the renewable energy ratio.

For Orange Communications Luxembourg, the electricity consumption not covered by Guarantees of Origin is assumed to originate

primarily from fossil fuel sources, to keep the calculation conservative.

The amount of self-produced electricity reported for 2025 is based on meter measurements, whereas in 2024, a portion was

estimated. This accounts for the variation, as the surface area of the solar panels remained unchanged.

2.1.2.4

Gross scopes 1, 2, 3 and total GHG emissions (E1-6)

The evolution of Orange Belgium and Orange Communications Luxembourg’s carbon footprint is the following:

E

m

i

s

i

o

n

s

i

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t

C

O

2

e

q

R

e

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2

0

2

0

2

0

2

4

2

0

2

5

%

2

0

2

4

-

2

0

2

5

2

0

3

0

8

2

0

4

0

A

n

u

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l

%

t

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/

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a

r

S

c

o

p

e

1

G

H

G

e

m

i

s

i

o

n

s

Gross scope 1 GHG emissions

6,230

6,141

5,225

-15%

-

Percentage of scope 1 GHG

emissions from regulated

emission trading schemes (%)

N/A

-

S

c

o

p

e

2

G

H

G

e

m

i

s

i

o

n

s

Gross location-based scope 2

GHG emissions

9

6,830

26,387

25,811

-2%

-

Gross market-based scope 2

GHG emissions

10

668

551

354

-36%

-

S

i

g

n

i

f

i

c

a

n

t

s

c

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p

e

3

G

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s

-

T

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b

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d

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3

G

H

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e

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i

s

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s

2

0

4

,

6

5

4

2

1

,

1

6

1

9

4

,

3

5

-

8

%

-

1 Purchased goods and services

110,519

105,537

102,480

-3%

-

2

Capital goods

57,091

65,300

60,781

-7%

-

3 Fuel and energy-related

activities

2,687

10,967

3,785

-65%

-

4 Upstream transportation and

distribution

1,806

1,096

1,409

+29%

-

5 Waste generated in operations

-

2,431

1,862

-23%

-

6 Business travels

124

71

245

+245%

-

8

Orange Belgium contributes to the target of the Orange Group and does not disclose local targets.

9

Note that the 2024 Gross location-based scope 2 GHG emissions included a typo that did not affect the total emissions and has been corrected this year.

10

Under the market-based method, the remaining emissions are solely attributed to Orange Communications Luxembourg.

124

Orange Belgium

_

Annual report 2025

125

E

m

i

s

i

o

n

s

i

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t

C

O

2

e

q

R

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B

a

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e

a

r

2

0

2

0

2

0

2

4

2

0

2

5

%

2

0

2

4

-

2

0

2

5

2

0

3

0

8

2

0

4

0

A

n

u

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l

%

t

a

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t

/

b

a

s

e

y

e

a

r

7 Employee commuting

3,886

4,510

1,539

-66%

-

8 Upstream leased assets

-

9 Downstream transportation and

distribution

70

75

84

+11%

-

10 Processing of sold products

-

11 Use of sold products

2,455

727

789

+9%

-

12 End-of-life treatment of sold

products

-

13 Downstream leased assets

26,016

20,446

21,360

+4%

-

14 Franchises

-

15 Financial investments

-

T

o

t

a

l

G

H

G

e

m

i

s

i

o

n

s

Total GHG emissions

(location-based) (tCO

2

eq)

11

223,723

233,766

228,533

-2%

-

Total GHG emissions (market-

based) (tCO

2

eq)

211,552

217,893

199,914

-8%

-

T

a

b

l

e

5

:

O

r

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e

B

e

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g

i

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o

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f

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t

p

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t

The 2025 variations are driven by enhanced data collection. The

main share of the variation is observed for the combined scope

1, 2 and scope 3, category 3. Belgium’s scope 1 reductions are

mainly due to fleet electrification, the largest driver of scope 1

emissions. Scope 3, category 3 results reflect ongoing

reductions in scopes 1 and 2. For the remaining scope 3

categories, observed differences are primarily due to improved

local data ownership and, consequently, greater data accuracy,

notably in Purchased goods and services (category 1), Capital

goods (category 2), Business travels (category 6), and Employee

commuting (category 7). Additionally, Orange Communications

Luxembourg calculated for the first time emissions related to its

Business travel (scope 3 category 6) and emissions related to the

Use of sold products (scope 3, category 11), which may affect

year on year comparability.

M

E

T

H

O

D

O

L

O

G

I

C

A

L

N

O

T

E

Orange adheres to the Greenhouse Gas Protocol

(

G

H

G

P

r

o

t

o

c

o

l

)

,

a globally recognised standard for measuring and reporting

emissions, and includes all seven greenhouse gases. Its comprehensive methodology covers all scopes and relevant emissions

sources (see appendix 5.1 Note on carbon footprint assessment methodology).

To ensure transparent and accurate reporting, Orange is committed to disclosing the impact of all significant events and changes

in circumstances that may have an impact on its GHG emissions. This includes all relevant developments that occur between the

last reporting dates, such as changes in value chain activities, and the date of Orange's financial statements. For example, if a

subsidiary or supplier undergoes a significant operational change, such as a change in production methods or a change in energy

sources, Orange will assess how these changes affect the overall emissions profile and disclose this information in its report. This

approach allows stakeholders to understand the context of the emissions data and the potential impact of any discrepancies

between reporting periods.

This year, despite legal restructuring of entities, there has been no change in operational activities and therefore no effect on the

GHG calculations. There have also been no significant changes in the definition of what constitutes the reporting undertaking and

its upstream and downstream value chain.

In order to comply with the recommendations of the GHG Protocol, the Group's CSR department and the countries involved

arbitrate on the reliable and audited emission factor most representative of the electricity supplied, between the data communicated

by the countries' electricity producers and the average emission factor communicated by the International Energy Agency (IEA) or

the Association of Issuing Bodies (AIB).

Reporting is monitored on a quarterly basis through the Group environmental data management platform. Raw data is collected

locally by designated stakeholders for the following scope and sub-categories (scope 1, scope 2, scope 3.1 Purchased goods and

11

Scope 3 GHG emissions have also been calculated under the location-based method.

125

Orange Belgium

_

Annual report 2025

126

services, scope 3.2 Capital goods, scope 3.3 Fuel and energy-related activities, scope 3.5 Waste generated in operations, scope

3.6 Business travels, scope 3.7 Employee commuting, scope 3.13 Downstream leased assets) and by the Group for the following

scope and sub-categories (scope 3.4 Upstream transportation and distribution, scope 3.9 Downstream transportation and

distribution, scope 3.11 Use of sold products) and converted into GHG emissions into tools provided by the Group. Life Cycle

Assessments (LCAs) are used to identify the environmental impacts of specific products and services.

For further information on the carbon footprint methodology, consult

appendix 5.1 Note on carbon footprint assessment

methodology

.

Orange sources 95% of its electricity through b

b

u

n

d

l

e

d

i

n

s

t

r

u

m

e

n

t

s

and 5% through u

u

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d

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e

r

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y

a

t

r

i

b

u

t

e

c

l

a

i

m

s

as part of its electricity procurement strategy. Orange

Communications

Luxembourg

only

purchases

electricity

bundled with instruments such as Guarantee of Origins. The

unbundled energy attribute claims are intended to cover

electricity consumption at private technical sites that Orange

Belgium leases and for which it does not control the electricity

contract.

Under Orange’s m

m

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2

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g

,

100% of the electricity consumed by Orange Belgium from the

grid is covered by G

G

u

a

r

a

n

t

e

s

o

f

O

r

i

g

i

n

(

G

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s

)

, resulting in z

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o

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c

i

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d

s

c

o

p

e

2

e

m

i

s

i

o

n

s

f

o

r

B

e

l

g

i

u

m

. Guarantees of Origin

are certificates that provide evidence that a given quantity of

electricity has been generated from renewable energy sources.

To secure these guarantees, Orange Belgium has established a

partnership with E

E

n

e

c

o

. The former V

V

O

e

n

t

i

t

y

relies on a

partnership with L

L

u

m

i

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u

s

, under contracts that are still in force.

The renewable electricity purchased is generated from a m

m

i

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o

f

w

i

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d

,

h

y

d

r

o

a

n

d

s

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l

a

r

s

o

u

r

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e

s

.

Orange Communications Luxembourg does not currently benefit

from 100% Guarantees of Origin for its scope 2 electricity

consumption, which results in l

l

i

m

i

t

e

d

s

c

o

p

e

2

e

m

i

s

i

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m

a

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t

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b

a

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m

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t

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o

d

.

As a result, 9

9

7

%

o

f

t

h

e

l

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r

i

c

i

t

y

p

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t

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c

o

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d

i

n

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p

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d

b

y

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u

a

r

a

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f

O

r

i

g

i

n

.

In comparison, in 2024, 100% of the electricity consumed by

Orange Belgium was covered by bundled Guarantees of Origin,

while no information on the origin of electricity was available for

Orange Communications Luxembourg at that time.

In addition, all the energy produced with renewable technologies

on site is auto consumed and never sold.

The greenhouse gas intensity has decreased slightly compared to 2024:

G

H

G

i

n

t

e

n

s

i

t

y

i

n

t

C

O

2

e

q

/

M

€

2

0

2

4

2

0

2

5

%

2

0

2

4

-

2

0

2

5

Total GHG emissions (location-based) per net revenue

117 tCO

2

eq/M

€

118 tCO

2

eq/M

€

+1%

Total GHG emissions (market-based) per net revenue

109 tCO

2

eq/M

€

103 tCO

2

eq/M

€

-6%

T

a

b

l

e

6

:

O

r

a

n

g

e

’

s

e

c

o

n

o

m

i

c

a

r

b

o

n

i

n

t

e

n

s

i

t

y

126

Orange Belgium

_

Annual report 2025

127

M

E

T

H

O

D

O

L

O

G

I

C

A

L

N

O

T

E

The net revenue used for calculating the GHG emissions intensity corresponds with the revenue from the operations as mentioned

in the general disclosures (see section

1.1.3.1 Strategy, business model and value chain (SBM-1)

), corresponding to line Revenue

in the financial statements (section consolidated financial statements line 3 as reference). No adjustments are made. This

reconciliation ensures that reported emissions intensity aligns with core business activities as outlined in the financial disclosures.

2.1.2.5

GHG removals and GHG mitigation projects financed through carbon credits

(E1-7)

Orange Group has not modelled GHG emissions beyond 2030 at

this stage because the evolution of Orange's economic activities

beyond 2030 has not been conducted in a way that allows it to

be translated into GHG emissions, which is the basis for

constructing the trajectory.

To deliver on its commitment to be Net Zero Carbon by 2040,

Orange Group will have to reduce its GHG emissions by 90%

compared to the reference year. Despite all its efforts, there will

be residual emissions that cannot be reduced, which the Group

will sequester; the remaining 10% of emissions will be offset by

carbon credits from nature-based projects.

The Group has set a trajectory for the carbon credits it will need

by 2040, taking into account the SBTi’s recommendations on

how to treat these residual emissions over time. Thus, these

future carbon credits will not prevent or reduce the achievement

of GHG emission reduction targets and the Net Zero Carbon

goal.

2.1.2.6

Taking actions on climate change mitigation and energy (E1-3)

Orange focuses its efforts on preventive measures aimed at

reducing its greenhouse gas (GHG) emissions and limiting its

impact on the environment and climate change. Orange Belgium

and Orange Communications Luxembourg are committed to

supporting the Group in achieving its emissions reduction targets

through the following set of actions, well aligned with the above

mentioned k

k

e

y

d

e

c

a

r

b

o

n

i

s

a

t

i

o

n

l

e

v

e

r

s

.

127

Orange Belgium

_

Annual report 2025

128

Energy efficiency improvements

First goal aims at e

e

n

e

r

g

y

c

o

n

s

u

m

p

t

i

o

n

r

e

d

u

c

t

i

o

n

thanks to e

e

n

e

r

g

y

e

f

i

c

i

e

n

c

y

p

r

o

g

r

a

m

e

s

in 3 areas:

Fleet & mobility decarbonisation

•

Decarbonisation of employee fleet (among Flex Plan i.e.

a flexible way to compensate employees in Belgium)

towards electric vehicles, for all Orange Belgium, and

Orange Communications Luxembourg employees’

vehicles. Time horizon is December 2030.

•

Option to adopt a legal mobility budget for employees

who give up the company car advantage (with

awareness raising for all employees): this applies to all

Orange Belgium employees while not those at Orange

Communications Luxembourg.

•

Decarbonisation of service fleet towards electric

vehicles in 2025: currently only at the proof-of-concept

stage for a few vehicles at Orange Belgium.

•

Charging cards for all and installation of charging

stations at employees’ homes when possible: this is for

all Orange Belgium employees with company car (not

applicable to service cars). This (up to December 2030)

does not cover Orange Communications Luxembourg.

•

Installation (by December 2030) of charging stations for

all offices and shops at Orange Belgium and Orange

Communications Luxembourg.

•

Implementation (in 2025) of fleet monitoring system

(distance, maintenance needs, …) for all Orange

Belgium fleet. This action does not cover Orange

Communications Luxembourg.

•

Improvement of infrastructure supporting low-carbon

commuting, including facilities for employees using

bicycles and other active mobility solutions.

Buildings’ energy decarbonisation

•

Energy optimisation: smart heating, timer to limit

(stand-by mode) use of IT devices and lighting, at

Orange

Belgium

and

Orange

Communications

Luxembourg offices. It does not cover shops. Ongoing

optimisation since 2021.

•

Space optimisation and closing of most energy

intensive buildings: over 2023-December 2030 period,

this action covers Orange Belgium (offices and shops)

but

does

not

cover

Orange

Communications

Luxembourg.

•

Installation of LED lighting at Orange Belgium (offices

and shops), and Orange Communications Luxembourg

(over 2024-2026 period).

•

Installing heat pumps and “heating, ventilation, and air

conditioning” (HVAC) where feasible: this action covers

Orange Belgium offices (over 2025-2026) and shops

(ongoing), but does not cover Orange Communications

Luxembourg.

128

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_

Annual report 2025

129

•

Remote

monitoring

system

of

gas

heating

(consumption, maintenance needs, …). This action

covers Orange Belgium offices (by December 2025)

and shops (ongoing) but does not cover Orange

Communications Luxembourg.

•

Solar photovoltaic panels are currently being installed

throughout Orange's infrastructure where feasible: this

action covers Orange Belgium buildings (offices and

shops). Implementation depends on feasibility until

2030.

Network operations decarbonisation following the

Green ITN Programme

•

Smart metering of data centre and other technical core

sites consumption (energy use, air conditioning): this

completed action covers Orange Belgium. Orange

Communications Luxembourg has no data centre;

hence it is not applicable.

•

Machine learning system to monitor traffic behaviour

and optimise energy saving features accordingly: this

ongoing action covers Orange Belgium and is in work-

in-progress at Orange Communications Luxembourg.

•

Smart metering of energy consumption of Radio

Access Network (RAN) roll-out: this ongoing action

covers Orange Belgium but is still in project phase in

Orange Communications Luxembourg.

•

RAN sharing with other Telecom provider with most

energy efficient technology and configuration: this

action covers Orange Belgium (ongoing until 2027) but

not Orange Communications Luxembourg.

Electricity mix decarbonisation

Second goal aims at

energy supply decarbonisation:

Orange

Belgium has been buying renewable electricity since 2009 and

has a clear target for renewable energy in its Group Environment

Policy: maintain the sourcing of 100% of its electricity from

renewable sources and produced by its energy supplier, ensuring

that it remains as low-carbon as possible. Although this last

aspect is beyond the company’s control , it is nevertheless

expected in most countries and is well-integrated in most carbon

trajectory models . Orange Communications Luxembourg is

working on improving its renewable energy ratio.

Procurement with suppliers

The purchasing scope represented around 82% of the Group’s

scope 3 GHG emissions, in the digital sector, in 2025. Meeting

the Group’s decarbonisation target requires joint efforts with

suppliers in areas such as logistics and production processes,

the design and manufacture of products and services, and the

content and management of purchasing practices, to leverage

both procurement volumes and carbon intensity. As part of its

global responsible purchasing approach, Orange Group’s action

plan

involves

engaging

with

suppliers

to

increase

the

transparency and traceability of its supply chains’ carbon

footprint via several initiatives.

Suppliers’

integration

of

environmental

issues

considered in the selection process

•

ITN equipment and home devices: Starting in 2024,

Orange Belgium incorporates an ESG score into

responses to its calls for tender. This score, which

accounts for 20% of the purchase decision, is based

on the supplier’s maturity, evaluated through the

supplier sustainability scorecard and environmental

criteria specific to the products being purchased.

•

Smartphones and IoT: The integration of an eco-rating

index into the portfolio selection for smartphones and

IoT devices is ongoing. This index is based on the

following

criteria:

durability

(particularly software

longevity), repairability, recyclability, climate impact

(using GHG thresholds), and resource preservation of

the product.

•

New suppliers: All new suppliers have to sign the

Supplier Code of Conduct.

This action covers the whole Group, including Orange Belgium

and Orange Communications Luxembourg.

Engaging suppliers in an active decarbonisation

process through the Partners to Net Zero Carbon

(PTNZC) programme

In 2024, Orange Group launched the PTNZC programme to

engage its suppliers at the Group level in an active

decarbonisation process. With this programme, Orange seeks to

transform its relationship with its suppliers and make them

partners in a shared decarbonisation process. It aims to:

•

Reduce Orange’s scope 3 GHG emissions through its

purchases, in line with each entity’s objectives;

•

Improve the quality of Orange’s scope 3 reporting by

collecting more comprehensive information from

suppliers to estimate the carbon footprint of their

products and services;

•

Encourage a broader transformation of the entire

ecosystem and supply chain.

The Group seeks to engage its suppliers in improvement plans

with milestones to put their activities with Orange on a GHG

emissions reduction trajectory that is consistent with its strategy

and commitments. Orange Group has prioritised working with

the 35 suppliers that account for 60% of purchasing

‑

related GHG

emissions. At the same time, the Group is developing reporting

tools that will enable it to better differentiate between product

‑

and supplier

‑

based emission factors, in order to report on the

progress made.

Orange Belgium and Orange Communications Luxembourg will

be impacted positively by this programme (managed at Group

level). This action plan is a process of continuous improvement

and has no defined time horizon.

Distribution flows

For downstream freight (scope 3 category 3.9) in 2019, Orange

Group set up a supply chain programme O’GREEN, designed to

measure the carbon footprint of distribution flows and energy

consumption in warehouses and thus better target and drive the

roll

‑

out of several programmes aimed at reducing the carbon

footprint of the downstream supply chain.

Orange Belgium was included in it in 2024, and the scope of this

programme is growing from year to year.

For upstream transport, the carbon footprint measurement is

carried out using physical data from Orange Group’s top 10

129

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_

Annual report 2025

130

suppliers. Means of transport are being reviewed in favour of

maritime and rail transport, especially for boxes.

Orange Belgium and Orange Communications Luxembourg are

impacted positively by this programme (managed at Group level).

All these actions constitute a process of continuous improvement

and have no defined time horizon.

Circular economy

See details infra in section

2.2.1.3 Taking actions on resource use

and circular economy (E5-2)

.

I

n

2

0

2

5

,

p

r

o

g

r

e

s

m

a

i

n

l

y

r

e

l

a

t

e

s

t

o

t

h

e

o

p

e

r

a

t

i

o

n

a

l

d

e

p

l

o

y

m

e

n

t

o

f

p

r

e

v

i

o

u

s

l

y

d

e

f

i

n

e

d

e

c

a

r

b

o

n

i

s

a

t

i

o

n

a

c

t

i

o

n

s

.

These actions did

not represent a change in strategy but strengthened execution

capabilities and contributed to observable scope 1 and 2

emission reductions in 2025, primarily driven by improved

heating performance, energy monitoring and energy-efficient

technologies. In parallel, 2025 marked a strong focus on

improving the quality and granularity of scope 3 emissions data,

a key step to enable more accurate monitoring and more

effective steering of future decarbonisation actions across the

value

chain.

Overall

progress

reflects

a

continuous

implementation trajectory, with 2025 marking a step-up in

operational maturity rather than the introduction of new action

plans.

At this stage, Orange Belgium and Orange Communications

Luxembourg do not yet disclose the specific contribution at

national level of each individual decarbonisation lever to the total

emissions reductions achieved as this is part of the Orange

Group efforts. Nor do they publish forward looking expected

reductions as these are defined at Group level and can be found

in the Group Universal Registration Document as part of the

transition plan.

Nevertheless, in the reporting year 2025, Orange Belgium and

Orange Communications Luxembourg achieved a reduction o

o

f

1

,

1

3

t

C

O

2

e

i

n

s

c

o

p

e

1

a

n

d

2

from its fleet electrification and

implemented

energy

efficiency

measures

throughout

its

operations.

.

This decrease was mainly due to the improvement of

heating systems, the implementation of intelligent meters, and

the utilisation of energy-conserving technologies.

Currently, Orange Belgium does not provide remedy for its

impact on climate change. Instead, the emphasis is placed on

implementing strategies and initiatives that aim to mitigate the

effects of climate change by improving energy efficiency,

adopting

circular

economy

practices,

and

investing

in

decarbonisation projects. These actions are designed to prevent

negative environmental impacts and promote a transition to more

sustainable practices, thereby contributing to resilience in facing

climate challenges.

Orange has not assessed whether its ability to implement action

depends on availability and allocation of resources and does not

disclose any current and future financial resources allocated to

its climate transition plan or sustainability-related action plans, as

methodologies for their calculations are still under development

in coordination with the Group.

2.1.3

Management of impacts, risks and opportunities related to

climate change adaptation

2.1.3.1

Policies related to climate change adaptation (E1-2)

Orange Group has developed an adaptation plan based on an

analysis of the exposure and vulnerability of its infrastructure and

associated people to climate risks, using Intergovernmental

Panel on Climate Change (IPCC) scenarios and the support of a

specialised external consultancy. The Group has identified more

than 1,000 strategic sites in 11 countries to develop local

adaptation plans to manage the risks associated with climate

hazards.

An overview of the Belgian sites, showing f

f

o

r

e

c

a

s

t

s

f

o

r

t

h

e

m

o

s

t

c

r

i

t

i

c

a

l

e

x

p

o

s

u

r

e

s

to climate risks and their potential impacts by

2030 and 2050, and based on the IPCC’s SSP5-8.5 scenario,

lead to the following takeaways:

•

By 2030, the risks most likely to impact Orange Belgium

are: landslides, flooding and heat stress emerging.

•

By 2050, exposure to heat stress will increase

significantly, and wildfire will emerge.

With the increase in climate crises, Orange Group has

s

t

r

e

n

g

t

h

e

n

e

d

i

t

s

G

r

o

u

p

S

e

c

u

r

i

t

y

P

o

l

i

c

y

which encompasses

various aspects of security, including physical, digital, and

operational security measures (covering also data privacy and

cybersecurity as detailed infra in

section 3.3.4 Management of

impacts, risks and opportunities related to data privacy and

cybersecurity

). It is a policy overarching other components such

as the B

B

u

s

i

n

e

s

C

o

n

t

i

n

u

i

t

y

M

a

n

a

g

e

m

e

n

t

(

B

C

M

)

p

o

l

i

c

y

and the

C

r

i

s

i

s

M

a

n

a

g

e

m

e

n

t

p

o

l

i

c

y

, both aim to prepare Orange for the

consequences of risks materialising and to document continuity

and crisis management plans accordingly.

As regards climate change adaptation more specifically, the

objective is to i

i

n

t

e

g

r

a

t

e

a

l

n

e

w

c

l

i

m

a

t

e

r

i

s

k

s

into the existing

BCM analyses and plans (e.g. droughts, land slides, high

temperature in addition to existing risks such as flooding and

storms for instance).

The BCM policy sets out the following principles, which every

Orange entity must comply with:

•

Identification of critical activities in line with the Belgian

Institute for Postal Services and Telecommunications

(BIPT), with approval from senior management;

•

Identification of essential assets (sites, network

components, IT applications, personnel, etc.);

•

Conducting a Business Impact Analysis (BIA) to

determine

business

continuity

and

recovery

requirements following a disruption;

•

Developing continuity solutions, including business

continuity plans (BCPs), recovery plans (RPs) and other

backup site activation plans and crisis management

plans;

•

Testing plans and conducting exercises related to

recovery plans.

130

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_

Annual report 2025

131

Within Orange Belgium, Business Continuity Management (BCM)

is the capability to maintain the delivery of services and products

at acceptable predefined levels following a disruptive incident,

including

extreme

weather

events,

in

accordance

with

management-approved security continuity objectives. This

concept is supported by a local BCM policy.

BCM is a holistic management process that identifies potential

threats to Orange and assesses the impacts these threats could

have on business operations if they were to materialise. It

provides a framework for building organisational resilience,

enabling an effective response that safeguards the interests of

key stakeholders, as well as the company's reputation, brand,

and value-creating activities.

The local policy in Belgium and in Luxembourg is designed to be

consistent with the broader Group BCM policy. This alignment

ensures that the local policy adheres to the standards and

guidelines established at Group level, promoting a cohesive and

unified approach to business continuity across the entire

organisation. This way, the organisation aims to enhance its

resilience and preparedness for potential disruptions, ensuring

that all levels of the organisation are equipped to maintain critical

functions and recover swiftly in the face of unforeseen events.

The BCM policy is shared with those employees who are directly

involved in implementing it, but it is not publicly shared.

2.1.3.2

Targets related to climate change adaptation (E1-4)

Note that Orange has not defined target on climate adaptation or

determined global indicators to monitor the effectiveness of

adaptation plans at the moment. Orange Belgium is however

pursuing efforts to adapt to the effects of climate change to

ensure continuity of service to its customers and populations in

a world subject to global warming.

2.1.3.3

Taking actions on climate change adaptation (E1-3)

As introduced supra in

1.1.4.1.4 Climate impacts, risks and

opportunities process

, in 2023, Orange Group launched a project

in conjunction with a specialised firm with climate expertise and

equipped with an analysis tool to estimate change scenarios per

main climatic hazards in the countries where the Group operates

and to accurately qualify the exposure of the Group's main

infrastructures to each of these hazards.

In 2024, in Orange Belgium, most critical sites exposure to

climate change had been assessed. And in 2025, this exposure

analysis has been extended to the critical assets of the former

VOO entity and to Orange Communications Luxembourg. The

analysis has been performed on Orange Belgium critical sites

(144 sites) and Orange Communications Luxembourg critical

sites (12 sites). The term "critical sites" refers to essential

infrastructures or locations for Orange's operations that could be

vulnerable to the impacts of climate change. These sites may

include core sites, network facilities, offices, or other key

infrastructures whose continuity of service is crucial for the

company and its customers.

This analysis considers various factors, such as geographical

location, the type of climate risks each site is exposed to (such

as flooding, storms, droughts, landslides, high temperature, etc.),

and the operational importance of each site for the overall

functioning of Orange. Specialised tools and climate data have

been used to assess these risks and will determine which sites

require priority adaptation measures.

In

the

framework

of

ISO

27001

(Information

Security

Management) and 22301 (Business Continuity Management),

environmental risks that could impact Orange Belgium

security and business continuity are properly considered at

governance level

12

and regularly assessed.

Only the scenario

of flooding undermining Orange Belgium asset supports was

slightly above acceptable level, but action plans have been

defined to return this risk to a green zone. Furthermore, efficient

security and business continuity measures (proactive and

reactive), are implemented and well known. Therefore, the

situation regarding the short-term risks can be considered

currently under control.

These analyses make it possible to measure risks for each of the

relevant hazards over three time-horizons, and to deduce

potential vulnerabilities of sites and infrastructures. Where

necessary and starting in 2026, Orange will gradually draw up

adaptation plans to c

c

o

u

n

t

e

r

p

h

y

s

i

c

a

l

r

i

s

k

s

b

y

r

e

i

n

f

o

r

c

i

n

g

i

n

f

r

a

s

t

r

u

c

t

u

r

e

s

and/or s

s

e

r

v

i

c

e

r

e

s

t

o

r

a

t

i

o

n

p

r

o

c

e

d

u

r

e

s

. In terms of

progress, the organisation is currently at the stage of conducting

a vulnerability analysis of physical risks. No action plan has been

defined yet to limit the harmful material impacts.

The integration of these new climate risks within the ongoing

security

and

business

continuity

management

plans

is

encouraged by the Group and undertaken by many different

stakeholders

within

Orange

Belgium

and

Orange

Communications Luxembourg on top of their existing roles and

responsibilities.

12

ISO scope encompassing critical infrastructure and services (excluding Radio Access Network)

131

Orange Belgium

_

Annual report 2025

132

2.2

Resource Use and Circular Economy (E5)

2.2.1

Management of impacts, risks and opportunities related to

resource use and circular economy

2.2.1.1

Policies related to resource use and circular economy (E5-1)

The management framework linked to the resource use and

circular economy topic is based on the e

e

n

v

i

r

o

n

m

e

n

t

a

n

d

e

n

e

r

g

y

p

o

l

i

c

y

1

3

. This policy aims to support the sustainability (economic,

environmental and social) of Orange’s business model by

reducing the environmental impacts of Orange’s activities and

services (GHG emissions and natural resources), by reducing

dependence on the supply challenges of its suppliers of critical

metals through the roll

‑

out of circular economy principles, and by

developing new offers.

13

The Group Environment and Energy Policy:

https://mastermedia.dam-broadcast.com/medias/domain12751/media101367/410206-099fde5djo-75.pdf

132

Orange Belgium

_

Annual report 2025

133

These principles are organised around the following four areas:

•

I

n

c

r

e

a

s

i

n

g

t

h

e

l

i

f

e

t

i

m

e

o

f

e

q

u

i

p

m

e

n

t

a

n

d

e

v

e

l

o

p

i

n

g

e

c

o

‑

d

e

s

i

g

n

:

Orange aims to extend the life of its IT and

network equipment and customer handsets in order to

reduce its GHG emissions, the consumption of natural

resources, and its dependency on critical metals. This

involves

the

eco

‑

design,

repair,

reuse

and

refurbishment of equipment, as well as raising its

customer’ awareness about responsible use. This

approach also reduces the generation of waste

electrical and electronic equipment (WEEE);

•

R

e

c

o

v

e

r

i

n

g

a

n

d

p

r

o

c

e

s

i

n

g

u

s

e

d

e

q

u

i

p

m

e

n

t

: Orange is

committed to recovering and processing end

‑

of

‑

life

equipment

and

handsets

in

order

to

reduce

environmental impacts and promote the trend in the

market for refurbishing and recycling raw materials. A

WEEE waste policy has been published and is detailed

infra in section

2.2.2.1 Policies related to resource

outflows / waste (E5-1);

•

E

v

o

l

v

i

n

g

b

u

s

i

n

e

s

m

o

d

e

l

: Orange collaborates with

actors in its ecosystem, in particular with its suppliers

and peers, to ensure the sustainable development of

circular economy practices in the digital industry;

•

I

n

o

v

a

t

i

n

g

i

n

m

a

r

k

e

t

i

n

g

:

Orange is developing new

offers to meet market needs and seize opportunities

that make it stand out.

The policy applies to all Orange’s activities, including Belgium

and Luxembourg. As Orange does not manufacture equipment

or directly manage the extraction of materials, this policy does

not specifically address the phasing out of the use of virgin

resources, including increased use of recycled resources, or the

sustainable supply and use of renewable resources. The

company works with suppliers to mitigate risks related to supply

disruption and sustainable sourcing. Supplier management is

further described in

section 4.1.2 Management of impacts, risks

and opportunities related to suppliers’ relations

.

As explained in the description of the Group’s environmental

policy, objectives are set out in a letter of commitment signed by

the Group Executive Director of Corporate Social Responsibility

and the Executive Director of the division. The operational

i

m

p

l

e

m

e

n

t

a

t

i

o

n

of this policy is carried out by the Group

Environmental Strategy Committee (ESC), which is based on the

work of the operational committees specific to each of the

circular economy projects, under the aegis of the Executive

Committee. As an integral part of the budget and strategic plan

processes, they are monitored by the Group’s Executive

Committee, under the control of the Group Audit Committee, the

Internal control of CSR and the Group Board of Directors.

At Orange Belgium, the Chief Brand, Communication & ESG

Officer leads the commitment related to circularity, supported by

the entire Executive Committee. At Orange Communications

Luxembourg, the Head of Communication & ESG leads the

commitment.

The process for interacting with stakeholders, set consultation,

get feedback, communicate on updates, and educate is also

explained above in section

2.1.2.1. Policies related to climate

change mitigation and energy (E1-2)

.

Collaboration with i

i

n

d

u

s

t

r

y

a

s

o

c

i

a

t

i

o

n

s

and

r

e

g

u

l

a

t

o

r

y

b

o

d

i

e

s

is

essential to the strategy. By working with these partners, Orange

disseminates information about its policies to a broader

audience, ensuring that stakeholders critical to implementation

are well-informed. For example, the latest policy on the treatment

of E

E

l

e

c

t

r

i

c

a

n

d

E

l

e

c

t

r

o

n

i

c

E

q

u

i

p

m

e

n

t

W

a

s

t

e

(WEEE)

14

and the

F

a

c

t

S

h

e

t

o

n

C

i

r

c

u

l

a

r

E

c

o

n

o

m

y

15

are publicly available through

the Orange website.

The environment and energy policy entails Orange Group's

commitment to decreasing dependence on the supply issues of

its suppliers of c

c

r

i

t

i

c

a

l

m

e

t

a

l

s

through the deployment of circular

economy principles. It aims to increased the lifespan of

equipment, networks and customer terminals and develop eco-

design in order to reduce its consumption of natural resources

and its dependence on critical metals.

For several years now, Orange has obliged all its suppliers to sign

its Supplier Code of Conduct. This sets out principles related to

circularity by requiring application of circular economy principles

(e

e

c

o

-

d

e

s

i

g

n

, offering r

r

e

f

u

r

b

i

s

h

e

d

equipment, responsible w

w

a

s

t

e

m

a

n

a

g

e

m

e

n

t

) and compliance with all applicable laws and

regulations concerning information on product composition,

permits, authorisations and environmental registrations.

2.2.1.2

Targets related to resource use and circular economy (E5-3)

Orange does not publish any target related to resources use,

circular economy, or waste management. Still, subsidiaries

monitor several KPIs against predefined internal targets, such as

the number of used mobile phones collected, the penetration of

refurbished phones sales and the collection rate of fixed

equipment. The more Orange can collect mobile phones and

fixed equipment, the more the level of circular loops with

refurbished devices can be increased, and thereby reduce the

need of resources upstream.

2.2.1.3

Taking actions on resource use and circular economy (E5-2)

Development and strengthening of circular

economy

The action plan described in this section aims to support the

sustainability (economic, environmental and social) of Orange's

business model by reducing the environmental impacts of

Orange's activities and services (GHG and natural resources),

14

Available here:

https://gallery.orange.com/en/element?id=411895

15

Available here:

https://gallery.orange.com/en/element?id=410563

reducing dependence on the supply challenges of its suppliers

of critical metals, and developing new offerings.

The initiatives presented in this chapter are rolled out at Group

level and encompass all operations, including Orange Belgium

and Orange Communications Luxembourg. Many actions are

part of a continuous improvement process and have no fixed

timeframe. A roadmap is to be detailed and consolidated in 2026.

133

Orange Belgium

_

Annual report 2025

134

Orange Belgium does not disclose any current and future financial resources allocated to its climate transition plan or sustainability-

related action plans, as methodologies for their calculations are still under development in coordination with the Group.

Below, nine actions related to development and strengthening of circular economy are described:

1.

Developing eco-design approaches

Eco-design is a cornerstone of Orange's circular economy policy,

aimed at reducing the use of critical metals, enhancing product

durability

and

recyclability,

decrease

electrical

energy

consummation and minimising the Waste Electrical and

Electronic Equipment (WEEE). To this end, Orange Group is

committed to implementing eco-design principles for all

products

marketed

under

its

brand.

A

methodological

framework, initially established in 2021 and revised in 2023 and

2024, supports this commitment. Multi-regional governance has

been established, with eco-design referents and leads providing

operational support across regions, complemented by a

dedicated training programme for marketing teams and project

managers.

The eco-design approach encompasses products such as

modems

and

routers

(“Livebox”),

TV

decoders,

mobile

broadband devices (MBBs), WiFi repeaters, and selected

134

Orange Belgium

_

Annual report 2025

135

phones. Special emphasis is placed on the power consumption

of Livebox and TV decoders, as their usage phase accounts for

over 80% of carbon emissions in countries with carbon-intensive

electricity grids. For example, the latest TV decoder features

optimised energy consumption in standard operation and a

highly efficient standby mode activated by default, resulting in a

75% reduction in average electricity consumption compared to

the previous generation. The new Livebox 7, designed for easy

repairability with a 100% recycled and recyclable plastic shell,

also includes a standby mode to reduce energy use. Recognising

these efforts, Bureau Veritas awarded "Footprint Progress"

certification to Livebox 7, thanks to an initiative led by the

marketing and technical team.

In the realm of smartphones, Orange has collaborated with

European operators to develop the "eco-rating" index. This index

provides an overall environmental footprint score for each device,

evaluated on five criteria: durability, repairability, recyclability,

climate impact, and resource preservation. This initiative,

accessible to all operators via a licensing agreement, offers

customers transparency on the environmental impact of

smartphones, particularly significant during the manufacturing

phase.

Orange also applies eco-design to its digital services, internal

processes and offerings. For example, the ‘Circular Mobility’

offering, launched in 2024 for businesses, aims at reducing the

carbon footprint of mobile fleets by between 26% and 40%,

according to the French association for norming (AFNOR)

certification. Similarly, ‘Evolution Platform’, the new modular

connectivity platform for businesses, has incorporated an eco-

design approach from the outset. This approach applies to the

entire solution, including the numerous software components it

contains. Specific work is also being carried out with service

providers to reduce their carbon impact on the platform.

Beyond these examples, Orange Business is carrying out in-

depth work aiming at rolling out the eco-design approach for the

most strategic new offerings and existing offerings with a

significant carbon footprint by 2030. In the short and medium

term, Orange aims at extending its eco-design approach to new

products and services while establishing measurable impact

targets to further enhance its sustainability efforts.

2.

Increase the proportion of reconditioned mobiles in

mobile sales

Using reconditioned mobile phones can reduce the carbon

footprint by up to tenfold compared to purchasing new devices,

according to the Agence de l’Environnement et de la Maîtrise de

l’Energie (ADEME)

16

. As such, increasing the proportion of

reconditioned mobiles in sales is a critical lever for Orange to

achieve its decarbonisation targets and using less virgin material.

For customers, this initiative not only supports purchasing power

but also promotes awareness of sustainable consumption

practices.

Orange aims at positioning itself as a trusted player in the

reconditioned mobile market, offering quality handsets backed

by guarantees. To this end, the company is diversifying its supply

sources and standardising its rating system to assess the

condition of phones accurately. In Belgium and Luxembourg,

16

ADEME study is available here:

https://librairie.ademe.fr/ged/7385/ademe_impact_environnemental_reconditionnement_rapport_en.pdf

Orange has signed purchase contracts with suppliers of

refurbished devices, primarily Apple and, to a lesser extent,

Samsung, to meet the growing demand in this segment.

The objective for the coming years is to increase the share of

reconditioned mobiles in total sales, within the constraints of

market dynamics. Additionally, Orange plans to introduce

incentives to encourage customers to keep their phones for

longer, which remains the most sustainable option in terms of

carbon emissions. However, the competitive landscape for

refurbished devices is becoming increasingly challenging, as

European Union regulations limit the importation of reconditioned

phones from outside the European Union. This supply constraint

has been identified as a potential risk and is thoroughly analysed

continuously.

To address these challenges and achieve its goals, Orange has

outlined several c

c

o

n

c

r

e

t

e

a

c

t

i

o

n

s

:

•

P

r

o

m

o

t

i

n

g

r

e

f

u

r

b

i

s

h

e

d

e

v

i

c

e

s

by educating the market

and exploring new levers, such as raising awareness of

their environmental footprint.

•

L

e

v

e

r

a

g

i

n

g

t

h

e

r

e

f

u

r

b

i

s

h

e

d

.

o

r

a

n

g

e

.

b

e

p

l

a

t

f

o

r

m

to

capture the standalone sales market with a broad range

of devices.

•

E

x

p

l

o

r

i

n

g

l

o

c

a

l

r

e

f

u

r

b

i

s

h

m

e

n

t

p

r

o

c

e

s

e

s

to establish

"true" circularity within the supply chain.

•

E

n

h

a

n

c

i

n

g

c

u

s

t

o

m

e

r

s

e

r

v

i

c

e

o

f

e

r

i

n

g

s

for device

returns, including end-to-end digital buy-back options

and data transfer services.

Through these initiatives, Orange is committed to advancing

sustainable

practices

and

increasing

the

proportion

of

reconditioned mobiles in mobile sales while navigating market

challenges effectively.

3.

Promoting repairs

Repairing mobile phones is a key component of extending their

useful life. Beyond meeting the regulatory obligation to provide

standard warranty services, Orange Group is dedicated to

offering appealing repair services in all its European markets,

helping customers extend the lifespan of their devices even after

the warranty period. Such repair services are operational in

Belgium and Luxembourg.

The a

a

p

e

a

l

o

f

t

h

e

s

e

s

e

r

v

i

c

e

s

is evaluated based on f

f

i

v

e

k

e

y

c

r

i

t

e

r

i

a

:

•

The availability of repair services across distribution

channels

•

The autonomy provided to customers for conducting

diagnostics

•

The predictability of the repair process

•

The transparency of progress updates

•

The continuity of service, including the provision of loan

devices during repairs.

In 2023, a sixth criterion was introduced to include customer

perceptions of the repair service's attractiveness. This addition

considers the competitive landscape and evolving customer

expectations in each country, ensuring that repair services

remain relevant and valued. Through these measures, Orange

135

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136

reinforces its commitment to promoting sustainable practices

while meeting customer needs effectively.

4.

Develop the use of re-used ITN equipment and the

purchase of reconditioned equipment

The shift toward a circular economy requires a reassessment of

Orange's industrial policies for network deployment, equipment

management, and procurement practices. A central element of

this transformation is the implementation of a unified repository

for

equipment

management,

which

enables

streamlined

configurations and the definition of new renewal criteria for

network equipment. Additionally, a dedicated "marketplace" has

been developed to facilitate equipment reuse both within Orange

and with external partners.

Orange's medium-term objective is to foster a robust market for

used equipment and spare parts by working closely with

manufacturers and establishing new supplier agreements. This

effort includes collaboration with industry peers to promote

marketplace interoperability. To support these goals, Orange has

introduced a "positive list" in partnership with its procurement

ally, BuyIn

17

. This list identifies equipment for which suppliers can

offer refurbished alternatives, bolstering the availability of reused

options.

The Group’s Orange Sustainable & Circular Ambition for

Recertification (OSCAR) programme drives this strategy by

building an ecosystem that extends the useful life of equipment.

The programme focuses on extended hardware and software

maintenance, cross-subsidiary reuse of technical equipment,

and the acquisition of reconditioned equipment. Key initiatives

within the OSCAR framework include:

•

Collaborating with equipment suppliers to measure and

reduce natural resource impacts while fostering an

ecosystem that prioritises reuse. Suppliers such as

Nokia, Ericsson, and Juniper have officially committed

to providing refurbished equipment under contractual

agreements. Partnerships with BuyIn and the Joint

Alliance for CSR (JAC

18

) further reinforce these efforts

by integrating circular economy principles into supply

chains.

•

Planning the decommissioning of technical equipment

to enable reuse within the Group and operating an

internal marketplace for reconditioned equipment.

This approach yields significant CapEx savings by allowing the

purchase of reconditioned equipment at lower costs and

reducing the need for new investments when existing equipment

within the Group meets operational needs.

In 2023, several projects were initiated to refine the list of eligible

equipment, accounting for product-specific conditions, and to

define processes for decommissioning and destocking. These

efforts aim to highlight equipment available for reuse from other

Group subsidiaries or external sources, further advancing

Orange’s circular economy ambitions.

5.

Encouraging responsible use

Launched in October 2020, the RE programme is designed to

promote responsible consumption and usage of terminals by

17

BuyIn is a joint-venture of Orange SA with Deutsche Telekom.

18

For more details, see

https://jointallianceforcsr.org/about-us/#jac

encouraging customers to recycle, participate in take-back

initiatives, or purchase reconditioned equipment. Through a

combination of product and service offerings, the programme

raises awareness about sustainable practices. In 2023, this

initiative was introduced in Belgium and Luxembourg, marking a

significant step in extending its reach.

Additionally, the Circular Mobility offer supports this mission by

incentivising moderation in mobile data usage through a

thoughtfully structured pricing model, further reinforcing the

principles of responsible consumption.

6.

Adding value to fixed customer equipment under

leasing contracts (boxes, decoders, etc.)

Orange adds value to fixed customer equipment, such as

Liveboxes, SetTopBox, optical termination boxes (ONTs), and

modems, through a robust collection and reconditioning

initiative. This process targets equipment collected during after-

sales services, product generation migrations, or contract

terminations.

Central to this initiative is the ORBIT management tool, which

provides end-to-end traceability for reverse operations, from

collection to recycling. ORBIT enhances cost efficiency and

resilience in Orange’s supply chain, particularly in response to

challenges such as electronic component shortages, rising

prices, and extended delivery times for new products.

The programme focuses on recovering and repurposing as much

equipment as possible. Retrieved devices are sorted, tested,

repaired, reset, and reconditioned for reuse, reducing the need

for manufacturing new products. Equipment deemed unsuitable

for repair or reconditioning is processed through recycling chains

for material recovery.

In Belgium, this initiative is bolstered by a long-term collaboration

with "Out of Use," managed under the guidance of the supply

chain department. The process is fully operational and

undergoes continuous improvement to maximise efficiency and

sustainability.

7.

Collecting used mobile phones

As a mobile operator and distributor, Orange recognises its

responsibility to collect used mobile phones, addressing the

staggering number of inactive devices, estimated at 5 billion

globally,

according

to

the

Global

System

for

Mobile

Communication (GSMA). The goal is to maximise the recovery of

these devices, either by giving them a second life when they

remain usable or by directing them to appropriate recycling

channels when they are obsolete.

Orange facilitates this collection through various means,

including buy-back programmes, "eco-citizen" initiatives without

commercial transactions, and after-sales services. In Belgium,

the initiative is carried out in collaboration with Recupel, the

national federation for responsible collection of electronic

devices.

In the short term, Orange aims to expand its collection channels

across Europe, prioritising customer buy-back programmes.

Additionally, the company is promoting mobile leasing solutions

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137

for its business customers, a strategy that simplifies the recovery

process compared to traditional handset sales. This dual

approach aligns with Orange’s commitment to reducing

electronic waste and fostering a circular economy.

8.

Cooperating with suppliers and peers to develop

circular economy principles

The development of a circular economy in the telecoms industry

requires a shift in business models and a collaborative effort

involving all stakeholders, particularly suppliers and peers.

Orange Group is actively engaging with its suppliers to

implement responsible purchasing programmes, incorporating

circular economy assessment criteria into its procurement

processes. These criteria include evaluating manufacturers’

capabilities to provide information on material composition (both

virgin and recycled), conduct life cycle analyses, ensure

extended maintenance periods for hardware and software

updates, and offer reconditioned equipment.

The OSCAR programme, described above, aims at involving

suppliers in a model that integrates circularity into information

and network systems infrastructure through the purchase of

reconditioned equipment, its internal reuse and resale. Aligned

with the GHG emission challenges of Orange's strategic plan,

this programme innovates in a market historically based on a

linear rather than circular model.

At industry level, 21 operators have been participating in the Joint

Alliance for CSR (JAC) working group on the circular economy

since January 2025. Methodologies are being structured and

standardised, with a presentation made at the JAC general

meeting on 1 October, 2025, confirming the industry's interest in

the circularity of information systems and network equipment,

routers and smartphones. An initiative has been underway since

2024 by the Orange, Telefonica and Nokia consortium (and

supported by the United Nations). It aims to develop and deploy

a

marketplace

interconnecting

industry

stakeholders

to

accelerate the development of the secondary market and extend

the life of electrical and electronic equipment, a major lever for

decarbonisation in the telecommunications industry.

In Belgium, such cooperation with peers exists with for instance

Orange Belgium sharing with another major operator, the Mwingz

entity for the mutualisation of mobile network. The Belgian

Institute for Post and Telecom (BIPT) also produces an annual

report on the sustainability market practice of all Belgian

operators. A next possible step could consist of facilitating such

cooperation around circular economy levers.

9.

B2B / Wholesale

In the business-to-business (B2B) and Wholesale segment in

2025, Orange Belgium set up a tracking of Customer Premises

Equipment (CPE) and assessment of strategies to enhance their

lifecycle. From 2026 onwards, the focus will shift to implementing

innovative circular business models to align with the principles of

the circular economy. Resource depletion

Orange is a service company that purchases its equipment from

suppliers with long and complex value chains, which indirectly

exposes it to metal markets.

In 2023, Orange set up an internal working group to assess the

footprint of its assets in terms of critical materials and its level of

exposure to risks. This working group was tasked with defining

the potential impacts for Orange of supply tensions in the

Group's value chain, defining the Group's engagement priorities,

responding to upcoming non-financial reporting on incoming

flows, and addressing sovereignty issues.

In 2024, initial studies were conducted to assess the quantity of

metals present in equipment and infrastructure through the

Group's purchases, particularly metals for which China imposes

export restrictions, such as germanium (found in optical fibres)

and gallium (found in radio amplifiers in telecoms equipment

used in many applications), for which the financial exposure to

risk remains low as long as the geopolitical context does not

deteriorate further.

In 2025, following the identification of natural resources that

could be ‘material’ for Orange, the Group modelled the inflows

and outflows of 14 critical metals and aluminium present in its

electronic equipment. The aim of this modelling is to assess the

criticality of these metals in relation to Orange's economic

performance, to be able to analyse their environmental impacts

(GHG emissions, biodiversity, water consumption) and their

recycling potential within the framework of the European

Commission's Critical Raw Materials Act. The circular economy

action plans described above will help to reduce this impact.

Orange Group study is applicable to all its subsidiaries, including

Orange Belgium and Orange Communications Luxembourg.

Orange does not manufacture equipment or directly manage the

extraction of materials. As its role is limited to supply chain

management, the company works with suppliers to mitigate risks

related to supply disruption, corporate social responsibility and

reputation. Action plans will be further developed in the course

of 2026.

Obviously, monitoring and ensuring transparency of rare and

critical resources used in its operations is a priority for Orange.

Suppliers must ensure the traceability and transparency of

minerals from conflict zones and take measures to minimise

negative social and environmental impacts (Dodd-Frank Act).

Audits include evaluations of compliance with conflict mineral

regulations. Suppliers are also encouraged to limit and substitute

the use of scarce resources, use recycled materials and increase

transparency through a code of conduct and contractual clauses

on resource use. Suppliers are supported with tools to analyse

critical materials and guided by standards from organisations like

the International Telecommunication Union (ITU). Orange Group

partners with industries and public authorities to develop efficient

recycling processes for urban mines (e-waste), which are rich in

extractable minerals.

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138

2.2.2

Management of impacts, risks and opportunities related to

resource outflows / waste

2.2.2.1

Policies related to resource outflows / waste (E5-1)

The e

e

n

v

i

r

o

n

m

e

n

t

a

n

d

e

n

e

r

g

y

p

o

l

i

c

y

19

includes a component on

mitigation of the impacts of Orange’s activity, including the

management of its waste. In line with the European waste

hierarchy concept, Orange’s approach to waste prevention and

management, both for its own needs and for those of its

customers, is based on preventing waste from being waste and

extending the life of equipment, in particular through reuse and

the optimisation of end

‑

of

‑

life treatment by opting preferentially

for recycling, and on other types of recovery, including energy

recovery and controlled disposal as a last resort.

At a more granular level on waste management, the environment

and energy policy is broken down into the p

p

o

l

i

c

y

o

n

t

h

e

t

r

e

a

t

m

e

n

t

o

f

h

o

u

s

e

h

o

l

d

a

n

d

p

r

o

f

e

s

i

o

n

a

l

W

a

s

t

e

E

l

e

c

t

r

i

c

a

l

a

n

d

E

l

e

c

t

r

o

n

i

c

E

q

u

i

p

m

e

n

t

(

W

E

)

a

s

w

e

l

a

s

b

a

t

e

r

y

w

a

s

t

e

2

0

, published in 2023.

WEEE from end

‑

of

‑

life equipment and waste batteries is, for the

most part, considered hazardous waste under environmental

regulations and is significant in the Group’s activity. This policy

aims to define the priority issues and to identify the operational

measures to address them, with regional operating practices

covering:

•

Risk management and the Group’s compliance with

applicable regulations;

•

Specific commitments for equipment recovery and

treatment;

•

The management model with a view to optimising

performance.

Its scope of application is that of all Group entities, including

Orange Belgium and Orange Communications Luxembourg. Like

for the environment and energy policy, the same governance

structure and stakeholders’ involvement apply.

By rolling out its Electric and Electronic Equipment Waste policy,

Orange Belgium and Orange Communications Luxembourg are

ensuring reliable collection of electronic equipment and batteries,

aligning closely with the European Union's 2000/532/EC1

classification for compliance.

As for the environment and energy policy, this specific waste

policy is published on the official website, making it accessible

to the public and ensuring that all potentially affected

stakeholders can review it, and with regular communication

about the possible updates on the company’s commitments and

progress (including training, workshop, feedback loops, etc.).

2.2.2.2

Targets related to resource outflows and waste (E5-3)

Orange Group is implementing a new monitoring indicator to

ensure that its WEEE and batteries are treated appropriately in

accordance with European and local regulations. Orange aims to

ensure that 100% of WEEE and batteries collected are sent to

approved treatment providers by 2030 across the Group. Orange

Belgium and Orange Communications Luxembourg participate

to this target. Reporting on this target will begin in 2026.

Subsidiaries monitor several KPIs related to waste management,

such as the volumes of different types of waste per location or

business (network infrastructures, offices, shops, etc.). The more

Orange can understand and trace the waste generation from the

different sources of waste, the better it can work with waste

collector partners on optimisation of sorting per site, frequency

of collection, and on the optimisation of reuse, refurbished and

recycling treatments.

2.2.2.3

Metrics related to resource outflows and waste (E5-5)

In 2025, Orange Belgium and Orange Communications

Luxembourg generated a total of 2,032,320 kg of waste,

encompassing both hazardous and non-hazardous categories,

of which 96% was diverted from disposal for recycling, reuse and

recovery.

This waste originates from the company’s operations and

activities across the telecommunications sector. This sector

generates several distinct waste streams, reflecting the

complexity and diversity of the equipment and materials used.

H

a

z

a

r

d

o

u

s

w

a

s

t

e

includes:

•

WEEE (Waste of Electrical and Electronic Equipment):

end-of-life network equipment (e.g., routers, modems,

antennas) and customer-related devices.

•

Hazardous batteries: Both large (>5 kg) and small (<5

kg) batteries and accumulators.

19

The Group Environment and Energy Policy:

https://mastermedia.dam-broadcast.com/medias/domain12751/media101367/410206-099fde5djo-75.pdf

20

Available here:

https://gallery.orange.com/en/element?id=411895

•

Ink and toner cartridges: Waste from office operations.

•

Wooden poles: Treated wood from Radio Access

Network (RAN) maintenance.

•

Other hazardous waste: Items like TL tubes (fluorescent

lamp) and treated wood, which require specialised

disposal.

N

o

n

-

h

a

z

a

r

d

o

u

s

w

a

s

t

e

originates from a variety of operations,

including network builds, maintenance, and office activities.

Examples include:

•

Metal poles: from RAN maintenance.

•

Network cables: Includes copper and fibre cables.

•

Paper and cardboard: Waste from offices, shops, and

network sites.

138

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Annual report 2025

139

•

Other non-hazardous waste encompasses iron, scrap

metal, aluminium, copper, cables, steel, soft plastics,

rubber, demolition waste (unsorted), wood (packing,

floors, structures, …), chemical small waste (ex. empty

pain cans) residual waste, and electronic components

like Printed Circuit Boards (PCBs).

Waste

2024

2025

Total amount by weight diverted from disposal

3,488,215 kg

1,952,231 kg

Weight of hazardous waste diverted from disposal

605,735 kg

489,028 kg

Of which waste diverted by preparation for reuse

9,770 kg

29,128 kg

Of which waste diverted by recycling

590,788

kg

408,120 kg

Of which waste diverted by other recovery options

5,177

kg

51,779 kg

Weight of non-hazardous waste diverted from disposal

2,882,480 kg

1,463,203 kg

Of which waste diverted by preparation for reuse

0 kg

Of which waste diverted by recycling

2,590,100 kg

673,656 kg

Of which waste diverted by other recovery options

292,380 kg

789,548 kg

Total amount by weight directed to disposal

17,090 kg

80,089 kg

Weight of hazardous waste directed to disposal

1,350 kg

21,119 kg

Of which waste

directed to disposal by incineration

1,350 kg

5,915 kg

Of which waste directed to disposal by landfill

0 kg

Of which waste directed to disposal by other disposal operations

0 kg

15,204 kg

Weight of non-hazardous waste directed to disposal

15,740 kg

58,970 kg

Of which waste

directed to disposal by incineration

15,740 kg

58,891 kg

Of which waste directed to disposal by landfill

0 kg

80 kg

Of which waste directed to disposal by other disposal operations

0 kg

Total amount of waste

3,505,305 kg

2,032,320kg

Total amount of hazardous waste

607,085 kg

510,147kg

Total amount of radioactive waste

-

Total amount of non-recycled waste

324,417 kg

950,544 kg

Percentage of non-recycled waste

9.3%

47%

T

a

b

l

e

7

:

W

a

s

t

e

b

r

e

a

k

d

o

w

n

b

y

h

a

z

a

r

d

o

u

s

a

n

d

n

o

n

-

h

a

z

a

r

d

o

u

s

w

a

s

t

e

a

n

d

t

r

e

a

t

m

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y

p

e

In 2025, focus was set on improving coverage and data reliability.

It remains an ongoing process, but data traceability is increasing

through certificates from waste contractors detailing volumes

and treatment methods. The observed decrease in waste

generated in 2025 is largely due to 2 projects that occurred

mainly in 2024 and generated significant waste: the VOO

acquisition, which required technical storage cleaning and

sorting (electronics, paper & cardboard, other non-hazardous)

and the decommissioning of the 3G network (network cables and

electronics). At that time, additional containers were rented to

enable proper sorting, contributing to the high recycling rate in

2024. Part of the variation is also explained by improved

coverage of waste data.

M

E

T

H

O

D

O

L

O

G

I

C

A

L

N

O

T

E

The methodologies used to calculate resource outflows focus on key products and materials that are designed along circular

principles. This includes attributes such as durability, reusability, repairability, disassembly, remanufacturing, refurbishment,

recycling, and optimisation of use through circular business models.

To justify the classification of these products as circular, the following criteria and assumptions are applied:

•

Durability: The estimated lifespan of products is based on historical performance data and manufacturer specifications,

ensuring that products are designed to last longer than typical market standards.

139

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Annual report 2025

140

•

Reusability and repairability: Products are evaluated based on design features that facilitate easy disassembly and repair.

This assessment is informed by industry standards and best practices, such as the ease of accessing components for

repairs.

Recycling rates: the potential for recycling is assessed using data from recycling partners and industry benchmarks, indicating the

percentage of materials that can be effectively recycled at the end of the product's life.

Key assumptions for these calculations include:

•

Assumption of product lifespan: Based on average usage patterns and historical data.

•

Assumption of repairability: Based on design analysis and feedback from repair service providers.

The methodologies used to calculate waste generated focus on the total waste produced during the production process, including

both hazardous and non-hazardous waste. This data is collected through direct measurement of waste outputs at production

facilities, with estimations applied for the last quarter of the year. Orange uses a combination of direct measurements and estimates

to calculate waste data.

Direct measurements: data is sourced from key suppliers through regular audits and reporting.

•

Estimation methodology: The last quarter of 2025 data is estimated using an average of October and November months

on volumes and treatment method. The core sites and the Radio Access Network (RAN) collaborate with several

subcontractors, who provide quarterly reports including such information.

•

Treatment type distribution: In cases where the distribution by treatment type was not available, we applied the treatment

methods used for similar waste types processed by other subcontractors. As of the end of 2025, a clause is included in

all supplier contracts requiring them to report on volumes and treatment method and further progress is expected.

Key assumptions for this calculation include:

•

Waste composition analysis: Conducted to determine the types of waste generated, which informs whether waste is

categorised as hazardous or non-hazardous. In this assessment, we rely on the European Waste Code, which provides a

classification system to identify the hazardous nature of waste based on its composition and properties.

•

Regulatory compliance: Assumptions regarding compliance with local waste management regulations influence waste

categorisation and reporting.

At Orange Belgium, waste data are reported data from waste treatment service providers until November, while December data is

estimated. Mobile devices weights are estimated using the average phone weight per item collected.

At Orange Communications Luxembourg, some waste treatments are estimated, but all volumes are based on reported data from

waste treatment service providers.

2.2.2.4

Taking actions on resource outflows and waste (E5-2)

The waste related action plans are structured around three key themes, reflecting a Group-wide approach implemented across all

European entities. These actions are part of an ongoing continuous improvement process without a fixed timeframe.

140

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141

D

a

t

a

g

o

v

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r

n

a

n

c

e

a

n

d

i

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t

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r

n

a

l

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e

p

o

r

t

i

n

g

•

Enhance the r

r

e

l

i

a

b

i

l

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y

o

f

w

a

s

t

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r

e

p

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t

i

n

g

a

n

d

t

r

a

c

e

a

b

i

l

i

t

y

in

compliance

with

the

regulatory

framework, the Group’s policy, and the capabilities of

industrial players.

•

Promote the use of services provided by the Group to

streamline processes and r

r

e

d

u

c

e

d

u

p

l

i

c

a

t

i

o

n

, ensuring

simplified tracking and tracing of waste information.

Waste treatment providers and processes

•

S

e

l

e

c

t

s

e

r

v

i

c

e

p

r

o

v

i

d

e

r

s

based on their recovery

performance and ability to ensure detailed traceability

of waste from collection to end-of-life.

•

Collaborate with current waste treatment service

providers to achieve a h

h

i

g

h

e

r

l

e

v

e

l

o

f

t

r

a

c

e

a

b

i

l

i

t

y

. A E

E

S

G

c

l

a

u

s

e

has been issued and communicated to these

providers.

•

Manage waste following the waste hierarchy and

avoiding at all costs disposal and incineration without

heat recovery. As examples, Orange Belgium intends to

m

a

x

i

m

i

s

e

i

t

s

r

e

u

s

e

o

f

o

f

i

c

e

q

u

i

p

m

e

n

t

. As a result, the

potential for re-use of building materials, finishings and

technical equipment within the scope of property works

is systematically studied for projects of more than

1,000 m

2

by carrying out resource diagnostics of

existing buildings. Circular economy clauses have been

included in invitations to tender and contracts with

property service providers to encourage companies to

reuse materials. Orange Communications Luxembourg

being a small structure, office and shop waste are

limited. As they do not represent the most material

issue to this entity, they are not subject to an action

plan. Nevertheless, they are monitored quarterly.

Additionally, c

c

i

r

c

u

l

a

r

e

c

o

n

o

m

y

c

l

a

u

s

e

s

have been

incorporated into tender invitations and contracts with

property service providers to promote the reuse of

materials.

•

Efforts also include minimising f

f

o

d

w

a

s

t

e

in the

company restaurant.

•

By collecting old phones and ensuring proper sorting

and recycling, Orange reduces the amount of e

e

l

e

c

t

r

o

n

i

c

w

a

s

t

e

ending up in landfills or incinerators. This

initiative not only contributes to effective waste

management but also facilitates the recovery of

valuable materials, minimising the need for new

resource extraction.

•

This waste management strategy is an o

o

n

g

o

i

n

g

p

r

o

c

e

s

,

underpinned by a commitment to continuous

improvement and a clear waste hierarchy prioritising

prevention as the first and foremost action. If waste

cannot be avoided, reuse is considered as the next best

option. When neither prevention nor reuse is feasible,

recycling becomes the preferred approach, with

disposal undertaken only as a last resort. This

structured hierarchy guides through a more sustainable

and efficient approach to waste reduction.

•

Orange Communications Luxembourg being a small

structure, office and shop waste are limited. As they do

not represent the most material issue to this entity, they

are not subject to an action plan. Nevertheless, they are

monitored quarterly.

Recovery process improvement plan

•

Roll out policies and operational procedures to

strengthen and ensure reliable collection of electronic

equipment and batteries, aligning closely with the

European

Union

2000/532/EC1

classification

for

compliance and consistent data reporting.

•

Enhance collection processes in collaboration with the

supply

chain,

logistics

teams,

and

all

Group

stakeholders (e.g., Re Programme).

•

Refine processes for reconditioning and reusing

customer equipment (e.g., boxes, mobile phones),

networks

(e.g.,

OSCAR

programme),

and

non-

electronic waste (e.g., furniture reuse services).

•

Reinforce the principle of testing equipment to confirm

it is no longer reusable before assigning it waste status.

•

Facilitate the creation of a sharing community and the

introduction of business reviews to monitor this activity

are planned.

Actions described are driven by the Group and implemented to

all European entities. Therefore, they cover both Orange Belgium

and Orange Communications Luxembourg. They are part of a

continuous improvement process and have no fixed timeframe.

Orange Belgium and Orange Communications Luxembourg have

made significant progress in implementing waste management

practices aimed at reducing environmental harm and addressing

material impacts. These actions are part of a continuous effort to

mitigate the negative effects of waste on both the environment

and communities. While specific remedies for individuals or

communities affected by actual material impacts are still under

development, the following measures highlight the ongoing

efforts:

•

I

m

p

l

e

m

e

n

t

a

t

i

o

n

o

f

W

E

p

o

l

i

c

y

:

Orange Group has

established a comprehensive waste management

policy that outlines the company's commitment to

minimising waste generation and promoting recycling

and recovery. This policy is designed to address the

negative impacts of WEEE on the environment and

communities.

•

C

o

l

e

c

t

i

o

n

a

n

d

r

e

c

y

c

l

i

n

g

i

n

i

t

i

a

t

i

v

e

s

:

Orange Group has

initiated programmes for the collection and recycling of

waste, particularly focusing on Waste Electrical and

Electronic Equipment (WEEE) and batteries. These

initiatives aim to reduce the environmental impact of

discarded

electronic

devices

and

ensure

that

hazardous materials are managed properly.

•

P

a

r

t

n

e

r

s

h

i

p

s

w

i

t

h

r

e

c

y

c

l

i

n

g

o

r

g

a

n

i

s

a

t

i

o

n

s

:

Orange

Belgium and Orange Communications Luxembourg

collaborate with various recycling organisations and

service providers for the collection and treatment of

waste streams, in line with applicable regulatory

requirements.

•

M

o

n

i

t

o

r

i

n

g

a

n

d

r

e

p

o

r

t

i

n

g

:

Orange Belgium and Orange

Communications

Luxembourg

have

implemented

systems to monitor and report on waste management

performance, including the volume of waste collected,

recycled, and disposed of.

141

Orange Belgium

_

Annual report 2025

142

While specific metrics on the direct progress by these initiatives

in reducing environmental and communities’ impact are not yet

available, the ongoing waste management efforts lay the

foundation for future actions. Orange is committed to

continuously enhancing its waste management practices and

exploring ways to provide support to communities impacted by

waste-related issues.

2.3

The EU Taxonomy

For the financial year ending 31 December 2024, Orange Belgium

and Orange Communications Luxembourg published, for their

entire financial consolidation scope, performance indicators

relating to the share of their eligible and aligned turnover, capital

expenditure (CapEx) and operating expenditure (OpEx) resulting

from products and/or services associated with economic

activities considered sustainable within the meaning of Article 8

of Regulation (EU) 2020/852 of the European Parliament and of

the Council of 18 June 2020 on the establishment of a framework

to facilitate sustainable investment in the European Union and

Delegated Regulations 2021/2139, 2021/2178, 2023/2485 and

2023/2486 of the Commission (hereinafter collectively referred to

as the ‘European Taxonomy’).

From the financial year ending 31 December 2025, Orange

Belgium and Orange Communications Luxembourg have chosen

to apply Delegated Regulation 2026/73 of 4 July 2025. In this

context, the company has analysed its activities to determine

their eligibility under the European Taxonomy. This analysis

concluded that Orange Belgium's and Orange Communications

Luxembourg’s main activities, corresponding to its core

business, are not currently included in the scope covered by the

European Taxonomy and that the other activities that may be

eligible are not material in nature.

The analysis was carried out and materiality was assessed

individually for each of the taxonomy's performance indicators.

Economic activities representing cumulatively less than 10% of

turnover, CapEx or OpEx were not subject to a detailed eligibility

and alignment analysis, in accordance with the materiality

threshold provided for in Delegated Regulation 2026/73 of 4 July

2025.

Turnover

The analysis of turnover shows that the provision of connectivity

services (convergent services, mobile-only services and fixed-

only services) to residential customers, businesses and other

telecommunications operators is Orange’s main activity. These

connectivity services are not included in the European Taxonomy

in accordance with the provisions of the Delegated Regulations

in force.

Among the turnover excluding connectivity services, the total

turnover that can be attributed to eligible activities is considered

immaterial (less than 10%) and mainly concerns Data-driven

solutions for GHG emissions reductions (CCM 8.2), the Sale of

second-hand goods (refurbished mobile phones) (EC 5.4) and

Product-as-a-service and other circular use- and result-oriented

service models (rental of routers and decoders) (EC 5.5). As these

activities are immaterial, Orange no longer publishes details of

turnover relating to activities that may be eligible and aligned with

the European Taxonomy.

The share of the companies’ turnover relating to unmeasured

activities considered immaterial, presented in the table below, is

determined by dividing the sum of the turnover from eligible

activities by the consolidated turnover (prepared in accordance

with IFRS 15) presented in section 2.1 Consolidated income

statement.

Capital expenditure (CapEx)

An analysis of the companies’ investments shows that the

majority of CapEx is devoted to the deployment of infrastructure

necessary

for

the

operation

of

fixed

and

mobile

telecommunications networks.

As these activities do not currently fall within the scope of the

European Taxonomy, most of Orange’s investments are

considered ineligible.

CapEx relating to other activities that may be eligible under the

European Taxonomy cumulatively represent less than 10% of

CapEx and are therefore considered immaterial. These activities

mainly concern the Transport by motorbikes, passenger cars and

light

commercial

vehicles,

as

well

as

the

Installation,

maintenance and repair of charging stations for electric vehicles

in buildings (and parking spaces attached to buildings) (CCM 6.5

and CCM 7.4), Installation, maintenance and repair of

instruments

and

devices

for

measuring,

regulation

and

controlling energy performance of buildings (CCM 7.5) as well as

repair, refurbishment and remanufacturing (CE 5.1).

Consequently, in accordance with the materiality threshold

provided for in the regulations, Orange does not publish details

of CapEx relating to these activities.

Capital expenditure as defined by the European Taxonomy

should be distinguished from the economic CapEx operational

indicator (‘eCAPEX’) as published in the financial statements,

which corresponds to the acquisition of intangible and tangible

assets excluding telecommunications licences and financed

asset investments, less the disposal price of fixed assets (Note

19 Glossary – Financial KPIs). Details of Orange’s CapEx are

provided in Note 2.1 Consolidated income statement.

Operating expenditure (OpEx)

A quantitative analysis of OpEx within the meaning of the

European Taxonomy shows that these are not representative of

Orange’s business model, as they are linked to consolidated

revenue, which mainly consists of activities that are currently

ineligible. Furthermore, most OpEx is intended to maintain assets

(fixed and mobile telecommunications networks) that are not

included in the eligibility scope of the European Taxonomy.The

OpEx indicator as defined by the European Taxonomy is not

material in Orange’s economic model, in line with the

immateriality of the turnover and CapEx performance indicators.

As a result, the companies no longer publish details of OpEx

relating to activities that may be eligible and aligned with the

European Taxonomy.

142

Orange Belgium

_

Annual report 2025

The analysis of the eligibility of the various economic sectors for each turnover, CapEx and OpEx indicator may evolve in line with the progress of the European Commission's

work.

K

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)

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%

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R

%

Turnover

1,963

-

5.20%

66.2

3.30%

CapEx

415

-

3.60%

1.6

0.4%

OpEx

108

-

5.2

5.6%

T

a

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e

8

:

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g

*Percentage calculated on data as of 30 November 2025. Due to the linearity of the activity, this period is representative, and the possible impact of December is considered

not significant.

143

Orange Belgium

_

Annual report 2025

144

3.

Social information

3.1

Human rights

3.1.1

Orange Group human rights

3.1.1.1

Human Rights Policy

Orange Group's H

H

u

m

a

n

R

i

g

h

t

s

P

o

l

i

c

y

21

provides the overall

framework for the company's commitments regarding human

rights. It is based on f

f

i

v

e

k

e

y

a

r

e

a

s

and adopts a thematic

approach rather than a target-based one, due to the cross-

cutting nature of the issues addressed.

21

Orange Group's Human Rights Policy is available here:

https://mastermedia.dam-broadcast.com/medias/domain12751/media101367/410239-quw8t3woit-75.pdf

144

Orange Belgium

_

Annual report 2025

145

The areas are as follows:

1.

Promote d

d

i

g

i

t

a

l

c

i

t

i

z

e

n

s

h

i

p

to enable equitable access

to

telecommunications

services,

make

inclusion

through and with digital technology a pillar of Orange’s

societal engagement, and work towards ethical,

inclusive, and responsible innovation;

2.

Work to r

r

e

s

p

e

c

t

p

r

i

v

a

c

y

a

n

d

f

r

e

d

o

m

o

f

e

x

p

r

e

s

i

o

n

to

ensure customers' data and digital identities are

protected, raise awareness about risks related to the

exploitation of digital data, and uphold the right to

privacy and freedom of expression;

3.

Act a

a

g

a

i

n

s

t

d

i

s

c

r

i

m

i

n

a

t

i

o

n

a

n

d

f

o

r

e

q

u

a

l

o

p

o

r

t

u

n

i

t

i

e

s

to promote recognition of everyone’s differences and

develop actions supporting equal chances;

4.

Ensure d

d

e

c

e

n

t

w

o

r

k

i

n

g

c

o

n

d

i

t

i

o

n

s

a

n

d

t

r

u

s

t

w

o

r

t

h

y

b

u

s

i

n

e

s

p

r

a

c

t

i

c

e

s

to provide a safe and healthy work

environment for all employees across all countries

where the Group operates, to uphold human rights in all

activities—including those of suppliers, subcontractors,

affected communities, consumers, and end-users—

and to act with honesty, integrity, and loyalty in

conducting its activities;

5.

Mitigate the e

e

n

v

i

r

o

n

m

e

n

t

a

l

i

m

p

a

c

t

s

related to Orange’s

activities to promote a holistic approach to human

rights and the environment and ensure that its activities

d

o

n

o

t

h

a

r

m

t

h

e

h

e

a

l

t

h

o

f

l

o

c

a

l

c

o

m

u

n

i

t

i

e

s

.

Orange Group is dedicated to respecting and promoting human

rights and fundamental freedoms within its sphere of influence,

in accordance with the commitment made upon signing the

United Nations Global Compact in July 2000 and reaffirmed

annually since then. This approach a

a

p

l

i

e

s

t

o

a

l

i

t

s

t

a

k

e

h

o

l

d

e

r

s

a

c

r

o

s

i

t

s

e

n

t

i

r

e

v

a

l

u

e

c

h

a

i

n

a

n

d

t

h

r

o

u

g

h

o

u

t

a

l

i

t

s

t

e

r

i

t

o

r

i

e

s

o

f

o

p

e

r

a

t

i

o

n

, in line with the fundamental principles outlined in all

above mentioned international human rights standards. All the

commitments made by the Group are explicitly stated in its Code

of Ethics, its Human Rights Policy, which is guided by the three

UN principles on business and human rights: p

p

r

o

t

e

c

t

,

r

e

s

p

e

c

t

,

a

n

d

r

e

m

e

d

y

,

and are also reflected in Orange's Supplier Code of

Conduct.

These commitments are implemented through, for instance:

•

N

o

n

-

d

i

s

c

r

i

m

i

n

a

t

i

o

n

:

Orange

enforces

strict

non-

discrimination

policies

in

recruitment,

career

management, and working conditions, in accordance

with International Labour Organization (ILO) Convention

C111. These policies are supported by a global

agreement signed in 2019 to promote equality and

combat

discrimination,

reinforced

by

reporting

mechanisms (Hello Ethics) and training programmes.

•

H

e

a

l

t

h

a

n

d

s

a

f

e

t

y

: Since 2006, Orange has applied a

global agreement on health and safety to ensure

employee protection in compliance with local laws and

international

standards.

Preventive

and

remedial

measures are implemented to guarantee safe and

healthy working conditions. The Group's Health, Safety,

Quality of Life, and Working Conditions Policy explicitly

references recommendations from the World Health

Organization (WHO) and ILO conventions.

•

S

o

c

i

a

l

d

i

a

l

o

g

u

e

: Orange fully recognises the rights of

association and collective bargaining, in line with ILO

Convention C87. Structured mechanisms for social

dialogue, such as European Works Councils, ensure

equitable employee representation.

•

M

o

n

i

t

o

r

i

n

g

p

r

o

c

e

s

e

s

:

Regular audits, performance

indicators, and impact assessments ensure the

effectiveness and compliance of these policies with the

UN Guiding Principles on Business and Human Rights

(UNGP).

Orange ensures compliance with international human rights

standards while r

r

e

s

p

e

c

t

i

n

g

l

o

c

a

l

a

w

s

a

n

d

r

e

g

u

l

a

t

i

o

n

s

.

The Orange Group's human rights policy is aligned with

i

n

t

e

r

n

a

t

i

o

n

a

l

f

o

u

n

d

a

t

i

o

n

a

l

p

r

i

n

c

i

p

l

e

s

:

•

The Universal Declaration of Human Rights;

•

The International Covenant on Economic, Social and

Cultural Rights;

•

The International Covenant on Civil and Political Rights;

•

The United Nations conventions on the elimination of all

forms of discrimination against women, on the rights of

the child, on the rights of persons with disabilities, and

on the elimination of all forms of racial discrimination.

Orange's Human Rights policy adheres to several t

t

h

i

r

d

-

p

a

r

t

y

s

t

a

n

d

a

r

d

s

and initiatives, including the United Nations Guiding

Principles on Business and Human Rights, the Organisation for

Economic Co-operation and Development (OECD) Guidelines for

Multinational Enterprises, the United Nations Global Compact

(UNGC), and the International Labour Organization Declaration

on Fundamental Principles and Rights at Work. It also complies

with the Modern Slavery Acts, notably the United Kingdom and

Australian laws, and follows the principles of the Global Network

Initiative (GNI) for privacy and freedom of expression.

Additionally, Orange participates in the Joint Alliance for CSR

(JAC), which audits suppliers for sustainability compliance,

adheres to the Responsible Business Alliance (RBA) Code of

Conduct for key suppliers, and supports the International Charter

for Inclusive AI.

All the commitments made by the Group are explicitly stated in

its Code of Ethics and its Human Rights Policy, which is guided

by the three UN principles on business and human rights:

protect, respect, and remedy, and are also reflected in Orange's

Supplier Code of Conduct and in Orange’s Customer Code of

Conduct.

The scope of application of the Human Rights policy

encompasses all entities and subsidiaries of the Orange Group,

across all geographies, including Belgium and Luxembourg. It

applies

to

employees,

suppliers,

commercial

partners,

customers, civil society, investors, authorities, and international

organisations.

The most senior level accountable for implementing the Human

Rights policy is the Group Governance and Corporate Social and

Environmental Responsibility Committee (CGRSE), which reports

directly to the Group Board of Directors. This committee

oversees the policy's application, ensures alignment with

Orange's ethical charter, and supervises the implementation of

compliance programmes.

Its operational implementation is carried out across various

departments (Human Resources, Purchasing Department,

General Secretary, etc.) through the implementation of policies

and operational documents associated with it (diversity, equity,

inclusion policy; health and safety policy; personal data

protection policy; supplier code of conduct, etc.).

145

Orange Belgium

_

Annual report 2025

146

The human rights policy was developed in consultation with

internal stakeholders (departments responsible for the topics

mentioned in the policy) and has been discussed with external

stakeholders who are experts in human rights and their impacts

on organisations. Their contributions, whether within this

framework or during discussions with generalist or specialised

think tanks and foresight laboratories, inform the action plans,

which are operational implementations of the five axes of the

policy.

Through its active participation and ongoing dialogues in multi-

stakeholders working groups of international and national

associations that promote respect for human rights in business

(Global Compact, ILO, etc.) or within the sector (Global System

for Mobile Communications Association (GSMA), International

Telecommunication Union (ITU), Global Network Initiative (GNI),

etc.), Orange further identifies and prioritises human rights issues

and promotes the Group’s positions.

The human rights policy is accessible online and its publication

in March 2024 was accompanied by numerous presentation

sessions within various Group entities (including Orange Belgium

and Orange Communications Luxembourg).

3.1.1.2

Focus on human trafficking, forced labour or compulsory labour and child

labour

Orange Group is firmly c

c

o

m

i

t

e

d

t

o

c

o

m

b

a

t

i

n

g

a

l

f

o

r

m

s

o

f

o

r

c

e

d

l

a

b

o

u

r

,

c

h

i

l

d

l

a

b

o

u

r

,

m

o

d

e

r

n

s

l

a

v

e

r

y

,

a

n

d

h

u

m

a

n

t

r

a

f

i

c

k

i

n

g

. This is particularly relevant for both its “own

workforce” and in its “value chain”. These commitments are

implemented across all entities, including Orange Belgium and

Orange Communications Luxembourg, and are formalised in

s

e

v

e

r

a

l

k

e

y

d

o

c

u

m

e

n

t

s

:

•

C

o

d

e

o

f

E

t

h

i

c

s

2

: Orange Group’s Code of Ethics

affirms that its principles of action and conduct align

with the Universal Declaration of Human Rights and the

conventions of the International Labour Organization

(ILO). These principles explicitly prohibit forced labour

and child labour.

•

H

u

m

a

n

R

i

g

h

t

s

P

o

l

i

c

y

: Orange’s Human Rights Policy

ensures decent working conditions and a safe and

healthy working environment for all employees,

regardless of their country of operation. The policy

includes specific measures to prevent child labour, in

compliance

with

international

conventions

(ILO

Conventions 138 and 182). Orange strictly prohibits the

employment of children under 15 years old (or a higher

age

if

required

by

local

regulations)

and

the

engagement of minors under 18 in hazardous or

strenuous work.

•

G

l

o

b

a

l

A

g

r

e

m

e

n

t

s

w

i

t

h

U

N

I

: Orange has signed three

global agreements with the international trade union

federation (UNI), applicable to all its entities, including

Orange

Belgium

and

Orange

Communications

Luxembourg. These agreements establish the following

principles: Prevention of forced labour and prohibition

of child exploitation; and Respect for fundamental

human rights, including workplace health and safety.

•

A

l

i

g

n

m

e

n

t

w

i

t

h

I

L

O

C

o

n

v

e

n

t

i

o

n

s

: Orange adheres to

ILO Conventions 29 and 105 on forced labour, as well

as Conventions 138 and 182 on minimum working age.

These commitments are implemented across all

Orange subsidiaries and supply chains, with regular

audits conducted to ensure compliance.

As part of the application of the fundamental

conventions of the ILO, Orange undertakes to take

particular care to:

o

Prevent the use of forced labour; prohibit child

labour and exploitation;

o

Combat discrimination;

o

Ensure occupational health and safety;

o

Respect freedom of association and the principle

of collective bargaining.

These formalisations highlight Orange Group's commitment to

upholding international labour standards and ensuring ethical

practices across its operations, and explicitly address trafficking

in human beings, forced labour or compulsory labour and child

labour.

Global agreements signed by Orange Group are binding for

Orange Belgium and Orange Communications Luxembourg.

22

The Group code of ethics is available here

https://mastermedia.dam-broadcast.com/medias/domain12751/media101361/408310-9e863d1neq-75.pdf

146

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_

Annual report 2025

147

3.1.2

Human rights for own workforce

Related to its own workforce, Orange in its Human Rights

Group’s policy commits to all elements already listed supra in

section

3.1.1 Orange Group human rights

, e.g. combating

discrimination; ensuring health and safety at work; and

preventing the use of forced labour; prohibiting child labour and

exploitation, all in line with the application of the ILO's

fundamental conventions. Orange is also committed to

respecting freedom of association and the principle of collective

bargaining. The principles set out in this policy apply to all

employees of Orange companies, including Orange Belgium and

Orange Communications Luxembourg.

Historically, Orange Group has signed t

t

h

r

e

g

l

o

b

a

l

a

g

r

e

m

e

n

t

s

related to human rights with the International Union Federation

(UNI).

•

The global agreement on f

f

u

n

d

a

m

e

n

t

a

l

s

o

c

i

a

l

r

i

g

h

t

s

within the France Telecom Group, signed in December

2006, is the Orange Group first global agreement. It

outlines

the

Group

commitments

to

respect

fundamental human rights.

•

The global h

h

e

a

l

t

h

a

n

d

s

a

f

e

t

y

agreement, signed in

November 2014, aims to help integrate health and

safety into all the Group's activities.

•

The global agreement on g

g

e

n

d

e

r

e

q

u

a

l

i

t

y

, signed in July

2019, aims to contribute to integrating professional

equality between women and men, the fight against

discrimination and violence, and work-life balance into

all the Group's activities by relying on structured local

social dialogue to enable the performance of local

assessments and the definition of appropriate action

plans.

In the event of proven violations, after investigations, remedial

measures are at the discretion of local Human Resources (HR)

management. Orange Belgium’s HR policies do respect the

national regulations prescribing clear procedure to follow in the

event of harassment described in the w

w

o

r

k

i

n

g

r

u

l

e

s

. Additionally,

Orange Belgium is compliant with the Belgian legislation and

international

human

resources

standards

including

discrimination

and

other

psychosocial

risks

(violence,

harassment, etc).

147

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148

Regarding s

s

o

c

i

a

l

d

i

a

l

o

g

u

e

,

the Voice Up employee barometer is

conducted at least once a year to better consider the needs,

feelings, and expectations of employees. Orange Belgium

engages with people in its own workforce including on human

rights concerns. In January 2025, Orange Belgium and Orange

Communications Luxembourg participated in the yearly Group

“Voice Up” survey. This survey also allows Orange Belgium to

benchmark not only within the Group but also with other

companies on the Belgian market. This survey contains a deep

dive into a series of questions relating to different themes such

as efficiency and performance, confidence in strategy, wellbeing,

diversity equity inclusion (DEI), career & development, culture &

engagement. The part on wellbeing and DEI contains different

questions related to discrimination, like “I am treated with respect

and dignity”, “My Company has created an environment where

people of diverse backgrounds can succeed”, “My Company

treats employees fairly regardless of their different backgrounds,

personal characteristics or other differences”, “I work in an

environment that is free from harassment and discrimination” and

“I can be myself at work (i.e., I can be my authentic self)”.

Effective respect for fundamental social rights is driven by the

following multiple actions implemented by Orange Group and/or

the UNI federation, p

p

r

o

v

i

d

i

n

g

r

e

m

e

d

y

for human rights impacts:

•

Trade

union

education

is

provided

jointly

by

management and the UNI when a new country enters

the Group’s scope based on Orange’s signed

agreements.

•

Direct dialogue during scheduled meetings or outside

these meetings, raised questions (through the conflict

resolution clause provided for in the agreement), and

escalations of collective bargaining, matters in all

Group companies or in subcontractors’ respect of

social rights (example during the Covid crisis,

concerning the way in which subcontractors ensured

the protection of their employees).

•

The implementation of a w

w

h

i

s

t

l

e

b

l

o

w

i

n

g

system (see

more details in section

4.1.1.1 Business conduct

policies and corporate culture (G1-1, G1-3)

) is available

to

employees

of

most

Group

entities

and

subcontractors, allowing them to report violations of

human rights and freedom of association, or of

personal health and safety.

This framework for action is regularly revised in line with changes

in the law, regulations and case law, and with feedback from local

entities in charge of dealing with the situations in question.

Further information regarding policies related to Orange’s

material topics for its own workforce can be found under sections

3.2.1 Orange’s own workforce (S1), 3.2.2.1 Policies related to

training and skills development (S1-1), 3.2.3.1 Policies related to

diversity (S1-1)

, and

3.2.4.1 Policies related to health and safety

(S1-1)

.

3.1.3

Human rights for consumers and end users

The Group's human rights policy includes a section on d

d

i

g

i

t

a

l

c

i

t

i

z

e

n

s

h

i

p

, which specifically addresses these positive impacts

related to inclusion, empowerment and equal opportunities.

Orange champions the idea of digital technology that can be

used for the social and economic development of all. For people

to be responsible digital citizens, exercise their fundamental

rights and develop in an increasingly digital world where

technologies are developing at an exponential rate, they must be

given the means to act consciously and confidently. This

approach aims to develop the positive impact of people's access

to telecommunications services. Further information on the

approach to digital inclusion can be found under section

3.3.2

Management of impacts, risks and opportunities related to digital

inclusion

under chapter

regarding 3.3 Orange’s consumers and

end-users (S4)

.

In addition, Orange’s C

C

h

i

l

d

r

e

n

’

s

R

i

g

h

t

s

a

n

d

P

r

o

t

e

c

t

i

o

n

i

n

t

h

e

D

i

g

i

t

a

l

A

g

e

p

o

l

i

c

y

23

builds on its Human Rights policy. By

recognising the specific rights of children and their vulnerability

to digital risks, Orange acknowledges that children, who are in a

key phase of development, are more sensitive to the effects of

prolonged screen exposure and age-inappropriate content,

which justifies the implementation of appropriate protective

measures.

Orange’s Children’s Rights and Protection policy was revised in

2025 to strengthen its ambition and address newly identified

challenges. This update notably includes:

23

It is available on Orange’s website:

https://gallery.orange.com/element?id=410245

•

Strengthening the fight against cyberbullying;

•

Raising employee awareness so that they themselves

become

active

contributors

to

prevention

and

awareness-raising efforts;

•

The explicit integration of the fight against online child

sexual exploitation and abuse, in partnership with the

authorities and specialised organisations.

These developments complement and enhance the f

f

i

v

e

f

o

u

n

d

i

n

g

p

r

i

n

c

i

p

l

e

s

o

f

t

h

e

p

o

l

i

c

y

:

1.

Orange offers and promotes the use of d

d

i

g

i

t

a

l

p

r

o

t

e

c

t

i

o

n

t

o

l

s

.

Orange provides solutions such as

parental controls and screen time management tools

adapted to the child’s age. Since 2025, the Group has

stepped up the development of tools and partnerships

to combat cyberbullying, in particular through support

services, the creation of secure spaces (“safe zones”)

in digital environments, and free support services for

victims;

2.

Orange provides education to stakeholders such as

parents, children and its employees with the keys to

understanding

the

digital

world.

Orange

offers

g

u

i

d

a

n

c

e

o

n

r

e

s

p

o

n

s

i

b

l

e

u

s

e

,

workshops

and

e

d

u

c

a

t

i

o

n

a

l

r

e

s

o

u

r

c

e

s

.

Since 2025, this approach has

been extended to employee training across all

geographies. In addition, Orange actively supports the

fight against online child sexual exploitation and abuse

by developing awareness-raising and prevention

148

Orange Belgium

_

Annual report 2025

149

initiatives in cooperation with the relevant authorities

and specialised organisations;

3.

Orange ensures that its c

c

o

m

e

r

c

i

a

l

,

m

a

r

k

e

t

i

n

g

a

n

d

c

o

m

u

n

i

c

a

t

i

o

n

s

t

r

a

t

e

g

y

respects children’s right to

protection. The company r

r

e

f

r

a

i

n

s

f

r

o

m

t

a

r

g

e

t

i

n

g

y

o

u

n

g

c

h

i

l

d

r

e

n

i

n

i

t

s

o

f

e

r

s

and communications, provides

services tailored to families, and applies an internal

charter on responsible representation;

4.

Orange works to make d

d

i

g

i

t

a

l

t

e

c

h

n

o

l

o

g

y

a

d

r

i

v

e

r

o

f

e

q

u

a

l

o

p

o

r

t

u

n

i

t

i

e

s

. Orange introduces children to

technology

through

several

programmes

with

Code&Play and the Orange Digital Center coding

schools. The Group also acts to promote the

feminisation of technical and digital professions, and

supports the education of disadvantaged young people

as well as the development of educational tools for

children with autism spectrum disorders;

5.

Orange ensures compliance with the principles of the

International

Labour

Organization

and

UNICEF’s

Children’s Rights and Business Principles regarding

child labour. Orange p

p

r

o

h

i

b

i

t

s

t

h

e

u

s

e

o

f

c

h

i

l

d

o

r

f

o

r

c

e

d

l

a

b

o

u

r

throughout its value chain and works to monitor

its suppliers and partners accordingly.

149

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Annual report 2025

150

The Children’s Rights and Protection in the Digital Age policy

applies across the entire scope of Orange Group, covering all its

subsidiaries, in all geographical regions, and involving all its

stakeholders.

The policy is endorsed and signed by the Group’s Executive

Director in charge of CSR, who is responsible for its

implementation.

Its governance and roll-out across the Group’s various entities

are supported by the Group Children’s Rights and Protection

Committee, which brings together Orange’s child protection and

sustainability managers from all geographies, as well as experts

in

public

affairs,

regulatory

matters,

marketing

and

communication.

The Children’s Rights and Protection in the Digital Age policy

complies with several reference frameworks, standards and

initiatives, including the United Nations Convention on the Rights

of the Child, UNICEF’s Children’s Rights and Business Principles

guidance to help companies improve children’s wellbeing

worldwide, and the United Nations Global Compact supporting

children’s fundamental rights.

Further information on the approach to the protection of

psychological health of end-users can be found under

section

3.3.3 Management of impacts, risks and opportunities related to

psychological health of end-users

under

chapter 3.3 consumers

and end-users (S4)

.

The Group bases its approach on ongoing, structured d

d

i

a

l

o

g

u

e

w

i

t

h

a

l

i

t

s

t

a

k

e

h

o

l

d

e

r

s

, particularly rights holders. It also draws

on coalitions (Global Network Initiative, Global Compact, JAC,

ILO, GSMA, Business for Human Rights).

In addition, Orange Group has established Hello Ethics, an alert

channel available to everyone, included for consumers and

stakeholders to report concerns or incidents affecting their rights,

it is also available in Orange Communications Luxembourg. At

Orange Belgium, external stakeholders can report concerns

through several channels, including a dedicated email address

and the federal ombudsman for external submissions This

mechanism is translated in Orange Belgium's whistleblowing

policy and approach (see more details infra in section

4.1.1.1

Business conduct policies and corporate culture (G1-1, G1-3)

).

Whether it is processed through Hello Ethics or through the

Orange Belgium’s whistleblowing (open to external stakeholders

as well), this is the way to provide remedy to actual issues.

Identification of impacts and the preventive measures related to

human rights impacts are part of duty of vigilance continuous

monitoring.

3.1.4

Human rights for workers in the value chain

At Group level, a global agreement on fundamental social rights

also includes provisions for personnel working in the value chain.

In order to apply it, Orange implements:

•

In terms of purchasing, the S

S

u

p

l

i

e

r

C

o

d

e

o

f

C

o

n

d

u

c

t

and the E

E

S

G

c

l

a

u

s

e

included in the contract remind

suppliers of their obligations in terms of freedom of

association,

non-use

of

child

labour,

non-

discrimination and diversity, inclusion, and non-use of

slavery and forced labour labour (

see section 4.1.2.2

Management of relationships with suppliers, building

trust and secure responsible supply (G1-2)

);

•

The whistleblowing system enables workers in the

value chain to report issues relating in particular to

violations of human rights and trade union freedoms or

to the health and safety of individuals (

see section

4.1.1.1 Business conduct policies and corporate

culture (G1-1, G1-3)

).

In terms of purchasing, the Supplier Code of Conduct and the

ESG clause incorporated into the contract remind suppliers of

their obligations in terms of freedom of association, non-use of

child labour, non-discrimination, diversity, inclusion, non-use of

slavery and forced labour, and sustainability audits. Prior

assessments or audits ensure that suppliers comply with these

principles. The ESG clause requires the suppliers to notify

Orange of any violations of the Supplier Code of Conduct and

international human rights frameworks of which they are aware,

to implement all appropriate measures to remedy such violations

and to inform Orange when such violations have ceased. Further

information can be found under

chapter

4.1 Business Conduct

(G1)

.

As defined in the following sections, Orange defines a concrete

action plan to pay close attention to the wellbeing of everyone.

The measures are designed to identify risks and prevent

violations of human rights and fundamental freedoms, the health

and safety of people and the environment. They apply to the

activities

of

Orange

Belgium

as

well

as

of

Orange

Communications Luxembourg, their subsidiaries, and to the

activities of their subcontractors and suppliers.

3.1.5

Human rights incidents (S1-17)

To Orange’s knowledge, no severe human rights issues or

incidents related to the own workforce were identified over the

past two years, and no fines or penalties were incurred during

this period. Similarly, no severe human rights issues or incidents

involving Orange’s consumers and end-users were reported over

the same timeframe.

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151

3.2

Orange’s own workforce (S1)

3.2.1

Management of impacts, risks and opportunities for the own

workforce

On top of the two main processes (engage with own workforce

about impacts, and remediate negative impacts), this section

covers the management of the following material topics related

to the own workforce, namely the training & skill development,

the diversity, and the health and safety. However, it does not

cover data privacy and cybersecurity issues. As these topics may

affect the company own workforce as much as consumers and

end-users, the management of these impacts, risks and

opportunities are described together in the next chapter relating

to consumers and end-users (S4) (see

section 3.3.4 Management

of impacts, risks and opportunities related to data privacy and

cybersecurity

).

3.2.1.1

Processes for engaging with own workers and workers’ representatives about

impacts (S1-2)

L

i

s

t

e

n

i

n

g

t

o

e

m

p

l

o

y

e

s

i

s

a

t

h

e

h

e

a

r

t

o

f

H

R

a

n

d

m

a

n

a

g

e

r

i

a

l

a

c

t

i

o

n

. This is an important step towards improving the Quality

of Life at Work, which enables Orange to better understand the

perception of the progress already made in the different areas of

the Group and within the different business lines, and to identify

areas for improvement in line with employees' expectations.

Orange Belgium

The team/department feedback received during the Voice Up

Group survey and Your Voice Belgium surveys are accessible to

the people managers, directors and the Chiefs (if above threshold

to ensure anonymity). A global analysis of the entire company is

shared with the Executive Committee and works council.

People managers and Directors are empowered to launch

specific action plans based on the team/department results in

cooperation with their People Manager or Business Partners. The

global analysis feeds more global action plans. At the launch of

every survey, a summary of the received feedback and actions

taken to respond thereto is provided to all employees, as

evidence of the “listen and respond” approach.

The above-mentioned surveys also allow Orange Belgium to

identify departments, divisions or even specific teams or

populations where there may be a more specific issue and take

appropriate actions where and when required.

Moreover, employees have also been involved by means of a

“needs & habits” based survey as well as workshops in the

decision-making process relative important decisions.

Orange Communications Luxembourg

The comments of teams/departments received during the Voice

Up Group survey and the regularly conducted LutherOne

surveys

24

, both of which collect employee input on working

conditions and managerial practices, are accessible to the

human resources director. A global analysis of the entire

company is shared with the Executive Committee.

People managers and Directors are empowered to initiate

specific action plans based on the team/department’s results.

24

LutherOne is an HR platform enabling employees to anonymously share feedback through questionnaires, helping HR understand expectations and identify

areas for improving the workplace experience.

The global analysis feeds into more global action plans. At the

launch of each survey, a summary of the comments received,

and the actions taken to respond to the previous survey is

provided as evidence of the 'listen and respond' approach. The

above-mentioned surveys also allow Orange Communications

Luxembourg to identify specific departments, divisions or even

teams where there may be a more specific problem and to take

appropriate measures when necessary.

In addition, employees are involved during the quarterly company

meetings "Open Talk", where they are invited to ask their

questions via an anonymous questionnaire beforehand, and

these are processed on the day of the meeting by the CEO and

the human resources Director of Orange Communications

Luxembourg.

C

o

n

c

r

e

t

e

l

y

,

i

n

J

a

n

u

a

r

y

2

0

2

5

, all Orange Belgium and Orange

Communications Luxembourg employees were invited to

participate to the Orange Group Voice Up, the aim of which is to

evaluate annually the commitment and confidence of employees

on topics such as efficiency and performance, confidence in

strategy and in business model, wellbeing, diversity equity and

inclusion, career & development, culture & engagement.

Compared with the Your Voice survey, it provides more in-depth

analysis and comparability with other subsidiaries in the Group

as well as on the Belgian market. It is implemented by a

dedicated

team

in

the

Group

HR

Department

and

correspondents identified in each division within the entities.

The local Your Voice survey focuses every six months on

Orange’s employee net promoter score (E-NPS) but also includes

questions on the pride to work for Orange or with its products

and services. The first question ‘recommend Orange as a good

employer’ allows to calculate the employee net promoter score

(E-NPS). Every six months, the company includes questions

about the understanding of and adhesion to Orange’s strategy or

about their people manager and possible extra questions. In

addition, Orange Belgium also listens and responds to its

employees on specific one-off occasion or in times of change

such as the potential move to a new location.

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This local survey enables the employee net promoter score (E-

NPS) to be to monitored. Until 2024, E-NPS targets for the entire

company (Orange Belgium, including WBCC, Be tv, and Orange

Communications Luxembourg) were set by the Remuneration

Committee for Executive Committee and Directors with an

impact on their short-term incentive collective performance

bonus.

The 2025 campaign of the Group’s Voice Up made it possible to

measure the evolution of Orange’s commitments and integrate

the appropriation of the new Group values launched in 2024. The

challenges of this new campaign were to improve the level of

participation, and to support managers in using the tool,

reporting the results, identifying action plans and developing a

culture of feedback and listening to employees in connection with

the "Culture" project.

The results of the employee feedback systems feed Orange’s

understanding of issues important to its workforce, and they

contribute to the company’s understanding of the drivers of

engagement. They contribute to improving the experience of

employees and managers, and help human resources policies,

processes, actions and tools to evolve. The results of the Group’s

Voice Up were presented and shared, with each of the Group's

divisions at dedicated sessions and are used to ensure that the

meaning of the strategy pursued by the Group is shared, to

identify areas for improvement in terms of processes serving the

business, wellbeing at work, career prospects and skills

development.

Orange Belgium has set

a

n

o

b

j

e

c

t

i

v

e

f

o

r

t

h

e

p

a

r

t

i

c

i

p

a

t

i

o

n

a

n

d

e

n

g

a

g

e

m

e

n

t

r

a

t

e

to the yearly Voice Up survey which will be held

in January 2026 as part of the Executive Committee and

Directors’ short-term incentive collective bonus, replacing the

local E-NPS targets as an objective. For all surveys, the company

monitors and report on the participations rates to the Executive

Committee and works council.

I

n

s

i

g

h

t

s

o

f

a

l

e

m

p

l

o

y

e

s

are gathered, regardless of whether

they may be particularly vulnerable or marginalised or not. To

guarantee access and participation, all surveys are available in

three languages (Dutch, French, and English). Important

communications pertaining to HR processes, company strategy,

invitations to events & webinars, or surveys are sent via mail in

minimum two languages. In the case of surveys, an introduction

mail is usually sent beforehand to the supplier, or the Group

sends the invitation. The company also foresees at least two

reminders. All employees have access to easy tools for

translations, might this be necessary.

Proximity events are also organised by Orange Belgium to foster

connection and engagement. The aim is to ensure close

interaction with groups of employees. In 2025, these included

three directors' calls and one leaders' meeting with directors and

middle management as well as three podcasts during which CEO

invites other executive committee members to share thoughts

about strategic subjects and answer questions.

The company’s Intranet also contains all information on HR

processes and policies as well as all links and manuals to HR

tools, info on our strategy, values, trade unions, works

regulations as well as a substantial part on health and safety and

wellbeing.

The company internal social network allows to share more

general information and engage with its employees. All

employees have access and may interact with each other via this

platform.

In parallel, there are regular consultations with worker

representatives throughout the year at Orange Belgium and

Orange Communications Luxembourg. At Orange Belgium,

employee representation is facilitated through three main bodies

for consultation with the unions.

Formal engagement with workers’ representatives takes place on

a regular basis. Trade union representatives were consulted

during the double materiality assessment carried out by Orange

Belgium in 2024. However, engagement with them also takes

place throughout the year independently of this assessment.

Orange Group operates several structured employee-feedback

mechanisms.

At Orange Belgium, meetings with the Works Council (WoCo) and

the Committee for Prevention and Protection at Work (CPPW) are

held at least once a month, and meetings with the Trade Union

Delegation (TUD) occur twice a month. On a quarterly basis, the

Works Council receives a social report covering a range of

indicators, including gender-related metrics, age distribution,

and seniority and nationality data. A quarterly learning and

development report is also presented, detailing the number and

types of training sessions completed, preferred topics, and

specific training pathways for targeted employee groups such as

managers.

On a yearly basis, a detailed gender equality report is presented

and discussed within the Works Council. Twice a year, a

Diversity, Equity and Inclusion (DEI) committee meeting is held

with the participation of the Executive Committee, subject-matter

experts, and four personnel representatives. In addition, matters

related to disability, accessibility and general wellbeing are

addressed on a regular or ad hoc basis within the CPPW. DEI

and wellbeing working groups are also convened on an ad hoc

basis when relevant issues arise.

Engagement with the own workforce is managed by the Chief

People Officer at Orange Belgium level and by the Head of

Human Resources at Orange Communications Luxembourg. The

subject is steered at group level by the HR Director.

In addition to the Group's human rights policy (see chapter

3.1

Human rights

), Orange signed a

a

g

l

o

b

a

l

a

g

r

e

m

e

n

t

o

n

f

u

n

d

a

m

e

n

t

a

l

s

o

c

i

a

l

r

i

g

h

t

s

w

i

t

h

t

h

e

i

n

t

e

r

n

a

t

i

o

n

a

l

t

r

a

d

e

u

n

i

o

n

f

e

d

e

r

a

t

i

o

n

U

N

I

G

l

o

b

a

l

U

n

i

o

n

in December 2006. This agreement

sets out Orange's commitments to respect fundamental human

rights and applies to all employees of Orange entities. It includes

the following elements:

•

In accordance with the fundamental ILO conventions,

Orange takes particular care to prevent the use of

forced labour, modern slavery and human trafficking, to

prohibit child labour and exploitation, to combat

discrimination, to ensure health and safety at work, and

to respect freedom of association and the principle of

collective bargaining.

•

In terms of combating all forms of c

c

o

m

p

u

l

s

o

r

y

a

n

d

f

o

r

c

e

d

l

a

b

o

u

r

a

n

d

p

r

o

h

i

b

i

t

i

n

g

c

h

i

l

d

l

a

b

o

u

r

, Orange

condemns and refrains from using any form of forced

or compulsory labour, and refrains from using child

152

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153

labour below the age at which compulsory schooling

ends in the country concerned or, in any case, below

the age of 15 or 18 for hazardous or harmful work.

•

With regard to n

n

o

n

-

d

i

s

c

r

i

m

i

n

a

t

i

o

n

, Orange's policy is

not to discriminate in any way in its working

relationships and, in particular, to recruit men and

women on the basis of their individual skills and to treat

everyone with dignity, in a non-discriminatory manner

that respects their age, social background, family

situation, gender, sexual orientation, disability, political,

trade union and religious opinions, and their real or

supposed membership or non-membership of an

ethnic group or nation. trade union and religious beliefs,

or their real or supposed membership or non-

membership of an ethnic group or nation. This theme of

non-discrimination was subsequently developed in the

global agreement signed in 2019 on professional

equality within Orange, which reaffirms its commitment

to combating discrimination and specifies the means of

action

(awareness-raising,

training,

reporting

mechanisms and their processing).

•

In terms of h

h

e

a

l

t

h

,

s

a

f

e

t

y

a

n

d

w

o

r

k

i

n

g

c

o

n

d

i

t

i

o

n

s

,

Orange is constantly concerned with ensuring the

health and working conditions of its employees and

provides medical monitoring for its employees in

accordance with local legislation. The commitment

made under this agreement to implement a managed

health policy in all Orange entities was supplemented

by the negotiation and signing of a separate global

agreement in 2014 on the health and safety of Orange

employees;

•

In terms of s

s

o

c

i

a

l

d

i

a

l

o

g

u

e

a

n

d

r

e

l

a

t

i

o

n

s

w

i

t

h

t

r

a

d

e

u

n

i

o

n

s

, Orange recognises its employees' freedom of

association, representation and membership of the

trade union of their choice.

Effective respect for fundamental social rights is ensured through

the following actions implemented by Orange and/or the

international trade union federation UNI Global Union:

•

T

r

a

d

e

u

n

i

o

n

t

r

a

i

n

i

n

g

provided jointly by management

and UNI Global Union when a new country joins the

Group on the basis of Orange's collective agreement;

•

D

i

r

e

c

t

d

i

a

l

o

g

u

e

during meetings scheduled for this

purpose or during consultations (conflict resolution

clause provided for in the agreement) concerning, in

particular, escalations on collective bargaining issues in

Group companies;

•

The implementation of an a

a

l

e

r

t

s

y

s

t

e

m

(see section

4.1.1.1 Business conduct policies and corporate

culture (G1-1, G1-3)

) available to employees of Group

entities, enabling them to report incidents relating in

particular to violations of human rights and trade union

freedoms or to the health and safety of individuals.

This first agreement served as the basis for the negotiation of two

subsequent agreements on health and safety and professional

equality. Together, these three agreements form a foundation

that is shared with Orange entities, particularly in the event of the

Group's expansion.

3.2.1.2

Processes to remediate negative impacts and channels for own workers to raise

concerns (S1-3)

Orange has no standard process to identify what action is

needed or appropriate to respond to potential negative impact as

it is dependent on the type of concern raised.

As general approach for contributing to remedy to a negative

impact, the information corresponding to admissible human

rights related incidents and complaints reported by employees

are following the w

w

h

i

s

t

l

e

b

l

o

w

i

n

g

a

n

d

c

o

r

u

p

t

i

o

n

p

r

o

c

e

s

(i.e.

using Hello Ethics, the Group's alert tool for

Orange

Communications Luxembourg and the whistleblowing process of

Orange Belgium). See also infra in section

4.1.1.1 Business

conduct policies and corporate culture (G1-1, G1-3)

for more

details for reporting breaches in areas such as health and safety

issues, data protection and network security, human rights, etc.

Furthermore, employees also have access to e

e

x

t

e

r

n

a

l

h

e

l

p

v

i

a

n

i

n

d

e

p

e

n

d

e

n

t

H

R

s

e

r

v

i

c

e

t

o

w

e

l

b

e

i

n

g

,

p

r

o

t

e

c

t

i

o

n

,

a

n

d

p

r

e

v

e

n

t

i

o

n

and may contact the prevention advisors, members of the

Internal Service for Prevention and Protection at work, or the trust

persons, all these numbers are made available widely. In the

event of a proven infringement following investigations, remedial

measures are the responsibility of HR departments. For instance,

employees guilty of acts of discrimination or insults of a

discriminatory nature on the company's premises, which after

investigation are established, must be subject to sanctions

commensurate with the seriousness of the acts. However, the

company does not systematically assess whether remedy

provided for these impacts on people is effective.

In the e

e

v

e

n

t

o

f

a

w

o

r

k

p

l

a

c

e

a

c

i

d

e

n

t

, the affected employee is

immediately assisted by a trained first aider or the company

nurse, and an ambulance is called if hospital care is required. For

less severe cases, Orange Belgium provides appropriate

transportation to ensure the employee can return home or visit

their general practitioner. If the employee is placed on medical

leave, a pre-return or return-to-work consultation is arranged

with the occupational physician to support a safe reintegration.

After every accident, an internal investigation is carried out by the

Prevention Advisor together with the members of the Committee

for Prevention and Protection at Work (CPPW) to determine root

causes and define corrective actions. Accident cases and

required measures are discussed in CPPW meetings, and

outcomes and actions are communicated to employees and

management to ensure continuous improvement in health and

safety.

In case of damage, and in particular psychological damage,

Orange Belgium supports employees through specific Employee

Assistance Programme in collaboration with the Internal

prevention service. There is also the possibility to get support

from Internal prevention service and trust persons.

Thus, Orange provides s

s

e

v

e

r

a

l

e

s

t

a

b

l

i

s

h

e

d

c

h

a

n

e

l

s

through

which its own workforce can raise concerns or express their

needs directly. As described in the previous chapter, employees

have access to structured feedback mechanisms, including the

Your Voice surveys and the Voice Up initiative, which enable

153

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154

them to communicate views related to their work experience,

organisational developments and broader workplace themes.

Additional avenues specifically related to health, safety, security

and wellbeing include access to i

i

n

t

e

r

n

a

l

t

r

u

s

t

p

e

r

s

o

n

s

and an

external

service

for

prevention

and

protection,

offering

confidential support through specialised professionals such as

security engineers, doctors and psychologists.

These combined channels ensure that employees across the

organisation have multiple and accessible means to voice

concerns or needs and to have them addressed by the

undertaking.

Orange has g

g

r

i

e

v

a

n

c

e

a

n

d

c

o

m

p

l

a

i

n

t

s

h

a

n

d

l

i

n

g

m

e

c

h

a

n

i

s

m

related to employee matters in place. To prevent negative

impacts on Orange’s workforce, employees are encouraged to

report any actions that are ethically irresponsible or that violate

legal regulations or the company’s internal policies and

procedures. Reports can include conduct or situations related to

Orange’s business that infringe laws or regulations (e.g., fraud,

corruption, serious violations of human rights, workplace safety,

or environmental standards), as well as breaches of internal

policies (e.g., anti-corruption policy, code of ethics). This is

further explained infra in section

4.1.1.1 Business conduct

policies

and

corporate

culture

(G1-1,

G1-3)

with

all

w

h

i

s

t

l

e

b

l

o

w

i

n

g

s

y

s

t

e

m

a

n

d

p

r

o

c

e

s

d

e

t

a

i

l

s

at Group level and for

Orange Communications Luxembourg, as well as more

specifically for Orange Belgium. It also details the way f

f

u

l

p

r

o

t

e

c

t

i

o

n

o

f

w

h

i

s

t

l

e

b

l

o

w

e

r

s

is

guaranteed.

The

legal

requirement mandates that issues must be acknowledged within

seven working days and resolved within three months.

No specific measure to ensure the effectiveness of the channel

is in place in the Whistleblower procedure. Nevertheless, within

Orange duty of vigilance, alerts are m

m

o

n

i

t

o

r

e

d

on yearly basis. If

no alerts are raised it can also point out a need of improvement

on the visibility of the system. In this regard, Orange Belgium is

considering using Orange Group alert mechanism "Hello Ethics",

already used by Orange Communications Luxembourg.

The availability and functionality of these reporting channels are

widely communicated through internal platforms and annual

c

o

m

p

l

i

a

n

c

e

t

r

a

i

n

i

n

g

mandatory for all employees. To monitor,

amongst other topics, the trust in these mechanisms, Orange

Belgium conducts an annual “Voice Up” survey, which includes

a question on trust and on confidence. Additionally, the "Your

Voice" open-ended responses allow employees to voice

concerns twice a year. These verbatims are subsequently

thoroughly analysed by the HR teams. Action plans are

developed based on both survey results and on the verbatim

analysis to address areas of improvement, reinforcing the

company’s commitment to transparent and constructive

engagement.

Orange Belgium’s whistleblowing mechanism, aligned with

Belgian regulations and detailed in its whistleblowing system,

ensures secure internal and external reporting channels For

further details, refer to section

4.1.1.1 Business conduct policies

and corporate culture (G1-1, G1-3)

on procedures addressing

corruption and bribery and whistleblowing system. There are

mechanisms in place to p

p

r

o

t

e

c

t

i

n

d

i

v

i

d

u

a

l

s

f

r

o

m

r

e

t

a

l

i

a

t

i

o

n

w

h

e

n

t

h

e

y

u

s

e

t

h

e

c

h

a

n

e

l

s

to raise concerns or needs. Orange

Belgium guarantees protection for whistleblowers who raise

concerns. The key points regarding protection against retaliation

are:

•

The identity of the whistleblower will be kept secret,

and all information will be treated as confidential.

•

No

employee

will

be

punished,

dismissed,

or

discriminated

against

for

drawing

attention

to

suspected abuse, even if the investigation concludes

that the facts are not correct, or no action is taken.

•

Whistleblowers have the option to consult with their

personnel's union representative.

These measures are in place to ensure that individuals feel safe

and protected when using the whistleblower channels to raise

concerns. However, abuse of the whistleblower system can lead

to disciplinary sanctions and prosecution.

Orange has no systematic process to ensure that its own

practices do not cause or contribute to negative impacts.

154

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Annual report 2025

155

3.2.2

Management of impacts, risks and opportunities related to

training and skills development

3.2.2.1

Policies related to training and skills development (S1-1)

Orange G

G

r

o

u

p

'

s

S

k

i

l

s

D

e

v

e

l

o

p

m

e

n

t

P

o

l

i

c

y

is designed to

strengthen

employees'

expertise

and

align

development

programmes with the Group's strategic objectives. It focuses on

anticipating skills needs, as well as on upskilling to acquire skills

that are complementary to those already held in one's own

profession, and reskilling to acquire all the skills needed to

practice a new profession. The aim is to ensure that the skills

acquired meet the company's requirements, while offering

employees prospects for career development. Through this

proactive approach, Orange is equipped to adapt continuously

to future challenges.

The Orange Group's Skills Development Policy has been

translated at Orange Belgium level. For this, an O

O

r

a

n

g

e

B

e

l

g

i

u

m

'

s

L

e

a

r

n

i

n

g

p

o

l

i

c

y

has been co-created with all the Orange Belgium

Learning and Development (L&D) teams beginning of 2025. It has

also been validated by the trade unions of the different

companies (Orange Belgium, WBCC & Be tv). This document is

available internally to everyone via Orange Belgium intranet

portal. The policy is monitored using performance indicators

such as the number of hours of training in strategic skills, the

impact of training courses, employee satisfaction with the

support provided, etc.

These policies focus on skills development as a cornerstone of

Orange's "Lead the Future" strategic plan. They address the dual

goals of enhancing current expertise and preparing employees

for emerging job roles. Learning is embedded within the

company culture as a lever to support employability and foster

inclusivity. Diversity and inclusion considerations are integrated

into learning initiatives to ensure that training opportunities are

accessible and reflect the diversity of the workforce.

155

Orange Belgium

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Annual report 2025

156

Both documents highlight the approaches described below:

Proactive and personalised training

The policy offers a streamlined, tailored approach to employee

learning. It focuses on transversal knowledge, upskilling for

existing roles and reskilling for career transitions into new

professions:

•

G

e

n

e

r

a

l

e

a

r

n

i

n

g

: cultural and foundational knowledge,

fostering a shared understanding of the company’s

vision.

•

U

p

s

k

i

l

i

n

g

: enhancing existing skills for improved

performance in current roles.

•

R

e

s

k

i

l

i

n

g

: training employees for entirely new roles in

response to evolving job demands.

Training is curated based on employee profiles, strategic

priorities, and market trends.

Structuring principles

•

Promotes continuous learning using hybrid methods

like digital platforms, immersive technologies, and on-

the-job training.

•

Encourages learning through a "70-20-10" approach:

70% practical experience, 20% peer collaboration, and

10% formal education.

•

Supports innovation including the consideration of

environmental aspects where relevant in learning

programmes.

Training delivery and management rely on c

c

e

n

t

r

a

l

i

s

e

d

i

g

i

t

a

l

p

l

a

t

f

o

r

m

s

, such as Orange Learning and Hello Learning, which

are used across the organisation. These platforms support

scalable deployment, ensure data security, and facilitate the

pooling of resources while promoting consistency in training

content and processes. Tailored communications support and

guide employees towards training courses that meet the

company's needs.

The policy is m

m

o

n

i

t

o

r

e

d

using performance indicators such as the

number of hours of training in strategic skills (including gender

KPIs) per department and employees. The e

e

f

e

c

t

i

v

e

n

e

s

of

learning and development initiatives is monitored using key

performance indicators, including employee satisfaction, skill

coverage rates and training impact assessments. Evaluation

methods such as the Kirkpatrick model are used to assess

learning outcomes.

All employees on the Orange Belgium, WBCC & Be tv payroll in

2025 are subject to this policy. Orange Communications

Luxembourg does not have specific skills development policy at

local level but follows the Skills Development Policy of Orange

Group:

•

A

l

E

m

p

l

o

y

e

s

:

Includes individuals across geographies

and business lines, addressing both current and future

skill requirements.

•

G

e

o

g

r

a

p

h

i

c

a

l

R

e

a

c

h

:

The Group policy applies globally

across all divisions and entities of Orange, with local

adaptations permitted to address specific regulatory or

market needs.

The final person accountable for the implementation of the

Orange Belgium Learning policy is its CEO. In practice, the Chief

People officer and the People & Workplace Solutions Delivery

Director are accountable for the implementation of this policy.

The most senior level accountable for the implementation of the

Group Skills Development Policy at Orange Group is the

Executive Director of Human Resources. Within Orange

Communications Luxembourg, the most senior level accountable

for the implementation of the Group Skills Development Policy at

Orange Communications Luxembourg is the Head of Human

Resources.

Employees benefit from the support of their managers and HR

teams in guiding them towards the appropriate training courses.

Responsibilities for learning and skills development are clearly

distributed among business lines, Group schools, Human

Resources teams and L&D departments. Managers and

employees play a central role in this governance framework, with

managers

supporting

employees

in

identifying

career

development paths and making informed training choices.

To guarantee the implementation of the Skills Development

Policy, coordination takes place at Group level, based on a

governance body that brings together the Group Schools

Directors and the Learning & Development Directors of each

Division on a monthly basis.

In the context of t

t

h

e

B

e

l

g

i

a

n

L

a

b

o

u

r

D

e

a

l

, the government

introduced an individual right to training for employees, together

with an obligation for employers to establish an annual training

plan. This legislation entered into force on 10 November 2022,

with the individual right to training applying as from 2023. Under

this framework, every employee at Orange Belgium benefits from

an individual right to training covering two types of learning:

•

F

o

r

m

a

l

t

r

a

i

n

i

n

g

, developed and delivered by teachers

or trainers, characterised by a high degree of

organisation and typically taking place outside the

workplace.

•

I

n

f

o

r

m

a

l

t

r

a

i

n

i

n

g

, characterised by a high degree of self-

organisation by the employer, with employees having

significant influence over the content and timing; these

trainings generally take place in the workplace.

In addition, Joint Commission 200 provides guidelines and

recommendations

aimed

at

protecting

workers’

rights.

Employees have a non-refusable right to request training days,

and workers’ representatives are consulted on training matters

on a quarterly basis through dedicated social reporting.

At Orange Communications Luxembourg, the Labour legislation

depends on the sector. As a telecom operator, Orange

Communications Luxembourg is not concerned by any training

obligation. However, an annual training plan is set up by Human

Resources each year to ensure every employee to be trained.

To build the Group policy in particular, different stakeholders'

interests considered include:

•

E

m

p

l

o

y

e

s

: Offers tailored, inclusive, and accessible

learning paths aligned with career growth and

employability;

•

M

a

n

a

g

e

r

s

: Provides tools and support to guide

employee development and align training with team

objectives;

•

B

u

s

i

n

e

s

l

i

n

e

s

: Aligns training with specific skills

needed for strategic and operational goals;

156

Orange Belgium

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Annual report 2025

157

•

L

&

D

t

e

a

m

s

: Equips them with centralised tools,

promotes

innovation,

and

facilitates

continuous

improvement;

•

H

R

t

e

a

m

s

:

Supports

workforce

planning

with

centralised platforms and data-driven decision-making;

•

L

e

a

d

e

r

s

h

i

p

: Ensures alignment with long-term business

strategy and efficient resource utilisation. A specific

focus on women in leadership functions is considered.

The Group policy is available on the Group intranet, and at

Belgian level, the Orange Learning policy is available in the entity

intranet.

3.2.2.2

Targets related to training and skills development (S1-5)

The G

G

r

o

u

p

'

s

T

a

l

e

n

t

M

a

n

a

g

e

m

e

n

t

p

o

l

i

c

y

is a policy of excellence

and inclusion that aims to provide a common approach for all

Group employees. It includes the assessment of performance

and potential, the construction of an individual development plan

and the preparation of succession for key positions through the

construction of talent pools and structured succession plans. To

ensure continuity of service, health and s

s

a

f

e

t

y

requirements,

compliance standards, and new competences development, the

Talent Management policy includes anticipating employee

mobility and assessing the criticality of positions. Implementation

of the policy is coordinated by the Group Talent Management

Department, which reports to the Executive Committee every six

months based on performance indicators. The department is

supported by governance bodies at divisional level and by the

Group Talent Management function.

Training and skills development targets in Belgium are the

following:

•

The objective is to have “no zero learner”, and it is a

strategic objective of Orange Belgium to manage risks

linked to the fast evolution of skills needed. This no zero

learner objective does not include the mandatory

trainings defined by the Group linked to strategic topics

of the Group (i.e. compliance, and cybersecurity).

•

In addition, there is an objective to ensure that

everybody follows at least five days of training per year

by 2028. Note that the five days of training in 2028 (with

an intermediary target of three days in 2025) are set by

the Joint Committee 200 under a sectoral agreement.

This target is set by the Belgian sectoral agreement of the Joint

Committee 200 (Commission Paritaire 200 / Paritair Comité 200)

as a recommendation. However, every employee has the right

(not refusable) to requests these days of trainings. KPIs are

followed with worker representatives in official committees and

worker council regularly. Workers’ representatives are consulted

in the reporting every quarter. These KPIs are also reported to

the Group.

In terms of timeframes, for companies being part of the Belgian

official ‘joint committee 200’, the cumulative training quota for the

employees will be progressive between 2024 and 2028.

In addition, to foster a learning culture within the company and

ensure all employees take time to develop themselves, a

a

m

a

n

d

a

t

o

r

y

d

e

v

e

l

o

p

m

e

n

t

o

b

j

e

c

t

i

v

e

o

f

1

0

%

o

f

t

h

e

i

n

d

i

v

i

d

u

a

l

p

e

r

f

o

r

m

a

n

c

e

o

b

j

e

c

t

i

v

e

s

f

o

c

u

s

i

n

g

o

n

d

e

v

e

l

o

p

m

e

n

t

a

c

t

i

v

i

t

i

e

s

(including but not restricted to mandatory e-learnings) has been

implemented since 2024. This objective applies to all level of

seniority and profile with no distinction between women and

men.

157

Orange Belgium

_

Annual report 2025

158

To enable monitoring of the target, all people managers have

access to their people's learning history via the Orange learning

tool.

Thanks to actions taken in 2025, Orange Belgium noticed a

positive progression of its learning KPIs. In 2024, Orange

Belgium reached 2.5 learnings day/employee in average. End of

2025, Orange Belgium reached the yearly target of the year: 3

3

.

1

d

a

y

s

p

e

r

e

m

p

l

o

y

e

i

n

a

v

e

r

a

g

e

.

With regards to the "zero learner" KPI, at the end of 2025, Orange

Belgium had 9

9

.

3

%

z

e

r

o

l

e

a

r

n

e

r

s

, i.e. employees who had not

followed at least one training.

For the mandatory e-learnings, while the objective is to reach

100% completion, the end-year (31/12/2025) completion status

of the "Cyber Ready 2025" e-learning was 97% and 96% for

"Business ethics" e-learning.

3.2.2.3

Training and skills development metrics (S1-13)

Employee

development

is

a

cornerstone

of

Orange’s

commitment to fostering a dynamic and inclusive work

environment. By investing in regular performance and career

development reviews, the organisation ensures that employees

across all levels have access to continuous learning and growth

opportunities.

The metrics displayed below reflect Orange Belgium’s dedication

to nurturing talent, enhancing skills, and promoting equity in

professional development.

2

0

2

4

2

0

2

5

Average number of training hours per

employee

14h

23h

T

a

b

l

e

9

:

O

r

a

n

g

e

m

p

l

o

y

e

s

’

t

r

a

i

n

i

n

g

a

n

d

s

k

i

l

s

d

e

v

e

l

o

p

m

e

n

t

The significant increase in the average number of learning hours

per employee in 2025 is driven by both an expansion of training

activities and improved tracking of learning hours.

Firstly, the reinforcement of the Learning & Development team

enabled better operational follow-up and more comprehensive

capture of learning activities across the organisation. Learning

activities that were not fully captured in 2024 (e.g. WBCC

learnings, MyVOO Academy or sales coaching sessions) were

progressively integrated into the learning systems in 2025.

Secondly, the harmonisation of HR processes following the

integration of VOO required the roll-out of numerous trainings on

new tools and processes for all employees. At the same time,

new learning initiatives were launched, including leadership

programmes (notably for all Tech people managers) and new

language courses via an external platform.

M

E

T

H

O

D

O

L

O

G

I

C

A

L

N

O

T

E

Orange monitors the number of trainings and the n

n

u

m

b

e

r

o

f

d

a

y

s

o

f

t

r

a

i

n

i

n

g

s

p

e

r

e

m

p

l

o

y

e

, per gender and per department and

function. The number of training days is calculated p

p

e

r

F

T

E

e

q

u

i

v

a

l

e

n

t

on a pro-rata basis for part-time employees or employees

who have not completed a full year of employment. This target includes all employees on payroll or Orange Belgium. Days of

training are counted as an equivalent of 8 hours of training, in line with the sectoral federation recommendation to base the objective

on working hours. For training courses (face-to-face or virtual), the hours scheduled are considered. For e-learnings, all the hours

of the different e-learnings followed are summed and divided by 8 hours to get the result in number of days. For trainings which

starts year 1 and terminates year 2, the total learning hours of the training is recorded to the year of training completion date. The

numbers of days are determined per year. However, if an employee has not filled its quota of the previous year, the difference will

be reported to the next year.

The absolute objective of achieving no z

z

e

r

o

l

e

a

r

n

e

r

, i.e. team members who do not follow any training, is also closely followed. This

KPI does not include mandatory e-learnings.

For the 1

1

0

%

d

e

v

e

l

o

p

m

e

n

t

o

b

j

e

c

t

i

v

e

set in place in 2024, a quota system per person will be put in place to allow employees to

develop themselves on competences they can use outside of Orange including: minimum 40% for generic knowledge, maximum

60% of specific to Orange knowledge, and maximum of 20% of declarative learning.

All Orange Belgium including former-VOO, Be tv and WBCC employees are covered by these objectives, but not Orange

Communications Luxembourg. There is no change in the targets set on this topic or in the ways of measuring it compared to last

year.

A global dashboard on Orange learning platform enables to follow the progress of learnings activities of its employees. A specific

dashboard has also been created to measure the percentage of employees following the mandatory compliance and cyber security

trainings completion per department and functions.

This KPI monitors the number of employees following various training as part of Orange identified risks of not having the skills to

ensure the deployment of the strategy and the business continuity, the opportunity in recruiting, developing and retaining talents

via career paths accessible to all. However, this KPI may contribute to several other material topics within Orange sustainability

strategy as the content of each training may contribute to specific objective. For instance, mandatory trainings on compliance and

cybersecurity contribute to the IROs identified under business ethics, governance and compliance on the one hand, and to the

IROs identified for cybersecurity, data protection and data privacy on the other hand.

158

Orange Belgium

_

Annual report 2025

159

3.2.2.4

Taking actions on training and skills development (S1-4)

Since 2024, at the instigation of the Group HR Director, the policy

applicable to all Group entities was amended and approved by

the Executive Committee. As a result, all Group employees,

regardless of the division or country in which they work, have

access to the same assessment and support principles. The

Group Talent Management Department is responsible for

implementing this policy throughout the Group. To this end, it

organises a b

b

i

-

w

e

k

l

y

m

e

t

i

n

g

o

f

a

c

o

m

u

n

i

t

y

o

f

t

a

l

e

n

t

m

a

n

a

g

e

r

s

representing all the organisations and geographies

responsible for rolling out the policy locally, to share information

(best practice, processes, policies, tools, timetable, etc.). Regular

updates are also provided to the Executive Committee (divisional

and sector HR Directors). It also uses talent management tools

that bring together all relevant key data, in compliance with the

Group's policy on the protection of personal data.

To foster the participation to trainings, the company has

implemented a personal development objective in the "Lead the

Future" strategy with a +

+

1

0

%

d

e

v

e

l

o

p

m

e

n

t

o

b

j

e

c

t

i

v

e

f

o

r

a

l

e

m

p

l

o

y

e

s

.

In addition, Orange also has introduced t

t

w

o

m

a

n

d

a

t

o

r

y

e

-

l

e

a

r

n

i

n

g

s

f

o

r

a

l

t

e

a

m

e

m

b

e

r

s

on ethics,

compliance and cybersecurity.

As mentioned previously, at the beginning of 2025, a new

learning policy was adopted for Orange Belgium, aligned with the

Group’s broader learning strategy, marking a critical milestone in

the ongoing development process.

In addition, to support the company ambition, a talent mapping

for the whole organisation has been performed in 2025.

M

E

T

H

O

D

O

L

O

G

I

C

A

L

N

O

T

E

The methodology to compute this KPI has not changed compared to 2024. The training hours recorded for the reference year are

allocated to the year in which the training has been completed. This means that for a course that takes place over several days

spanning two years, all the training hours will be counted in the second year.

To align with other metrics published in this report, this KPI is computed in headcount on a consolidated basis, including Orange

Communications Luxembourg, based on figures at the end of 2025. It therefore does not align with the way Orange Belgium’s

target is computed. In addition, this metric does include employees in long-term illness, while the target is computed in full-time

equivalent.

159

Orange Belgium

_

Annual report 2025

160

This year was also focused on the creation of a specific

E

m

p

l

o

y

e

A

c

a

d

e

m

y

p

a

g

e

available to all employees and

available via Orange Belgium’s intranet. The employees can use

this page to find all the documents they would need to find the

right learning solutions for them (e.g. key links to all available

learning solutions partners, the learning policy, the 2025 training

plan, some guidelines to support employees to complete their

10%

of

yearly

development

objective

etc.).

Tailored

communications support and guide employees towards training

courses that meet the company's needs. T

T

w

o

c

o

m

o

n

d

i

g

i

t

a

l

p

l

a

t

f

o

r

m

s

"

O

r

a

n

g

e

L

e

a

r

n

i

n

g

"

a

n

d

"

H

e

l

o

L

e

a

r

n

i

n

g

"

provide

access to training resources for Group employees.

Finally, a K

K

P

I

d

a

s

h

b

o

a

r

d

was created to monitor learning

activities at Orange Belgium's level. Additional specific

dashboards have also been created linked to company priorities

for 2025 such as: the completion status of the two mandatory e-

learnings on "Cyber Ready 2025" and "Business Ethics" for all

employees, Gen AI trainings for employees and managers (part

of their yearly objectives), completion status of the "culture

workshop" or "Culture Ready" e-learnings (part of employees'

yearly objectives). This dashboard enhances transparency for

people managers regarding the achievement of learning and

development objectives and supports the mandatory reporting to

the Federal Learning Account.

In short, learning and development actions were on track in 2025

and implemented in line with Group and legal requirements. The

year mainly focused on the effective deployment of learning

frameworks and the reinforcement of monitoring capabilities, in

line with Group and legal requirements. Initial governance and

reporting tools were put in place, enabling better visibility on

training participation and compliance.

The focus for 2026 will be to i

i

m

p

l

e

m

e

n

t

"

M

y

S

k

i

l

s

"

t

o

l

. Based

on job description of each employee, a list of competencies will

be defined at individual level. Employees will be able to complete

their profile with their LinkedIn profile. This will allow the tool to

propose a competency gap analysis finetuned with the possibility

for the employee to self-assess their competencies level. Finally,

thanks to "My Skills" tool integration with Orange learning,

employees will be able to define their development plan and get

tailored learning solutions propositions with a focus on reskilling

& upskilling in line with strategic workforce planning. Further

implementation of the “My Skills” tool will enable a more granular

identification of the skills required to manage the risks identified

above and to better steer future learning actions. In addition, new

mandatory trainings will be launched in 2026.

Orange Belgium finally expects to validate the 2026 training plan

and the updated Orange Belgium's learning policy with the trade

unions in the first quarter of 2026.

The aim of these actions to ensure that the skills acquired meet

the

company's

requirements,

while

offering

employees

prospects for career development. T

T

h

a

n

k

s

t

o

t

h

i

s

p

r

o

a

c

t

i

v

e

a

p

r

o

a

c

h

,

O

r

a

n

g

e

i

s

e

q

u

i

p

e

d

t

o

a

d

a

p

t

c

o

n

t

i

n

u

o

u

s

l

y

t

o

f

u

t

u

r

e

c

h

a

l

e

n

g

e

s

. Applying to all employees, it covers different

business lines and geographical areas, while allowing the

development of specific actions adapted to local needs.

Employees benefit from the support of their managers and HR

teams in guiding them towards the appropriate training courses.

These initiatives c

c

o

v

e

r

a

l

O

r

a

n

g

e

B

e

l

g

i

u

m

e

n

t

i

t

i

e

s

,

w

h

i

l

e

O

r

a

n

g

e

C

o

m

u

n

i

c

a

t

i

o

n

s

L

u

x

e

m

b

o

u

r

g

continues to implement various

activities driven at Group level, but not yet formalised into an

action plan.

Moreover, Orange also sees an o

o

p

o

r

t

u

n

i

t

y

in recruiting,

developing and retaining talents via career paths accessible to

all, including specific path centred on access for women to

technical professions. WomenInTech is a student initiative in

Belgium that champions gender diversity specifically in the fields

of technology and engineering within Science, Technology,

Engineering, and Mathematics (STEM). Orange is committed to

this cause, supporting efforts to inspire and empower women to

excel in these vital sectors. Orange is a sponsor and organise

several events with the aim to raise awareness of women for

technical jobs, offering internships at Orange for young women.

Via Orange Digital Center and Orange Belgium’s cooperation

with BeCode, people in vulnerable situation (person Not in

Education, Employment or Training - NEETs), including several

women, are provided free tech-courses. During their training,

they have the opportunity to engage in Orange use cases,

working for 2 weeks to address an Orange-related issue. At the

end of their training, some participants join Orange for a two-

month internship.

3.2.3

Management of impacts, risks and opportunities related to

diversity

3.2.3.1

Policies related to diversity (S1-1)

The G

G

r

o

u

p

’

s

D

i

v

e

r

s

i

t

y

,

E

q

u

i

t

y

a

n

d

I

n

c

l

u

s

i

o

n

(

D

E

I

)

p

o

l

i

c

y

2

5

is built

on principles that seek to ensure gender equality in the

workplace, combat all forms of discrimination and violence,

including harassment, and promote work-life balance. The goal

is not to discriminate in any way in its working relationships and,

in particular, to recruit men and women based on their individual

skills and to treat everyone with dignity, in a non-discriminatory

manner that respects their age, social background, family

25

The Group diversity, equity and inclusion policy can be found here:

https://mastermedia.dam-broadcast.com/medias/domain12751/media101369/410974-

v1fluwqha3-75.pdf

situation, gender, sexual orientation, disability, political, trade

union and religious opinions, and their real or supposed

membership or non-membership of an ethnic group or nation in

accordance

with

International

Labour

Organization

(ILO)

Convention 111.

This theme of non-discrimination was subsequently developed in

the global agreement signed in 2019 with the international trade

160

Orange Belgium

_

Annual report 2025

161

union federation UNI Global Union Union (see also supra in

section

3.2.1.2 Processes to remediate negative impacts and

channels for own workers to raise concerns (S1-3)

), which

operationalises the key principles of the policy across all Group

entities. The agreement aims to reinforce the Group’s

commitment to non-discrimination and equal opportunities and

to embed these principles into all Group activities.

The policy establishes a structured monitoring framework that

relies on local social dialogue to conduct assessments, create

action plans and oversee their implementation. It defines a set of

resources to support its deployment, including the uniform

measurement of pay gaps in all countries, training for managers

and HR teams on discrimination issues, partnerships with local

associations

and

awareness-raising

and

communication

initiatives. Local committees in each country manage the

monitoring indicators and report annually, ensuring that the

policy is adapted to national contexts and implemented through

a proactive and participatory approach. The policy also aims to

ensure that the Group’s pay practices are non-subjective and

non-discriminatory.

The DEI policy emphasises diversity, gender equality and equal

opportunities as drivers of innovation, social cohesion and

economic performance. It seeks to foster an inclusive and

trusting environment in which every employee can embrace their

uniqueness. The global dimension of the policy is complemented

by a thematic approach addressing specific challenges such as

gender

equality,

the

inclusion

of

young

people

from

disadvantaged areas and the fight against all forms of

discrimination in the workplace. Concretely, it aims to fighting

discrimination by continuously questioning practices, build an

inclusive environment that transforms employees’ differences

into collective strengths, ensure accessible products and

services, enhance competitiveness by diversifying profiles and

contribute to a more inclusive society by supporting career

guidance, skills development and pathways to employment.

In October 2023, the Group-wide policy was amended and

approved by the Executive Committee, signed and implemented

by the Group HR Director.

The policy sets out guidelines based on 3 pillars: gender equality

in the workplace, equal opportunities, digital equality and the

fight against digital discrimination.

161

Orange Belgium

_

Annual report 2025

162

The policy is organised around t

t

h

r

e

m

a

i

n

t

h

e

m

e

s

a

n

d

a

t

r

a

n

s

v

e

r

s

a

l

t

h

e

m

e

:

•

The W

W

o

r

k

p

l

a

c

e

G

e

n

d

e

r

E

q

u

a

l

i

t

y

pillar is based on five

principles: i

i

n

c

r

e

a

s

i

n

g

t

h

e

n

u

m

b

e

r

o

f

w

o

m

e

n

i

n

technical

and digital professions, giving women access to

positions of responsibility, ensuring equal pay for equal

work,

combating

discrimination

harassment

and

violence, and achieving work-life balance.

•

T

h

e

E

q

u

a

l

o

p

o

r

t

u

n

i

t

i

e

s

pillar

addresses

n

o

n

-

d

i

s

c

r

i

m

i

n

a

t

i

o

n

on the basis of ethnic and social origin,

age (youth integration and senior retention), disability

inclusion and neurodiversity, respect for sexual

orientation and gender identities, religious and political

or trade union views, socio-economic and cultural

diversity.

•

The D

D

i

g

i

t

a

l

E

q

u

a

l

i

t

y

pillar is based on 3

3

a

r

e

a

s

o

f

a

c

t

i

o

n

:

development of responsible and inclusive artificial

intelligence, diversity of profiles in digital professions,

particularly in innovation, accessibility of digital tools

within the company.

A transversal theme, which focuses on c

c

o

m

b

a

t

i

n

g

d

i

s

c

r

i

m

i

n

a

t

i

o

n

by raising awareness on stereotypes and prohibiting all forms of

violence at work.

The DEI policy and the 2019 global agreement a

a

p

l

y

t

o

a

l

G

r

o

u

p

e

n

t

i

t

i

e

s

including Belgium and Luxembourg. The scope of the

policy extends beyond internal operations to stakeholders such

as suppliers and subcontractors, who are encouraged to align

their initiatives with the Group’s objectives.

The G

G

r

o

u

p

H

R

D

i

r

e

c

t

o

r

i

s

t

h

e

m

o

s

t

s

e

n

i

o

r

o

f

i

c

i

a

l

a

c

o

u

n

t

a

b

l

e

for

the implementation of the policy, as demonstrated by the

signature of the 2019 global agreement with UNI Global Union,

reaffirming the Group’s commitment to equality in the workplace,

the fight against discrimination and the promotion of work-life

balance. In Belgium, this policy is under the accountability of the

Chief People Officer. In Luxembourg, this policy is under the

accountability of the Head of Human Resources.

The purpose of this agreement is to ensure that workplace

gender equality, combatting discrimination and violence and

work-life balance are duly considered in all Group activities,

based on:

•

An i

i

n

c

l

u

s

i

v

e

a

p

r

o

a

c

h

involving all stakeholders,

including structured social dialogue which allows local

reviews to be drawn up and adapted action plans to be

defined;

•

Establishing common objectives in terms of g

g

e

n

d

e

r

e

q

u

a

l

i

t

y

in the workplace, combatting discrimination

and violence, work-life balance;

•

Promoting any i

i

n

i

t

i

a

t

i

v

e

which meets these objectives,

and which is adapted to the context and local practices;

•

Involvement of s

s

u

p

l

i

e

r

s

a

n

d

s

u

b

c

o

n

t

r

a

c

t

o

r

s

in this

approach.

The implementation of the DEI policy is a

a

l

i

g

n

e

d

w

i

t

h

s

e

v

e

r

a

l

i

n

t

e

r

n

a

t

i

o

n

a

l

y

r

e

c

o

g

n

i

s

e

d

s

t

a

n

d

a

r

d

s

a

n

d

i

n

i

t

i

a

t

i

v

e

s

. The Group

acts in line with its adherence to the United Nations Global

Compact, the principles of the Universal Declaration of Human

Rights,

and the

standards

of the International

Labour

Organization that apply in the countries where it operates.

Orange has also committed to and implemented positive actions

f

o

r

p

e

o

p

l

e

a

n

d

g

r

o

u

p

s

p

a

r

t

i

c

u

l

a

r

l

y

a

t

r

i

s

k

o

f

v

u

l

n

e

r

a

b

i

l

i

t

y

. For

several years, Orange Belgium has a partnership with Entra, an

organization offering high quality, adapted and sustainable jobs

to persons who have certain limitations due to illness or

handicap. A number of administrative tasks related to customer

operations are sourced out to Entra. The policy was developed

and is implemented through a participatory and inclusive

approach t

t

h

a

t

a

k

e

s

i

n

t

o

a

c

o

u

n

t

h

e

i

n

t

e

r

e

s

t

s

of key

stakeholders. Continuous dialogue with staff representatives

ensures that their perspectives inform the application of the

policy. The need to adapt measures to local contexts is

acknowledged

throughout

the

policy’s

implementation.

Structured social dialogue at local and Group level allows

employees, managers, HR teams and union representatives to

contribute to assessments, action plans and shared objectives.

Stakeholder engagement also includes partnerships with local

associations, particularly on issues such as discrimination

awareness, training and local inclusion programmes. Suppliers

and subcontractors are encouraged to undertake initiatives

consistent with the Group’s DEI objectives. Progress is reviewed

annually with UNI Global Union, which provides an additional

level of stakeholder involvement.

The p

p

o

l

i

c

y

i

s

m

a

d

e

a

v

a

i

l

a

b

l

e

through established mechanisms of

social dialogue and structured communication. Employees,

managers, HR teams and union representatives, who are the

primary stakeholders involved in implementation, gain access to

the policy through training sessions, awareness-raising initiatives

and communication actions across the organisation. Monitoring

indicators and progress are reviewed and reported annually to

UNI Global Union, helping ensure transparency for stakeholders

involved in the oversight of the policy. The content of the policy

is disseminated through these internal channels and through

ongoing engagement processes that keep responsible actors

informed and aligned.

All main HR processes of Orange Belgium (such as talent

acquisition, internal mobility/promotion, talent management,

talent development, performance, pay gap...) are aligned with the

Group processes, have c

c

l

e

a

r

l

y

d

o

c

u

m

e

n

t

e

d

g

u

i

d

e

l

i

n

e

s

, which

are communicated to the (new) managers through the mandatory

HR Fundamentals for managers and HR fundamental for team

members.

These

processes

focus

on

developing

all

competencies and skills.

162

Orange Belgium

_

Annual report 2025

163

3.2.3.2

Targets related to diversity (S1-5)

The ambition of the Orange Diversity, Equity and Inclusion policy

is to contribute to improving the company's collective

performance

by

guaranteeing

an

inclusive

and

trusting

environment, in which each employee can make the most of his

or her individuality. Since 2004, this ambition has led to the

signing

of

agreements

in

consultation

with

employee

representatives, as well as charters. Formalised in 2009, the

policy promotes diversity, to enable the inclusion of everyone,

whatever their gender, age, social or ethnocultural origin, sexual

orientation, family situation, state of health or disability.

Taking up the main principles of the policy, in 2019 Orange and

UNI Global Union signed a global agreement on professional

equality

between

women

and

men,

the

fight

against

discrimination and violence, and work-life balance, setting out

the main principles applicable to the entities and establishing a

monitoring framework. Within this agreement, Orange Group

confirmed its relative objective to r

r

e

a

c

h

a

n

o

v

e

r

a

l

r

a

t

e

o

f

a

t

l

e

a

s

t

3

5

%

w

o

m

e

n

i

n

i

t

s

m

a

n

a

g

e

m

e

n

t

b

o

d

i

e

s

b

y

2

0

2

5

(

i

n

“

e

x

e

c

”

o

r

“

l

e

a

d

e

r

”

g

r

a

d

e

s

)

, and commits to: encouraging diversity within its

teams, at all levels and specifically in high-level roles; improving

support for women who wish to progress at all levels and/or

access high-level positions.

Related to the Orange Group’s target to reach 35% of women at

all levels of management by end 2025, Orange Belgium and

Orange Communications Luxembourg have also set the same

this target at local level. There is no specific baseline as this

percentage must be reached independently from today's

situation. There is no interim target, and it is tracked every quarter

and reported biyearly.

The targets are set by the Orange Belgium remuneration

committee on proposal from HR Compensation & Benefits team.

In addition, the targets on feminisation rate are also linked to the

Executive Committee objectives and their variable remuneration

(long-term incentive plan - LTIP bonus) is set in cooperation with

the Group Compensation & benefits committee.

M

E

T

H

O

D

O

L

O

G

I

C

A

L

N

O

T

E

For the purpose of this target, “management” position includes women from the Executive Committee, as well as people managers

classified in bands 1 (directors) and 2 (managers).

The percentage is monitored based on roles within management, programme management and project management, in order to

ensure representation across all levels of these functions.

This metric has not been validated by an external body. No changes were made to the target or to the calculation methodology

during the reporting period.

At the end of 2025, Orange Belgium (excludingWBCC and Be tv)

has monitored 3

3

%

o

f

w

o

m

e

n

i

n

m

a

n

a

g

e

m

e

n

t

, slightly below the

target. Orange Communications Luxembourg already reached

3

5

%

w

o

m

e

n

i

n

m

a

n

a

g

e

m

e

n

t

p

o

s

i

t

i

o

n

s

and aims to at least

maintain this level.

In addition to the target on gender diversity, and to ensure the

framework to promote gender diversity is sufficiently robust,

Orange also voluntarily follows KPIs on trainings by gender to

ensure the source of inequality can be identified, including

discrepancies among soft and hard skills.

Stakeholders are not involved in target setting, but they are

involved in the monitoring of the target and overall, the proportion

of males and females through the Diversity and Inclusion

Committee twice a year. Performance is measured continuously

via the DEI dashboard and shared with executive committee

monthly. In addition, results are shared with trade unions since,

once a year, a special works council committee (WoCo) is

dedicated to the subject of social matters including diversity.

In the future, the company also plans to monitor more closely on

a

g

e

-

r

e

l

a

t

e

d

i

s

c

r

i

m

i

n

a

t

i

o

n

.

3.2.3.3

Diversity metrics

The performance on women in management's performance is

measured continuously via a DEI dashboard. Results are shared

with Executive Committee monthly, twice a year through the

diversity and inclusion committee (DEI committee), and with

workers representative through the works council (WoCo)

dedicated to social report once a year. The DEI Committee is

monitoring actions and is assessing effectiveness of the actions.

163

Orange Belgium

_

Annual report 2025

164

Gender distribution of employees at top management level (S1-9)

2

0

2

4

2

0

2

5

N

u

m

b

e

r

o

f

e

m

p

l

o

y

e

s

a

t

o

p

m

a

n

a

g

e

m

e

n

t

l

e

v

e

l

Female

15

16

Male

41

44

Other

-

Not disclosed

-

Grand Total

56

60

P

e

r

c

e

n

t

a

g

e

o

f

e

m

p

l

o

y

e

s

a

t

o

p

m

a

n

a

g

e

m

e

n

t

l

e

v

e

l

Female

27%

Male

73%

Other

-

Not disclosed

-

Grand Total

100%

T

a

b

l

e

1

0

:

O

r

a

n

g

e

’

s

g

e

n

d

e

r

d

i

s

t

r

i

b

u

t

i

o

n

a

t

o

p

m

a

n

a

g

e

m

e

n

t

l

e

v

e

l

METHODOLOGICAL NOTE

For the purpose of this KPI, “top management” comprises the members of the Executive Committee, the Chief Executive Officer

of Orange Communications Luxembourg, the directors of Orange Belgium, as well as the directors of WBCC and Be tv (band 1,

director level according to internal organisation), and the management team of Orange Communications Luxembourg. Compared

to the target defined above, this KPI does not include employees classified in band 2 (manager level according to internal

organisation).

Distribution of employees by age group (S1-9)

2

0

2

4

2

0

2

5

N

u

m

b

e

r

o

f

e

m

p

l

o

y

e

s

Under 30 years old

288

266

30-50 years old

2,019

1,929

Over 50 years old

658

717

P

e

r

c

e

n

t

a

g

e

o

f

e

m

p

l

o

y

e

s

Under 30 years old

10%

9%

30-50 years old

68%

66%

Over 50 years old

22%

25%

T

a

b

l

e

1

:

O

r

a

n

g

e

’

s

e

m

p

l

o

y

e

d

i

s

t

r

i

b

u

t

i

o

n

b

y

a

g

e

g

r

o

u

p

Incidents and complaints for discrimination (S1-17.103)

2

0

2

4

2

0

2

5

Number of incidents of discrimination

1

Number of complaints filed through channels for people in the undertaking’s own workforce to raise

concerns

26

1

Number of complaints filed to National Contact Points for OECD Multinational Enterprises

27

-

Amount of fines, penalties, and compensation for damages as result of incidents of discrimination,

including harassment and complaints filed

0 €

71,420 €

T

a

b

l

e

1

2

:

O

r

a

n

g

e

n

u

m

b

e

r

o

f

d

i

s

c

r

i

m

i

n

a

t

i

o

n

i

n

c

i

d

e

n

t

s

a

n

d

c

o

m

p

l

a

i

n

t

s

26

This value is indicative, related to a known incident, as there is currently no process for systematically monitoring complaints within Orange

27

Neither Orange Belgium, nor the Group, has formalized a process to monitor complaints to the National Contact Points for OECD Guidelines for Multinational

Enterprises.

164

Orange Belgium

_

Annual report 2025

165

The incident reported for 2024 in the table above relates to

litigation involving a former employee. Subsequently, in March

2025, Orange Belgium s.a. was ordered to pay a compensation

following a dismissal deemed discriminatory on the grounds of

disability. The compensation paid in relation to the discrimination

case is recognised in the financial statements as part of labour

costs (line 421100). Accordingly, the amount disclosed in the

table above under ESRS S1-17 is fully reconciled with the

corresponding

labour

cost

recognised

in

the

financial

statements.

In 2025, another incident has been raised regarding inappropriate

behaviour of a team member through Orange Belgium local email

alert mechanism, the case is still being analysed by the

designated person within Ethics & Compliance and hereafter with

the most appropriate department (line manager) enabling to

follow-up. The file shall be analysed and followed up

anonymously. No other penalties were reported in 2025 for the

entities covered by this report.

M

E

T

H

O

D

O

L

O

G

I

C

A

L

N

O

T

E

There is t

t

w

o

w

a

y

s

o

f

r

a

i

s

i

n

g

a

l

e

r

t

s

regarding diversity or any other subject filed by its own workforce:

On the one hand,

,

w

o

r

k

-

r

e

l

a

t

e

d

i

n

c

i

d

e

n

t

s

include legal actions and actions treated via a formalised procedure internally. The

grievance process for incidents (formal and informal) is described on the intranet and is accessible to all. These incidents concern

harassment (moral or sexual) and discrimination. All complaints and incidents that must be reported are monitored and follow the

process in place. The cases can be raised and resolved through

ethicsandfraud@orange.be

, the Belgian local whistleblowing

mechanism, or resolved by negotiation with the contribution of the External Service for Prevention and Protection at work. Currently,

there is no distinction in the reporting yet as to whether employees or external temporary workers are involved. The internal

prevention department receives reporting of all incidents from the external prevention department.

On the other hand, the point of entry f

f

o

r

c

o

m

p

l

a

i

n

t

s

is the Human Resources department or a trusted person (i.e. volunteers in

charge of conflict and psycho-social risks prevention). Complaints are dealt with by the HR business partners and line manager

where relevant. In the case of severe incidents, they are directed towards a formal grievance process. Other cases are discussed

with HR, but do not engage in a formal process. Therefore, there is currently no process for systematically monitoring complaints

within Orange.

In the absence of a sufficiently precise measurement tool for the source of a claim (own workforce, workers in the value chain,

affected communities, consumers and end-users), and because alerts can be filed anonymously, Orange does not have the exact

number of c

c

o

m

p

l

a

i

n

t

s

related to discrimination or any other subject filed by its own workforce.

T

h

e

g

e

n

d

e

r

p

a

y

g

a

p

is defined as the difference of average pay

levels between female and male employees and is expressed as

percentage of the average pay level of male employees. The

values in the table below indicate a disadvantage for women. This

data is not adjusted, which means that it has been computed

without application of any correction factor.

The table below shows an improvement in Belgium compared to

2024. The difference in Luxembourg is due to improvement in the

calculation methodology as explained in the methodological note

below. The year-on-year variation between 2024 and 2025 is

mainly driven by changes in workforce composition. The

integration of VOO into Orange Belgium, representing a

significant number of employees, contributed positively to the

evolution of the gender pay gap. For Be tv and WBCC, changes

in the gender pay gap mainly reflect departures within higher-

paid positions, which had a positive effect on the overall gap.

While the unadjusted gender pay gap required by the CSRD

offers a standardised indicator, it does not reflect practical

differences such as functions, seniority or levels of responsibility.

Complementary analyses considering these factors may support

a more granular understanding of pay equity.

Gender pay gap (S1-16)

2

0

2

4

2

0

2

5

Consolidated figure for the entities in scope of this report

15%

Orange Belgium

11%

10%

VOO

10%

-

WBCC

12%

8%

Be tv

26%

22%

Orange Communications Luxembourg

5%

21%

T

a

b

l

e

1

3

:

G

e

n

d

e

r

p

a

y

g

a

p

o

f

O

r

a

n

g

e

165

Orange Belgium

_

Annual report 2025

166

M

E

T

H

O

D

O

L

O

G

I

C

A

L

N

O

T

E

The gender pay gap calculation includes only employees with permanent or fixed-term contracts in the salaries at the end of

October 2025. The ratio is based on annual full-

time equivalent remuneration, which combines fixed salary, the variable

remuneration effectively paid during the reporting year and other benefits. For consistency, data from all four entities have been

aggregated prior to calculation. Differences in remuneration structures across entities (e.g., annualisation factors) have been

standardised to ensure comparability.

It should be noted that the 2024 data for Orange Communications Luxembourg were based on theoretical estimates, whereas the

2025 figures are derived from actual data. The gender pay gap in Luxembourg is primarily driven by differences in variable

remuneration. When considering basic salary only, the gender pay gap is lower.

Orange Belgium has implemented several special efforts in its

policies to support gender equality. Company cars remain

available to team members for the first four months of long-term

absence, which applies to everyone but particularly benefits

young mothers. During the last months of pregnancy, women are

granted access to a reserved parking space close to their office

desk. Additionally, performance bonus payouts can be provided

by line managers to women on maternity leave, as maternity

leave is an absence considered as ‘presence’ for the calculation

of the performance bonus and the profit bonus if any (no prorated

payment).

Internal pay audits are conducted at Orange Communications

Luxembourg every semester by local HR to monitor pay equity

and identify any discrepancies, with a detailed analysis

performed by role, department, and seniority level. Transparent

pay structures are established through a salary grid by grade,

which is part of the collective bargaining agreement and is

updated in accordance with minimum wage changes mandated

by law.

To remove biases in hiring decisions, standardised hiring

processes are implemented, utilising structured interviews and

transparent criteria while ensuring a balanced gender pool at the

sourcing level. Additionally, favourable local legislation supports

gender-neutral parental leave policies, allowing up to six months

of parental leave for each parent of a child. Flexible work

arrangements are also available, permitting up to three days a

week of remote work, which helps both men and women balance

work and family responsibilities without negatively impacting

their career trajectories.

Finally, local senior leadership is made aware of and held

accountable for progress on pay equity, driving a consistent

focus on this important issue.

3.2.3.4

Taking actions on diversity (S1-4)

Orange recognises the importance of recruiting, developing, and

retaining a diversity of talent as a strategic opportunity to

strengthen its workforce. Therefore, the key focus of its activities

with its own workforce is centred on fostering career paths

accessible to all, with specific initiatives aimed at increasing

women’s participation in technical professions.

Orange Group adheres to the G

G

e

n

d

e

r

E

q

u

a

l

i

t

y

E

u

r

o

p

e

a

n

&

I

n

t

e

r

n

a

t

i

o

n

a

l

S

t

a

n

d

a

r

d

(

G

E

I

S

)

,

an international benchmark

audited by TÜV Rheinland that fosters a shared culture of gender

equality and workplace diversity. This certification evaluates the

Group’s Professional Equality and Diversity policy against ten

criteria, each assessed across six levels of maturity. It is renewed

every four years, with intermediate audits conducted every two

years.

The GEEIS framework enables Orange to assess, recognise and

promote local initiatives implemented by its subsidiaries, while

raising awareness of the importance of integrating diversity

considerations across human resources, corporate social

responsibility and communication processes. The certification

process covers key areas such as remuneration, promotion, skills

development, gender diversity across professions, inclusion

practices, social dialogue, and the overall impact of these actions

within the Group’s internal and external ecosystem.

This approach is steered and coordinated by the G

G

r

o

u

p

D

i

v

e

r

s

i

t

y

,

E

q

u

i

t

y

a

n

d

I

n

c

l

u

s

i

o

n

(

D

E

I

)

d

e

p

a

r

t

m

e

n

t

,

which

supports

subsidiaries throughout the preparation and audit process by

providing methodological tools and guidance. Each audit is

followed by a debriefing involving the auditor, the subsidiary’s

project team and the Group DEI Department, during which best

practices and areas for improvement are identified. These

outcomes support the implementation of the Group’s DEI policy

as part of a continuous improvement process and contribute to

progress in subsequent audits.

Through this ongoing process, Orange aims to consistently

strengthen its Diversity, Equity and Inclusion practices and

promote a more inclusive and equitable working environment

across its subsidiaries. In this context, Orange Belgium has taken

steps to foster gender equality and diversity by adhering to the

GEEIS framework. VOO and its subsidiaries were included in the

r

e

-

c

e

r

t

i

f

i

c

a

t

i

o

n

process conducted in November 2025. The next

follow-up audit will happen in 2027. Orange remains committed

to maintaining its GEEIS certification while continuing to enhance

its diversity and inclusion policies and practices.

The major project delivered in 2025 was the h

h

a

r

m

o

n

i

s

a

t

i

o

n

o

f

t

h

e

O

r

a

n

g

e

B

e

l

g

i

u

m

&

V

O

w

o

r

k

i

n

g

c

o

n

d

i

t

i

o

n

s

a

n

d

p

a

c

k

a

g

e

s

effective 1 July 2025. 785 VOO employees were impacted by this

implementation, which went along with numerous info sessions

and webinars which reached a joined audience of over 3,000

participants.

In 2025, Orange also deployed the n

n

e

w

G

r

o

u

p

v

a

l

u

e

s

(

c

a

r

e

,

r

e

s

p

o

n

s

i

b

l

e

,

b

o

l

d

)

through cascading workshops hosted by the

managers as well as through e-learning in the Hello Learning app

for employees working in shops and the technicians on the road.

166

Orange Belgium

_

Annual report 2025

167

These values are also included in the “How” objectives of all

employees starting 2025 (in terms of attitude in paving the way

to achieve their personal goals).

The Group tools to ensure i

i

n

c

l

u

s

i

v

e

j

o

b

p

o

s

t

i

n

g

s

a

n

d

h

i

r

i

n

g

were

promoted amongst all the hiring managers and a workshop was

organised in November on the importance of diverse and

inclusive hiring. In addition, 73 new managers were trained on

their role in employee wellbeing.

Following the signature of the CEASE network charter in 2024, all

e

m

e

r

g

e

n

c

y

n

u

m

b

e

r

s

,

including those concerning domestic

violence were made available via posters in all rest rooms.

Other initiatives focused on reducing the glass ceiling by

strengthening

mentoring,

coaching,

and

networking

opportunities, both internally and externally. A company-wide

t

a

l

e

n

t

e

x

e

r

c

i

s

e

was performed ensuring women were equitably

represented in the outcome.

In addition, the W

W

e

l

b

e

i

n

g

C

o

r

e

T

e

a

m

deployed his cross-

company wellbeing approach reaching 634 participants through

the sessions and distributing 1,630 wellbeing packages during

the wellbeing week in October 2025.

Finally, an internal and external communication plan was

developed to strengthen the messages related to DEI.

Awareness actions were conducted at the occasion of f

f

o

u

r

s

p

e

c

i

f

i

c

d

a

y

s

; Woman’s right day; International Day Against

Homophobia, Transphobia, and Biphobia; International day for

the elimination of violence against women and Disability-day.

Deploying the Group’s toolkits on the subjects, thus creating a

common culture with the Orange Group

Orange also strengthened external actions to highlight its

dedication to these issues, aiming to influence other companies.

The company further deployed the T

T

e

c

h

A

c

a

d

e

m

y

project with

the Polytechnic School of Brussels (EPB at ULB) resulting after

two years in 213 students having followed the Orange chair, 30

attendees to its summer school (of which 20% Women) and 32

of its employees benefitting from upskilling via the EPB (ULB).

In May 2025, Orange Belgium hosted close to 100 students

from

different

national

universities

in

Brussels

(EPB

-

ULB/VUB),

Liège (HEPL)

and

Mons (UMONS)

over the course of

three separate visits. On different sites and in different groups,

they got a rare look at what telecom looks like in practice: how

networks are built, tested, and monitored, and what it takes to

keep Belgium connected.

Orange Belgium continued its sponsoring of W

W

o

m

e

n

I

n

T

e

c

h

a

student initiative aimed at promoting gender diversity in

technology and engineering as well as careers in technology

amongst girls & women as part of its commitment to gender

diversity in STEM fields. To this regard Orange Belgium

participated in their Speed Networking event, to promote gender

balance, engage with students, and discuss opportunities for

internships and jobs in the tech world. The company invited them

to participate to an intense 48-hour hackathon with students

from a variety of disciplines and several universities.

Via Orange Digital Center and the company’s cooperation with

BeCode, p

p

e

o

p

l

e

i

n

v

u

l

n

e

r

a

b

l

e

s

i

t

u

a

t

i

o

n

(person Not in Education,

Employment or Training - NEETs), including several women, are

provided free tech courses. During their training, they have the

opportunity to engage in use cases, working for two weeks to

address an Orange-related issue. At the end of their training,

some participants join Orange for a two-month internship.

F

o

r

O

r

a

n

g

e

C

o

m

u

n

i

c

a

t

i

o

n

s

L

u

x

e

m

b

o

u

r

g

,

several activities are

implemented along the year but are not part of an action plan. In

2025, Orange Communications Luxembourg carried out a series

of initiatives to strengthen its commitment to Diversity, Equity

and Inclusion (DEI), in alignment with the Group’s strategy. The

deployment of the LutherOne HR engagement tool helped

reinforce closeness with teams and provided clearer insights into

key DEI and wellbeing needs. The company are also beginning

to work in a more structured way thanks to the introduction of an

action plan for the year, and Orange Communications

Luxembourg is participating in the GEEIS certification process.

The GEEIS certification will take place in 2026. The collaboration

between internal communication, the ESG manager, and HR

enables

the

implementation

of

more

awareness-raising

initiatives.

As a general principle, d

d

i

s

c

r

i

m

i

n

a

t

i

o

n

i

s

p

r

e

v

e

n

t

e

d

through the

fact that the main HR-processes (such as recruitment, internal

mobility, talent development, talent management, learning &

167

Orange Belgium

_

Annual report 2025

168

development) are designed in such a way that they focus on

developing all available talents.

Orange has set up a comprehensive system for preventing,

detecting and dealing with all situations of Harassment, Sexism,

Violence at Work (HSVT), and advocates zero tolerance of such

behaviour. The system includes training and awareness-raising

materials for the entities' HSVT referents, so that they can

prevent and deal with situations effectively, while taking care to

respect cultural elements and the local context. During the

harmonisation exercise with VOO, a clear and documented

appeal process was foreseen for the job grading exercise.

P

e

r

f

o

r

m

a

n

c

e

m

e

t

r

i

c

s

related to women in management are

continuously tracked via the DEI dashboard. Results are

reviewed quarterly by the Group SCR-team, biannually by

Diversity and Inclusion (DEI) Committee (composed of Executive

Committee members and union representatives), and annually by

worker representatives through the works council’s social report.

The DEI Committee monitors actions and assesses their

effectiveness.

In short, the main achievements in 2025 include:

•

The

integration

of

the

VOO

people

and

the

harmonisation of the work conditions & packages;

•

The GEEIS re-certification for the next four years;

•

The further deployment and enrichment of the Tech

Academy by Orange with student visits organised for

different schools and universities, courses for EPB/ULB

students and upskilling of Orange employees by the

EPB/ULB and a third edition of the Orange summer

school, as well as the participation in WomenInTech

speed networking to promote gender balance in all

roles;

•

Actions on remuneration alignment are still in progress,

and results are expected in the coming years.

The next 2026-2027 action plan will be validated in the first

quarter of 2026

3.2.4

Management of impacts, risks and opportunities related to

health and safety

3.2.4.1

Policies related to health and safety (S1-1)

The challenge is to limit the impact on the health of people,

employees

or

partners

that

Orange's

activities

or

the

transformations carried out by the company to support its

development may have.

Against a backdrop of increasing demands linked to the

environmental transition, technological change, longer working

lives, changes in professions, the development of new forms of

work organisation and new individual aspirations, Orange is

convinced of the need to strengthen its occupational risk

prevention culture.

In the O

O

r

a

n

g

e

G

r

o

u

p

H

e

a

l

t

h

,

S

a

f

e

t

y

a

n

d

Q

u

a

l

i

t

y

o

f

L

i

f

e

a

t

W

o

r

k

P

o

l

i

c

y

s

i

g

n

e

d

i

n

2

0

2

3

by the executive director in charge of

human resources, Orange affirms that occupational health and

safety issues for all Group employees are an absolute priority to

ensure the Group's success and sustainability. The policy's

orientations are in line with the company's "Lead the future"

strategy and the Group's CSR approach:

•

Build trust through safe and calm working conditions;

•

Enhance

the

performance

of

approaches

by

harmonising and sharing best practice;

•

Aim for excellence by strengthening the culture of

primary prevention.

This commitment is consistent with and underpinned by a

worldwide health and safety agreement signed with the social

partners in November 2014 for all Group employees, which

defines a common foundation for the Group in terms of health,

safety, quality of life at work and health protection in general.

It aims to guarantee the safety of employees, protect their health

and improve their quality of life at work. It is aimed at all

employees of the Group's divisions and subsidiaries, in all

geographical areas, as well as all stakeholders, partners,

subcontractors and persons who may be affected by the Group's

activities, and in the context of their interactions with Orange.

To achieve this, the policy is broken down into 4 major objectives

supported by a three-year Health Safety and Quality, Health, and

Value (QHV) roadmap, which is reviewed regularly to be adjusted

and enriched:

•

Deploying

an

Occupational

Health

and

Safety

Management System (OHSMS);

•

Applying principles common to all;

•

Monitoring

and

communicating

performance

indicators;

•

Listening to employees on a regular basis.

Policy implementation is coordinated at Group level by the Health

and Safety Prevention department.

The purpose of this agreement is to incorporate health and safety

in all aspects of the Group's operations. The policy and the

various communication tools used to implement it are available

on the intranet, which is dedicated to occupational health and

players such as the Prevention Officers, Human Resources

directors and managers. In particular, the policy is presented in

a video that is gradually being incorporated into the health and

safety induction modules for employees.

It includes a p

p

a

r

t

i

c

i

p

a

t

o

r

y

a

p

r

o

a

c

h

w

i

t

h

a

l

s

t

a

k

e

h

o

l

d

e

r

s

, the

definition

of

common

principles,

implementation

of

an

occupational health and safety management system, non-

discrimination towards vulnerable groups, participation in health

protection programmes, and ensuring the safety of service

providers and subcontractors. This is a long-term agreement that

will be monitored over time.

The content includes a common set of principles on health and

safety in the workplace : employee healthcare access; medical

monitoring; encouraging wellbeing in the workplace; safety in the

workplace and risk control; planning for and managing

emergency situations; public health and pandemic prevention

campaign; prevention and protection level for the company’s

168

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_

Annual report 2025

169

service providers and subcontractors; involvement, information,

communications, training (communication about the agreement,

management involvement, employee involvement, awareness-

raising, communications and training); and finally the monitoring

of agreement commitments.

This agreement a

a

p

l

i

e

s

t

o

a

l

c

o

m

p

a

n

i

e

s

o

f

t

h

e

O

r

a

n

g

e

G

r

o

u

p

,

including Orange Belgium (including VOO employees integrated

as of July 2025, WBCC and Be tv) and Orange Communications

Luxembourg. The Internal Service for Prevention and Protection

at work (ISPP) is one of the main actors to identify and analyse

risks, advise the employer, elaborate a prevention plan. It

collaborates with the External Service for Prevention and

Protection at work (ESPP) and the Committee for Prevention and

Protection at Work (CPPW).

The most senior role accountable for the implementation of this

policy is Orange's CEO. In practice, the Chief People officer &

Director People and Workplace Development solutions and the

Secretary General for health and safety are accountable for the

implementation of this policy.

The policy ensures compliance to Belgian regulations (Code on

wellbeing at work - 4 August 1996 Law) to maintain legal

standards.

Innovative and high-quality social dialogue in terms of health and

safety, involving union organisations and/or staff representatives,

is one of the key elements in the smooth implementation of the

health and safety policy within the Group, which aims to

guarantee employee safety, protect their health and improve

quality of life in the workplace. Each Group entity ensures that

union organisations and/or staff representatives, depending on

the existing context (legislation and local practices in force), are

stakeholders in all aspects of health and safety in the workplace

and particularly in the implementation and monitoring of relevant

action plans.

To pursue this aim, health and safety committees or equivalent

bodies are formed locally. The role of these committees includes

ensuring that this agreement is implemented locally. They are

called upon to rule on matters relating to the application of this

policy. The composition, roles and responsibilities of these

committees is determined in accordance with local legislation

and practices. The aforesaid committees organise a balanced

representation to allow quality dialogue on health and safety

questions.

This agreement was signed with the UNI-Orange Global Union

Alliance and is available for all on internal communication

channels.

W

o

r

k

a

c

i

d

e

n

t

s

are followed by the Internal Service for

Prevention and Protection at work, in cooperation with the

Committee for Prevention and Protection at Work.

The management systems entail:

•

Analysis of each work accident to take security

measures aimed at avoiding new accidents;

•

Risk analysis on the workplaces based on a standard

checklist;

•

Organisation of first aid trainings;

•

Distribution and control of protective equipment where

needed.

3.2.4.2

Targets related to health and safety (S1-5)

Orange Belgium does not explicitly have a target in accordance

with the ESRS; rather, it represents an aspirational objective, as

the pursuit of z

z

e

r

o

w

o

r

k

-

r

e

l

a

t

e

d

a

c

i

d

e

n

t

s

aligning with a widely

adopted approach in European companies that prioritises the

highest standards of health, safety and security in the workplace.

This ambition acts as a guiding principle to create a work

environment free from accidents, injuries and occupational

hazards. It specifically concerns w

w

o

r

k

-

r

e

l

a

t

e

d

a

c

i

d

e

n

t

s

,

excluding commuting accidents.

This ambition is linked to the O

O

r

a

n

g

e

G

r

o

u

p

G

l

o

b

a

l

H

e

a

l

t

h

a

n

d

S

a

f

e

t

y

A

g

r

e

m

e

n

t

, which sets the long-term policy framework for

the Group. The agreement establishes the objective of protecting

and maintaining employees’ physical and mental health at the

highest possible level by preventing accidents and occupational

hazards, reducing inherent workplace risks, and supporting

access to quality healthcare coverage. Progress towards this

objective is monitored over time across all Orange entities,

including Orange Belgium.

Number of accidents are monitored and reported annually. Exact

figures for this reporting year (2025) are presented in the next

section

3.2.4.3 Health and Safety Metrics S1-14

.

For health and safety, members of Committee of Protection and

Prevention at Work (CPPW, including Executive Committee

members and labour representatives) are informed of the

objective on zero work related accidents in Belgium.

METHODOLOGICAL NOTE

In Belgium, one of the main metrics used to assess the effectiveness of employee health and safety is the number of workplace

accidents. This indicator is reviewed by the Committee for Prevention and Protection at Work (CPPW) and is monitored annually.

It is also reported each year to the government authorities (Federal Public Service for Employment, Labour and Social Dialogue).

In Luxembourg, the number of workplace accidents is reviewed by the Health and Security Officer and is monitored annually.

This number includes mortal accidents, accidents with permanent disability and accidents with temporary disability. In line with

national regulations, this metric doesn't consider accidents from/to work.

The number of work-related accidents is confirmed by the insurance company yearly in Belgium and each work-related accident is

confirmed by the work-related accident association (AAA) in Luxembourg.

169

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Annual report 2025

170

3.2.4.3

Health and safety metrics (S1-14)

The table below provides an overview of health and safety

metrics for both employees and non-employees in 2025. It

highlights that 100% of the workforce is covered by a health and

safety management system compliant with legal requirements

and recognised standards or guidelines.

Notably, there were no fatalities recorded within the workforce

due to work-related injuries, reflecting a strong emphasis on

preventive measures and workplace safety. Nevertheless, there

were seven recordable work-related accidents, resulting in a

recordable accident rate of 1.42. However, the total number of

days lost due to work-related injuries stood at 841, emphasising

the importance of ongoing efforts to mitigate workplace risks.

H

e

a

l

t

h

a

n

d

s

a

f

e

t

y

(

S

1

-

1

4

)

2

0

2

4

2

0

2

5

Percentage of own workers who are covered by health and safety management system based on legal

requirements and (or) recognised standards or guidelines

28

100%

100 %

Number of fatalities in own workforce as result of work-related injuries

0

Number of recordable work-related accidents for own workforce

29

15

7

Rate of recordable work-related accidents for own workforce

2.81

1.42

Number of days lost to work-related injuries and fatalities from work-related accidents, work-related ill

health and fatalities from ill health

578

841

T

a

b

l

e

1

4

:

N

u

m

b

e

r

o

f

a

c

i

d

e

n

t

s

a

n

d

f

a

t

a

l

i

t

i

e

s

t

h

a

t

a

r

e

w

o

r

k

-

r

e

l

a

t

e

d

w

i

t

h

i

n

O

r

a

n

g

e

All employees are covered by health and safety system by law.

Accidents are systematically analysed, and corrective and

preventive measures are implemented to prevent recurrence (e.g.

targeted prevention training). No recurring patterns or trends

have been identified that would indicate the repetition of a

specific type of accident.

Accidents recorded in 2025 were more severe, resulting in a

higher number of days of absence. One reason may be linked to

the merger with VOO, which has expanded the Group’s exposure

to higher-risk environments due to the more technical and

industrial nature of its activities.

M

E

T

H

O

D

O

L

O

G

I

C

A

L

N

O

T

E

This table consolidated information of Belgium and Luxembourg. The accidents considered are accidents at work resulting in

incapacity. This excludes accidents on the way to work and accidents at work that did not result in incapacity. This method of

calculation is aligned with the reporting requirement that must be provided annually to the Belgian Government.

In cases where days of incapacity overlap two calendar years, days related to accidents that occurred in the previous year are

included in the 2025 figures.

Also note that the number of cases of recordable work-related ill health is not known to the company due to official constraints to

access this data in Belgium and Luxembourg.

To Orange’s knowledge, there was no case of fatalities resulting from work-related injuries of non-employees on the Orange

Belgium sites. These cases should be reported to Orange Belgium by the relevant subcontractors. In such cases, an investigation

must be conducted, involving all parties concerned, including the principal. Therefore, it is assumed that if no notification is received,

no (fatal) accidents have occurred among the company’s subcontractors’ workforce on site.

3.2.4.4

Taking actions on health and safety (S1-4)

Orange takes several actions to prevent or mitigate potential

negative impacts. Orange's strategy is to roll out an occupational

health and safety management system across all its geographies,

including prevention and listening measures.

28

In accordance with applicable legal requirements, non-employees are also covered by the health and safety management system.

29

Note that an error has been identified in the 2024 statement (21 accidents reported) and has been corrected in the present table.

Beyond the legally required health and safety processes in place,

Orange Belgium has deployed a structured

e

m

p

l

o

y

e

-

c

e

n

t

r

i

c

w

e

l

b

e

i

n

g

a

p

r

o

a

c

h

designed to proactively address work ability

and long-term health.

170

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Annual report 2025

171

The inclusive approach is organised around four pillars:

1.

A workplace prevention and wellbeing policy that

ensures a safe and healthy work environment in

support of mental and physical health;

2.

The opportunities for each employee to showcase their

skills and abilities, develop them, and advance

throughout their career;

3.

Shared values (caring, responsible, bold) and an

inclusive culture at the heart of our interactions and way

of working;

4.

Optimal working conditions (attractive compensation

package; clear role descriptions; fair goal setting and

evaluations process; and transparent communication

and strategy).

By addressing each of these levels, Orange fosters sustainable

productivity and wellbeing across diverse and aging workforces.

In 2025, both the health and safety and the HR department

contributed to delivering major projects on all four pillars:

(

1

)

A

w

o

r

k

p

l

a

c

e

p

r

e

v

e

n

t

i

o

n

a

n

d

w

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b

e

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g

p

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y

t

h

a

t

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n

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u

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s

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f

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n

d

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e

a

l

t

h

y

w

o

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k

e

n

v

i

r

o

n

m

e

n

t

.

In terms of p

p

r

o

g

r

e

s

i

n

2

0

2

5

o

n

h

e

a

l

t

h

a

n

d

s

a

f

e

t

y

, Orange

Belgium

identified

f

i

v

e

p

r

i

o

r

i

t

y

a

c

t

i

o

n

s

to

support

the

implementation of its health and safety objectives. As at the end

of 2025, the company has achieved measurable progress on

each action.

•

First, the update of the Care Scan, i.e. the internal

Health and Safety compliance audit, was completed in

June. This update enabled a refreshed assessment of

compliance levels and informed subsequent corrective

measures.

•

Second, the follow-up of the workplace-level risk

analyses was finalised during the first quarter.

Following completion, several information sessions

were organised with people managers to reinforce

awareness of mandatory training requirements, the use

of individual protective equipment, and the applicable

medical supervision procedures for their teams.

•

Third, the ergonomics risk analysis progressed

according

to

plan.

In

May,

the

ergonomics

questionnaire was distributed to all employees, and

responses were analysed by the External Service for

Prevention and Protection (ESPP - Attentia). The

reporting was presented to the CPPW in September.

Based on the findings, an action plan was developed

and implementation commenced in the fourth quarter.

Actions undertaken include individual and collective

training initiatives, as well as the replacement of office

furniture with ergonomic equipment in the Hasselt

premises. These actions are still ongoing.

•

Fourth, the annual flu vaccination campaign was

carried out from October to November. A total of 373

vaccinations were administered by the company nurse

during this period, representing a significant uptake

among staff.

•

Finally, the fire-risk analyses continued across the retail

network. In total, fire-risk assessments were completed

in 71 shops during the year, contributing to improved

identification and mitigation of fire-related hazards.

This information is reported to authorities annually and can be

found online in the yearly reporting prepared for the Belgian

Government.

171

Orange Belgium

_

Annual report 2025

172

In compliance with

B

e

l

g

i

a

n

C

o

d

e

o

n

W

e

l

b

e

i

n

g

a

t

W

o

r

k

,

Health

and safety management at Orange Belgium is deployed for its

employees, which includes former-VOO employees as of the 1

July 2025. The development of Orange Belgium Global

prevention plan is based on a five-year horizon. The global

prevention plan is set out on a five-years horizon and broken

down into annual action plan deployed by Orange Belgium and

focusing on wellbeing and legal compliance. Orange Belgium is

also considering adopting an ISO certification 45001 on health

and safety.

A transversal wellbeing team composed of health and safety,

wellbeing, internal communication & culture experts as well as

representatives of the Thriving team defined and organised a new

"Zest your wellbeing" week and year programme, based on

lessons learned from the wellbeing-week organised in October

2024. The 2026 plan is still to be designed but will be an

extension of the 2025 plan.

(

2

)

T

h

e

o

p

o

r

t

u

n

i

t

i

e

s

f

o

r

e

a

c

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m

p

l

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y

e

t

o

s

h

o

w

c

a

s

e

t

h

e

i

r

s

k

i

l

s

a

n

d

a

b

i

l

i

t

i

e

s

,

d

e

v

e

l

o

p

t

h

e

m

,

a

n

d

a

d

v

a

n

c

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t

h

r

o

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g

h

o

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t

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e

i

r

c

a

r

e

r

.

The Orange Belgium T

T

h

r

i

v

i

n

g

t

e

a

m

, which was deployed in early

2023, ensures a culture centred on wellbeing is implemented

across the organisation. The team is composed of internal

coaches

who

support

managers,

teams

and

individual

employees across sites and departments on several of the

above-mentioned pillars. The team meets monthly to ensure

consistency and alignment of interventions. Their work focuses

primarily on strengthening team synergies to support sustainable

and effective team dynamics, and on empowering individual

growth by helping employees unlock their potential, enhance

wellbeing and take ownership of their personal development.

On top of the Thriving team support, a new learning policy was

deployed in first quarter 2025 to boost employee skills, attract &

retain talent and ensure legal compliance (for more details, see

also supra in

section 3.2.2.4 Taking actions on training and skills

development (S1-4)

). Orange has also joined and promoted the

Group's Internal mobility platform publishing all internal

opportunities in Belgium and beyond.

(

3

)

S

h

a

r

e

d

v

a

l

u

e

s

(

c

a

r

i

n

g

,

r

e

s

p

o

n

s

i

b

l

e

,

b

o

l

d

)

a

n

d

a

n

i

n

c

l

u

s

i

v

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c

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l

t

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r

e

a

t

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e

a

r

t

o

f

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r

i

n

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a

c

t

i

o

n

s

a

n

d

w

a

y

o

f

w

o

r

k

i

n

g

.

The Orange Group values were deployed throughout the

company by means of team workshops and an e-learning

available on smartphones specifically designed for colleagues in

shops and technicians on the road. These new values are

included in the objectives of all team members and people

managers.

(

4

)

O

p

t

i

m

a

l

w

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k

i

n

g

c

o

n

d

i

t

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:

a

n

a

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,

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t

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,

a

f

a

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l

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p

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s

,

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s

t

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y

.

All managers had a people management objective which

included, amongst others the translation/cascading of the

strategy into the teams’ strategy. The working conditions and

packages of Orange Belgium and former VOO employees have

been aligned, starting with the review and the regrading of all job

descriptions.

These

changes

have

been

thoroughly

accompanied with extensive communications and info sessions

attended by over 3000 participants.

I

n

c

o

n

c

l

u

s

i

o

n

, this structured approach to wellbeing integrated

various voluntary and compliance measures, fostering a safe and

healthy work environment for all employees.

For Orange Communications Luxembourg, several activities are

implemented along the year but are not part of an action plan.

For more information on the process activated in the event of a

workplace accident (severe, less severe, psychological damage),

refer to the remedy process and actions supra in section

3.2.1.2

Processes to remediate negative impacts and channels for own

workers to raise concerns (S1-3)

.

The b

b

u

d

g

e

t

d

e

d

i

c

a

t

e

d

t

o

p

r

e

v

e

n

t

i

o

n

is regulated in Belgium,

where employers are required to allocate a legally defined

amount per employee each year. This amount is set by the

authorities and adjusted annually for indexation. For 2025,

Orange Belgium’s prevention budget amounts to €207,218.

In terms of human resources, the Internal Service for Prevention

and Protection (ISPP) was staffed with three full-time Prevention

Advisors and one advisor at 80% until 30 June 2025. As of 1 July,

the ISPP has been strengthened with an additional two full time

equivalents (FTEs), reflecting increased resource allocation to

support the implementation of the action plan.

To assess effectiveness of Orange actions and strategy, Orange

counts on “Your Voice” surveys and the yearly Voice Up from the

Group. Regarding health and safety, Orange Belgium conducts

annual monitoring of social risks through these employee surveys

to evaluate workplace dynamics and wellbeing (see also supra in

section 3.2.1.1 Processes for engaging with own workers and

workers’ representatives about impacts (S1-2)

). Reports from

complaints stemming from the whistleblowing system also

enables to identify issues related to the effectiveness of its

actions.

The company also tracks the completion rates of training courses

designed for employees in high-risk areas, including high-rise

sites and antenna work. In alignment with its duty of vigilance

framework, Orange Belgium annually evaluates health and safety

risks and implements action plans to mitigate them.

172

Orange Belgium

_

Annual report 2025

173

3.2.5

Additional metrics related to own workforce

The following sections present some characteristics of Orange’s employees. This section covers all entities covered by this report:

Orange Belgium, WBCC, Be tv, and Orange Communications Luxembourg. Note that, at the end of 2025, Netco did not count any

employees.

Number of employees by gender (S1-6)

N

u

m

b

e

r

o

f

e

m

p

l

o

y

e

s

b

y

g

e

n

d

e

r

(

h

e

a

d

c

o

u

n

t

)

2

0

2

4

2

0

2

5

Male

1,888

1,867

Female

1,077

1,045

Other

N/A

Not reported

N/A

T

o

t

a

l

e

m

p

l

o

y

e

s

2

,

9

6

5

2

,

9

1

2

T

a

b

l

e

1

5

:

O

r

a

n

g

e

’

s

e

m

p

l

o

y

e

s

’

d

i

s

t

r

i

b

u

t

i

o

n

b

y

g

e

n

d

e

r

Number of employees by country (S1-6)

N

u

m

b

e

r

o

f

e

m

p

l

o

y

e

s

b

y

c

o

u

n

t

r

y

(

h

e

a

d

c

o

u

n

t

)

2

0

2

4

2

0

2

5

Belgium

2,822

2,767

Luxembourg

143

145

T

a

b

l

e

1

6

:

O

r

a

n

g

e

’

s

e

m

p

l

o

y

e

s

’

d

i

s

t

r

i

b

u

t

i

o

n

b

y

c

o

u

n

t

r

y

All employees are located in Belgium and Luxembourg, within the European region. The Luxembourg entity represents a relatively

small entity with a limited workforce. As of the reporting period, NetCo does not employ any staff. In addition, the Group makes

generally

limited use of temporary workers.

173

Orange Belgium

_

Annual report 2025

174

Number of employees by contract type, broken down by gender (S1-6)

C

o

n

t

r

a

c

t

y

p

e

2

0

2

4

2

0

2

5

Number of permanent employees

2,950

2,902

Of which male

1,888

1,859

Of which female

1,070

1,043

Of which other

-

Of which not disclosed

-

Number of temporary employees

15

10

Of which male

8

Of which female

7

2

Of which other

-

Of which not disclosed

-

Number of non-guaranteed hours employees

-

T

a

b

l

e

1

7

:

O

r

a

n

g

e

’

s

e

m

p

l

o

y

e

s

’

d

i

s

t

r

i

b

u

t

i

o

n

b

y

c

o

n

t

r

a

c

t

y

p

e

a

n

d

g

e

n

d

e

r

E

m

p

l

o

y

e

d

e

p

a

r

t

u

r

e

a

n

d

t

u

r

n

o

v

e

r

2

0

2

4

2

0

2

5

Number of employees who have left the company

226

286

Employee turnover

7.6%

9.8%

T

a

b

l

e

1

8

:

O

r

a

n

g

e

’

s

e

m

p

l

o

y

e

d

e

p

a

r

t

u

r

e

s

a

n

d

t

u

r

n

o

v

e

r

a

t

e

These numbers are consistent with social statement published at the National Bank's Central Balance Sheet for each respective

entities in Belgium that are part of this report.

M

E

T

H

O

D

O

L

O

G

I

C

A

L

N

O

T

E

All numbers are reported in headcount based on 31 December 2025 figures.

The data collection process for workforce analysis is based on standardised Group definitions and a centralised HR data system.

An active employee is defined as an individual who is currently employed on a fixed-term or permanent contract, receiving

remuneration, and not on temporary leave at the end of the reporting period. Apprentices are excluded from the workforce data,

with the impact deemed non-material.

Data is extracted from the HR information system, which provides comprehensive details on all employees across multiple entities.

The dataset includes key attributes such as employment status, gender, contract type, organisational level, age, and site location.

The reporting period corresponds to the last day of the fiscal year.

Collective bargaining coverage and social dialogue (S1-8)

As in 2024, all employees in Belgium and Luxembourg are

covered by collective bargaining agreements and by workers’

representation mechanisms. In addition, an agreement is in place

providing for the representation of Orange employees through a

European Works Council (European Group Works Council).

Percentage of own employees covered by collective bargaining

agreements are within coverage rate by country with significant

employment (in the EEA countries i.e. Belgium and Luxembourg)

174

Orange Belgium

_

Annual report 2025

175

Percentage of own employees covered by collective bargaining agreements are within coverage rate by country with

significant employment (in the EEA countries i.e. Belgium and Luxembourg)

C

o

v

e

r

a

g

e

R

a

t

e

E

m

p

l

o

y

e

s

-

E

A

(

w

i

t

h

>

5

0

e

m

p

l

.

r

e

p

r

e

s

e

n

t

i

n

g

>

1

0

%

t

o

t

a

l

e

m

p

l

)

E

m

p

l

o

y

e

s

-

N

o

n

-

E

A

(

e

s

t

i

m

a

t

e

f

o

r

e

g

i

o

n

s

w

i

t

h

>

5

0

e

m

p

l

.

r

e

p

r

e

s

e

n

t

i

n

g

>

1

0

%

t

o

t

a

l

e

m

p

l

)

0-19%

-

20-39%

-

40-59%

-

60-79%

-

80-100%

100%

Belgium and Luxembourg

-

Table 19: Orange’s collective bargaining coverage

Percentage of employees covered by

workers' representatives in EEA countries:

C

o

v

e

r

a

g

e

R

a

t

e

W

o

r

k

p

l

a

c

e

r

e

p

r

e

s

e

n

t

a

t

i

o

n

(

E

A

o

n

l

y

)

(

f

o

r

c

o

u

n

t

r

i

e

s

w

i

t

h

>

5

0

e

m

p

l

.

)

0-19%

-

20-39%

-

40-59%

-

60-79%

-

80-100%

100%

Belgium and Luxembourg

T

a

b

l

e

2

0

:

O

r

a

n

g

e

’

s

o

c

i

a

l

d

i

a

l

o

g

u

e

c

o

v

e

r

a

g

e

Adequate wages (S1-10)

As

in

2024,

all

employees

are

compensated with adequate wages that

align

with

applicable

benchmarks.

Orange Group is actively pursuing the

Group Living Wage certification project,

issued by the Fair Wage Network, a non-

governmental organisation recognised

by the UN, under the designation of “Fair

Wage Employer” to ensure that a decent wage is guaranteed in

all Group entities. This certification is based on a recognised,

rigorous standard and methodology developed by the Fair Wage

Network to evaluate wage policies comprehensively. The Fair

Wage standard encompasses 12 dimensions, covering the full

spectrum

of

wage

indicators.

Companies

can

undergo

assessment by the Fair Wage Network in various markets and

may be awarded the Fair Wage Employer Certification upon

meeting the standard’s requirements.

Orange Belgium, WBCC, Be tv & Orange Communications

Luxembourg were included in the 2025 Living Wage certification

process. Orange Group initiated the certification assessment

process in May 2025. The certification process for Orange

Group’s 2025 assessment has been finalised, and the Living

Wage Certification has been granted by The Fair Wage Network

company in October 2025.

Annual remuneration ratio (S1-16)

The CEO-to-median pay ratio is a measure used to compare the

total remuneration of the Chief Executive Officer (highest paid

individual) to the median remuneration of all employees within the

organisation.

This ratio provides insight into income distribution and pay

equity, reflecting the relative position of the CEO’s compensation

in relation to the broader workforce of all entities covered in this

report.

The year-on-year increase is due to an increase on the side of

the highest total remuneration.

Annual total remuneration ratio (S1-16)

2

0

2

4

2

0

2

5

Annual total remuneration ratio

13.45

17.87

T

a

b

l

e

2

1

:

O

r

a

n

g

e

’

s

a

n

u

a

l

r

e

m

u

n

e

r

a

t

i

o

n

r

a

t

i

o

M

E

T

H

O

D

O

L

O

G

I

C

A

L

N

O

T

E

Calculation of this ratio is built on annual full-time remuneration based on the salaries in October 2025 including effective variable

remuneration paid. All salary information of the different entities has been aggregated before calculating the median.

This KPI is calculated as the ratio of the highest paid individual, specifically the CEO, to the median annual total remuneration in all

entities part of this report.

175

Orange Belgium

_

Annual report 2025

176

3.3

Orange’s consumers and end-users (S4)

3.3.1

Management of impacts, risks and opportunities with end users

In line with the company’s purpose “As a trusted partner, Orange

gives everyone the keys to a responsible digital world”, the goal

in this section is to cover some key topics of interest for

consumers, end-users, and potentially beyond for the good of

society at large. The key topics of interest relate to:

•

The digital divide and how Orange contributes to

reduce it through actions for digital inclusion;

•

The potential risk of psychological health of end-users

and how Orange helps to prevent it;

•

The data privacy and cybersecurity threats and how

Orange prepares to avoid such issues and if any, how

to recover from it.

Before exploring these topics in greater detail in the following

sub-sections, this first sub-section presents the two processes

used to engage with stakeholders and, where necessary,

address any possible negative impact.

3.3.1.1

Processes for engaging with consumers and end-users about impacts (S4-2)

Stakeholder

engagement

occurs

at

both

strategic

and

operational levels:

•

A

t

h

e

s

t

r

a

t

e

g

i

c

l

e

v

e

l

,

a structured stakeholder dialogue

was conducted in 2024 as part of the double materiality

assessment, including a survey addressed to a sample

of 3,000 customers as explained in more detail in

section

1.1.3.2 Interests and views of stakeholders

(SBM-2).

This engagement focused on gathering

insights from key stakeholder groups to determine

sustainability priorities and expectations.

•

A

t

h

e

o

p

e

r

a

t

i

o

n

a

l

e

v

e

l

,

Orange engages regularly with

end users through initiatives delivered notably through

the Orange Digital Center, Orange Belgium Fund or

Orange Fab or Orange care corners in shops. These

engagements take place throughout the year and

include activities related to digital inclusion, diversity

and

entrepreneurship

as

well

as

programmes

supporting the psychological wellbeing of end users.

These interactions provide ongoing input on user needs

and societal expectations.

Engagements through the double materiality exercise or through

Orange Belgium fund and Orange Digital Center’s initiatives are

under the responsibility of the Chief Brand, Communication &

ESG Officer. In addition, the person responsible for the contact

centre, the Chief of Customer business unit, is responsible for

ensuring that customer services are available and provided.

Additional customers’ surveys are also undertaken:

•

Customer

engagement

is

guaranteed

through

continuous

c

u

s

t

o

m

e

r

s

a

t

i

s

f

a

c

t

i

o

n

s

u

r

v

e

y

s

(newcomers/churns), sectorial studies (by BIPT), etc.

New offers are designed based on customer insights

and concept test studies;

•

Customer engagement therefore occurs both through

direct communication channels and through proxies.

In addition, in order to monitor the e

e

v

o

l

u

t

i

o

n

o

f

d

i

g

i

t

a

l

i

n

e

q

u

a

l

i

t

i

e

s

in Belgium, Orange Belgium consults the King Baudouin

Foundation Digital Inclusion Barometer published every two

years since 2020, with the aim of serving as a benchmark for

political, institutional and field players concerned by the issue.

The 2024 digital inclusion barometer of the Belgian population

between 16 and 74 years old, enabled us to highlight the most

vulnerable users, populations and ages, and therefore those to

be prioritised in the choice of support projects. On that front,

Orange Belgium is reinforcing its long-standing commitment to

p

r

o

t

e

c

t

i

n

g

young people against digital abuse: the first issue

addressed is cyberbullying before turning our attention to online

hate and hyperconnectivity. A mobilisation now defined under

the F

F

o

r

G

o

d

C

o

n

e

c

t

i

o

n

s

initiative. The company is initiating a

series of preventive and educational actions to help children, and

their parents adopt good practices so they can use digital tools

as responsibly and safely as possible.

The Belgian institute for the e

e

q

u

a

l

i

t

y

o

f

w

o

m

e

n

a

n

d

m

e

n

published a study showing that in Belgium 1 out of 5 young

people are victim of cyberbullying. Other external studies on the

digital divide and u

u

n

e

m

p

l

o

y

m

e

n

t

in Belgium are used to grasp

opportunities to have a positive impact on local socio-economic

development, support for local stakeholders, social cohesion and

professional integration. These studies are considered when

defining priorities at Orange Belgium to manage its impacts and

the priorities the company.

For over 30 years, the Orange Foundation has worked to ensure

that digital technology supports equal opportunities. In Belgium,

the

O

r

a

n

g

e

B

e

l

g

i

u

m

F

u

n

d

was

created to

support projects that

promote solidarity and responsibility. This patronage aims to

provide practical assistance to associations on the ground that

are active in digital inclusion, with a focus on education and

employability.

Effectiveness of the double materiality stakeholder dialogue is

not monitored as such but is part of a continuous improvement

process and learning from best practices. Activities of the Orange

Digital Center are followed by satisfaction surveys.

176

Orange Belgium

_

Annual report 2025

177

3.3.1.2

Processes to remediate negative impacts and channels for consumers and

end-users to raise concerns (S4-3)

Customer engagement is always possible thanks to Orange

Customer Services (CS) that are accessible to customers through

a toll-free number. The CS are trained and organised to be able

to answer a wide range of questions and requests, including

issues relating to negative impacts:

•

Blocking solution: enabling limits

on the number of

calls/messages a customer can make, i.e. premium

numbers.

•

Identity

usurpation:

managing

situations

where

Orange’s customers suspect that their identity has

been misused.

•

Fraud detection processes.

These solutions are available on a continuous basis, and

reporting is organised around these issues to ensure proper

execution.

After each conversation with the C

C

S

3

0

,

the customer receives a

customer satisfaction survey. This allows us to measure if the

solution provided was satisfactory for the end-user. If the

response is negative, the concerned team contacts the customer

again to help him further.

Orange applies the C

C

u

s

t

o

m

e

r

O

p

e

r

a

t

i

o

n

P

e

r

f

o

r

m

a

n

c

e

C

e

n

t

r

e

(COPC) guidance, which sets standards and best practices used

to help organisations improve customer service and operations

in call centres. Orange support team (managers, leaders,

knowledge responsible, workforce management team, quality

team) must be certified. This enables availability of the workforce

to be planned based on forecasts on expected changes in

customer calls and requests. Therefore, the company uses the

COPC guidance for defining and measuring KPI's and

implementing a quality standard within Orange.

Should one of the above engagement processes result in an

issue (human rights, health and safety, data privacy or security)

with the need to remediate to a possible negative impact, anyone

internal or external to Orange (thus including consumers and

end-users) can use the w

w

h

i

s

t

l

e

b

l

o

w

i

n

g

s

y

s

t

e

m

that can be

accessed via the Internet, on Orange’s website, the Group’s

Intranets and via public search engines

31

. This Group system may

be supplemented by local systems for individual countries or

entities. In Belgium, the mechanisms, safeguards, protection are

imposed and defined by the Belgian whistleblowing regulation

32

and translated in the Orange Belgium whistleblowing policy and

approach. See also more details infra in section

4.1.1.1 Business

conduct policies and corporate culture (G1-1, G1-3)

.

Contact reasons are continuously monitored. Based on these

reasons, actions are taken to tackle the most recurrent issues, to

resolve them, to improve customer communication / information

or to implement digital solutions.

A secure web platform is available that facilitates the

whistleblower's reporting process, while providing a clear

overview of the status of his or her report, and continues to

guarantee the confidentiality of the information transmitted, the

protection of his or her actions, and anonymity if he or she so

wishes. No employee may be penalised or subjected to

discriminatory measures for having reported an alert in a

disinterested manner and in good faith through the Group's

whistleblowing system or through the local system. Misuse of the

alert system exposes its author to disciplinary sanctions and/or

legal prosecution.

Considering the psychological health of end users, Orange’s

activities are focused on prevention. No remediation action is

foreseen.

Regarding data privacy and cybersecurity, consumers and end-

users are informed about their rights and can exercise them with

the Data Protection Officer in the country concerned (see more

details infra in

section 3.3.4.1 Policies related to data privacy and

cybersecurity (S4-1)

).

Orange has not a standardized approach in defining actions that

are needed and appropriate in response to negative impacts.

These are identified on a case-by-case basis. Currently, the

effectiveness of the actions or initiatives the company puts in

place to deliver positive outcomes for the users of its products

and services are not systematically monitored and assessed.

Currently there is no standardised approach within Orange to

ensure that processes to provide or enable remedy in the event

of material negative impacts on consumers and end-users are

available and effective.

30

Consumers can reach the Customer Service teams via the direct number 5000 or in Belgium 02 745 95 00. The information is shared on the company website:

https://www.orange.be/fr/ivr-helper-fr

31

The whistleblowing system can be found here

https://orange.integrityline.org/

32

The Belgian whistleblowing regulation:

https://www.ejustice.just.fgov.be/eli/besluit/2023/01/22/2023040158/justel

177

Orange Belgium

_

Annual report 2025

178

3.3.2

Management of impacts, risks and opportunities related to digital

inclusion

3.3.2.1

Policies related to digital inclusion (S4-1)

The Group’s human rights

33

policy includes a component

focused on digital citizenship described supra in

chapter 3.1

Human rights

and section

3.1.3 Human rights for consumers and

end users

which specifically addresses the p

p

o

s

i

t

i

v

e

i

m

p

a

c

t

s

r

e

l

a

t

e

d

t

o

i

n

c

l

u

s

i

o

n

, e

e

m

p

o

w

e

r

m

e

n

t

,

a

n

d

e

q

u

a

l

o

p

o

r

t

u

n

i

t

i

e

s

. This

policy applies to all entities and subsidiaries across all

geographic regions, including Belgium and Luxembourg.

Orange champions the idea that digital technology can be used

for social and economic development for everyone. To help

people become responsible digital citizens, exercise their basic

rights, and grow in a world that is becoming more digital and

where technology is advancing very quickly, they need to be

given the tools to act confidently and consciously. This approach

aims

at

increasing

the

positive

impact

of

access

to

telecommunications services.

From the same perspective, Orange is aware that while the

increasing digitisation of society offers many opportunities, it also

presents a significant r

r

i

s

k

o

f

s

i

d

e

l

i

n

i

n

g

p

e

o

p

l

e

w

h

o

h

a

v

e

d

i

f

i

c

u

l

t

y

u

s

i

n

g

d

i

g

i

t

a

l

t

e

c

h

n

o

l

o

g

i

e

s

. The company thus seeks to create a

more adapted inclusive digital environment by g

g

i

v

i

n

g

e

v

e

r

y

o

n

e

t

h

e

k

e

y

s

t

o

a

m

o

r

e

r

e

s

p

o

n

s

i

b

l

e

d

i

g

i

t

a

l

w

o

r

l

d

3

4

.

To this end, Orange Belgium embraces two fundamental

approaches to bridge the digital divide. The f

f

i

r

s

t

a

p

r

o

a

c

h

r

e

v

o

l

v

e

s

a

r

o

u

n

d

t

h

e

p

r

i

n

c

i

p

l

e

o

f

p

r

o

v

i

d

i

n

g

c

o

m

p

r

e

h

e

n

s

i

v

e

t

r

a

i

n

i

n

g

,

r

a

i

s

i

n

g

a

w

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s

,

a

n

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f

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r

i

n

g

o

n

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o

i

n

g

s

u

p

o

r

t

, all

carefully structured around three core ambitions: a

a

w

a

r

e

n

e

s

o

n

p

r

o

t

e

c

t

i

o

n

and e

e

d

u

c

a

t

i

o

n

,

ensuring safety and security as well as

fostering digital literacy and knowledge; d

d

e

v

e

l

o

p

e

m

p

l

o

y

a

b

i

l

i

t

y

,

which enhances skills and job opportunities; and

e

n

c

o

u

r

a

g

e

i

n

o

v

a

t

i

o

n

a

n

d

e

n

t

r

e

p

r

e

n

e

u

r

s

h

i

p

.

The s

s

e

c

o

n

d

o

n

e

f

o

c

u

s

e

s

o

n

t

h

e

t

a

n

g

i

b

l

e

d

e

p

l

o

y

m

e

n

t

o

f

i

n

f

r

a

s

t

r

u

c

t

u

r

e

,

m

a

k

i

n

g

c

o

n

e

c

t

i

v

i

t

y

m

o

r

e

w

i

d

e

s

p

r

e

a

d

a

n

d

r

e

l

i

a

b

l

e

, a

a

l

o

n

g

s

i

d

e

f

o

r

t

s

t

o

i

m

p

r

o

v

e

a

f

o

r

d

a

b

i

l

i

t

y

and ensure that

access to devices is within reach for all, thereby creating a more

inclusive digital environment.

3.3.2.2

Target related to digital inclusion (S4-5)

In line with the positive material impacts of digital inclusion,

Orange Belgium and Orange Communications Luxembourg

contribute to the objectives set by Orange Group to offer f

f

r

e

t

r

a

i

n

i

n

g

s

o

r

d

i

g

i

t

a

l

w

o

r

k

s

h

o

p

s

t

o

s

i

x

m

i

l

i

o

n

p

e

o

p

l

e

b

e

t

w

e

n

2

0

2

1

a

n

d

2

0

3

0

. The number of people benefiting from these

programmes contributes to this goal, and the Group’s CSR

management monitors progress towards achieving the target.

Considering the prominent role of digital technology in society,

Orange believes that simply providing access to connectivity or

services may be insufficient for populations distant from digital

tools.

One of the two approaches involves developing locally: t

t

r

a

i

n

i

n

g

,

e

d

u

c

a

t

i

n

g

,

a

n

d

e

m

p

o

w

e

r

i

n

g

c

o

m

u

n

i

t

i

e

s

.

33

Orange Group's Human Rights Policy is available here https://gallery.orange.com/en/element?id=410239

34

More information and access to reports are available on the corporate website:

https://corporate.orange.be/en/durability/social

178

Orange Belgium

_

Annual report 2025

179

The targets related to digital inclusion are set by the Orange

Group based on the realistic but ambitious Key Performance

Indicators to which each country of operations is expected to

contribute. They are defined through a multidimensional

approach: studies and benchmarks, an inventory of initiatives by

Orange’s subsidiaries and foundations carried out in 2021, and

finally a proactive, centralised approach to bring these initiatives

together and ensure their contribution to the Group's objectives.

These absolute targets stem from the Group strategy that has

been implemented at local level. The strategy underscores the

need for inclusivity in digital access and education, particularly

for marginalised groups. This aligns with the target of ensuring

equal opportunities for all children to thrive in a digital

environment, thereby addressing issues of discrimination and

access.

In 2025, thanks to the actions implemented described infra in

section

3.3.2.3 Taking actions on digital inclusion (S4-4)

and, in

section

3.3.3.3 Taking actions on psychological health of end-

users (S4-4)

, 1

1

3

,

0

people have benefited f

f

r

o

m

O

r

a

n

g

e

B

e

l

g

i

u

m

’

s

digital inclusions initiatives and 1

1

,

5

0

for O

O

r

a

n

g

e

C

o

m

u

n

i

c

a

t

i

o

n

s

L

u

x

e

m

b

o

u

r

g

.

In 2024, 9,900 people have

benefited from Orange Belgium’s digital inclusion initiatives and

120 for Orange Communications Luxembourg, meaning a

a

n

i

n

c

r

e

a

s

e

o

f

4

5

%

i

n

t

o

t

a

l

b

e

t

w

e

n

2

0

2

4

a

n

d

2

0

2

5

.

Orange has formalised a list of programmes eligible to contribute

to the number of beneficiaries with the criterion that the learner

must be supported by Orange or its partners.

M

E

T

H

O

D

O

L

O

G

I

C

A

L

N

O

T

E

A beneficiary is defined as a participant in one of the programmes delivered by Orange’s care initiatives, so the same person may

represent multiple beneficiaries:

•

Orange aims at addressing the specific challenges faced by vulnerable groups, including c

c

h

i

l

d

r

e

n

, the e

e

l

d

e

r

l

y

,

and

i

n

d

i

v

i

d

u

a

l

s

w

i

t

h

d

i

s

a

b

i

l

i

t

i

e

s

,

as well as underrepresented groups such as y

y

o

u

n

g

i

r

l

s

a

n

d

w

o

m

e

n

, to encourage careers in

technology and digital sectors. This initiative contributes to building a more diverse and inclusive digital workforce.

•

A person or organisation supported by Orange in acquiring digital skills, either in person or online, regardless of the

duration or format. This may include workshops, training courses, webinars, hackathons or master classes. Beneficiaries

include individuals who benefit from programmes run by the company, Orange's partners, the Orange Foundation, as well

as organisations such as supported start-ups.

Eligible trainings reported only include free training sessions. Additional information is collected on the gender, age and training

duration.

This metric is not validated by an external body. The methodologies related to these targets have not changed compared to last

year.

To monitor the evolution of digital inequalities in Belgium, the

King Baudouin Foundation

35

has been publishing the Digital

Inclusion Barometer

36

every two years since 2020, aiming at

serving as a benchmark for political, institutional and field

stakeholders concerned by the issue. Orange Belgium, and more

specifically the Orange Belgium Fund uses this data as a source

to identify local key targets and highlight the most vulnerable

users, populations and age groups, thereby prioritising them in

support projects.

The Orange Foundation is present in Belgium via the Orange

Belgium Fund. It is a corporate fund managed by the King

Baudouin Foundation. As partners, the company can benefit

from its expertise, recognition and network, and build synergies

to increase the impact of its activities in the field.

For each support, a new agreement is established between the

King Baudouin Foundation and the partner organisation,

specifying the amount and the objectives. These agreements

cannot be established without being submitted and validated by

a committee composed of external members.

Following each training delivered by Orange or partnership via

the King Baudouin Foundation, the number of beneficiaries is

collected, and reporting is conducted regularly within an internal

sustainability data management system. These data enable

Orange to manage its impacts, risks and opportunities related to

digital inclusion.

3.3.2.3

Taking actions on digital inclusion (S4-4)

The actions described below are not designed to address harm

caused by material negative impacts but rather to proactively

create positive societal impacts by addressing the digital divide

and improving access to technology and education for

underrepresented or vulnerable groups. Instead, the initiatives

focus on a

a

m

p

l

i

f

y

i

n

g

b

e

n

e

f

i

t

s

and f

f

o

s

t

e

r

i

n

g

i

n

c

l

u

s

i

o

n

through

35

Complete information on the website:

https://kbs-frb.be/en

36

Resources and articles available on the foundation's website here:

https://kbs-frb.be/en/search?searchTerm=barometer

prevention. There is no remediation action foreseen. To Orange’s

knowledge, there are no individuals or stakeholder groups

harmed by these actions.

Related to the two above explained fundamental approaches to

bridge the digital divide, here are the actions taken in 2025.

179

Orange Belgium

_

Annual report 2025

180

Inform, train, awareness

Orange actively collaborates with various stakeholders, including

educational institutions, this collaborative approach is essential

for addressing systemic barriers to digital access and ensuring

that inclusive practices are implemented effectively across

different communities. Those actions are rather focused on

prevention than on remediation. Negative impacts on digital

inclusion are mainly dealt with through preventive measures only

as described in the respective actions plans.

The approach is structured around three core ambitions:

As previously mentioned, C

C

o

r

p

o

r

a

t

e

P

h

i

l

a

n

t

h

r

o

p

y

, through the

O

r

a

n

g

e

B

e

l

g

i

u

m

F

u

n

d

a

n

d

O

r

a

n

g

e

D

i

g

i

t

a

l

C

e

n

t

e

r

s

, truly focuses

on promoting education, social, and professional integration,

especially for children, young people, people with disabilities and

women facing challenges. Some specific examples below:

•

A

w

a

r

e

n

e

s

o

n

p

r

o

t

e

c

t

i

o

n

and e

e

d

u

c

a

t

i

o

n

,

ensuring

safety and security as well as fostering digital literacy

and knowledge:

o

In partnership with the association

Bibliothèques

Sans Frontières

, the company is launching the

intergenerational project Digital Buddy aimed at

helping more specifically seniors) and address

basic daily digital issues (passwords, updates,

banking apps, etc.) and to strengthen digital

autonomy

and

social

ties.

Additionally,

the

company launched Digital Buddies (internal), a

dedicated programme for Orange Belgium team

members

to

become

Digital

Inclusion

Ambassadors;

o

Presence of Care Corners and Care Agents present

in four Orange Shops (across the country) offered

over 400 services and personalised individual

support to beneficiaries in 2025. In

o

addition, the company works to improve the

accessibility of applications and services to

increase and retain customers with inclusive digital

services;

o

Fostering early engagement in technology among

young girls to ensure the integration of women into

the tech sector, particularly from primary school,

and introducing digital skills through robotics and

programming. In partnership with the non-profit

organisation

Code&Play

, 700 children have been

trained through workshops in schools;

180

Orange Belgium

_

Annual report 2025

181

o

The non-profit association

Tic Tac Lab

receives

support from Orange to assist young teenagers

with disabilities or specific needs in developing

digital skills through tangible projects, using tech

machines from a FabLab;

o

Specific training and e-training programmes for

women in situations of digital vulnerability have

been offered to many beneficiaries with the support

of the non-profit association

Girleek.

•

D

e

v

e

l

o

p

e

m

p

l

o

y

a

b

i

l

i

t

y

, which enhances skills and job

opportunities;

and

e

n

c

o

u

r

a

g

e

i

n

o

v

a

t

i

o

n

a

n

d

e

n

t

r

e

p

r

e

n

e

u

r

s

h

i

p

:

o

To

develop

employability

and

support

the

economic fabric, and recognising the need for

digital skills, Orange has been offering training

programmes through its own Orange Digital Center

since 2022. Supported and partnered with various

organisations and the Orange Belgium Fund, these

programs include coding schools, access and

training at FabLab, and startup support via Orange

Fab;

o

These initiatives mainly target young adults, career

switchers, and especially women, to promote

professional inclusion in digital fields. To enhance

employability and promote diversity in technology,

a partnership with the non-profit organisation

Becode

has

supported

AI/Cybersecurity

Hackathons, and a NoCode course has been

offered, benefiting over 700 individuals in total;

o

The FabLab has also trained and provided access

to many beneficiaries to develop their skills in

technology,

digital

fabrication,

and

entrepreneurship;

o

At Orange Communications Luxembourg, digital

skills and inclusion programmes are implemented

through their Orange Digital Center, focusing on

developing access to digital skills (including basic

skills and coding.) These training courses are

monitored quarterly through participant follow-up.

Most of the initiatives mentioned above are performed on a

continuous roll out across the years without defined deadlines.

Initiatives of the Orange Digital Center and the Orange Belgium

Fund for digital inclusion: they both are active since 2022 and will

continue deploying digital inclusion and trainings dedicated to

digital wellbeing delivered to Belgian population on yearly basis

with a long-term horizon of 2030 ambition.

Connect and equip (combating the digital divide

through the deployment of infrastructure)

Orange's policy objectives emphasise the importance of

providing equitable access to digital tools and resources for all

users, regardless of their socio-economic background.

When considering the positive impact Orange can have on digital

inclusion, the company mainly identified populations with limited

digital skills who could be limited in their access to information

and essential online services. Orange Belgium also identified a

positive impact of its products and services on marginalised

groups who suffer from economic and social exclusion.

•

I

n

f

r

a

s

t

r

u

c

t

u

r

e

f

o

r

d

i

g

i

t

a

l

i

n

c

l

u

s

i

o

n

:

Investing

in

expanding Orange’s digital infrastructure to make

connectivity accessible for all and enable the adoption

of

digital

tools,

supporting

socio-economic

development. For instance, rolling out very high-speed

fixed network (1 Gbps) in Walloon

w

h

i

t

e

z

o

n

e

s

(covering 114,000 homes across 75 municipalities) with

88,000 homes already connected and full deployment

expected by June 2026 aim to reach underserved

communities

and

populations.

Additionally,

the

company monitors mobile and broadband network

coverage in relation to the population coverage for

Orange Belgium to ensure effective extension and

improvement of network access.

•

E

q

u

i

p

:

Offering accessible services and products for

families, young and elders in precarious situations,

people

with

disabilities,

small

businesses,

and

associations. This includes essential services like

financial products, energy, healthcare, and cultural

access. To ensure accessibility, Orange implemented

s

o

c

i

a

l

t

a

r

i

f

s

for low-income seniors, individuals

receiving integration income.

•

I

n

c

l

u

s

i

v

e

S

e

r

v

i

c

e

s

B

e

y

o

n

d

C

o

n

e

c

t

i

v

i

t

y

:

To address

essential needs, Orange extends services in financial

access,

energy,

healthcare,

and

education,

all

supported by its connectivity infrastructure, making

digital a tool for equal opportunity.

•

N

e

t

w

o

r

k

i

n

v

e

s

t

m

e

n

t

s

i

n

B

e

l

g

i

u

m

:

o

Launch of a new Social Tariff in March 2024 within

the VOO footprint (€19 fixed offer).

o

Deployment of satellite broadband offer in 2024 for

households not eligible for fibre or HFC.

o

Ongoing rollout of very high-speed fibre (1 Gbps) in

Walloon white zones (114k homes, 75 communes)

— 88k homes already covered, full completion by

June 2026.

•

A

c

e

s

a

n

d

a

f

o

r

d

a

b

i

l

i

t

y

a

t

O

r

a

n

g

e

C

o

m

u

n

i

c

a

t

i

o

n

s

L

u

x

e

m

b

o

u

r

g

:

The programme “Coup De Pouce”

offers available for fibre and mobile services, aimed at

low-income households receiving the cost-of-living

allowance who have received the connectivity

voucher from the Luxembourg government. The

social offer is available at the start of each new year,

once the connectivity voucher has been distributed.

The company assesses how service degradation or network

outages could negatively affect users, especially d

d

u

r

i

n

g

t

e

c

h

n

i

c

a

l

o

r

c

l

i

m

a

t

i

c

r

i

s

e

s

.

This evaluation guides the prioritisation of

network improvements and the ongoing refinement of monitoring

and maintenance tools, ensuring efforts target situations where

users would be most impacted. In case of incidents, this

approach also helps determine the most efficient way to restore

service quickly.

For over 10 years, as mentioned in supra section

1.1.3.1

Strategy, business model and value chain (SBM-1)

, Orange has

adopted

a

strategic

approach

to

investing

in

Gigabit

infrastructure and has been deploying its own network since the

end of 2024. Orange Belgium remains committed and actively

works on the continuous development of its fixed and mobile

networks. Starting from the end of 2025, the Satellite offer

provides connectivity for the entire population.

181

Orange Belgium

_

Annual report 2025

182

3.3.3

Management of impacts, risks and opportunities related to

psychological health of end-users

3.3.3.1

Policies related to psychological health of end-users (S4-1)

Through its h

h

u

m

a

n

r

i

g

h

t

s

p

o

l

i

c

y

as well as the p

p

o

l

i

c

y

o

n

c

h

i

l

d

r

e

n

'

s

r

i

g

h

t

s

a

n

d

p

r

o

t

e

c

t

i

o

n

i

n

t

h

e

d

i

g

i

t

a

l

a

g

e

(see supra section

3.1.3

Human rights for consumers and end-users

), Orange encourages

balanced usage habits and an understanding of the impacts of

digital technology in order to limit its potential impacts on health,

particularly those related to prolonged screen exposure,

cognitive overload, or the effects of dependence on digital

services. It emphasises the need to protect vulnerable people,

including children, seniors and people with physical, mental or

cognitive disabilities.

Promoting informed digital citizenship is a key focus of Orange's

policy. It aims to highlight the digital rights and responsibilities of

each user by educating and raising awareness of good digital

practices. It emphasises that the use of technology must respect

people's fundamental rights and contribute to their overall

wellbeing, whether physical or mental.

3.3.3.2

Targets related to psychological health of end-users (S4-5)

Orange has not set targets relating to the negative impact of

addiction to usage or exposure to inappropriate content and

does not disclose any indicators on the effectiveness and

efficiency of its action plans for 2025.

3.3.3.3

Taking actions on psychological health of end-users (S4-4)

Regarding psychological health of end-users, actions that a

company such as Orange can perform are rather focused on

prevention than on remediation. The key actions undertaken by

Orange Belgium and Orange Communications Luxembourg

relate to the promotion of safe, responsible and inclusive digital

practices among vulnerable audiences, with each entity

implementing its own country-specific initiatives.

O

r

a

n

g

e

B

e

l

g

i

u

m

has launched the #

#

F

o

r

G

o

d

C

o

n

e

c

t

i

o

n

s

platform to protect young people from the risks associated with

digital technology.

182

Orange Belgium

_

Annual report 2025

183

These actions form part of a first phase focused on

understanding young people’s needs, raising awareness, and

encouraging good online practices. For consumer health,

particularly regarding risks to mental health such as addiction,

exposure to inappropriate content or cyberbullying, the company

bases its prioritisation on findings from user surveys. These

insights allow the company to identify the age groups most

exposed and to focus its efforts on them. In line with this analysis,

within the #ForGoodConnections programme, the company

excludes children under nine to avoid encouraging early

smartphone use and prioritises young people aged 10 to 14 as

the most relevant and vulnerable audience for its preventive

initiatives.

Negative impacts on psychological health of consumers are

mainly dealt with through preventive measures only as described

in the actions plans. To protect health and safety of its

customers, and in particular children, the company has no

marketing targeting children under nine and an internal

communications

charter

imposes

strict

rules

on

the

representation of children in advertising. The Orange Mobile

Serenity / Serenity Plus enables to block adult content, gambling,

or specific online usages, screen time management.

O

r

a

n

g

e

C

o

m

u

n

i

c

a

t

i

o

n

s

L

u

x

e

m

b

o

u

r

g

has implemented its own

key actions through the Orange Digital Center, which focuses

specifically on cyberbullying and cybersecurity.

The duration of each action varies, but they run throughout the

year to reduce the risk on psychological health problems in

Belgium. Awareness activities and partnerships, including those

initiated in 2024 and 2025 such as the TKT campaign, the

Smartphone Pass and school debates, form part of a phased

approach. Indeed, current initiatives represent a first phase,

enabling result analysis and the identification of the next set of

concrete solutions to be implemented in subsequent phases.

The above-mentioned actions taken to date aim at preventing

harm by equipping vulnerable groups with knowledge, tools and

appropriate behaviours to navigate digital risks safely.

In terms of progress, the campaign supporting the Belgian film

TKT, launched in October 2024, marked the beginning of the

current awareness phase. In 2025, Orange Belgium expanded

the initiative through partnerships with local associations,

debates

in

secondary

schools,

and

offline

e-parenting

conferences. The launch of the Smartphone Pass in 2025 and the

acceleration of strategic partnerships enabling the conversion of

customer loyalty benefits into donations indicate qualitative

progress in family-oriented digital safety initiatives. These actions

allow Orange to analyse results, identify relevant next steps, and

prepare concrete solutions for future phases, demonstrating

ongoing progress in digital inclusion and online safety initiatives

in both Belgium and Luxembourg.

183

Orange Belgium

_

Annual report 2025

184

3.3.4

Management of impacts, risks and opportunities related to data

privacy and cybersecurity

These data privacy and cybersecurity topics may affect Orange’s

own workforce as much as end-users and customers. Hence,

these impacts risks and opportunities are described together in

this section.

3.3.4.1

Policies related to data privacy and cybersecurity (S4-1)

Related to data privacy

Orange commits to a s

s

a

f

e

r

a

n

d

m

o

r

e

t

r

a

n

s

p

a

r

e

n

t

d

i

g

i

t

a

l

w

o

r

l

d

.

This is reflected through several commitments, including

protecting users' data and ensuring respect for their privacy. The

Group mobilises all its stakeholders, including employees,

suppliers, and partners, to promote the protection of users'

personal data and commits to three main areas:

•

The security of their personal data;

•

Transparency regarding the use of this data;

•

And respecting their rights over this data, in

accordance with local and international regulations,

especially their control when interacting with Orange.

Orange Group has published a P

P

e

r

s

o

n

a

l

D

a

t

a

P

r

o

t

e

c

t

i

o

n

(

P

D

P

)

C

h

a

r

t

e

r

to demonstrate Orange's commitments to respecting

internationally recognised principles related to personal data

protection and fundamental rights. It complements the Group's

internal policy. It applies to all Group entities and their

employees, regardless of their location.

This PDP Charter provides further details on:

•

Respect of the main principles of data protection

•

Governance

•

Documentation

and

assessments

under

the

"accountability" principle

•

Evaluation and involvement of service providers in data

protection

•

International transfers of personal data

•

Access to data by competent authorities

•

Promotion of a data protection culture

For Orange Belgium to provide transparency on the use of the

personal data, the P

P

e

r

s

o

n

a

l

D

a

t

a

P

r

o

t

e

c

t

i

o

n

p

o

l

i

c

y

has been

published on the website f

f

o

r

i

t

s

c

l

i

e

n

t

s

,

s

u

p

l

i

e

r

s

,

p

a

r

t

n

e

r

s

. A

specific Personal Data Protection policy

f

o

r

i

t

s

e

m

p

l

o

y

e

s

is

published on the intranet. The purpose of these policies is to

provide further details on the objectives for which Orange

Belgium processes the personal data, its legal grounds, the type

of personal data processed, etc. The policies also provide

information to the company’s clients, employees, suppliers and

partners about their rights in terms of complaints.

Additionally Orange Belgium published on its website, an article

about C

C

o

k

i

e

s

3

7

with its primary objective to inform users about

37

Available on:

https://business.orange.be/fr/cookies

the types of cookies used on their website, explain the purpose

of each category of cookies (functional, analytical, and

marketing), and provide guidance on how users can manage or

block cookies through their browser settings. The policy aims at

ensuring transparency regarding data collection practices related

to cookies and to give users control over their privacy

preferences while using Orange Belgium's online services.

At the Group level, the Group

D

a

t

a

P

r

o

t

e

c

t

i

o

n

O

f

i

c

e

r

(Group

DPO) is responsible for coordinating data protection actions,

providing expertise, and leading the network of DPOs across

different entities. Together, these roles ensure that data

protection is integrated into the Group's processes and projects.

At each entity level, the responsibility for implementing and

overseeing the Data Protection Charter lies primarily with the

General Managers, who ensure that risks are identified and

managed. At Orange Belgium, the CEO is accountable for the

management of the personal data protection management for

which he appointed a DPO to advise and assist him upon this

responsibility.

In addition, Orange e

e

x

p

e

c

t

s

i

t

s

p

r

o

v

i

d

e

r

s

(

s

u

p

l

i

e

r

s

,

p

a

r

t

n

e

r

s

,

e

x

t

e

r

n

a

l

c

o

n

s

u

l

t

a

n

t

s

,

.

)

t

o

a

d

h

e

r

e

to the same high standards of

data protection and security as its employees. Therefore, Orange

requires its providers to respect applicable regulations,

implement best practices in data protection, and ensure security

measures are in place to prevent unauthorised access,

disclosure, alteration, or destruction of data. Providers must also

be able to demonstrate compliance with relevant laws, such as

the General Data Protection Regulation (GDPR) in Europe, and

provide documentation of their data protection measures for

accountability and audit purposes. Orange emphasises towards

its providers to protect personal data and exercise data subjects'

rights effectively.

There standards applicable by the third parties are being agreed

upon and i

i

m

p

l

e

m

e

n

t

e

d

through:

•

Specific data protection and security articles upon the

master agreement between concerned parties;

•

Its security annexes with various risk levels depending

on the context;

•

A data processing agreement if the third party

intervenes as a processor to which they must comply.

Reference is made to both data protection and security policies.

184

Orange Belgium

_

Annual report 2025

185

Related to cybersecurity

A G

G

l

o

b

a

l

S

e

c

u

r

i

t

y

P

o

l

i

c

y

3

8

&

M

a

n

a

g

e

m

e

n

t

S

y

s

t

e

m

is implemented

to manage risks. It sets out the security organisation, and the

human and financial resources needed to implement the

following functional policies:

•

Cross-functional policies

•

Personal policies

•

Physical policies

•

Information security

•

Environmental security

To meet the expectations set by the Group, all departments

involved align themselves with the shared objectives and, at each

level, they implement them within their own scope of

responsibility. In the ongoing search for efficiency, each entity

translates these principles into operational procedures by putting

in place and monitoring action plans.

Regular assessments are carried out both locally and at Group

level through checks, such as audits and monitoring of

objectives, which are used to review the risk mapping.

Approved by the Group Chief Executive Officer and built on a

risk-based approach, the Group Security Policy applies to all

Orange Group subsidiaries, including Orange Belgium and

Orange Communications Luxembourg. It is implemented in all

entities under the responsibility of its CEO who ensures that the

risks are mapped and treated. To do so, the CEO appoints a

Chief Security Officer (CSO) and a Chief Information Security

Officer (CISO) and sets them security objectives.

Related to both data privacy and cybersecurity

Group entities c

c

o

m

p

l

y

w

i

t

h

b

o

t

h

i

n

t

e

r

n

a

t

i

o

n

a

l

a

n

d

n

a

t

i

o

n

a

l

a

w

s

,

r

e

g

u

l

a

t

i

o

n

s

a

n

d

s

t

a

n

d

a

r

d

s

, which may be further reinforced by

local regulations imposed by supervisory authorities, including:

•

General Data Protection Regulation (GDPR): Applicable

to all entities operating in Belgium and Luxembourg,

this regulation establishes strict requirements for the

processing and security of personal data. This is also

reflected in the Belgian Law of 30 July 2018, on the

protection of individuals with regard to the processing

of personal data, which adapts the principles of the

GDPR to the national context, and the Luxembourg

Law of 1 August 2018, which transposes the GDPR into

Luxembourgish law.

•

The Directive on Network and Information Security (NIS

Directive): Applicable in both countries, this directive

aims

at

strengthening

cybersecurity

in

critical

infrastructures.

•

The

Information

Security

Management

System

(ISO/IEC

27001)

and

the

Business

Continuity

Management System (ISO 22301) standards: These are

internationally

recognised

standards

for

robust

information security management and personal data

protection (including robust security protocols), and for

effective continuity planning, respectively.

The P

P

e

r

s

o

n

a

l

D

a

t

a

P

r

o

t

e

c

t

i

o

n

p

o

l

i

c

y

a

n

d

G

r

o

u

p

S

e

c

u

r

i

t

y

p

o

l

i

c

y

consider the interests of key stakeholders, including employees,

customers, and partners:

•

Employee awareness and training: Employees are

regularly trained on these policies, compliance, and

how to respond to incidents. They are encouraged to

report any security issues immediately, reinforcing their

role in protecting data security.

•

Manager responsibility: Managers are responsible for

implementing these policies within their teams,

adapting procedures to improve security, and ensuring

annual awareness training. They analyse incidents and

report them to the responsible security entity,

maintaining alignment with departmental needs.

•

Consultation with external stakeholders: The policies

meet

customer

and

partner

expectations

on

cybersecurity and privacy by integrating legal and

contractual requirements, with feedback mechanisms

for policy adjustments.

•

Continuous improvement: these policies are regularly

reviewed and updated in collaboration with internal and

external stakeholders, ensuring alignment with industry

best practices and stakeholder needs.

This approach ensures that these policies focus on both

compliance and protecting stakeholder trust, with active

involvement from all employees. Protecting customers through

data security and privacy measures to maintain trust. Complying

with regulations to meet legal requirements, particularly around

data protection and cybersecurity. Maintaining operational

resilience to safeguard the company's reputation and stability.

3.3.4.2

Targets related to data privacy and cybersecurity (S4-5)

Orange does not disclose a target associated with material

impacts, risks and opportunities related to personal data

protection and cybersecurity and does not disclose metrics on

the effectiveness and efficacy of its action plans in its 2025

sustainability statement.

3.3.4.3

Taking actions on data privacy and cybersecurity (S4-4)

The company relies on the Group’s guidance to structure its

approach to defining and prioritising actions related to its

material impacts on consumers and end-users. For data privacy,

this approach consists of assessing how users’ personal data

could be exposed to security risks and using this assessment to

prioritise measures that reinforce data protection and ensure

users are informed about how their data is safeguarded.

38

The Group Security Policy is available on the website here:

https://gallery.orange.com/element?id=411907

Orange Belgium recognises that material negative impacts may

arise in relation to data privacy and cybersecurity, particularly

through its downstream value chain. The company’s approach

combines

i

m

e

d

i

a

t

e

r

e

m

e

d

i

a

t

i

o

n

m

e

a

s

u

r

e

s

with l

l

o

n

g

e

r

-

t

e

r

m

p

r

e

v

e

n

t

i

v

e

a

c

t

i

o

n

s

, acknowledging that it may take time to fully

understand the scope of such impacts and to implement

appropriate responses.

185

Orange Belgium

_

Annual report 2025

186

In July 2025, Orange Belgium was subject to a c

c

y

b

e

r

a

t

a

c

k

. Upon

detection, access to the affected system was immediately

blocked and security measures were reinforced to contain the

incident. Competent authorities were notified without delay, and

an official complaint was filed with judicial authorities to ensure

transparency and accountability. In addition to a public

communication, customers whose data may have been impacted

were informed by email or text message. They were advised to

remain vigilant against suspicious communications, and Orange

Belgium continues to monitor for potential misuse of personal

data. These remediation steps demonstrate the company’s

commitment to protecting stakeholders and restoring trust

following adverse events.

Orange Belgium is committed to enhancing data privacy and

cybersecurity measures to positively impact its consumers and

end-users but also mitigating risks for the company. Here are

some key initiatives:

•

E

x

p

a

n

s

i

o

n

o

f

s

e

c

u

r

i

t

y

s

e

r

v

i

c

e

s

: Orange is dedicated to

expanding offerings like Orange Serenity, which

provides enhanced protection against cyber risks

(secure online browsing designed to reduce exposure

to potential cyberattacks). There are today well over 1

million customers using security services offered by

Orange.

•

U

s

e

r

e

d

u

c

a

t

i

o

n

a

n

d

a

w

a

r

e

n

e

s

: Orange has set itself

the target of making 100% of its employees aware of

cybersecurity and personal data protection. At the end

of 2025, 97% of the employees had passed the

mandatory cybersecurity training. The company also

aims

to

empower

its

customers

by

providing

educational resources and tools that help them

understand and mitigate cyber threats effectively. The

Smartphone Pass includes a dedicated section on data

protection for young people and parents, strengthens

awareness and education on safe digital behaviour.

•

P

r

o

a

c

t

i

v

e

t

h

r

e

a

t

m

o

n

i

t

o

r

i

n

g

: Orange’s monitoring

systems will continuously assess potential threats,

ensuring timely alerts and responses to safeguard its

customers' digital environments.

•

C

u

s

t

o

m

i

s

e

d

s

e

c

u

r

i

t

y

s

o

l

u

t

i

o

n

s

: Orange is developing

tailored security packages that cater to the specific

needs of different consumer segments, ensuring that

everyone has access to appropriate protection.

These initiatives are designed to create a safer online experience

for its consumers, reinforcing the company’s commitment to their

security and peace of mind.

Orange Belgium’s approach to personal data protection is also

integrated into its broader data security framework, supporting

the Engage 2025 and ‘Lead the Future’ strategic plan on the

long-term. Orange Belgium has r

r

e

i

n

f

o

r

c

e

d

i

t

s

e

c

u

r

i

t

y

s

y

s

t

e

m

s

to

186

Orange Belgium

_

Annual report 2025

187

ensure greater resilience against evolving threats. These actions

reflect the company’s aim to build on existing safeguards,

enhance customer protection, and maintain trust by continuously

improving both preventive and corrective measures in the field of

data privacy and cybersecurity. The key actions of this plan are

executed for most of them o

o

n

y

e

a

r

l

y

b

a

s

i

s

. They aim at

developing a culture of security and business continuity, with the

goal of integrating security and continuity into everyone's daily

activities.

It also seeks to guarantee legal and regulatory c

c

o

m

p

l

i

a

n

c

e

,

ensuring that Orange Belgium adheres to all applicable

frameworks and regulations. Orange Belgium made significant

strides in enhancing its operational resilience and security in

recent years. The company successfully deployed and acquired

the two above mentioned critical management systems and is

certified since June 2024

for

the I

I

n

f

o

r

m

a

t

i

o

n

S

e

c

u

r

i

t

y

M

a

n

a

g

e

m

e

n

t

S

y

s

t

e

m

(ISO/IEC 27001) and the B

B

u

s

i

n

e

s

C

o

n

t

i

n

u

i

t

y

M

a

n

a

g

e

m

e

n

t

S

y

s

t

e

m

(ISO 22301).

This annual revisit of the action plan consists of:

•

A

n

u

a

l

r

i

s

k

a

s

e

s

m

e

n

t

: Conducting thorough risk

assessments to identify vulnerabilities and potential

impacts on customer data.

•

S

e

c

u

r

i

t

y

m

e

a

s

u

r

e

s

:

Establishing

robust

security

protocols

and

measures

to

protect

customer

information.

•

I

n

c

i

d

e

n

t

r

e

s

p

o

n

s

e

p

l

a

n

i

n

g

:

Developing

comprehensive incident response plans to address

data breaches effectively.

•

T

r

a

i

n

i

n

g

a

n

d

a

w

a

r

e

n

e

s

: Providing mandatory training

for employees on data protection and security

practices, fostering heightened awareness of data

protection.

Governance is overseen by the Executive Director of Strategy

and Cybersecurity, with implementation by the Group Security

Department. Compliance with the GDPR is ensured through a

risk-based approach, supported by a network of Data Protection

Officers (DPOs) and regular training for employees. The DPO

network facilitates adherence to evolving regulations, ensuring

awareness and best practices across the organisation.

T

o

r

e

d

u

c

e

t

h

e

r

i

s

k

o

f

d

a

t

a

l

e

a

k

s

a

n

d

t

o

g

u

a

r

a

n

t

e

t

h

e

i

n

t

e

g

r

i

t

y

o

f

O

r

a

n

g

e

B

e

l

g

i

u

m

b

u

s

i

n

e

s

c

o

n

t

i

n

u

i

t

y

a

n

d

i

n

f

o

r

m

a

t

i

o

n

s

e

c

u

r

i

t

y

m

a

n

a

g

e

m

e

n

t

s

y

s

t

e

m

s

with these international standards

(ISO/IEC 27001 and ISO 22301), a

a

c

t

i

o

n

s

a

r

e

m

o

n

i

t

o

r

e

d

o

n

y

e

a

r

l

y

b

a

s

i

s

with surveillance a

a

u

d

i

t

s

and continuous improvement until

certificate renewal in 2027. It also covers the annual review of

published Policies, Contracts, Data processing agreements,

Security annexes, annual data protection trainings. T

T

h

e

a

u

d

i

t

c

o

n

t

r

o

l

f

o

r

2

0

2

5

w

a

s

c

o

n

d

u

c

t

e

d

s

u

c

e

s

f

u

l

y

, demonstrating

Orange Belgium's commitment to maintaining high standards in

security and business continuity. For 2026, the goal is to identify

and have validated an awareness campaign action plan for the

coming years with focus on specific key subjects.

As a result, these actions contributed to a robust framework for

managing risks and providing remedies for those impacted by

material breaches, thereby safeguarding customer interests

effectively. The adoption of these standards improved the

organisation's ability to manage and mitigate risks associated

with data breaches, leading to a more secure environment for

customer data. Aligning with international standards also ensures

compliance with legal obligations, reducing the risk of penalties

and enhancing the organisation's reputation in the market.

With its c

c

r

i

s

i

s

m

a

n

a

g

e

m

e

n

t

, Orange has a structured response to

security incidents involving personal data, supported by

monitoring centres for suspicious activities. Orange is committed

to addressing material negative impacts on consumers and end-

users by implementing concrete actions and enabling effective

remedies in terms of data privacy and cybersecurity. The

company ensures proactive network maintenance and repair in

the event of an incident. In the event of data breaches, timely

support measures, such as credit monitoring and identity theft

protection, were provided to affected individuals. Transparent

communication and effective incident response strategies

fostered trust among customers, reassuring them that their data

was being handled with care. Orange’s customer service and

retail stores are also available to address customer claims.

Currently no key performance indicators have been validated to

track progress of actions. However, with the processes upon

Data Subject Request (DSRs) and Personal data breach

management, the company can extract this information if

required. From a data protection perspective, a s

s

p

e

c

i

f

i

c

d

a

t

a

p

r

o

t

e

c

t

i

o

n

g

o

v

e

r

n

a

n

c

e

a

n

d

m

a

n

a

g

e

m

e

n

t

r

e

p

o

r

t

i

n

g

is being

drafted for proposal with its aim to present to the management

in 2026.

These actions cover all Belgian entities. The scope of the

Information Security Management System (ISMS) and Business

continuity management System (BCMS) of Orange Belgium

S.A/N.V. covers services, infrastructures and operation in scope

of Belgium national regulation on cybersecurity and resilience of

critical infrastructures (defined by national sectorial authority); all

in accordance with the statement of applicability version 2.0 from

13 March 2024.

For Orange Communications Luxembourg, several activities are

implemented along the year but are not part of a structured

action plan.

187

Orange Belgium

_

Annual report 2025

188

4.

Governance

4.1

Business Conduct (G1)

In addition to the core governance processes, this section covers

the management of the following material governance topics,

namely corruption and bribery, business conduct and corporate

culture, as well as supplier relationship management. These

topics are material given the financial and reputational risks

arising from corruption and non-compliance with ethical and

regulatory requirements. By reinforcing its culture of ethics and

compliance, Orange seeks to strengthen trust with its partners

throughout the value chain, enhance its differentiation, and

support sustainable growth, while opening up new sustainability-

related business opportunities.

4.1.1

Management of impacts, risks and opportunities related to

business ethics

4.1.1.1

Business conduct policies and corporate culture (G1-1, G1-3)

Corporate culture

In order to strengthen the commitment of employees, Orange

Group launched three values at the end of 2024, which were co-

created with employees all over the world and which define the

Orange culture and guide collective practices and individual

behaviour, with specific behaviours defined for the people

managers. Orange aims to be:

•

C

a

r

i

n

g

: Act to offer the best to customers, colleagues

and stakeholders;

•

R

e

s

p

o

n

s

i

b

l

e

:

Keeping

commitments,

acting

responsibly and speaking the truth;

•

B

o

l

d

: Show ambition, determination and take the

initiative to seize opportunities.

To roll out the cultural transformation project, Orange relies on

five levers - each comprising specific actions - which will enable

employees to understand and embody this culture and these

values on daily basis:

1.

Understanding meaning (communication and culture

workshops)

2.

See the people around you change (leadership model,

training, etc.)

3.

See the system change (processes and emblematic

actions)

4.

Know how to act within your entity (local roadmap)

5.

Be part of a global dynamic (governance and sharing of

best practice)

Appropriation of the culture is measured by means of dedicated

questions in the Voice Up employee survey, sent to all employees

each year. At Belgian level, value workshops were held by people

managers with their team (hosting these workshops - or

alternatively allowing time to follow an e-learning for team

members in shops or technicians on the road - is part of the

people management objective of each people manager, starting

with exco and directors). These values and corporate culture are

presented as introduction to all newcomers. Dedicated pages on

intranet explain Orange values and culture and the values now

represent the ‘How’ objectives of all employees (i.e. the expected

attitude in paving the way to achieve their personal objectives).

Ethics and compliance approach

The financial and reputational risk management framework in the

event of corruption is based on an ethical approach, supported

by the O

O

r

a

n

g

e

C

o

d

e

o

f

E

t

h

i

c

s

. This is based on the following four

commitments: respect, integrity, quality, and team spirit. The

Code of Ethics describes the principles of action with respect to

stakeholders and the principles of individual behaviour that must

guide the conduct of employees in their professional activities.

These reflect the same fundamental principles as those set out

in the universal declaration of human rights, as well as by the

International Labor Organization (ILO) and the Organisation for

Economic Cooperation and Development (OECD) and the

commitments undertaken by Orange in terms of social

responsibility. In particular, the charter affirms the principle of

zero tolerance toward corruption and influence peddling and

applies to all Group entities.

The prevention and detection of corruption risks are part of this

ethical business conduct policy, which was implemented in the

early 2000s. This programme is regularly reinforced to ensure

compliance with various regulations, including the US Foreign

Corrupt Practices Act (FCPA), the UK Bribery Act, and the French

law known as “Sapin 2.”

The comprehensive approach to managing the risks of unethical

behaviour and risks of non-compliance (fraud, corruption,

influence peddling, and all violations of business ethics) is

integrated into all of Orange's activities, particularly in its

relations with its stakeholders.

It is aimed at continuous improvement and built around six steps:

setting the tone, governance, risk analysis, policies and

procedures, awareness-raising and training, and audits.

188

Orange Belgium

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Annual report 2025

189

Orange’s compliance approach is based on:

•

Strong political commitments supported by the Chief

Executive Officer, with adaptations of the Group’s

Code of Ethics, the first version of which was adopted

in 2003, like the S

S

u

p

l

i

e

r

C

o

d

e

o

f

C

o

n

d

u

c

t

and the D

D

a

t

a

n

d

A

I

E

t

h

i

c

s

C

h

a

r

t

e

r

. The “tone at the top,” driven by

executives and managers, is unambiguous: present in

the Group’s Code of Ethics and its anti-corruption

policy, this commitment to responsibility and integrity

is regularly and publicly reaffirmed.

•

Governance established at several levels of the

undertaking helps control risks;

•

An a

a

n

a

l

y

s

i

s

o

f

t

h

e

r

i

s

k

s

of corruption and influence

peddling carried out at the level of the Group,

subsidiaries and relevant entities to identify major risks

and to define and roll out management actions. The

analysis of corruption risks (risk mapping and

associated action plans) is the essential step in

Orange’s approach. Risk mapping is consolidated at

the division level and then at the Group level: it is then

approved by the Group’s Executive Committee.

•

Group policies and procedures adapted to local

situations, including:

o

An anti-corruption policy,

o

A third-party fraud and non-compliance risks

based d

d

u

e

d

i

l

i

g

e

n

c

e

p

r

o

c

e

d

u

r

e

,

o

Rules on “gifts and invitations” that govern any

benefits received or offered; dedicated apps are

rolled out to track declarations and manager

approvals of any overruns of the established

thresholds,

o

Guiding

principles

on

the

prevention

and

management of conflicts of interest,

o

A system of accounting controls that can play a

part in the prevention and detection of fraud, of

the override of internal procedures, of corruption

and of the laundering of these practices.

•

A

Group

w

h

i

s

t

l

e

b

l

o

w

i

n

g

s

y

s

t

e

m

and

local

whistleblowing systems that are monitored annually;

•

Training and awareness programmes on ethics and the

prevention of corruption and bribery (see below in this

section);

•

Regular control measures (internal audits, project

reviews, etc.) to assess the efficiency of the measures

implemented and to identify areas for improvement. An

incident management process (case management)

identifying allegations or suspicions of corruption,

influence peddling, or internal fraud resulting from

various sources (internal audits, referrals, fraud

detection, whistleblowing mechanisms, etc.).

At Orange Belgium, the Audit and Risk Committee oversees and

follows-up the monitoring of compliance and ethical matters

including corruption risks. It is composed mostly of independent

Board members, operating separately from management to

maintain an objective oversight and issue recommendations. At

Orange Communications Luxembourg, the Compliance Officer

oversees and follows-up the monitoring of compliance and

ethical matters including corruption risks.

189

Orange Belgium

_

Annual report 2025

190

Anti-corruption policy

To better control the risk of financial sanctions and the risk of

seeing the liability of its executives engaged in the event of a

breach of business ethics, and more particularly in the event of

corruption of or by its employees, Orange has implemented an

a

n

t

i

-

c

o

r

u

p

t

i

o

n

p

o

l

i

c

y

. The objective of this policy is to provide all

Group workers with a framework of principles to be respected in

the context of its activities and behaviours to be proscribed as

they could be indicative of corruption or influence peddling.

This anti-corruption policy is defined in accordance with the 1997

OECD Anti-Bribery Convention and the 2003 United Nations

Convention Against Corruption. It meets the requirements of the

so-called “Sapin 2” law. As such, this anti-corruption policy is the

equivalent of a “code of conduct” within the meaning of Article

17 of that law.

It also meets the requirements of the US Foreign Corrupt

Practices Act (FCPA), as well as the UK Bribery Act.

It is rolled out or adapted throughout the Group and its

subsidiaries. This policy applies to all Orange workers and must

be respected by all stakeholders with which the Group is

engaged (undertakings, subcontractors, partners, consultants or

intermediaries working for the Group or on behalf of Orange). In

the event of a violation of the anti-corruption policy, any Group

employee is exposed to the disciplinary sanctions provided for in

the Internal Guidelines.

Orange Group’s anti-corruption policy includes a definition of

corruption and influence peddling offenses and affirms the

principle of zero tolerance for corruption and influence peddling.

It sets out the measures to prevent and combat corruption and

influence peddling as well as how the policy is managed. The

Management Committee of the subsidiary or entity is responsible

for ensuring that the anti-corruption policy complies with the

legal and ethical obligations of the country or countries in which

it operates and that all those under its control comply with it. The

Boards of Directors of Orange SA and the subsidiaries assess the

effectiveness of the corruption prevention programme at least

once a year. The Group Chief Compliance Officers and

Compliance Officers are responsible, within their respective

scopes, for overseeing the policy roll out programme and for

monitoring its effectiveness.

This policy is supplemented by “the Orange Group’s guidelines

on the prevention of corruption.” In addition, each entity or

subsidiary may supplement it, regarding any adaptations

imposed by local laws and regulations.

Orange Group disseminates its anti-corruption policy based on

permanent internal information tools, such as Intranets (Group

Intranet and those of subsidiaries), which have sections

dedicated to the prevention of corruption, the whistleblowing

system and the prevention of conflicts of interest.

The anti-corruption policy

39

can also be accessed externally on

Orange’s website, Orange Belgium’s website and on the website

for Orange suppliers.

39

The anti-corruption policy can be found here:

https://gallery.orange.com/element?id=411682

40

The whistleblowing system can be found here:

https://orange.integrityline.org/

Due diligence procedure

Orange Group has defined a specific process for assessing third

parties' exposure to fraud and non-compliance risks, based on

risk, and applied to partners, intermediaries, and corporate

customers. This process allows efforts to be focused on

analysing so-called “at-risk” partners and is carried out in two

stages:

•

First, a pre-assessment of the partner's overall risk level

is carried out according to the criteria of “country” and

“partner.” This assessment determines a risk level on a

scale of four (low, moderate, high, and very high).

•

Then, controls tailored to each risk level constitute the

due diligence itself, which identifies potential red flags

and

produces

recommendations

to

inform

management's decision on whether contract with the

partner.

It is regularly updated, refined, and deployed throughout the

Group and its subsidiaries. It is subject to “project reviews” that

enable precise monitoring of its implementation and the

identification of areas for improvement in each division or

country, through targeted training.

This procedure is fully implemented within Orange Belgium and

Orange Communications Luxembourg.

Whistleblowing system

In the early 2000s, Orange Group set up a whistleblowing system

called “Hello Ethics”, o

o

p

e

n

t

o

a

l

G

r

o

u

p

w

o

r

k

e

r

s

.

This system has

been strengthened year after year and is now open to p

p

a

r

t

n

e

r

s

,

s

u

p

l

i

e

r

s

,

w

o

r

k

e

r

s

i

n

t

h

e

v

a

l

u

e

c

h

a

i

n

o

r

a

n

y

e

x

t

e

r

n

a

l

s

t

a

k

e

h

o

l

d

e

r

.

It was presented to employee representative bodies before its

implementation and it has been regularly adapted to comply with

the “Sapin 2,” “duty of vigilance” and “Waserman” (the latter

transposing into French law the European directive on protection

for whistleblowers) laws.

This “Hello Ethics” system, can be used to report conduct or

situations that go against the Group’s a

a

n

t

i

-

c

o

r

u

p

t

i

o

n

p

o

l

i

c

y

,

C

o

d

e

o

f

E

t

h

i

c

s

, or policies and procedures relating to

a

c

o

u

n

t

i

n

g

,

i

n

t

e

r

n

a

l

c

o

n

t

r

o

l

a

n

d

a

u

d

i

t

i

n

g

, that represent a clear

and serious violation of laws or regulations, or that seriously

infringe h

h

u

m

a

n

r

i

g

h

t

s

a

n

d

f

u

n

d

a

m

e

n

t

a

l

f

r

e

d

o

m

s

,

t

h

e

h

e

a

l

t

h

a

n

d

s

a

f

e

t

y

o

f

i

n

d

i

v

i

d

u

a

l

s

o

r

t

h

e

n

v

i

r

o

n

m

e

n

t

.

The whistleblowing system

40

can be accessed via the Internet, on

Orange’s website, the Group’s Intranets and via public search

engines. It may be supplemented by local systems of the country

subsidiaries.

Employees are regularly provided information on Group and local

whistleblowing

systems

through

training

courses

and

communication campaigns (emails, Intranet, site posters, etc.).

Reports are processed according to the Group or subsidiary

procedure: This procedure is available on the Group Intranet and

on the Hello Ethics platform.

1)

I

n

i

t

i

a

l

r

e

p

o

r

t

s

u

b

m

i

s

i

o

n

:

An employee who has first-

hand knowledge of unethical behaviour or violations of

legal regulations or company policies can submit their

190

Orange Belgium

_

Annual report 2025

191

concerns through the whistleblower system, with

acknowledgment of receipt.

2)

P

r

e

l

i

m

i

n

a

r

y

e

v

a

l

u

a

t

i

o

n

: The report is archived by the

authorised person managing the case, who conducts a

preliminary evaluation to determine its admissibility,

while

acting

impartially

and

respecting

the

confidentiality of the whistleblower’s identity and the

people concerned throughout the process.

3)

I

n

v

e

s

t

i

g

a

t

i

o

n

: Admissible reports are investigated

within three months to verify the validity of the

allegations. During this time, the whistleblower is

informed about the admissibility of their report and the

initiation of an investigation under the supervision of the

Chief Compliance Officer. Orange at Group level has a

specialised team independent of the management line

of the persons concerned, which carries out, at the

request of management or compliance, internal

investigations in the event of a justified report,

suspected fraud or corruption: the investigation team,

including people from the Group’s General Control

Department as needed, is small, duly authorised and

subject to an enhanced obligation of confidentiality.

The team conducts investigations in compliance with

laws and regulations.

4)

F

i

n

a

l

r

e

p

o

r

t

a

n

d

a

c

t

i

o

n

s

: After completing the

investigation, a final report is submitted to the Chief

Compliance Officer, who shares the findings with

relevant parties. Based on the report’s conclusions,

additional

investigations

may

be

requested,

or

appropriate disciplinary actions may be taken in line

with company rules and procedures. Whistleblowers

are encouraged to report breaches through internal

channels and can mail descriptions of suspicious

activities.

The whistleblowing procedure provides p

p

r

o

t

e

c

t

i

o

n

f

o

r

i

n

d

i

v

i

d

u

a

l

s

who meet the legal definition of whistleblowers, in accordance

with legal and regulatory provisions. The reporting system is

compliant with national whistleblowing regulations transposing

Directive (EU) 2019/1937, with protections against retaliation for

those raising concerns in good faith.

•

Orange undertakes to ensure that the procedures

implemented to collect reports guarantee that the

identity of the author of the report and the information

collected through the whistleblowing system remain

strictly confidential, in accordance with the applicable

laws and regulations.

•

Orange undertakes to ensure that no employee will be

punished, dismissed or subjected to any discriminatory

measure, whether direct or indirect, for having, in a

disinterested manner and in good faith, reported facts

of which they have personal knowledge, even in cases

where the reported facts are later determined to be

incorrect or lead to no further action.

•

Whistleblowers are encouraged to identify themselves

to ensure they receive appropriate protection, can

provide additional information if needed, and prevent

defamatory accusations. Anonymous reports are only

considered admissible if they contain sufficiently

detailed factual elements to establish the seriousness

41

Belgian whistleblowing regulation:

https://www.ejustice.just.fgov.be/eli/besluit/2023/01/22/2023040158/justel

of the allegations. Use of the whistleblower system is

optional, and employees cannot be sanctioned for

choosing not to use it.

Communications relating to the Group whistleblowing system

and local systems are regularly provided to employees through

t

r

a

i

n

i

n

g

s

e

s

i

o

n

s

a

n

d

c

o

m

u

n

i

c

a

t

i

o

n

c

a

m

p

a

i

g

n

s

(emails,

intranet, notices posted on sites, etc.).

Locally, Orange Belgium has a specific whistleblower procedure

(in alignment with Belgian regulations

41

) that supersedes the

Group’s Hello Ethics Programme available on its intranet and

communicated annually to employees. Orange Communications

Luxembourg has deployed Hello Ethics.

Further details on Orange Belgium

All

matters

are

dealt

with

promptly,

objectively

and

independently. For O

O

r

a

n

g

e

B

e

l

g

i

u

m

, complaints report comes in

to and is dealt with by the Chief Compliance Officer or by

someone that he designates for this purpose. Whistleblowers will

receive a confirmation of receipt within 7 days. The report is kept

in a special archive by the person who is following up the case,

but not without the latter first conducting a preliminary evaluation

to guarantee its admissibility. Each report that is declared to be

admissible is investigated within 3 months to establish the

genuineness of the indicated facts. The whistleblower is informed

of the admissibility of his report and of the fact that an

investigation has commenced, under the supervision of the Chief

Compliance Officer. The accused person(s) is (are) also informed

of the report’s existence. The identity of the whistleblower

remains a carefully guarded secret. When a whistleblower wishes

to sound the alarm linked to a member of the management, the

Chairman of the Audit Committee, who is an independent

director, will handle the file confidentially, in accordance with

Orange Belgium procedure.

After completion of the investigation, a final report is submitted

to the Chief Compliance Officer, who forwards it to the parties

concerned. Based on the conclusions contained in that report: a

supplementary investigation can be requested; proportionate

disciplinary measures can be taken, in accordance with the

company´s in-house rules and the applicable procedures; the file

can possibly be turned over to the judicial authorities, or

adaptations to the procedures will be proposed to prevent similar

facts or actions in the future. The whistleblower is kept informed

of how the report is being dealt with and what measures –

penalties or other – might stem from the investigation.

Orange

Belgium´s

Chief

Compliance

Officer

guarantees

protection for employees who raise an alarm. Orange Belgium

promises to keep the whistleblower´s identity secret and to treat

all information as confidential; and not to punish, dismiss or

discriminate against any employee whosoever because he/she

drew attention to a suspected abuse (or abuses), even if it

appears after investigation that the facts are not correct, or no

action is taken with respect to them. However, abuse of the

system can expose the whistleblower to disciplinary sanctions

and prosecution.

191

Orange Belgium

_

Annual report 2025

192

Further details on Orange Communications

Luxembourg

For O

O

r

a

n

g

e

C

o

m

u

n

i

c

a

t

i

o

n

s

L

u

x

e

m

b

o

u

r

g

,

both internal and

external whistleblowers enter their reports on the Hello Ethics

platform. Depending on the subject, the alert is received either

by the Group Compliance department, or by the Group CSR

department, which examines the admissibility of the alert. The

author of the alert is informed of the receipt of this report, and of

the admissibility of his or her alert, preceded, if necessary, by a

request for further information. In the event of inadmissibility, the

whistleblower is informed of the reason.

If the alert is admissible, an investigation is carried out by the

Controlling Department or a team of experts (Compliance, HR,

Security, Legal, for example). A decision is then taken by the

management concerned, in consultation with the expert teams.

The author of the alert is notified of the conclusion of the

processing.

Once an investigation has been completed, a report containing

the findings is submitted to the Compliance Director, who will

pass it on to those who need to know. Depending on the

conclusions of the report and the seriousness of the facts

established, further investigation may be requested, and

proportionate disciplinary measures may be taken in compliance

with the internal regulations and associated procedures. If

necessary, the case will be referred to the judicial authorities. In

addition, any necessary changes to procedures will be proposed

to avoid any repetition of similar behaviour or events. The author

of the alert will be informed of the conclusion of the handling of

the alert within a reasonable time following the end of the

investigation and the implementation of any disciplinary or other

measures resulting from it.

Awareness-raising and training programme

Information regarding ethics and prevention and detection of

corruption or bribery are communicated through several

channels:

•

T

r

a

i

n

i

n

g

p

r

o

g

r

a

m

e

s

:

Targeted

and

multilingual

modules, especially for high-risk roles, from which

some are mandatory ones.

•

A

n

u

a

l

c

o

m

p

l

i

a

n

c

e

&

e

t

h

i

c

s

e

v

e

n

t

:

Actions like CEO

and

Chief

Compliance

Officer

communications,

debates, and training, are organised locally in Belgium

and Luxembourg based on a Group guidance. The

conferences

organised

at

Orange

Group’s

headquarters during Ethics & Compliance days are

broadcast live to the entire Group and dubbed in

different languages; their recording remains available

and accessible online to all staff for educational

purposes on the Group's internal sites.

•

A

c

e

s

i

b

l

e

g

u

i

d

e

l

i

n

e

s

:

Regularly updated on the

company intranet.

•

A

w

a

r

e

n

e

s

c

a

m

p

a

i

g

n

s

:

Digital communications to

ensure reach. Note that this action specifically only

applies to Orange Belgium.

Since 2018, Orange Group has developed several online training

modules to cover the entire Group and ensure the enrichment

and renewal of training content. These may include internally

designed content or market-based content adapted to Orange's

context and rules. These training modules, lasting between 30

and 60 minutes, are generally available in multiple languages.

They conclude with a final assessment questionnaire to evaluate

learning outcomes.

The modules, primarily designed to train the most exposed

personnel, have also been used by a broader audience within the

entities.

In addition to generalist modules, specific modules have been

developed on:

•

Customer relationship ethics, with a primary focus on

sales teams and intervention technicians.

•

Trade control rules and compliance with international

economic sanctions programmes, aimed at individuals

exposed to issues related to economic sanctions and

trade control (e.g., supply chain);

•

Prevention of conflicts of interest

A mandatory dedicated training programme entitled

'

B

u

s

i

n

e

s

E

t

h

i

c

s

:

M

a

k

e

t

h

e

R

i

g

h

t

D

e

c

i

s

i

o

n

'

has been developed by the

Group and has become mandatory at the request of the Group

Executive Committee. All employees across subsidiaries are

required to complete this training on a yearly basis. Its purpose

is to communicate the fundamental principles that underpin

professional conduct at Orange. As this training is mandatory for

all employees, all functions-at-risk are covered by the training

programme.

Additionally, starting as of December 2025, a dedicated training

programme for exposed functions has been launched. The initial

phase will focus on Orange Belgium’s management through

face-to-face sessions conducted by the Group Chief Compliance

for the Executive Committees and Directors of Orange Belgium.

The programme will be further extended to other identified

exposed employees throughout 2026.

Members of administrative, supervisory and management bodies

follow the anti-corruption and anti-bribery training given to all

team members and management for Orange Belgium. Ad hoc

trainings for administrative, supervisory and management bodies

are also provided in Belgium.

The aim is to ensure that 100% of all employees, thereby

including functions at risk

42

, are covered by the mandatory

training programme. At the end of 2025, 96.42% of the

employees passed the business ethics training in Belgium.

42

At-risk functions will be monitored as of 2026 and published in the next sustainability statement.

192

Orange Belgium

_

Annual report 2025

193

Communication and training on policies related to corruption or bribery

2

0

2

4

2

0

2

5

Total at-risk functions

-

At-risk functions receiving training

-

Total administrative, management and supervisory bodies

21

16

Administrative, management and supervisory bodies receiving training

21

14

Total managers

478

419

Managers receiving training

478

405

T

a

b

l

e

2

:

C

o

v

e

r

a

g

e

o

f

t

h

e

c

o

m

p

l

i

a

n

c

e

t

r

a

i

n

i

n

g

p

e

r

f

u

n

c

t

i

o

n

s

w

i

t

h

i

n

O

r

a

n

g

e

M

E

T

H

O

D

O

L

O

G

I

C

A

L

N

O

T

E

In 2024, the achievement of the 100% mandatory training target was based on an assumption. In 2025, completion rates for

Administrative, Management and Supervisory Bodies (AMSB) are based on actual data, while a completion ratio of 96.42% was

calculated for managers at Orange Belgium.

4.1.1.2

Incidents of corruption or bribery (G1-4)

To the best of Orange Belgium's knowledge, there were no convictions or fines imposed in 2025 for violations of anti-corruption laws.

2

0

2

4

2

0

2

5

Number of convictions (number value)

0

Amount of fines (monetary units)

0

T

a

b

l

e

2

3

:

N

u

m

b

e

r

o

f

c

o

n

v

i

c

t

i

o

n

s

a

n

d

a

m

o

u

n

t

o

f

i

n

e

s

f

o

r

v

i

o

l

a

t

i

o

n

o

f

a

n

t

i

-

c

o

r

u

p

t

i

o

n

a

n

d

a

n

t

i

-

b

r

i

b

e

r

y

l

a

w

s

w

i

t

h

i

n

O

r

a

n

g

e

There was no need for specific action plans in 2025 on top of the general process already described in the company’s approach.

4.1.2

Management of impacts, risks and opportunities related to

suppliers’ relations

4.1.2.1

Management of relationships with suppliers, lowering late payment impact on

suppliers’ liquidity (G1-2)

Orange Belgium strictly complies to the local regulation

43

in terms

of payment terms towards its suppliers and Small and Medium-

size Enterprises (SME's). This regulation contains the following

key provisions:

Fighting late payment in commercial transactions

Long payment periods and late payments have a negative impact

on companies' liquidity. Correct payment terms are of vital

importance to Orange’s businesses, and to SMEs in particular.

The transposition of the EU directive on late payment in

commercial transactions creates a clear payment framework that

strengthens the position of businesses regarding the rules on

payment periods and binding penalties for late payment.

Payment periods

In accordance with the European Directive, the draft bill provides

for a statutory payment period of 30 days for contracts between

businesses and public authorities. This statutory payment period

43

This regulation can be found on the Belgian website of Justice

https://justitie.belgium.be/nl/nieuws/persberichten/bestrijding_van_betalingsachterstand_bij_handelstransacties_0

may be extended contractually under strict conditions. However,

the contractually agreed payment period may never exceed 60

calendar days, which is stricter than current legislation. An

exception is made for public services providing healthcare. Here,

the statutory payment period is 60 calendar days instead of 30.

However, the new law on late payment will only serve as a

general framework between businesses and public authorities for

transactions that do not fall within the specific scope of the public

procurement rules. In other words, smaller public contracts

below certain thresholds.

For contracts between companies, there is a statutory payment

period of 30 days. Here too, companies may contractually agree

a different payment period. Normally, this contractually agreed

payment period must be limited to 60 calendar days. In fact, a

period of 60 calendar days is acceptable in practice based on

commercial practice in many sectors. However, the parties

always have the possibility, in certain situations and under strict

conditions, of agreeing a payment period which exceeds this

193

Orange Belgium

_

Annual report 2025

194

threshold of 60 calendar days. In this way, account will be taken

of companies' different business models. However, as with any

contractual provision, there can be no question of the provision

being unfair to the creditor. The judge can control this.

Following the example of current legislation, a verification and

control period can be provided for both commercial transactions

between companies and those between companies and public

authorities. The bill limits the duration of such periods to 30

calendar days. However, in both cases, this period may be

extended contractually, provided that this is not manifestly

abusive. This qualified rule, derived from the Directive, is aimed

at particularly complex contracts concluded between parties.

Once this period has elapsed, the actual payment period begins

to run. Until now, there have been no clear rules on this point.

Interest on late payment and compensation

In the event of late payment, the creditor is entitled to interest on

arrears, although the parties themselves may agree a rate of

interest. In the absence of a contractually agreed interest rate,

the statutory interest rate will apply. This is equal to 8 percentage

points over and above the interest rate on the European Central

Bank’s main refinancing operations. However, in the case of

contracts between companies and public authorities, the

statutory interest rate must be applied, and the parties may not

agree another interest rate. In addition, the creditor is also

entitled, ipso jure and without notice of default, to a flat-rate

recovery fee of €40. In addition to this fixed amount, the creditor

is entitled to reasonable compensation for any other collection

costs incurred that exceed this fixed amount, such as lawyers'

fees or collection office costs.

Taking actions

The transposition of the European directive aims to strengthen

the competitiveness and financial situation of businesses,

particularly SMEs, by creating a more favourable climate for

payments:

•

Contractual payment periods between businesses and

public authorities are subject to a maximum (60

calendar days);

•

Business-to-business

payment

periods

are

differentiated to take account of commercial practices

and leave room for the various business models of

companies and sectors;

•

For the first time, clear and detailed rules have been laid

down for verification and control periods in commercial

transactions

between

companies

and

between

companies and public authorities;

•

There are rules on recovery costs in the event of non-

compliance with payment rules (a statutory flat rate of

40 euros and reasonable compensation for recovery

costs in excess of this amount, e.g. lawyers' fees,

collection agency fees);

•

There is also provision for additional effective means of

control by the judge in the event of contractual

derogations (extension of the existing injunction to

abusive practices between parties).

At Orange Communications Luxembourg:

•

Efforts are made to adhere to suppliers' deadlines;

however, delays may occur primarily due to issues in

the validation process, which can impact the creation,

receipt of Purchase Orders, or invoice processing.

•

Payments related to workforce activities, particularly

subcontracting,

are

prioritised

to

ensure

timely

settlement.

•

The contractual maximum delay for payments is 60

days.

•

When suppliers charge late payment or reminder fees,

negotiations are typically conducted to have these fees

waived, especially when maintaining a strong business

relationship. If necessary, these charges are settled

promptly.

4.1.2.2

Management of relationships with suppliers, building trust and secure

responsible supply (G1-2)

In 2024, Orange adopted a new G

G

r

o

u

p

u

r

c

h

a

s

i

n

g

p

o

l

i

c

y

signed

by the Executive Director of Finance, Performance and

Development and the Group Director of Purchasing and Supply

Chain. It was updated in 2025. Its main objectives are to

continuously improve the Group's economic and operational

performance, protect against supplier-related risks and fulfil the

Group's environmental and social commitments. As part of this

policy, Orange describes the commitments and r

r

e

s

p

e

c

t

f

o

r

h

u

m

a

n

r

i

g

h

t

s

that it expects from its suppliers, subcontractors

and partners. For more details refer to the above section

3.1.4

Human rights for workers in the value chain

. In accordance with

the Group's purchasing policy, ‘Orange's commitments to

Responsible Procurement’ focus on the following key objectives:

•

Developing balanced relationships with its suppliers,

based on trust, respect and long-term commercial

relationships;

•

Continuously

improving

the

Group's

economic

performance by creating sustainable value;

•

Managing risks and seizing sustainability opportunities

related to the Group's purchasing and supply chain;

•

Enabling the Group and its customers to benefit from

the expertise of its innovative and high-performing

suppliers.

194

Orange Belgium

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Annual report 2025

195

Orange therefore requires its suppliers to comply with its

sustainability standards and to apply them in their own

purchasing chains, by requiring the Group's suppliers to sign up

to a S

S

u

p

l

i

e

r

C

o

d

e

o

f

C

o

n

d

u

c

t

and to comply with laws and

regulations through the widespread use of E

E

S

G

c

l

a

u

s

e

s

4

in the

Group's framework agreements and in contracts for exclusively

local use.

Orange's commitments to responsible purchasing are based on

the principles of the ISO 20400 standard. These commitments

are also based on international standards, including the Universal

Declaration of Human Rights, ILO standards, OECD conventions,

as well as commitments made by Orange, such as the United

Nations Global Compact and the agreements signed in 2006 and

2014 with the international trade union federation UNI Global

Union.

At Group level, Orange defines its purchasing and supplier-

engagement policies through continuous dialogue with key

stakeholders, including strategic suppliers, telecom operators,

industry bodies (e.g., ITU, GSMA, JAC) and internal prescribers.

Dedicated working groups address for instance the reduction of

environmental impacts, the improvement of carbon data quality

and the development of circular-economy practices.

These commitments therefore a

a

p

l

y

t

o

all its subsidiaries and

entities, to purchasing and supply chain activities, as well as to

purchases delegated to BuyIn, the Orange Group joint-venture

with Deutsche Telekom acting as central purchasing body, in the

context of their relationships with their suppliers and

subcontractors. As with the Group's purchasing policy, the main

points of Orange's commitments to responsible purchasing are

made available to all Orange stakeholders on the purchasing

portal dedicated to suppliers

45

and on the Orange intranet.

At local level, the new Group purchasing policy has been

communicated to all employees involved in its application. It

applies to primarily Group employees responsible for its

implementation and suppliers with whom a contractual

relationship has been established. The purchasing teams in each

country and entity are responsible for implementing the

purchasing policy within their respective organisations. They are

supervised by the Group Responsible Purchasing Committee for

all Group entities and subsidiaries. This committee ensures that

sustainability requirements are integrated into purchasing

processes and contracts, through the ESG clause, the Supplier

Code of Conduct and Orange's commitments to responsible

purchasing.

Local responsibility of this policy is born by the Purchasing

Director, reporting to the Chief Finance Officer.

Orange Communications Luxembourg has not yet integrated

ESG criteria into the selection of local suppliers. However,

suppliers are chosen from those recommended by the Group and

for major suppliers, contracts are managed through Orange

Belgium, and when local suppliers are engaged, they are typically

well-established and reputable companies.

44

The ESG clause is public and available online here:

https://fournisseurs.orange.com/wp-

content/uploads/2020/11/en_orange_commitments_responsible_procurement.pdf

45

Purchasing portal:

https://fournisseurs.orange.com/en/our-expectations-from-suppliers/

195

Orange Belgium

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Annual report 2025

196

M

E

T

H

O

D

O

L

O

G

I

C

A

L

N

O

T

E

In Belgium, Orange monitors the number of signed contracts including sustainability clause and shared it annually with the Orange

Group. All signed contracts are in scope of this monitoring.

To improve the consideration of environmental, social and

governance performance in its supplier selection process,

Orange incorporates E

E

S

G

c

r

i

t

e

r

i

a

i

n

t

o

2

0

%

o

f

t

h

e

s

c

o

r

e

a

w

a

r

d

e

d

t

o

s

u

p

l

i

e

r

s

i

n

p

u

r

c

h

a

s

i

n

g

d

e

c

i

s

i

o

n

s

for projects falling within the

scope of BuyIn with a value of more than €1 million.

Half of this ESG score is based on an assessment of the

supplier's overall sustainability maturity, and the other half on

environmental criteria specific to the product purchased by

Orange depending on the area (IT and networks, fixed customer

equipment such as SetTopBox).

The weighting of ESG criteria in the decision-making criteria for

all purchasing projects in Belgium and Luxembourg (for contracts

covered by Orange Belgium) carried out by the purchasing

department was implemented since 2023 and now follows the

following rules:

•

For projects with high or very-high sustainability risk

and/or projects with a significant carbon impact, it is

set at 20%;

•

For procurement projects with low sustainability risk,

the recommendation is to allocate 10% of the score

awarded to suppliers to ESG criteria, to be decided in

consultation with the prescribing departments.

In addition, depending on the issues and risks relating to human

rights,

specific

requirements

may

be

included

in

the

specifications attached to the consultations.

The assessment of the supplier's sustainability maturity must

take place before any contractual relationship is entered into for

procurement projects involving high and very high ESG risk

categories (subject to the application of a projected expenditure

threshold). The list of ESG risk procurement categories is defined

by the Group duty of vigilance and Group Procurement and

Supply Chain manager, considering the impact on health and

safety, human rights and the environment, the likelihood of risks

occurring, and the specific characteristics of the geographical

areas of the Orange entities making the purchase.

This list, defined at Group level, was distributed to all parties

involved in assessing suppliers' sustainability maturity. To ensure

the independence and quality of the analysis, supplier

assessments were entrusted to a partner company whose

methodology is based on international sustainability standards

and guidelines such as the Global Compact, ISO 26000, ILO and

GRI.

Supplier sustainability maturity assessments include questions

relating to respect for the health, safety and working conditions

of their employees and those of their suppliers. When analysing

the results, Orange teams pay particular attention to these two

aspects. Orange's activities extend across the globe. To adapt

to the specific local characteristics of the Group's entities, the

ESG analysis may be based on an internal Orange assessment

in the form of a questionnaire. This assessment process and the

objectives pursued are mandatory.

At Orange Communications Luxembourg, the compliance officer

performs a due diligence on suppliers. Due diligence criteria are

those imposed by the Group and applied for all suppliers with

contract(s) reaching more than 2,000€ annually.

In 2025, the purchasing policy has been updated at Group level.

However, no other specific action has been implemented on top

of the general supplier screening process explained above.

196

Orange Belgium

_

Annual report 2025

197

5.

Appendix

5.1

Note on carbon footprint assessment methodology

Orange has opted to assess its scope 1, scope 2 and scope 3

GHG emissions using the GHG Protocol’s “Financial Control”

approach as far as feasible. Accordingly, the subsidiaries that are

financially consolidated by the Group are included in the scope 1,

scope 2 and scope 3 assessments. This means that for Orange

Belgium, the reporting boundaries include emissions from the

consolidated entities that are in the scope of this statement,

which consists of Orange Belgium (including Netco, WBCC and

Be tv and Orange Communications Luxembourg). However,

emissions of other associates, joint ventures are not assessed as

part of scope 1 and 2 but are included in scope 3 the same way

as any other indirect emission stemming from activities with

business partners and clients.

The Group's CSR department oversees and consolidates the

assessment of all Scope 3 GHG emissions, with the participation

of numerous departments, divisions and entities. Significant

assumptions are made by the Group during the calculations and

may cover decisions on the use of historical data for establishing

trends where data is missing (for instance, values relating to the

fourth quarter may be subject to estimates locally if the data is

not available within the time required for publication), the

selection of emission factors, and the consideration of the

specific operational context of each subsidiary.

Orange also employs a data management tool that facilitates the

accurate measurement of GHG emissions. That tool is

referenced in the internal guidelines provided to the relevant

teams contributing to this calculation ensuring the reliability of

data collected.

Scope 1 GHG emissions are calculated by multiplying actual

activity data (energy consumption) by an emission factor for the

year in question, chosen by the Group and sourced from the

Agence de l’Environnement et de la Maîtrise de l’Energie

(ADEME) database. These emission factors are likely to be

updated regularly directly in the tool by the Group. The energy

sources considered in this scope are fuel oil, gas, petrol and

diesel. Leaks of refrigerants (fluids used for air conditioning) or

automatic fire extinguishers (fluids used to limit the impact of a

fire in strategic network rooms) are not included in Belgium and

Luxembourg because they are not significant. The entities do not

have biogenic emissions of CO

₂

from the combustion or

biodegradation of biomass included in scope 1 GHG emissions.

Scope 2 GHG emissions encompass indirect emissions linked to

electricity consumption from public grid. The GHG emissions

associated with scope 2 electricity consumption must be

assessed, in accordance with the recommendations of the GHG

Protocol, using both the market-based method and the location-

based method.

•

The location-based method

considers the average

emission factors corresponding to the electricity grids -

national by default - on which the electricity is

consumed. The activity data is multiplied by an

emission factor, corresponding to the consumption

phase only (excluding the production of generator-type

equipment and excluding energy transport), for the year

and country in question. These country mix emission

factors are collected by the Group's CSR department

from the International Energy Agency (IEA) and updated

regularly.

•

The

market-based method

is the one most frequently

used by companies, as it allows scope 2 GHG

emissions corresponding to electricity from renewable

sources to be set to zero. In the context of scope 2

greenhouse gas (GHG) emissions reporting,

GHG emissions other than CO

₂

are included in location-based

emissions and market-based emissions factors. The entities

covered in this report do not have biogenic emissions identified

in scope 2.

The assessments carried out are based on all 15 categories of

the GHG Protocol, with the exception of categories 3.8, 3.10,

3.12, 3.14 to 3.15, for which the estimates were considered

insignificant or not applicable to the Group's activity. Orange

Belgium and Orange Communications Luxembourg calculate

emissions for the following scope 3 categories prescribed by the

GHG Protocol:

3

.

1

-

P

u

r

c

h

a

s

e

d

g

o

d

s

a

n

d

s

e

r

v

i

c

e

s

: Customer Premise

Equipment (CPE) manufacturing, smartphones manufacturing,

MBB Flybox manufacturing, other devices manufacturing,

purchased services.

3

.

2

-

C

a

p

i

t

a

l

g

o

d

s

: buildings, networks equipment, vehicles.

3

.

3

-

F

u

e

l

-

a

n

d

e

n

e

r

g

y

-

r

e

l

a

t

e

d

a

c

t

i

v

i

t

i

e

s

(

u

p

s

t

r

e

a

m

)

:

energy

upstream emissions.

3

.

4

-

U

p

s

t

r

e

a

m

t

r

a

n

s

p

o

r

t

a

t

i

o

n

a

n

d

i

s

t

r

i

b

u

t

i

o

n

3

.

5

-

W

a

s

t

e

g

e

n

e

r

a

t

e

d

i

n

o

p

e

r

a

t

i

o

n

s

3

.

6

-

B

u

s

i

n

e

s

t

r

a

v

e

l

3

.

7

-

E

m

p

l

o

y

e

c

o

m

u

t

i

n

g

3

.

9

-

D

o

w

n

s

t

r

e

a

m

t

r

a

n

s

p

o

r

t

a

t

i

o

n

a

n

d

i

s

t

r

i

b

u

t

i

o

n

3

.

1

-

U

s

e

o

f

s

o

l

d

p

r

o

d

u

c

t

s

:

smartphone use, MBB Flybox use,

other devices use.

3

.

1

3

-

D

o

w

n

s

t

r

e

a

m

l

e

a

s

e

d

a

s

e

t

s

However, the following scope categories are excluded: 3.8

Upstream leased assets, 3.10 Processing of sold products, 3.12

End of life treatment of sold products, 3.14 Franchises and 3.15

Investments,

for

which

the

estimates

were

considered

insignificant or not applicable to the Group's activity. The

exclusion may also be due to challenges in obtaining reliable data

or the lack of direct involvement in those specific activities within

the value chain. Orange Belgium and Orange Communications

Luxembourg focus on categories that have a more direct impact

on its GHG emissions profile and where it can effectively measure

and manage emissions.

197

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Annual report 2025

198

In 2025, Orange continued to strengthen the quality of the

assessment of its scope 3 GHG emissions regarding both

monetary and physical flows, and the monetary emission factors

used. Reported scope 3 GHG emissions cover the following

scope 3 categories: 3.1, 3.2, 3.3, 3.4, 3.5, 3.6, 3.7, 3.9, 3.11 and

3.13. In line with it, Orange Belgium and Orange Communications

Luxembourg put focus on these categories.

No biogenic emissions have been identified in scope 3

emissions.

Physical data

In 2025, circular economy and waste KPIs such as the number of

smartphones collected/refurbished (scope 3 category 1) and the

amount of waste generated and associated treatment (scope 3

category 5) were reported on a quarterly basis in the tool at the

same time as scope 1 & 2 data.

Additionally, two scope 3 specific data collection campaigns

were organised over the year using the tool provided by the

Group. This data collection at local level concerned the following

topics: purchase of Customer Premises Equipment (CPE) (scope

3 category 1), building and vehicle fleet fixed assets (scope 3

category 2), business travel (scope 3 category 6), employee

commuting (scope 3 category 7) and usage of Customer

Premises Equipment (CPE) (scope 3 category 13). All data is

converted into GHG emissions using emission factors (EFs) from

life cycle analyses, from databases, such as those developed by

ADEME (the French Agency for Ecological Transition) or the

International Energy Agency (IEA), or from extrapolations.

Monetary data

Monetary data covers purchased services (scope 3 category 1)

and network equipment (scope 3 category 2) and was collected

from the financial system, using Q3F 2025 data (9 months real

and 3 months estimated). Financial data is then converted into

GHG emissions using ADEME’s monetary emission factors or, as

much as possible, monetary emission factors specific to

Orange’s suppliers gathered from CDP reports (supplier CDP).

With regard to monetary data, inflation was taken into account

by applying a discount rate to all Group entities corresponding to

the average cumulative inflation rate since 2016 (the reference

year for ADEME emission factors) as recorded by INSEE in

France. A correction for 2024 inflation using the actual rate was

applied in order to obtain a more reliable cumulative value from

2016 to 2025 (reference year for ADEME emission factors)

applied to the monetary data used to calculate Scope 3

emissions.

Remaining categories (scope 3 category 4, scope 3 category 9

and scope 3 category 11) are consolidated by Group following

methodology presented below.

The different assessment methods are described in the table

below, presented according to the categories of the GHG

Protocol, the main international reference and framework chosen

by the Group.

198

Orange Belgium

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Annual report 2025

199

Scope 3 GHG emissions categories

GHG Protocol categories taken into account

U

p

s

t

r

e

a

m

3

.

1

-

P

u

r

c

h

a

s

e

d

g

o

d

s

a

n

d

s

e

r

v

i

c

e

s

To date, purchases of Liveboxes and SetTopBox are counted in scope 3 category 1, although they are treated

financially within the Orange Group as e

-CAPEX, as they are leased to the customer.

For purchases of services, GHG emissions are calculated by multiplying annual expenditure on purchases of services

by monetary emission factors (EF). The expenditure taken into account is the annual expenditure on service

purchases for all Orange entities,

classified according to the Group's financial accounting standards. The source files

are extracted from the financial consolidation tool, then the data already counted in physical terms and Orange

Business's telecommunications service expenditure are restated. The EFs used are weighted averages of EFs by CC3

(purchase categories) from the purchasing database for previous years, based on a mapping between financial

accounts and CC3s. Where possible, these are monetary EFs specific to Orange suppliers, or those of ADEME, or are

calculated by Orange Innovation based on work and the results of technical consultations conducted with network

suppliers in particular.

For Orange Business's telecoms expenditure, a specific monetary EF per country is calculated

by ad

justing the French telecoms EF corresponding to GHG emissions from electricity, in proportion to the electricity

mix of the country in question.

For customer equipment purchases (e

-

CAPEX 30 or OPEX), GHG emissions are calculated by multiplying the number

of devices purchased by Orange each year, by country, by type and model, with the distinction between new and

refurbished devices by specific emis

sion factors wherever possible. Manufacturing emission factors (for boxes, IoT

and MBB) are based as far as possible on life cycle analyses (LCA) carried out by Orange or by manufacturers. For

Apple and Huawei smartphones, model

-specific EFs are used. For

other mobile devices, the EFs used are taken from

Ecorating. When physical data is not available, monetary data is used (using monetary EF specific to Orange). When

no Orange LCA exists for certain equipment, these Orange

-specific EFs are averaged or extrapolated to cover as

many situations as possible. As a last resort, Orange uses the ADEME monetary EF (Service

- IT, electronic and

optical products) at 400 kgCO

2

e/k€.

3

.

2

–

C

a

p

i

t

a

l

g

o

d

s

Two calculations have been carried out, one with depreciation and one without, in accordance with the rules of the

GHG Protocol.

For the calculation of GHG emissions corresponding to buildings with depreciation, to date, data from item 3.8

–

Upstream leased assets for buildings has been included in this item due to difficulties in separating data relating to

owned buildings from dat

a relating to leased buildings.

Network equipment and information systems (IS): the corresponding investments are assessed on the basis of

physical or monetary FE depending on the type of equipment and entity.

For Orange Belgium and Orange Communications Luxembourg SA, as physical data is not yet available and/or

usable, monetary data from the financial consolidation tool is used for the calculations; this data corresponds to

expenditure in thousands of euros pe

r category of network and IT fixed assets. The ambition is to increase the

proportion of valuation using the physical method in the coming years for all

Group entities.

The physical emission factors used come from various sources (PEP EcoPassPort

– ACV Orange – Calcul Carbone 4

–

ADEME Carbon Database). In some cases, it is necessary to calculate emission factors per unit based on monetary

emission factors from the ADEME

Carbon Database. For monetary data from the financial consolidation tool, the

emission factors used are weighted averages of EFs by CC3 from previous years, based on a mapping between

financial accounts and CC3s. Certain monetary EFs specific to Orange networks were calculated by Carbone 4 based

on analyses of French networks.

Buildings (fixed assets or rents): GHG emissions are calculated by multiplying physical data (surface areas occupied

by Orange), by type of building (shops, offices, warehouses, car parks, etc.), whether the buildings are rented or

owned, by the correspond

ing ADEME surface area EFs (in kgCO

2

e/m

2

). This value is then divided by 50 years, which

is the period used for the depreciation of buildings in carbon accounting (consequently, buildings over 50 years old

are not included in the carbon footprint calculati

on). All buildings occupied by Orange are included in this item,

whether Orange rents or owns them.

Vehicles: GHG emissions are calculated by multiplying the number of vehicles used by Orange (fleet of vehicles,

owned or leased), by type (passenger cars, light commercial vehicles, sedan,

trucks, vans, etc.), by the corresponding

EFs from the ADEME Carbon Database or the Carbone 4 internal databases. This value is then divided by 10 years,

which is the period used for depreciating vehicles in carbon accounting (consequently, vehicles over 1

0 years old are

not included in the carbon footprint calculation). When the type of vehicle is not known, the default type applied is the

sedan, as this is associated with an FE value that falls between that of passenger cars and light commercial vehicles.

All vehicles used by Orange are included in this item, whether leased or owned.

3

.

3

–

F

u

e

l

a

n

d

e

n

e

r

g

y

r

e

l

a

t

e

d

a

c

t

i

v

i

t

i

e

s

The approach adopted by default is the market

-based method, which allows for the initiatives of entities intended to

use more renewable energy to be taken into account.

The calculation is also carried out using the location

-

based method. GHG emissions are calculated by multiplying the

quantities of energy purchased by Orange (gas, fuel oil, electricity or energy from renewable sources purchased or

self

-generated, in m³, litres or GWh respectively) by the upstream energy EF (EF for energy excluding combustion)

taken from the IEA database and updated in Q3 of each year. The activity data are mainly taken from those used to

calculate scope 1 and scope 2, with a breakdown of r

enewable energy into solar and wind power in order to apply

the relevant EFs for the market

-based method.

Use of energy sold: GHG emissions (due to the combustion and upstream use of energy) are calculated by

multiplying the quantities of energy sold by the Orange Group (in tons, litres, m³ or GWh) by the corresponding EFs.

The emission factors for electricity from renewable sources are those of ADEME, including combustion and upstream.

3.4 - Upstream

t

r

a

n

s

p

o

r

t

a

t

i

o

n

a

n

d

i

s

t

r

i

b

u

t

i

o

n

The data provided by Orange are the tonnes transported upstream by receiving country and the corresponding GHG

emissions by mode of transport. These data are based on actual and operational data collected from certain

suppliers.

This approach should be systemat

ised for the largest suppliers (top 12, based on their sales) and taken into account

in the Group's scope 3 reporting. However, these data remain incomplete, so Orange extrapolates on the basis of the

tonnes transported downstream monitored by the O'GREEN pro

gramme. LCAs have been used for the transport of

smartphones and boxes, thanks to the work carried out as part of the O'GREEN

programme.

For other transport, extrapolations were made.

199

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Annual report 2025

200

Scope 3 GHG emissions categories

GHG Protocol categories taken into account

3

.

5

–

W

a

s

t

e

GHG emissions are calculated by multiplying the quantities of waste (in tons or m³ per material), by country,

supplemented by the percentage of recovery per recovery channel, by the corresponding ADEME or ASTEEE (for

wastewater) emission factors, depending on whether the waste is recovered or not.

3.6 - Business travel

GHG emissions are calculated by multiplying the distances travelled, by country and by mode of transport (train,

plane), as reported by the travel agencies used by the Group, by the ADEME EF per passenger.km, by mode of

transport.

3.7 – Employee

c

o

m

u

t

i

n

g

GHG emissions are calculated by multiplying the number of FTEs per country by an average annual home-work

commuting EF based on the National Transport and Travel Survey of INSEE) and ADEME. The calculation takes into

account the proportion of employees usi

ng public transport, bicycles, as well as the estimated number of days

worked from home, obtained from survey results.

Care is taken to avoid double counting of emissions in Belgium between this category and emissions reported in

scope 1 due to the dual use of leased cars in Belgium for both professional and private transportation.

3.8 - Upstream leased

a

s

e

t

s

Evaluated, but included in 3.2

For the calculation with depreciation of GHG emissions corresponding to buildings, to date, data from item 3.8

-

Upstream leased assets for buildings has been included in item 3.2 due to difficulties in separating data relating to

owned buildings from data relating to leased buildings.

Downstream

3.9 - Downstream

t

r

a

n

s

p

o

r

t

a

t

i

o

n

a

n

d

distribution

GHG emissions are sourced directly from the O'GREEN programme in Europe. They include GHG emissions linked to

transporters' logistics warehouses.

3

.

1

0

-

P

r

o

c

e

s

i

n

g

o

f

s

o

l

d

p

r

o

d

u

c

t

s

Not applicable to Orange activities to date.

3.11 - Use of sold

p

r

o

d

u

c

t

s

GHG emissions are calculated by multiplying the number of devices, by type of device, by their specific annual

electricity consumption, and by the EF of the average electricity mix in the country of use.

For smartphones, feature phones and DECT (Digital Enhanced Cordless Telecommunications), the calculation is

based on the number of products sold by the Orange Group during the year. Each type of equipment has a specific

annual electricity consumption, whic

h is multiplied by the emission factor of the average electricity mix in the country

of use. A useful life of 2.5 years from the year of purchase of the device is assumed. For Orange Business customer

equipment, the calculation is based on the number of ro

uters in use by Orange Business customers, by brand. Each

type of equipment has a specific annual electricity consumption, which is multiplied by the emission factor of the

average electricity mix in the country of use. Mobile consumption data is provided

by Orange Innovation.

The emission factors for electricity are by default the same as those used for scope 2 electricity (Combustion part of

the Electricity EF), with the IEA database as the reference.

3.12 - End of life of sold

p

r

o

d

u

c

t

s

Not evaluated.

Estimated GHG emissions not significant and not assessed. However, WEEE collected from customers is included in

category 3.5. related to waste.

3

.

1

3

-

D

o

w

n

s

t

r

e

a

m

l

e

a

s

e

d

a

s

e

t

s

As some customer equipment is leased to customers, Orange has decided to move it from category 3.11 to category

3.13 from 2023 onwards. The latter concerns GHG emissions linked to Livebox and SetTopBox equipment and WiFi

repeaters; the calculation is based

on the consumption of this equipment in use expressed in KWh/year/product, the

average electricity mix in the country of use (in gCO

2

/KWh) and a usage profile between active and standby mode.

Livebox consumption data is provided by Orange.

The emission factors for electricity are by default the same as those used for scope 2 electricity (Combustion part of

the Electricity EF), with the IEA database as the reference.

3.14 - Franchises

Not applicable to Orange activities to date

3.15 - Investments

Not evaluated. Non-significant and non-assessed GHG emissions

To calculate scope 3 emissions, Orange Belgium and Orange Luxembourg used 79% of primary data. The percentage of emissions

calculated from primary data is calculated by averaging the percentages of emissions calculated from primary emissions data by

category or subcategory weighted by location-based emissions in tonnes of GHG from those same categories or subcategories of

emissions. Each percentage of emissions calculated from primary emissions data for a category or subcategory is assessed by

calculating the ratio between the measured data and the measured data plus the estimated data.

200

Orange Belgium

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Annual report 2025

201

5.2

Disclosures on the materiality assessment process

(ESRS 2 IRO-2)

5.2.1

List of complied disclosure requirements

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q

u

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t

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t

a

t

u

s

S

e

c

t

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n

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o

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e

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u

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t

E

S

R

S

2

G

e

n

e

r

a

l

D

i

s

c

l

o

s

u

r

e

ESRS2 BP-1

Disclosed

1.1.1.1 General basis for preparation of the sustainability statement (BP-1)

ESRS2 BP-2

Disclosed

1.1.1.2 Disclosures in relation to specific circumstances (BP-2)

ESRS2 GOV-1

Disclosed

1.1.2.1 The role of the administrative, management and supervisory bodies (GOV-1)

ESRS2 GOV-2

Disclosed

1.1.2.2 Information provided to and sustainability matters addressed by the undertaking’s

administrative, management and supervisory bodies (GOV-2)

ESRS2 GOV-3

Disclosed

1.1.2.3 Integration of sustainability-related performance in incentive schemes (GOV-3)

ESRS2 GOV-4

Disclosed

1.1.2.4 Statement on due diligence (GOV-4)

ESRS2 GOV-5

Disclosed

1.1.2.5 Risk management and internal controls over sustainability reporting (GOV-5)

ESRS2 SBM-1

Disclosed

1.1.3.1 Strategy, business model and value chain (SBM-1)

ESRS2 SBM-2

Disclosed

1.1.3.2 Interests and views of stakeholders (SBM-2)

ESRS2 SBM-3

Disclosed

1.1.3.3 Material impacts, risks and opportunities (IROs) and their interaction with strategy and

business model (SBM-3)

ESRS2 IRO-1

Disclosed

1.1.4.1 Description of the process to identify and assess material impacts, risks and opportunities

(IRO-1)

ESRS2 IRO-2

Disclosed

5.2 Disclosures on the materiality assessment process (ESRS 2 IRO-2)

ESRS2 MDR-P

Disclosed

2.1.2.1 Policies related to climate change mitigation and energy (E1-2)

2.1.3.1 Policies related to climate change adaptation (E1-2)

2.2.1.1 Policies related to resource use and circular economy (E5-1)

2.2.2.1 Policies related to resource outflows / waste (E5-1)

3.1.1 Orange Group human rights

3.2.2.1 Policies related to training and skills development (S1-1)

3.2.3.1 Policies related to diversity (S1-1)

3.2.4.1 Policies related to health and safety (S1-1)

3.3.2.1 Policies related to digital inclusion (S4-1)

3.3.3.1 Policies related to psychological health of end-users (S4-1)

3.3.4.1 Policies related to data privacy and cybersecurity (S4-1)

4.1.1.1 Business conduct policies and corporate culture (G1-1, G1-3)

4.1.2.2 Management of relationships with suppliers, building trust and secure responsible supply

(G1-2)

ESRS2 MDR-A

Disclosed

2.1.2.6 Taking actions on climate change mitigation and energy (E1-3)

2.1.3.3 Taking actions on climate change adaptation (E1-3)

2.2.1.3 Taking actions on resource use and circular economy (E5-2)

2.2.2.4 Taking actions on resource outflows and waste (E5-2)

3.2.2.4 Taking actions on training and skills development (S1-4)

3.2.3.4 Taking actions on diversity (S1-4)

3.2.4.4 Taking actions on health and safety (S1-4)

3.3.2.3 Taking actions on digital inclusion (S4-4)

3.3.3.3 Taking actions on psychological health of end-users (S4-4)

3.3.4.3 Taking actions on data privacy and cybersecurity (S4-4)

4.1.2.2 Management of relationships with suppliers, building trust and secure responsible supply

(G1-2)

201

Orange Belgium

_

Annual report 2025

202

D

i

s

c

l

o

s

u

r

e

r

e

q

u

i

r

e

m

e

n

t

S

t

a

t

u

s

S

e

c

t

i

o

n

s

o

f

t

h

e

s

u

s

t

a

i

n

a

b

i

l

i

t

y

s

t

a

t

e

m

e

n

t

ESRS2 MDR-M

Disclosed

1.1.2.1.1 Composition and diversity of the members of the administrative, management and

supervisory bodies

1.1.3.1 Strategy, business model and value chain (SBM-1)

2.1.2.3 Energy consumption and mix (E1-5)

2.1.2.4 Gross scopes 1, 2, 3 and total GHG emissions (E1-6)

2.2.2.3 Metrics related to resource outflows and waste (E5-5)

3.1.5 Human rights incidents

3.2.2.3 Training and skills development metrics (S1-13)

3.2.3.3 Diversity metrics

3.2.4.3 Health and safety metrics (S1-14)

3.2.5 Additional metrics related to own workforce

4.1.1.2 Incidents of corruption or bribery (G1-4)

ESRS2 MDR-T

Disclosed

2.1.2.2 Targets related to climate change mitigation and energy (E1-4)

2.1.3.2 Targets related to climate change adaptation (E1-4)

2.2.1.2 Targets related to resource use and circular economy (E5-3)

2.2.2.2 Targets related to resource outflows and waste (E5-3)

3.2.2.2 Targets related to training and skills development (S1-5)

3.2.3.2 Targets related to diversity (S1-5)

3.2.4.2 Targets related to health and safety (S1-5)

3.3.2.2 Target related do digital inclusion (S4-5)

3.3.3.2 Targets related to psychological health of end-users (S4-5)

3.3.4.2 Targets related to data privacy and cybersecurity (S4-5)

E

S

R

S

E

1

C

l

i

m

a

t

e

C

h

a

n

g

e

ESRS2 GOV-3

Disclosed

1.1.2.3 Integration of sustainability-related performance in incentive schemes (GOV-3)

ESRS2 SBM-3

Disclosed

1.1.3.3 Material impacts, risks and opportunities (IROs) and their interaction with strategy and

business model (SBM-3)

ESRS2 IRO-1

Disclosed

1.1.4.1 Description of the process to identify and assess material impacts, risks and opportunities

(IRO-1)

ESRS E1-1

Disclosed

2.1.1.1 Transition plan for climate change mitigation (E1-1)

ESRS E1-2

Disclosed

2.1.2.1 Policies related to climate change mitigation and energy (E1-2)

2.1.3.1 Policies related to climate change adaptation (E1-2)

ESRS E1-3

Disclosed

2.1.2.6 Taking actions on climate change mitigation and energy (E1-3)

2.1.3.3 Taking actions on climate change adaptation (E1-3)

ESRS E1-4

Disclosed

2.1.2.2 Targets related to climate change mitigation and energy (E1-4)

2.1.3.2 Targets related to climate change adaptation (E1-4)

ESRS E1-5

Disclosed

2.1.2.3 Energy consumption and mix (E1-5)

ESRS E1-6

Disclosed

2.1.2.4 Gross 1, 2, 3 and total GHG emissions (E1-6)

ESRS E1-7

Disclosed

2.1.2.5 GHG removals and GHG mitigation projects financed through carbon credits (E1-7)

ESRS E1-8

Not

applicable

46

N/A

ESRS E1-9

Phase-in

allowed

N/A

E

S

R

S

E

2

P

o

l

u

t

i

o

n

ESRS2 IRO-1

Not material

N/A

ESRS E2-1

Not material

N/A

ESRS E2-2

Not material

N/A

46

Note that Orange does not implement any internal carbon pricing scheme

202

Orange Belgium

_

Annual report 2025

203

D

i

s

c

l

o

s

u

r

e

r

e

q

u

i

r

e

m

e

n

t

S

t

a

t

u

s

S

e

c

t

i

o

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s

o

f

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e

s

u

s

t

a

i

n

a

b

i

l

i

t

y

s

t

a

t

e

m

e

n

t

ESRS E2-3

Not material

N/A

ESRS E2-4

Not material

N/A

ESRS E2-5

Not material

N/A

ESRS E2-6

Not material

N/A

E

S

R

S

E

3

W

a

t

e

r

a

n

d

M

a

r

i

n

e

R

e

s

o

u

r

c

e

s

ESRS2 IRO-1

Not material

N/A

ESRS E3-1

Not material

N/A

ESRS E3-2

Not material

N/A

ESRS E3-3

Not material

N/A

ESRS E3-4

Not material

N/A

ESRS E3-5

Not material

N/A

E

S

R

S

E

4

B

i

o

d

i

v

e

r

s

i

t

y

a

n

d

E

c

o

s

y

s

t

e

m

s

ESRS E4-1

Not material

N/A

ESRS2 SBM-3

Not material

N/A

ESRS2 IRO-1

Not material

N/A

ESRS E4-2

Not material

N/A

ESRS E4-3

Not material

N/A

ESRS E4-4

Not material

N/A

ESRS E4-5

Not material

N/A

ESRS E4-6

Not material

N/A

E

S

R

S

E

5

R

e

s

o

u

r

c

e

U

s

e

a

n

d

C

i

r

c

u

l

a

r

E

c

o

n

o

m

y

ESRS2 IRO-1

Disclosed

1.1.4.1 Description of the process to identify and assess material impacts, risks and opportunities

(IRO-1)

ESRS E5-1

Disclosed

2.2.1.1 Policies related to resource use and circular economy (E5-1)

2.2.2.1 Policies related to resource outflows / waste (E5-1)

ESRS E5-2

Disclosed

2.2.1.3 Taking actions on resource use and circular economy (E5-2)

2.2.2.4 Taking actions on resource outflows and waste (E5-2)

ESRS E5-3

Disclosed

2.2.1.2 Targets related to resource use and circular economy (E5-3)

2.2.2.2 Targets related to resource outflows and waste (E5-3)

ESRS E5-4

Not applicable

N/A

ESRS E5-5

Disclosed

2.2.2.3 Metrics related to resource outflows and waste (E5-5)

ESRS E5-6

Phase-in

allowed

N/A

E

S

R

S

1

O

w

n

W

o

r

k

f

o

r

c

e

ESRS2 SBM-2

Disclosed

1.1.3.2 Interests and views of stakeholders (SBM-2)

ESRS2 SBM-3

Disclosed

1.1.3.3 Material impacts, risks and opportunities (IROs) and their interaction with strategy and

business model (SBM-3)

ESRS2 S1-1

Disclosed

3.1.1.1 Human Rights Policy

3.1.2 Human rights for own workforce

3.2.2.1 Policies related to training and skills development (S1-1)

3.2.3.1 Policies related to diversity (S1-1)

3.2.4.1 Policies related to health and safety (S1-1)

203

Orange Belgium

_

Annual report 2025

204

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i

s

c

l

o

s

u

r

e

r

e

q

u

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t

S

t

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u

s

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e

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n

a

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i

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y

s

t

a

t

e

m

e

n

t

ESRS2 S1-2

Disclosed

3.2.1.1 Processes for engaging with own workers and workers’ representatives about impacts (S1-

2)

ESRS2 S1-3

Disclosed

3.2.1.2 Processes to remediate negative impacts and channels for own workers to raise concerns

(S1-3)

ESRS2 S1-4

Disclosed

3.2.2.4 Taking actions on training and skills development (S1-4)

3.2.3.4 Taking actions on diversity (S1-4)

3.2.4.4 Taking actions on health and safety (S1-4)

ESRS2 S1-5

Disclosed

3.2.2.2 Targets related to training and skills development (S1-5)

3.2.3.2 Targets related to diversity (S1-5)

3.2.4.2 Targets related to health and safety (S1-5)

ESRS2 S1-6

Disclosed

3.2.5 Additional metrics related to own workforce

ESRS2 S1-7

Phase-in

allowed

N/A

ESRS2 S1-8

Disclosed

3.2.5 Additional metrics related to own workforce

ESRS2 S1-9

Disclosed

3.2.3.3 Diversity metrics

ESRS2 S1-10

Disclosed

3.2.5 Additional metrics related to own workforce

ESRS2 S1-11

Phase-in

allowed

N/A

ESRS2 S1-12

Phase-in

allowed

N/A

ESRS2 S1-13

Disclosed

3.2.2.3 Training and skills development metrics (S1-13)

ESRS2 S1-14

Disclosed

3.2.4.3 Health and safety Metrics (S1-14)

ESRS2 S1-15

Phase-in

allowed

N/A

ESRS2 S1-16

Disclosed

3.2.3.3 Diversity metrics

3.2.5 Additional metrics related to own workforce

ESRS2 S1-17

Disclosed

3.2.3.3 Diversity metrics

3.1.5 Human rights incidents

E

S

R

S

2

W

o

r

k

e

r

s

i

n

t

h

e

v

a

l

u

e

c

h

a

i

n

ESRS2 SBM-2

Not material

N/A

ESRS2 SBM-3

Not material

N/A

ESRS2 S2-1

Disclosed

3.1.4 Human rights for workers in the value chain

ESRS2 S2-2

Not material

N/A

ESRS2 S2-3

Not material

N/A

ESRS2 S2-4

Not material

N/A

ESRS2 S2-5

Not material

N/A

E

S

R

S

3

A

f

e

c

t

e

d

c

o

m

u

n

i

t

i

e

s

ESRS2 SBM-2

Not material

N/A

ESRS2 SBM-3

Not material

N/A

ESRS2 S3-1

Not material

N/A

ESRS2 S3-2

Not material

N/A

ESRS2 S3-3

Not material

N/A

ESRS2 S3-4

Not material

N/A

ESRS2 S3-5

Not material

N/A

204

Orange Belgium

_

Annual report 2025

205

D

i

s

c

l

o

s

u

r

e

r

e

q

u

i

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e

m

e

n

t

S

t

a

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u

s

S

e

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E

S

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S

4

C

o

n

s

u

m

e

r

s

a

n

d

E

n

d

-

u

s

e

r

s

ESRS2 SBM-2

Disclosed

1.1.3.2 Interests and views of stakeholders (SBM-2)

ESRS2 SBM-3

Disclosed

1.1.3.3 Material impacts, risks and opportunities (IROs) and their interaction with strategy and

business model (SBM-3)

ESRS2 S4-1

Disclosed

3.1.3 Human rights for consumers and end users

3.3.2.1 Policies related to digital inclusion (S4-1)

3.3.3.1 Policies related to psychological health of end-users (S4-1)

3.3.4.1 Policies related to data privacy and cybersecurity (S4-1)

ESRS2 S4-2

Disclosed

3.3.1.1 Processes for engaging with consumers and end-users about impacts (S4-2)

ESRS2 S4-3

Disclosed

3.3.1.2 Processes to remediate negative impacts and channels for consumers and end-users to

raise concerns (S4-3)

ESRS2 S4-4

Disclosed

3.1.5 Human rights incidents

3.3.2.3 Taking actions on digital inclusion (S4-4)

3.3.3.3 Taking actions on psychological health of end-users (S4-4)

3.3.4.3 Taking actions on data privacy and cybersecurity (S4-4)

ESRS2 S4-5

Disclosed

3.3.2.2 Target related do digital inclusion (S4-5)

3.3.3.2 Targets related to psychological health of end-users (S4-5)

3.3.4.2 Targets related to data privacy and cybersecurity (S4-5)

E

S

R

S

G

1

B

u

s

i

n

e

s

C

o

n

d

u

c

t

ESRS2 GOV-1

Disclosed

1.1.2.1 The role of the administrative, management and supervisory bodies (GOV-1)

ESRS2 IRO-1

Disclosed

1.1.4.1 Description of the process to identify and assess material impacts, risks and opportunities

(IRO-1)

ESRS2 G1-1

Disclosed

4.1.1.1 Business conduct policies and corporate culture (G1-1, G1-3)

ESRS2 G1-2

Disclosed

4.1.2.1 Management of relationships with suppliers, lowering late payment impact on suppliers’

liquidity (G1-2)

4.1.2.2 Management of relationships with suppliers, building trust and secure responsible supply

(G1-2)

ESRS2 G1-3

Disclosed

4.1.1.1 Business conduct policies and corporate culture (G1-1, G1-3)

ESRS2 G1-4

Disclosed

4.1.1.2 Incidents of corruption or bribery (G1-4)

ESRS2 G1-5

Not material

N/A

ESRS2 G1-6

Not material

N/A

205

Orange Belgium

_

Annual report 2025

206

Orange Belgium

_

Annual report 2025

5.2.2

List of datapoints in cross-cutting and topical standards that derive from other EU legislation

This table lists all data points that derive from other EU legislations

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(

47

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(

48

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(

49

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(

50

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c

e

ESRS 2 GOV

-1

Board's gender diversity

paragraph 21 (d)

Indicator number 13 of Table

#1 of Annex 1

Commission Delegated

Regulation (EU) 2020/1816

(

51

), Annex II

Material

1.1.2.1.1 Composition and

diversity of the members of

the administrative,

management and

supervisory bodies

ESRS 2 GOV

-1

Percentage of board members

who are independent

paragraph 21 (e)

Delegated Regulation

(EU) 2020/1816, Annex II

Material

1.1.2.1.1 Composition and

diversity of the members of

the administrative,

management and

supervisory bodies

ESRS 2 GOV

-4

Statement on due diligence

paragraph 30

Indicator number 10 Table

#3 of Annex 1

Material

1.1.2.4 Statement on due

diligence (GOV-4)

ESRS 2 SBM

-1

Involvement in activities related

to fossil fuel activities

paragraph 40 (d) i

Indicators number 4 Table

#1 of Annex 1

Article

449a Regulation (EU)

No 575/2013;

Commission Implementing Regulation

(EU) 2022/2453 (

52

)Table 1:

Qualitative information on

Environmental risk and Table 2:

Qualitative information on Social risk

Delegated Regulation

(EU) 2020/1816, Annex II

Not applicable

-

47

Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (Sustainable Finance Disclosures Regulation)

48

Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and investment firms and amending Regulation (EU) No 648/2012 (Capital

Requirements Regulation “CRR”)

49

Regulation (EU) 2016/1011 of the European Parliament and of the Council of 8 June 2016 on indices used as benchmarks in financial instruments and financial contracts or to measure the performance of investment funds and

amending Directives 2008/48/EC and 2014/17/EU and Regulation (EU) No 596/2014

50

Regulation (EU) 2021/1119 of the European Parliament and of the Council of 30 June 2021 establishing the framework for achieving climate neutrality and amending Regulations (EC) No 401/2009 and (EU) 2018/1999

(‘European Climate Law’)

51

Commission Delegated Regulation (EU) 2020/1816 of 17 July 2020 supplementing Regulation (EU) 2016/1011 of the European Parliament and of the Council as regards the explanation in the benchmark statement of how

environmental, social and governance factors are reflected in each benchmark provided and published

52

Commission Implementing Regulation (EU) 2022/2453 of 30 November 2022 amending the implementing technical standards laid down in Implementing Regulation (EU) 2021/637 as regards the disclosure of environmental,

social and governance risks

207

Orange Belgium

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Annual report 2025

ESRS 2 SBM

-1

Involvement in activities related

to chemical production

paragraph 40 (d) ii

Indicator number 9 Table #2

of Annex 1

Delegated Regulation

(EU) 2020/1816, Annex II

Not applicable

-

ESRS 2 SBM

-1

Involvement in activities related

to controversial weapons

paragraph 40 (d) iii

Indicator number 14 Table

#1 of Annex 1

Delegated Regulation

(EU) 2020/1818 (

53

),

Article 12(1) Delegated

Regulation (EU) 2020/1816,

Annex II

Not applicable

-

ESRS 2 SBM

-1

Involvement in activities related

to cultivation and production of

tobacco paragraph 40 (d) iv

Delegated Regulation

(EU) 2020/1818, Article

12(1)

Delegated Regulation

(EU) 2020/1816, Annex II

Not applicable

-

ESRS E1

-1

Transition plan to reach climate

neutrality by 2050 paragraph 14

Regulation

(EU) 2021/1119,

Article 2(1)

Material

2.1.1.1 Transition plan for

climate change mitigation

(E1-1)

ESRS E1

-1

Undertakings excluded from

Paris

-aligned Benchmarks

paragraph 16 (g)

Article

449a

Regulation (EU) No 575/2013;

Commission Implementing Regulation

(EU) 2022/2453 Template 1: Banking

book-Climate Change transition risk:

Credit quality of exposures by sector,

emissions and residual maturity

Delegated Regulation

(EU) 2020/1818, Article12.1

(d) to (g), and Article 12.2

Material

2.1.1.1 Transition plan for

climate change mitigation

(E1-1)

ESRS E1

-4

GHG emission reduction

targets paragraph 34

Indicator number 4 Table #2

of Annex 1

Article

449a

Regulation (EU) No 575/2013;

Commission Implementing Regulation

(EU) 2022/2453 Template 3: Banking

book –

Climate change transition risk:

alignment metrics

Delegated Regulation

(EU) 2020/1818, Article 6

Material

2.1.2.2 Targets related to

climate change mitigation

and energy (E1-4)

ESRS E1

-5

Energy consumption from fossil

sources disaggregated by

sources (only high climate

impact sectors) paragraph 38

Indicator number 5 Table #1

and Indicator n. 5 Table #2

of Annex 1

Not applicable

-

ESRS E1

-5 Energy

consumption and mix

paragraph 37

Indicator number 5 Table #1

of Annex 1

Material

2.1.2.3 Energy consumption

and mix (E1-5)

53

Commission Delegated Regulation (EU) 2020/1818 of 17 July 2020 supplementing Regulation (EU) 2016/1011 of the European Parliament and of the Council as regards minimum standards for EU Climate Transition

Benchmarks and EU Paris-aligned Benchmarks

208

Orange Belgium

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Annual report 2025

ESRS E1

-5

Energy intensity associated

with activities in high climate

impact sectors paragraphs 40

to 43

Indicator number 6 Table #1

of Annex 1

Not applicable

-

ESRS E1

-6

Gross scope 1, 2, 3 and Total

GHG emissions paragraph 44

Indicators number 1 and 2

Table #1 of Annex 1

Article 449a; Regulation (EU)

No 575/2013; Commission

Implementing Regulation

(EU) 2022/2453 Template 1: Banking

book –

Climate change transition risk:

Credit quality of exposures by sector,

emissions and residual maturity

Delegated Regulation

(EU) 2020/1818, Article

5(1),

6 and 8(1)

Material

2.1.2.4 Gross scopes 1, 2, 3

and total GHG emissions

(E1-6)

ESRS E1

-6

Gross GHG emissions intensity

paragraphs 53 to 55

Indicators number 3 Table

#1 of Annex 1

Article 449a Regulation (EU)

No 575/2013; Commission

Implementing Regulation

(EU) 2022/2453 Template 3: Banking

book –

Climate change transition risk:

alignment metrics

Delegated Regulation

(EU) 2020/1818, Article 8(1)

Material

2.1.2.4 Gross scopes 1, 2, 3

and total GHG emissions

(E1-6)

ESRS E1

-7

GHG removals and carbon

credits paragraph 56

Regulation

(EU) 2021/1119,

Article 2(1)

Material

2.1.2.5 GHG removals and

GHG mitigation projects

financed through carbon

credits (E1-7)

ESRS E1

-9

Exposure of the benchmark

portfolio to climate

-related

physical risks paragraph 66

Delegated Regulation

(EU) 2020/1818, Annex II

Delegated Regulation

(EU) 2020/1816, Annex II

Not disclosed

-

ESRS E1

-9

Disaggregation of monetary

amounts by acute and chronic

physical risk paragraph 66 (a)

ESRS E1

-9

Location of significant assets at

material physical risk paragraph

66 (c).

Article 449a Regulation (EU)

No 575/2013; Commission

Implementing Regulation

(EU) 2022/2453 paragraphs 46

and 47; Template 5: Banking book -

Climate change physical risk:

Exposures subject to physical risk.

Not disclosed

-

ESRS E1

-9 Breakdown of the

carrying value of its real estate

assets by energy

-efficiency

classes paragraph 67 (c).

Article 449a Regulation (EU)

No 575/2013; Commission

Implementing Regulation

(EU) 2022/2453 paragraph 34;

Template 2:Banking book -Climate

change transition risk: Loans

collateralised by immovable property -

Energy efficiency of the collateral

Not disclosed

-

209

Orange Belgium

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Annual report 2025

ESRS E1

-9

Degree of exposure of the

portfolio to climate

- related

opportunities paragraph 69

Delegated Regulation

(EU) 2020/1818, Annex II

Not disclosed

-

ESRS E2

-4

Amount of each pollutant listed

in Annex

II of the E-PRTR

Regulation (European Pollutant

Release and Transfer Register)

emitted to air, water and soil,

paragraph 28

Indicator number 8 Table #1

of Annex 1 Indicator number

2 Table #2 of Annex 1

Indicator number 1 Table #2

of Annex 1 Indicator number

3 Table #2 of Annex 1

Not material

-

ESRS E3

-1

Water and marine resources

paragraph 9

Indicator number 7 Table #2

of Annex 1

Not material

-

ESRS E3

-1

Dedicated policy paragraph 13

Indicator number 8 Table 2

of Annex 1

Not material

-

ESRS E3

-1

Sustainable oceans and seas

paragraph 14

Indicator number 12 Table

#2 of Annex 1

Not material

-

ESRS E3

-4

Total water recycled and

reused paragraph 28 (c)

Indicator number 6.2 Table

#2 of Annex 1

Not material

-

ESRS E3

-4

Total water consumption in

m

3

per net revenue on own

operations paragraph 29

Indicator number 6.1 Table

#2 of Annex 1

Not material

-

ESRS 2

- IRO 1 -

E4 paragraph

16 (a) i

Indicator number 7 Table #1

of Annex 1

Not material

-

ESRS 2

- IRO 1 -

E4 paragraph

16 (b)

Indicator number 10 Table

#2 of Annex 1

Not material

-

ESRS 2

- IRO 1 -

E4 paragraph

16 (c)

Indicator number 14 Table

#2 of Annex 1

Not material

-

ESRS E4

-2

Sustainable land / agriculture

practices or policies paragraph

24 (b)

Indicator number 11 Table

#2 of Annex 1

Not material

-

210

Orange Belgium

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Annual report 2025

ESRS E4

-2

Sustainable oceans / seas

practices or policies paragraph

24 (c)

Indicator number 12 Table

#2 of Annex 1

Not material

-

ESRS E4

-2

Policies to address

deforestation paragraph 24 (d)

Indicator number 15 Table

#2 of Annex 1

Not material

-

ESRS E5

-5

Non

-recycled waste paragraph

37 (d)

Indicator number 13 Table

#2 of Annex 1

Material

2.2.2.3 Metrics related to

resource outflows and

waste (E5-5)

ESRS E5

-5

Hazardous waste and

radioactive waste paragraph 39

Indicator number 9 Table #1

of Annex 1

Material

2.2.2.3 Metrics related to

resource outflows and

waste (E5-5)

ESRS 2

- SBM3 - S1

Risk of incidents of forced

labour paragraph 14 (f)

Indicator number 13 Table

#3 of Annex I

Material

1.1.3.3.3 Overview of

Orange’s material Impacts,

Risks and Opportunities

related to own workforce

ESRS 2

- SBM3 - S1

Risk of incidents of child labour

paragraph 14 (g)

Indicator number 12 Table

#3 of Annex I

Material

1.1.3.3.3 Overview of

Orange’s material Impacts,

Risks and Opportunities

related to own workforce

ESRS S1

-1

Human rights policy

commitments paragraph 20

Indicator number 9 Table #3

and Indicator number 11

Table #1 of Annex I

Material

3.1.1.1 Human Rights Policy

ESRS S1

-1

Due diligence policies on issues

addressed by the fundamental

International Labor

Organisation Conventions 1 to

8, paragraph 21

Delegated Regulation

(EU) 2020/1816, Annex II

Material

3.1.1.1 Human Rights Policy

ESRS S1

-1

processes and measures for

preventing trafficking in human

beings paragraph 22

Indicator number 11 Table

#3 of Annex I

Material

3.1.1.2 Address trafficking in

human beings, forced

labour or compulsory labour

and child labour

ESRS S1

-1

workplace accident prevention

policy or management system

paragraph 23

Indicator number 1 Table #3

of Annex I

Material

3.2.4.1 Policies related to

health and safety (S1-1)

211

Orange Belgium

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Annual report 2025

ESRS

S1-3

grievance/complaints handling

mechanisms paragraph 32 (c)

Indicator number 5 Table #3

of Annex I

Material

3.2.1.2 Processes to

remediate negative impacts

and channels for own

workers to raise concerns

(S1-3)

ESRS S1

-14

Number of fatalities and

number and rate of work

-

related accidents paragraph 88

(b) and (c)

Indicator number 2 Table #3

of Annex I

Delegated Regulation

(EU) 2020/1816, Annex II

Material

3.2.4.3 Health and safety

Metrics (S1-14)

ESRS S1

-14

Number of days lost to injuries,

accidents, fatalities or illness

paragraph 88 (e)

Indicator number 3 Table #3

of Annex I

Material

3.2.4.3 Health and safety

Metrics (S1-14)

ESRS S1

-16

Unadjusted gender pay gap

paragraph 97 (a)

Indicator number 12 Table

#1 of Annex I

Delegated Regulation

(EU) 2020/1816, Annex II

Material

3.2.3.3 Diversity metrics

ESRS S1

-16

Excessive CEO pay ratio

paragraph 97 (b)

Indicator number 8 Table #3

of Annex I

Material

3.2.5 Additional metrics

related to own workforce

ESRS S1

-17

Incidents of discrimination

paragraph 103 (a)

Indicator number 7 Table #3

of Annex I

Material

3.2.3.3 Diversity metrics

ESRS S1

-17 Non-respect of

UNGPs on Business and

Human Rights and OECD

paragraph 104 (a)

Indicator number 10 Table

#1 and Indicator n.

14 Table

#3 of Annex I

Delegated Regulation

(EU) 2020/1816, Annex II

Delegated Regulation

(EU) 2020/1818 Art 12 (1)

Material

3.1.5 Human rights

incidents

ESRS 2

- SBM3

–

S2

Significant risk of child labour or

forced labour in the value chain

paragraph 11 (b)

Indicators number 12 and

n. 13 Table #3 of Annex I

Not material

-

ESRS S2

-1

Human rights policy

commitments paragraph 17

Indicator number 9 Table #3

and Indicator n.

11 Table #1

of Annex 1

Material

3.1.4 Human rights for

workers in the value chain

ESRS S2

-1

Policies related to value chain

workers paragraph 18

Indicator number 11 and n.

4

Table #3 of Annex 1

Not material

-

212

Orange Belgium

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Annual report 2025

ESRS S2

-1

Non

-respect of UNGPs on

Business and Human Rights

principles and OECD guidelines

paragraph 19

Indicator number 10 Table

#1 of Annex 1

Delegated Regulation

(EU) 2020/1816, Annex II

Delegated Regulation

(EU) 2020/1818, Art 12 (1)

Not material

-

ESRS S2

-1

Due diligence policies on issues

addressed by the fundamental

International Labor

Organisation Conventions 1 to

8, paragraph 19

Delegated Regulation

(EU) 2020/1816, Annex II

Not material

-

ESRS S2

-4

Human rights issues and

incidents connected to its

upstream and downstream

value chain paragraph 36

Indicator number 14 Table

#3 of Annex 1

Not material

-

ESRS S3

-1

Human rights policy

commitments paragraph 16

Indicator number 9 Table #3

of Annex 1 and Indicator

number 11 Table #1 of

Annex 1

Not material

-

ESRS S3

-1

non

-respect of UNGPs on

Business and Human Rights,

ILO principles or and OECD

guidelines paragraph 17

Indicator number 10 Table

#1 Annex 1

Delegated Regulation

(EU) 2020/1816, Annex II

Delegated Regulation

(EU) 2020/1818, Art 12 (1)

Not material

-

ESRS S3

-4

Human rights issues and

incidents paragraph 36

Indicator number 14 Table

#3 of Annex 1

Not material

-

ESRS S4

-1 Policies related to

consumers and end

-users

paragraph 16

Indicator number 9 Table #3

and Indicator number 11

Table #1 of Annex 1

Material

3.1.3 Human rights for

consumers and end users

ESRS S4

-1

Non

-respect of UNGPs on

Business and Human Rights

and OECD guidelines

paragraph 17

Indicator number 10 Table

#1 of Annex 1

Delegated Regulation

(EU) 2020/1816, Annex II

Delegated Regulation

(EU) 2020/1818, Art 12 (1)

Material

3.1.3 Human rights for

consumers and end users

ESRS S4

-4

Human rights issues and

incidents paragraph 35

Indicator number 14 Table

#3 of Annex 1

Material

3.1.5 Human rights

incidents

213

Orange Belgium

_

Annual report 2025

ESRS G1

-1

United Nations Convention

against Corruption paragraph

10 (b)

Indicator number 15 Table

#3 of Annex 1

Not material

-

ESRS G1

-1

Protection of whistleblowers

paragraph 10 (d)

Indicator number 6 Table #3

of Annex 1

Not material

-

ESRS G1

-4

Fines for violation of anti

-

corruption and anti

-

bribery laws

paragraph 24 (a)

Indicator number 17 Table

#3 of Annex 1

Delegated Regulation

(EU) 2020/1816, Annex II)

Material

4.1.1.2 Incidents of

corruption or bribery (G1-4)

ESRS G1

-4

Standards of anti

- corruption

and anti

- bribery paragraph 24

(b)

Indicator number 16 Table

#3 of Annex 1

Material

4.1.1.2 Incidents of

corruption or bribery (G1-4)

214

5.3

Limited assurance report of the statutory auditor on

the consolidated sustainability statement of Orange

Belgium

Orange Belgium SA/NV

The original text of this report is in Dutch/French

214

Orange Belgium

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Annual report 2025

215

Limited assurance report of the statutory auditor on the consolidated

sustainability statement of Orange Belgium SA/NV

To the general shareholders’ meeting

In the framework of our legal limited assurance engagement on the consolidated sustainability statement of

Orange Belgium SA/NV (“the company”) and its subsidiaries (“the group”), we hereby submit our report on this

mission.

We have been appointed by the by the general meeting dated 7 May 2025, in accordance with the proposal of

the board of directors issued upon recommendation of the audit committee and as proposed by the works

council of the company, to perform a limited assurance engagement on the consolidated sustainability statement

of the group, included in the

management report on 31 December 2025 and for the financial year then ended

(the “consolidated sustainability statement”).

Our mandate will expire on the date of the general meeting deliberating on the financial statements for the

financial year ended 31 December 2025. We have performed our limited assurance engagement on the

consolidated sustainability statement of the group during two consecutive years.

L

i

m

i

t

e

d

a

s

u

r

a

n

c

e

c

o

n

c

l

u

s

i

o

n

We have performed a limited assurance engagement on the sustainability statement of the

group

.

Based on the procedures we have performed and the evidence we have obtained, nothing has come to our

attention that causes us to believe that the sustainability statement, in all material respects:

•

has not been prepared in accordance with the requirements stipulated in article 3:32/2 of the Code of

Companies and Associations, in accordance with the applicable

European Sustainability Reporting

Standards (ESRS);

•

has not been prepared in accordance with the process carried out by the group to identify the

information reported in the consolidated sustainability statement (the “process”) as set out in the note

“Description of the process to identify and assess material impacts, risks and opportunities (IRO-1)“;

•

does not comply with the requirements of Article 8 of EU Regulation 2020/852 (the “Taxonomy

Regulation”) regarding the disclosures in section “The EU Taxonomy” within the environmental section of

the sustainability statement.

B

a

s

i

s

f

o

r

c

o

n

c

l

u

s

i

o

n

We conducted our limited assurance engagement in accordance with International Standard on Assurance

Engagements (ISAE) 3000 (Revised), Assurance engagements other than audits or reviews of historical financial

information (“ISAE 3000 (Revised)”),

as applicable in Belgium.

Our responsibilities under this standard are described in more detail in the section of our report "Responsibilities

of the statutory auditor relating to the limited assurance engagement on the sustainability statement”.

We have complied with all ethical requirements relevant to limited assurance engagements on the consolidated

sustainability statement in Belgium, including those regarding independence.We apply the International Standard

on Quality Management 1 (ISQM 1), which requires us to design, implement and operate a system of quality

management including policies or procedures regarding compliance with ethical requirements, professional

standards and applicable legal and regulatory requirements.

We have obtained from the board of directors and the company’s officials all explanations and information

required for our limited assurance engagement.

We believe that the evidence we have obtained in the framework of our limited assurance engagement is

sufficient and appropriate to provide a basis for our conclusion.

215

Orange Belgium

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Annual report 2025

216

O

t

h

e

r

m

a

t

e

r

s

Our limited assurance engagement does not extend to information related to the figures prior to 1 January 2024

included in the consolidated sustainability statement.

R

e

s

p

o

n

s

i

b

i

l

i

t

i

e

s

o

f

t

h

e

b

o

a

r

d

o

f

d

i

r

e

c

t

o

r

s

r

e

l

a

t

i

n

g

t

o

t

h

e

p

r

e

p

a

r

a

t

i

o

n

o

f

t

h

e

c

o

n

s

o

l

i

d

a

t

e

d

s

u

s

t

a

i

n

a

b

i

l

i

t

y

s

t

a

t

e

m

e

n

t

The board of directors of the group is responsible for designing and implementing a process and for disclosing

this process in the note “Description of the process to identify and assess material impacts, risks and

opportunities (IRO-1)“ of the consolidated sustainability statement. This responsibility includes:

•

understanding the context in which the group’s activities and business relationships take place and

developing an understanding of its affected stakeholders;

•

the identification of the actual and potential impacts (both negative and positive) related to sustainability

matters, as well as risks and opportunities that affect, or could reasonably be expected to affect, the

group’s financial position, financial performance, cash flows, access to finance or cost of capital over the

short-, medium-, or long-term;

•

the assessment of the materiality of the identified impacts, risks and opportunities related to

sustainability matters by selecting and applying appropriate thresholds; and

•

making assumptions and estimates that are reasonable in the circumstances.

The board of directors of the group is also responsible for the preparation of the consolidated sustainability

statement, which includes the information established by the process,

•

in accordance with the requirements set out in article

3:32/2 of the Code of Companies and Associations,

including the applicable European Sustainability Reporting Standards (ESRS);

•

in compliance with the requirements of Article 8 of the Taxonomy Regulation regarding the disclosure of

the information included in section “The EU Taxonomy” within the environmental section of the

sustainability statement.

This responsibility comprises:

•

designing, implementing and maintaining such internal control that the board of directors deems

necessary for the preparation of the sustainability statement that is free from material misstatement,

whether due to fraud or error; and

•

the selection and application of appropriate sustainability reporting methods and making assumptions

and estimates that are reasonable in the circumstances.

The audit committee and board of directors are responsible for overseeing the group’s sustainability reporting

process.

216

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Annual report 2025

217

I

n

h

e

r

e

n

t

l

i

m

i

t

a

t

i

o

n

s

i

n

p

r

e

p

a

r

i

n

g

t

h

e

s

u

s

t

a

i

n

a

b

i

l

i

t

y

s

t

a

t

e

m

e

n

t

In reporting forward-looking information in accordance with ESRS, the board of directors of the group is required

to prepare the forward-looking information on the basis of disclosed assumptions about events that may occur in

the future and possible future actions by the group. Actual outcomes are likely to be different since anticipated

events frequently do not occur as expected and deviations may be of material importance.

R

e

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p

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s

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b

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s

o

f

t

h

e

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t

a

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y

a

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d

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e

l

a

t

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g

t

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t

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e

l

i

m

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d

a

s

u

r

a

n

c

e

n

g

a

g

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n

t

o

n

t

h

e

c

o

n

s

o

l

i

d

a

t

e

d

s

u

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t

a

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n

a

b

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l

i

t

y

s

t

a

t

e

m

e

n

t

Our responsibility is to plan and perform the assurance engagement to obtain limited assurance about whether

the consolidated sustainability statement is free from material misstatement, whether due to fraud or error, and

to issue a limited assurance report that includes our conclusion. Misstatements can arise from fraud or error and

are considered material if, individually or in the aggregate, they could reasonably be expected to influence

decisions of users taken based on the consolidated sustainability statement.

As part of a limited assurance engagement in accordance with ISAE 3000 (Revised), as applicable in Belgium, we

apply professional judgement and maintain professional scepticism throughout the engagement. The work

performed in an engagement aiming to obtain a limited level of assurance, for which we refer to the section

“Summary of the work performed” is less in scope than in an engagement aiming to obtain a reasonable level of

assurance. Therefore, we do not express an opinion with a reasonable level of assurance as part of this

engagement.

Since the forward-looking information in the consolidated sustainability statement and the assumptions on which

it is based, relate to the future, they may be affected by events that may occur in the future and/or by potential

actions of the group. The actual outcomes are likely to be different from the assumptions made, as the

anticipated events often do not occur as expected, and the deviation from them could be material. Therefore, our

conclusion does not provide any assurance that the reported actual outcomes will correspond with those

included in the forward-looking information in the consolidated sustainability statement.

Our responsibilities in respect of the consolidated sustainability statement, in relation to the process, include:

•

obtaining an understanding of the process, but not for the purpose of providing a conclusion on the

effectiveness of the process, including the outcome of the process; and

•

designing and performing procedures to evaluate whether the process is consistent with the group’s

description of its process, as disclosed in the note “Description of the process to identify and assess

material impacts, risks and opportunities (IRO-1)”.

217

Orange Belgium

_

Annual report 2025

218

Our other responsibilities in respect of the consolidated sustainability statement include:

•

acquiring an understanding of the group’s control environment, the relevant processes, and information

systems for preparing the consolidated sustainability statement, but without assessing the design of

specific control activities, obtaining supporting information about their implementation, or testing the

effective operation of the established internal control measures;

•

identifying where material misstatements are likely to arise in the consolidated sustainability statement,

whether due to fraud or error; and

•

designing and performing procedures responsive to where material misstatements are likely to arise in

the consolidated sustainability statement. The risk of not detecting a material misstatement resulting

from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional

omissions, misrepresentations, or the override of internal control.

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A limited assurance engagement involves performing procedures to obtain evidence about the consolidated

sustainability statement. The procedures in a limited assurance engagement vary in nature and timing and are

less in extent than procedures performed for a reasonable assurance engagement. Consequently, the level of

assurance obtained in a limited assurance engagement is substantially lower than the assurance that would have

been obtained had a reasonable assurance engagement been performed.

The nature, timing and extent of the procedures selected depend on professional judgement, including the

identification of areas where material misstatements are likely to arise in the consolidated sustainability

statement, whether due to fraud or error.

In conducting our limited assurance engagement, with respect to the process, we:

•

obtained an understanding of the process by:

-

performing inquiries to understand the sources of the information used by management (e.g.,

stakeholder engagement, business plans and strategy documents); and

-

reviewing the company / group’s internal documentation of its process; and

•

evaluated whether the assurance evidence obtained from our procedures with respect to the process

implemented by the group was consistent with the description of the process set out in the note

“Description of the process to identify and assess material impacts, risks and opportunities (IRO-1)”.

218

Orange Belgium

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Annual report 2025

219

Deloitte Bedrijfsrevisoren/Réviseurs d’Entreprises BV/SRL

Registered Office: Gateway building, Luchthaven Brussel Nationaal 1 J, B-1930 Zaventem

VAT BE 0429.053.863 - RPR Brussel/RPM Bruxelles - IBAN BE90 4350 2974 5132 - BIC KREDBEBB

Member of Deloitte Touche Tohmatsu Limited

In conducting our limited assurance engagement, with respect to the consolidated sustainability statement, we

have:

•

obtained an understanding of the group’s reporting processes relevant to the preparation of its

consolidated sustainability statement by obtaining an understanding of the company’s / group’s control

environment, processes and information system relevant to the preparation of the consolidated

sustainability statement but not with the purpose of providing a conclusion on the effectiveness of the

group’s internal control;

•

evaluated whether the information identified by the process is included in the consolidated sustainability

statement;

•

evaluated whether the structure and the presentation of the consolidated sustainability statement has

been prepared in accordance with the ESRS;

•

performed inquires with relevant personnel and analytical procedures on selected information in the

consolidated sustainability statement;

•

performed substantive assurance procedures on selected information in the consolidated sustainability

statement;

•

compared disclosures in the sustainability statement with the corresponding disclosures in the financial

statements and the annual report/management report;

•

obtained evidence on the methods and assumptions for developing estimates and forward-looking

information as described in the section “Responsibilities of the statutory auditor related to the limited

assurance engagement on the consolidated sustainability statement”;

•

obtained an understanding of the group’s process to identify taxonomy-eligible and taxonomy-aligned

economic activities and the corresponding disclosures in the consolidated sustainability statement;

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Our audit firm and our network have not performed any engagements which are incompatible with the limited

assurance engagement, and our audit firm has remained independent of the group throughout the course of our

mandate.

Signed at Zaventem.

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Represented by Nico Houthaeve

219

Orange Belgium

_

Annual report 2025

Consolidated

Financial Statements

2025

220

Orange Belgium

_

Annual report 2025

221

Consolidated

financial statements

2025

CONSOLIDATED FINANCIAL STATEMENTS 2025

221

CONSOLIDATED FINANCIAL STATEMENTS

222

1.1

Consolidated statement of profit or loss and other comprehensive income

222

1.2

Consolidated statement of financial position

223

1.3

Consolidated cash flow statement

224

1.4

Consolidated statement of changes in equity

225

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS

226

Note 1: Segment Information

226

Note 2: Description of business and basis of preparation of the consolidated financial statements

229

Note 3: Sales, trade receivables, other current and non-current assets

237

Note 4: Expenses, payables, prepaid and inventory

239

Note 5: Goodwill

244

Note 6: Other intangible assets and property, plant and equipment

246

Note 7: Taxes and levies

249

Note 8: Interests in associates

252

Note 9: Financial assets, liabilities and financial result

252

Note 10: Shareholders’ equity

259

Note 11: Commitments and contingencies

259

Note 12: (Non)-current provisions

260

Note 13: Related parties

260

Note 14: Liabilities related to contracts with customers and other assets related to contracts with customers

261

Note 15: Lease agreements

264

Note 16: Significant changes to the consolidation scope

265

Note 17: Significant accounting policies

265

Note 18: Subsequent events

278

Note 19: Glossary

279

ORANGE BELGIUM S.A. ANNUAL ACCOUNTS 2025

281

222

In this document, unless otherwise indicated, the terms “the company” and “Orange” refer to Orange Belgium SA together with its

consolidated subsidiaries.

Consolidated financial statements

Consolidated statement of profit or loss and other comprehensive income

in thousand EUR

Ref

.

31.12.2025

31.12.2024

3

Retail service revenues

1 577 456

1 600 774

3

Convergent service revenues

634 293

611 113

3

Mobile only services revenues

562 501

602 857

3

Fixed only service revenues

330 564

335 953

3

IT & Integration Service

50 098

50 851

3

Equipment sales

214 447

197 641

3

Wholesale revenues

158 730

164 449

3

Other revenues

12 720

30 879

3

Revenues

1 963 353

1 993 743

4

Purchase of material

-226 503

-233 975

4

Other direct costs

-403 420

-414 825

4

Impairment loss on trade and other receivables, including contract assets

-5 649

-11 571

4

Direct costs

-635 572

-660 371

4

Labour costs

-257 680

-251 503

4

Commercial expenses

-53 540

-57 218

4

Other IT & Network expenses

-196 445

-201 034

4

Property expenses

-25 785

-24 201

4

General expenses

-139 141

-147 913

4

Other indirect income

37 816

35 742

4

Other indirect costs

-64 950

-75 896

4/1

5

Depreciation of right-of-use of leased assets

-56 574

-61 239

4

Indirect costs, net of other indirect income

-498 618

-531 759

of which operational taxes and fees

-13 879

-32 845

4

Other restructuring costs (*)

-18 759

-19 421

6

Depreciation and amortization of other intangible assets and property, plant and

equipment

-418 428

-411 498

6

Impairment of fixed assets

1 918

-783

8

Share of profits (losses) of associates

128

438

Operating Profit (EBIT)

136 342

118 846

9

Financial result

-96 984

-114 561

9

Financial costs

-96 986

-114 563

9

Financial income

2

Profit (loss) before taxation (PBT)

39 358

4 285

7

Tax income / (expense)

1 950

12 867

Net profit (loss) for the period

41 308

17 152

Profit (loss) attributable to owners of the parent

41 308

22 149

Profit (loss) attributable to non-controlling interests

0

-4 997

Consolidated Statement of Comprehensive Income

Net profit (loss) for the period

41 308

17 152

Other comprehensive income (cash flow hedging net of tax)

8 693

-4 599

Total comprehensive income for the period

50 001

12 553

Comprehensive income for the period attributable to owners of the parent

company

50 001

16 544

Comprehensive income for the period attributable to non-controlling interests

0

-3 992

Basic earnings per share (in EUR)

0.61

0.34

Weighted average number of ordinary shares

67 412 205

64 923 056

Diluted earnings per share (in EUR)

0.61

0.34

Diluted weighted average number of ordinary shares

67 412 205

64 923 056

223

Consolidated statement of financial position

in thousand EUR

Ref.

31.12.2025

31.12.2024

ASSETS

5

Goodwill

751 179

6

Other intangible assets

813 332

861 887

6

Property, plant and equipment

1 812 353

1 803 870

15

Rights-of-use of leased assets

182 669

172 391

8

Interests in associates and joint ventures

7 157

7 029

9

Non-current financial assets

1 970

1 678

3

Other non-current assets

6 059

2 383

7

Deferred tax assets

7 352

7 547

Total non-current assets

3 582 070

3 607 963

4

Inventories

38 313

34 762

3

Trade receivables

245 012

220 771

14

Other assets related to contracts with customers

127 463

117 894

Current financial assets

1 998

2 125

9

Current derivatives assets

463

203

3

Other current assets

11 318

5 713

Operating taxes and levies receivables

22

605

7

Current tax assets

4 985

9 210

4

Prepaid expenses

11 216

18 802

9

Cash and cash equivalents

80 628

58 245

Total current assets

521 417

468 329

Total Assets

4 103 485

4 076 290

EQUITY AND LIABILITIES

10

Share capital

148 149

Additional paid-in capital

136 768

Legal reserve

14 815

Retained earnings (excl. legal reserve)

708 800

659 522

Equity attributable to the owners of the parent

1 008 532

959 254

Total equity

1 008 532

959 254

9

Non-current financial liabilities

1 690 730

1 887 001

15

Non-current lease liabilities

162 717

150 351

9

Non-current derivatives liabilities

11 089

16 861

6

Non-current fixed assets payable

131 008

138 742

Non-current employee benefits

1 889

3 171

6/12

Non-current provisions for dismantling

55 149

54 209

Other non-current liabilities

33 451

38 903

7

Deferred tax liabilities

51 519

55 121

Total non-current liabilities

2 137 552

2 344 359

6

Current fixed assets payable

67 155

59 473

4/9

Trade payables

335 679

286 070

9

Current financial liabilities

205 027

76 109

15

Current lease liabilities

29 512

29 723

9

Current derivatives liabilities

463

203

4

Current employee benefits

65 447

63 228

6

Current provisions for dismantling

4 116

5 565

4

Current restructuring provisions

7 921

5 872

4

Other current liabilities

8 557

10 970

7

Operating taxes and levies payables

146 213

151 200

7

Current tax payables

15 996

17 859

14

Liabilities related to contracts with customers

70 502

65 620

Deferred income

817

787

Total current liabilities

957 402

772 678

Total Equity and Liabilities

4 103 485

4 076 290

224

Consolidated cash flow statement

in thousand EUR

Ref.

31.12.2025

31.12.2024

Operating Activities

Consolidated net profit

41 308

17 152

Adjustments to reconcile net profit (loss) to cash generated from operations

4

Operating taxes and levies

13 879

32 845

6

Depreciation and amortization of other intangible assets and property, plant and equipment

418 428

411 498

4/15

Depreciation of right-of-use assets

58 321

61 239

6

Impairment of non-current assets

-1 918

783

Gains (losses) on disposal

-2 251

-1 053

Changes in other provisions

-5 272

490

8

Share of profits (losses) of associates and joint ventures

-128

-438

7

Income tax expense

-1 950

-12 867

9

Finance costs, net

96 984

114 561

Operational net foreign exchange and derivatives

-374

747

Share-based compensation

222

198

3

Impairment loss on trade and other receivables, including contract assets

5 649

11 571

Changes in working capital requirements

4

Decrease (increase) in inventories, gross

-1 471

4 110

Decrease (increase) in trade receivables, gross

-29 141

-15 140

4

Increase (decrease) in trade payables

47 960

1 731

14

Change in other assets related to contracts with customers

-9 670

-17 451

14

Change in liabilities related to contracts with customers

4 882

-1 951

Changes in other assets and liabilities

-765

19 772

Other net cash out

Operating taxes and levies paid

-18 284

-14 805

Interest paid and interest rates effects on derivatives, net

-89 251

-106 016

7

Income tax paid

-1 474

-4 189

Net cash provided by operating activities

525 684

502 787

Investing Activities

Purchases of property, plant and equipment and intangible assets

6

Purchases of property, plant and equipment and intangible assets

-376 362

-368 514

Prepayments on investment grants

507

-8 442

Increase (decrease) in fixed assets payables

-4 814

-27 537

Proceeds from sales of property, plant and equipment and intangible assets

474

526

5

Cash paid for investments securities and acquired businesses, net of cash acquired

0

-1

Proceeds from sale of investment securities and businesses, net of cash sold

0

-2

Decrease (increase) in securities and other financial assets

150

-2 147

Net cash used in investing activities

-380 045

-406 117

Financing Activities

Long-term debt issuances

6 000

0

9

Long-term debt redemptions and repayments

-88 128

-40 919

15

Repayment of lease liabilities

-54 697

-57 003

9

Increase (decrease) of bank overdrafts and short-term borrowings

13 570

11 777

10

Dividends paid to owners of the parent company

-1

3

Net cash from financing activities

-123 256

-86 142

Net change in cash and cash equivalents

22 383

10 528

9

Cash and cash equivalents -opening balance

58 245

47 717

o/w cash

58 226

47 680

o/w cash equivalents

19

37

Cash change in cash and cash equivalents

22 383

10 528

9

Cash and cash equivalents -closing balance

80 628

58 245

o/w cash

80 628

58 226

o/w cash equivalents

0

19

225

Consolidated statement of changes in equity

in thousand EUR

Ref.

Share

capital

additional

paid-in

capital

Legal

reserve

Retained

earnings

Total

equity

Balance at 31 December 2024

148 149

136 768

14 815

659 522

959 254

Net profit for the period

41 308

Other comprehensive income

8 693

Total comprehensive income for the period

50 001

Other

-945

Employee -Share-based compensation

222

Balance as at 31 December 2025

148 149

136 768

14 815

708 800

1 008 532

in thousand EUR

Ref.

Share

capital

additional

paid-in

capital

Legal

reserve

Retained

earnings

Total

equity

Balance at 31 December 2023

131 721

13 172

519 583

664 476

Net profit for the period

17 152

Other comprehensive income

-4 599

Total comprehensive income for the period

12 553

Other

1 643

-1 412

231

Employee -Share-based compensation

198

10

Put Option exercise Nethys S.A.

16 428

136 768

128 600

281 796

Balance as at 31 December 2024

148 149

136 768

14 815

659 522

959 254

226

Notes to the consolidated financial statements

Note 1: Segment Information

Consolidated statement of comprehensive income for the year ended 31 December 2025


				in thousand EUR
				Orange
31.12.2025	Belgium	Luxembourg	Interco	Belgium
			elimination	Group
Retail service revenues	1 525 290	52 166		1 577 456
Convergent service revenues	634 293			634 293
Mobile only service revenues	521 175	41 326		562 501
Fixed only service revenues	319 817	10 747		330 564
IT & Integration service revenues	50 005	93		50 098
Equipment sales	200 904	13 543		214 447
Wholesale revenues	149 914	12 737	-3 921	158 730
Other revenues	25 154		-12 434	12 720
Total revenues	1 901 262	78 446	-16 355	1 963 353
Direct costs	-619 078	-32 840	16 346	-635 572
Labour costs	-248 094	-9 586		-257 680
Indirect costs, of which	-479 172	-19 455		-498 618
Operational taxes and fees	-12 209	-1 670		-13 879
Depreciation of right-of-use of leased assets	-53 625	-4 696		-58 321
Restructuring, integration & acquisition costs	-18 751			-18 759
Depreciation, amortization of other intangible assets and property, plant and equipment	-406 537	-11 891		-418 428
Impairment of goodwill
Impairment of fixed assets	2 499	-581		1 918
Share of profits (losses) of associates	128			128
Operating Profit (EBIT)	132 257	4 085		136 342
Net financial income (expense)	-96 684	-300		-96 984
Profit (loss) before taxation (PBT)	35 573	3 785		39 358
Tax income / (expense)	2 653	-703		1 950
Net profit (loss) of the period	38 226	3 082		41 308

Reconciliation from EBITDAaL to net profit (loss) for the period for the year

ended 31 December 2025


				in thousand EUR
			Interco	Orange
31.12.2025	Belgium	Luxembourg	elimination	Belgium Group
EBITDAaL	549 496	16 565		566 061
Share of profits (losses) of associates	128			128
Impairment of goodwill
Impairment of fixed assets	2 499			1 918
Depreciation, amortization of other intangible assets and property, plant and equipment	-406 537	-11 891		-418 428
Restructuring, integration & acquisition costs	-18 751			-18 759
Finance lease costs	5 423			5 423
Operating profit (EBIT)	132 257	4 085		136 342
Financial result	-96 684	-300		-96 984
Profit (loss) before taxation (PBT)	35 573	3 785		39 358
Tax income / (expense)	2 653	-703		1 950
Net profit (loss) for the period	38 226	3 082		41 308

227

Consolidated statement of comprehensive income for the year ended 31 December 2024

				in thousand EUR
				Orange
31.12.2024	Belgium	Luxembourg	Interco	Belgium
			elimination	Group
Retail service revenues	1 551 263	49 511		1 600 774
Convergent service revenues	611 113			611 113
Mobile only service revenues	562 574	40 283		602 857
Fixed only service revenues	326 824	9 129		335 953
IT & Integration service revenues	50 752	99		50 851
Equipment sales	183 306	14 335		197 641
Wholesale revenues	155 058	13 270	-3 879	164 449
Other revenues	43 936		-13 057	30 879
Total revenues	1 933 563	77 116	-16 936	1 993 743
Direct costs	-643 370	-33 937	16 936	-660 371
Labour costs	-242 557	-8 946		-251 503
Indirect costs, of which	-513 056	-18 703		-531 759
Operational taxes and fees	-31 006	-1 839		-32 845
Depreciation of right-of-use of leased assets	-57 511	-3 728		-61 239
Restructuring, integration & acquisition costs	-19 421			-19 421
Depreciation, amortization of other intangible assets and property, plant and equipment	-400 122	-11 376		-411 498
Impairment of goodwill				0
Impairment of fixed assets	-783			-783
Share of profits (losses) of associates	438			438
Operating Profit (EBIT)	114 692	4 154		118 846
Net financial income (expense)	-114 197	-364		-114 561
Profit (loss) before taxation (PBT)	495	3 790		4 285
Tax income / (expense)	12 512	355		12 867
Net profit (loss) for the period	13 007	4 145		17 152

Reconciliation from EBITDAaL to net profit (loss) for the period for the year ended 31

December 2024

				in thousand EUR
			Interco	Orange
31.12.2024	Belgium	Luxembourg	elimination	Belgium Group
EBITDAaL	528 778	15 530		544 308
Share of profits (losses) of associates	438			438
Impairment of goodwill
Impairment of fixed assets	-783			-783
Depreciation, amortization of other intangible assets and property, plant and equipment	-400 122	-11 376		-411 498
Restructuring, integration & acquisition costs	-19 421			-19 421
Finance lease costs	5 802			5 802
Operating profit (EBIT)	114 692	4 154		118 846
Financial result	-114 197	-364		-114 561
Profit (loss) before taxation (PBT)	495	3 790		4 285
Tax income / (expense)	12 512	355		12 867
Net profit (loss) for the period	13 007	4 145		17 152

228

Consolidated statement of financial position for the year ended 31 December 2025

				in thousand EUR
			Interco	Orange
31.12.2025	Belgium	Luxembourg	elimination	Belgium Group
Goodwill	700 315	50 864		751 179
Other intangible assets	783 993	29 339		813 332
Property, plant and equipment	1 798 862	13 491		1 812 353
Rights-of-use of leased assets	167 148	15 521		182 669
Interests in associates and joint ventures	7 157			7 157
Non-current assets included in the calculation of the net financial debt	1 970			1 970
Other	13 095	316		13 411
Total non-current assets	3 472 539	109 531		3 582 070
Inventories	37 203	1 110		38 313
Trade receivables	222 357	21 397	1 258	245 012
Prepaid expenses	10 500	716		11 216
Current assets included in the calculation of the net financial debt	66 571	14 520		81 091
Other	145 352	1 561	-1 127	145 786
Total current assets	481 982	39 304	131	521 417
Total assets	3 954 520	148 835	131	4 103 485
Total equity			1 008 532	1 008 532
Non-current employee benefits	1 889			1 889
Non-current fixed assets payable	122 326	8 682		131 008
Non-current financial liabilities included in the calculation of the net financial debt	1 853 708	10 828		1 864 536
Other	134 887	5 232		140 119
Total non-current liabilities	2 112 810	24 742		2 137 552
Current fixed assets payable	62 492	4 663		67 155
Trade payables	317 767	16 654	1 258	335 679
Current employee benefits	63 677	1 770		65 447
Deferred income	817			817
Current liabilities included in the calculation of the net financial debt	230 313	4 692	-3	235 002
Others	249 397	5 030	-1 124	253 303
Total current liabilities	924 462	32 809	131	957 402
Total equities and liabilities	3 037 272	57 551	1 008 663	4 103 485

229

Consolidated statement of financial position for the year ended 31 December 2024


				in thousand EUR
				Orange
31.12.2024	Belgium	Luxembourg	Interco	Belgium
			elimination	Group
Goodwill	700 315	50 864		751 179
Other intangible assets	831 863	30 024		861 887
Property, plant and equipment	1 790 237	13 633		1 803 870
Rights-of-use of leased assets	168 478	3 913		172 391
Interests in associates and joint ventures	7 029			7 029
Non-current assets included in the calculation of the net financial debt	1 678			1 678
Other	9 051	879		9 930
Total non-current assets	3 508 650	99 313		3 607 963
Inventories	33 486	1 276		34 762
Trade receivables	198 921	23 395	-1 545	220 771
Prepaid expenses	17 994	808		18 802
Current assets included in the calculation of the net financial debt	45 858	12 590		58 448
Other	137 757	1 895	-4 106	135 546
Total current assets	434 016	39 964	-5 651	468 329
Total assets	3 942 665	139 277	-5 651	4 076 290
Total equity			959 254	959 254
Non-current employee benefits	3 171			3 171
Non-current fixed assets payable	129 803	8 939		138 742
Non-current financial liabilities included in the calculation of the net financial debt	2 050 966	3 247		2 054 213
Other	143 094	5 139		148 233
Total non-current liabilities	2 327 034	17 325		2 344 359
Current fixed assets payable	54 962	4 511		59 473
Trade payables	267 769	19 846	-1 545	286 070
Current employee benefits	62 200	1 028		63 228
Deferred income	787			787
Current liabilities included in the calculation of the net financial debt	105 386	3 635	-2 986	106 035
Others	253 476	4 730	-1 120	257 086
Total current liabilities	744 579	33 750	-5 651	772 678
Total equities and liabilities	3 071 613	51 075	953 603	4 076 290

Note 2: Description of business and basis of preparation of the consolidated

financial statements

Description of business

Orange Belgium S.A

. is a public limited company (the company’s ultimate majority shareholder is Orange S.A.) and one of the main

actors on the telecommunications market in Belgium and Luxembourg. Orange Belgium is listed on the Brussels Stock Exchange

(OBEL). As a convergent actor, the company provides mobile telecommunication, internet and TV services to residential clients, as

well as innovative mobile and fixed line services to businesses and large corporates. Orange Belgium also acts as a wholesale operator,

providing its partners with access to its infrastructure and service capacities. Orange Belgium’s high-performance mobile network

supports 2G, 3G, 4G, 4G+ and 5G technology and is the subject of on-going investments.

Orange Communications Luxembourg S.A.

, incorporated under the laws of Luxembourg, was acquired as of 2 July 2007 by Orange

Belgium S.A. The purchase concerned 90% of the shares of Orange Communications Luxembourg S.A. The remaining 10% of shares

were acquired on 12 November 2008. The results of Orange Communications Luxembourg S.A. are fully consolidated by the company

since 2 July 2007.

Smart Services Network S.A

. (SSN) is a Belgian company that distributes telecommunication and energy services including those of

Orange Belgium and Luminus. SSN’s route to market is based on the principle of multi-level marketing. SSN’s network consists of

more than 1,000 independent consultants.

Smart Services Network S.A., incorporated under the laws of Belgium, was created as of 30 September 2014. Orange Belgium S.A.

contributed in cash for 999,900 euros equivalent to 9,999 shares out of the 10,000 shares issued by the company. Atlas Services

Belgium S.A. contributed in cash for 100 euros equivalent to 1 share. This one share has been sold by Atlas Services Belgium S.A. to

Orange Belgium S.A. during the accounting year 2020.

In 2016, Orange Belgium S.A. contributed in cash to the capital increase of Smart Services Network S.A. for 700,000 euros, equivalent

to 7,000 shares.

230

On 25 March 2022, the carried forwarded losses have been integrated in the capital of the company for an amount of 1,041,610.41

euros and a capital increase of 341,610.41 euros has been funded. After these transactions, the capital of the company amounts to

1,000,000.00 euros.

IRISnet S.C.R.L

. is a company constituted in July 2012 in collaboration with the Brussels authorities in order to take over the activities

performed by the temporary association Irisnet and is responsible for the operation of the Irisnet 2 optical fiber network and for the

provision of fixed telephony, data transmission services (internet, e-mail) and other network-related services (video-conferencing,

video surveillance, etc.).

The take-over of the activities took place on 1 November 2012. In this new legal structure, Orange Belgium S.A. contributed in cash

for 3,450,000 euros equivalent to 345,000 shares out of the 1,225,000 shares issued by the company.

Walcom Business Solutions S.A.

, incorporated under the laws of Belgium, was created as of 13 July 2017. Walcom Business

Solutions S.A. specializes in the sales of telecommunication products and services for the professional market. Orange Belgium S.A.

contributed in cash for 60,885 euros equivalent to 99 shares of the 100 shares issued by Walcom Business Solutions S.A.

Walcom S.A. contributed in cash for 615 euros equivalent to 1 share. The results of Walcom Business Solutions S.A. are fully

consolidated by the company since 13 July 2017. As a result of the dissolution and liquidation of Walcom S.A. during the accounting

year 2020 all shares are held now by Orange Belgium S.A.

A&S Partners S.A.,

also an existing Orange Belgium agent, provides telecommunications services to B2B customers within the

Brussels region via a dedicated sales team of 35 professionals under the name of AS Mobility. A&S Partners S.A., incorporated under

the laws of Belgium, was acquired as of 30 September 2017 by Orange Belgium S.A. The purchase concerned 100% of the 620 shares

of A&S Partners S.A. The results of A&S Partners S.A. are fully consolidated by the company since 1 October 2017.

MWingz S.R.L

. is a joint operation between Orange Belgium S.A. and Proximus S.A., each owning 50% of the company that will

manage the unilateral and shared mobile radio access network of both shareholders. In 2019 both companies decided to build a

shared mobile radio access network with the objective to meet customers’ increasing demand for mobile network quality and deeper

indoor coverage. The agreement will also allow a faster and more comprehensive 5G roll-out in Belgium. While sharing the common

part of their mobile radio access networks, both companies will continue to have full control over their own core network and spectrum

assets ensuring differentiated services. MWingz S.R.L. is incorporated under the laws of Belgium and was created on 6 December

2019. Orange Belgium S.A. contributed in cash for 1 euro equivalent to 1 share out of the 2 shares issued by the Company. Proximus

S.A. contributed in cash for 1 euro equivalent to 1 share. In April 2020, Orange Belgium participated in the capital increase of MWingz

S.R.L. for 1,599,999 million euros. Orange Belgium holds 50% of the shares of MWingz S.R.L. This company started operational

activities as from 1 April 2020.

On 29 June 2016, Orange Belgium S.A. subscribed in the capital of

Belgian Mobile ID S.A

. (for 6.28% or 1,745,853.92 euros), with

four banks and the two other mobile telecom operators of the country, to collaborate on the establishment of a mobile identification

system for both private and professional users. With this mobile solution, Belgian Mobile ID S.A. wants to make it easier for anyone

with a mobile phone and a bank account or an eID to digitally log in, confirm transactions and even sign documents. In April 2018,

Orange Belgium S.A. further contributed in cash to the capital increase of Belgian Mobile ID S.A. for 1,846,294.43 euros (or 6.28% of

the total shares).

In April 2019, Orange Belgium S.A. led the series B funding of

CommuniThings S.A

. through a €1.3m investment (for a stake of

10.45%). Orange Belgium S.A. invested directly into one of its Orange-Fab scale-ups, CommuniThings, and embarks on a commercial

partnership to market state-of-the-art smart parking solutions. Orange Belgium S.A., Finance.Brussels S.A. and Essex Innovation

invested in total €3 million. In line with Orange’s support of IoT solutions over its IoT networks, the investment will be combined with

a long-term partnership to commercialize CommuniThings’ smart parking solutions across Belgium. In addition, the investment will

serve CommuniThings’ global expansion efforts as it spearheads the roll-out of its platform over IoT networks. In 2020, Orange Belgium

participated in an additional capital increase of CommuniThings through a 0.35 million euros investment. In April 2021, Orange Belgium

participated again in the capital increase of CommuniThings through a 0.35 million euros investment.

Orange Belgium S.A. holds, directly or indirectly (e.g. through other subsidiaries), less than 20% of the voting power of Belgian Mobile

ID S.A. and CommuniThings S.A. and as such, it is presumed that Orange Belgium S.A. does not have significant influence. Moreover,

generating surplus value is not the main purpose of the investment in Belgian Mobile ID S.A. and CommuniThings S.A.

VOO S.A.

is a telecommunication operator organized and created under the laws of Belgium, with the following purposes:

development and maintenance of optical fiber network, provision of all services to customers, design-creation and production of any

audiovisual goods or services. On 2 June 2023, VOO Holding S.A. acquired VOO S.A and its 100% subsidiaries. On the 2025 october

1

st

, the dissolution of VOO S.A. signifies the company ceases to exist as a legal entity (with retroactive effect on the 1

st

July 2025. Its

assets and liabilities related to fixed network activities are transferred to the public limited company Orange NetCo, a direct subsidiary

wholly owned by Orange Belgium. All other activities, such as customer services and commercial operations, are transferred to Orange

Belgium S.A.

Orange NetCo S.A. now owns and manages the fixed access networks (due to the demerger of VOO SA). This move aligns with

Orange Belgium’s long-term vision to build a modern, efficient, and future-proof network infrastructure, supporting Belgium’s digital

ambitions and the European Union’s Digital Decade 2030 objectives.

Orange NetCo was created on 2025 April 17 with capital of

231

61.500,00 € fully paid up by Orange Belgium (100% - 123.000 shares).

Following the demerger of VOO and the contribution to Orange

NetCo via a capital increase of 621.364.532,39 € represented by 1.328.244.383 new shares. Orange NetCo is a owned subsidiary of

Orange Belgium.

WBCC S.A.

is VOO’s subsidiary, organized and created under the laws of Belgium. Main purposes: providing customers several

telephone services, as assistance or help; providing also marketing and telemarketing services. The company was acquired by the

Orange Group on 2 June 2023 through the VOO acquisition.

BeTV S.A.

is VOO’s subsidiary organized and created under the laws of Belgium, with the following purposes: television broadcast

service intended for the public, by ensuring the programming, production, promotion, exploitation of these broadcasts. The

exploitation concerns both the direct or indirect exploitation of the right to access the service, the marketing, publication or other, of

the broadcast time, the exploitation of all derived rights or even any production or publishing operation. The company was acquired

by the Orange Belgium Group on 2 June 2023 through the VOO acquisition.

Scope of consolidation

The parent company and the subsidiaries listed below are included in the scope of consolidation as at 31.12.2025. Except when

indicated below, there have been no changes in ownership percentage since 31.12.2024

FULL CONSOLIDATION

Orange Belgium S.A.

Parent company, incorporated under Belgian law

Limited company with publicly traded shares Avenue du Bourget 3

B - 1140 Brussels

Belgium

Company identification number: BE 0456 810 810

Orange Communications Luxembourg S.A.

100% of the shares held by Orange Belgium S.A.

8, rue des Mérovingiens

L - 8070 Bertrange

Luxembourg

Company identification number: LU 19749504

Smart Services Network S.A.

100% of the shares held by Orange Belgium S.A.

Avenue du Bourget 3

B - 1140 Brussels

Belgium

Company identification number: BE 0563 470 723

Walcom Business Solutions S.A.

100% of the shares held by Orange Belgium S.A.

Avenue du Bourget 3

B - 1140 Brussels

Belgium

Company identification number: BE 0678 686 036

A&S Partners S.A.

100% of the shares held by Orange Belgium S.A.

Rue Américaine 61-65

1050 Ixelles

Belgium

Company identification number: BE 0885 920 794

VOO S.A. (till 30 June 2025)

100% of the shares held by Orange Belgium S.A.

Rue Louvrex 95

B – 4000 Liège

Belgium

Company identification number: BE 0696 668 549

232

Orange NetCo S.A. (as of 17 April 2025)

100% of the shares held by Orange Belgium S.A.

Avenue du Bourget 3

B - 1140 Brussels

Belgium

Company identification number: BE 1022 514 315

BeTV S.A.

100% of the shares held by Orange Belgium S.A.

Avenue du Bourget 3

B - 1140 Brussels

Belgium

Company identification number: BE 0435 115 967

WALLONIE BRUXELLES CONTACT CENTER

100% of the shares held by Orange Belgium S.A.

Rue Louvrex 95

B – 4000 Liège

Belgium

Company identification number: BE 0807 319 518

PROPORTIONAL CONSOLIDATION

MWINGZ S.R.L.

50% of the shares held by Orange Belgium S.A.

Simon Bolivarlaan 34

B - 1000 Brussel

Belgium

Company identification number: BE 0738 987 372

233

EQUITY METHOD

IRISnet S.C.R.L.

28.16% of the shares held by Orange Belgium S.A.

Accounted for by equity method

Avenue des Arts 21

B - 1000 Brussels

Belgium

Company identification number: BE 0847 220 467

There are no significant restrictions on the assets and liabilities of the subsidiaries included in the scope of consolidation.

Subsidiaries are fully or proportionally (Mwingz S.R.L.) consolidated from the date of acquisition, being the date on which the Group

obtains control, and continue to be consolidated until the date such control ceases.

Date of authorization for issue of the financial statements

On 18 March 2026, the Board of Directors of Orange Belgium S.A. reviewed the 2025 consolidated financial statements and authorized

them for issue.

Basis of preparation

The consolidated financial statements are presented in thousands of euros except when otherwise indicated. The Group's functional

and presentation currency is the Euro. Each entity within the Group applies this functional currency for its financial statements.

All amounts have been rounded to the nearest thousand, unless otherwise indicated.

Statement of compliance

The consolidated financial statements of Orange Belgium S.A. and all its subsidiaries have been prepared in accordance with the

International Financial Reporting Standards (IFRS), as adopted by the European Union, and with the legal and regulatory requirements

applicable in Belgium.

The principles applied to prepare financial data relating to the 2025 financial year are based on:

-

all the standards and interpretations endorsed by the European Union compulsory as of 1 January 2025;

-

the recognition and measurement alternatives allowed by the IFRS:


Standard		Alternative used
IAS 1	Accretion expense on operating liabilities (employee benefits,
	environmental liabilities)	Classification as financial expenses
IAS 2	Inventories	Measurement of inventories determined by the weighted average unit cost
		method
IAS 7	Interest paid and received dividends	Classification as net operating cash flows
IAS 16	Property, Plant and Equipment	Measurement at amortized historical cost
IAS 38	Intangible Assets	Measurement at amortized historical cost
IFRS 3	Non-controlling interests	At the acquisition date, measurement either at fair value or according to the
		portion of the identifiable net assets of the acquired entity

In the absence of any accounting standard or interpretation, management uses its judgment to define and apply an accounting policy

that will result in relevant and reliable information, such that the financial statements:

-

fairly present the Group’s financial position, financial performance and cash flows;

-

reflect the economic substance of transactions;

-

are neutral;

-

are prepared on a prudent basis; and

-

are complete in all material respects.

Changes to accounting policies are described below and in note 16 “Significant accounting policies”.

234

Changes in accounting policy and disclosures

The accounting policies and methods of computation adopted in the preparation of the consolidated financial statements have

remained unchanged compared to those followed in the preparation of the consolidated financial statements for the year ended 31

December 2024.

EBITDAaL and eCapex remained the key performance indicators.

These operating performance indicators are used by the Group:

-

to manage and assess its operating and segment results; and

-

to implement its investment and resource allocation strategy.

The Group’s management believes that the presentation of these indicators is relevant as it provides readers with the same

management indicators as those used internally.

EBITDAaL

corresponds to operating income before depreciation and amortization of fixed assets, effects resulting from business

combinations, reclassification of cumulative translation adjustment from liquidated entities, impairment of goodwill and fixed assets,

share of profits (losses) of associates and joint ventures, and after interests on debts related to financed assets and on lease liabilities,

adjusted for:

-

significant litigation;

-

specific labour expenses;

-

fixed assets, investments, and businesses portfolio review;

-

restructuring program costs;

-

acquisition and integration costs;

-

and, where appropriate, other specific elements.

The measurement indicator allows for the effects of certain specific factors to be isolated, irrespective of their recurrence and the

type of income and expense, when they are linked to:

-

significant litigation

:

Significant litigation expenses correspond to risk reassessments regarding various litigations. Associated procedures are based on

third-party decisions (regulatory authority, court, etc.) and occurring over a different period to the activities at the source of the

litigation. By their very nature, costs are difficult to predict in terms of their source, amount and period;

-

fixed assets

,

investments and businesses portfolio review

:

The Group constantly reviews its fixed assets, investments, and businesses portfolio: as part of this review, decisions to dispose of

or to sell assets are implemented, which by their very nature have an impact on the period during which they occur;

-

restructuring program costs

:

The adjustment of Group activities in line with changes in the business environment may also incur other types of transformation costs.

They include restructuring costs. These actions may have a negative effect on the period during which they are announced and

implemented. For illustrative purposes, and not limited to, this could include some of the transformation plans approved by the internal

governance bodies;

-

acquisition and integration costs

:

The Group also incurs costs which are directly linked to the acquisition and integration of entities. These are primarily legal and

advisory fees, registration fees and earn-outs;

-

where applicable, other specific elements that are systematically specified in relation to income and/or expenses

.

EBITDAaL is not a financial aggregate as defined by IFRS and is not comparable to similarly titled indicators used by other groups. It

is provided as additional information only and should not be considered as a substitute for operating income or cash flow provided

by operating activities.

eCapex

relate to acquisitions of property, plant and equipment and intangible assets excluding telecommunications licenses and

financed assets minus the price of disposal of fixed assets. They are used internally as an indicator to allocate resources. eCapex are

not a financial aggregate defined by IFRS and may not be comparable to similarly-titled indicators used by other companies.

The Group uses organic cash flow from telecom activities as an operating performance measure for telecom activities as a whole.

Organic cash flow from telecom activities corresponds to net cash provided by operating activities minus (i) lease liabilities repayments

235

and debts related to financed assets repayments, (ii) purchases and sales of property, plant and equipment and intangible assets net

of the change in fixed assets payables, (iii) excluding effect of telecommunications licenses paid and excluding effect of significant

litigations paid (and received). Organic cash-flow from telecom activities is not a financial aggregate defined by IFRS and may not be

comparable to similarly-titled indicators used by other companies.

New standards and interpretations applicable for the annual period beginning or after 1 January 2025

Only amendments to standards applicable to the Group and effective as of January 1,2025 are described below:

-

Amendments to IAS 21: Non-convertibility

The amendment to the standard specifies the situations in which a currency is convertible and clarifies how to determine the exchange

rate in the absence of convertibility. This amendment, which is effective from January 1, 2025, had no significant impact on the Group's

consolidated financial statements.

New and revised IFRS Accounting Standards in issue but not yet effective.

-

Amendments to IFRS 7 and IFRS 9:

This standard clarifies that financial assets and financial liabilities are recognized and derecognized at settlement date except for

regular way purchases or sales of financial assets and financial liabilities meeting conditions for new exception. The new exception

permits companies to elect to derecognize certain financial liabilities settled via electronic payment systems earlier than the settlement

date.

They also provide guidelines to assess contractual cash flow characteristics of financial assets, which apply to all contingent cash

flows, including those arising from environmental, social, and governance (ESG)-linked features. Additionally, these amendments

introduce new disclosure requirements and update others. The effective date of this amendment is 1 January 2026.

-

Amendments to IFRS 1, IFRS 7, IFRS9, IFRS 10 and IAS 7: Annual improvements to IFRS Accounting Standards Volume 11

(effective date 1 January 2026).

-

IFRS 18: Presentation and Disclosure in Financial Statements

Published in April 2024, IFRS 18 will replace IAS 1 and related interpretations. The objective of the standard is to enable investors to

obtain more detailed and comparable information on the presentation of financial performance, particularly with regard to:

−

improved comparability of the income statement through the addition of new categories of income and expense (operating,

investing, and financing) and subtotals that must be disclosed;

−

enhanced disclosures on performance indicators;

−

a critical review of the information disclosed in both the summary statements and the notes to the financial statements to

ensure that the information necessary for investors is provided.

IFRS 18 will be applicable retrospectively from January 1, 2027, with an option for early application from January 1, 2026, subject to

its adoption by the European Union. The Group has set up a working group to analyse the expected impacts on its consolidated

financial statements, while taking into account the necessary changes to the tools used to produce the consolidated financial

statements. The Group has not chosen to apply this standard early.

-

IFRS 19 - Subsidiaries without Public Accountability: Disclosures

The group did not early apply “IFRS 19 - Subsidiaries without Public Accountability: Disclosures” . The standard is not anticipated to

have any effect for Orange Belgium’s financial reporting as of its effective date.

Basis of preparation

In order to avoid differences in the information published by the Orange Belgium Group and its majority shareholder Orange S.A., the

Orange Belgium Group applies a reporting format and reporting standards that are similar to the ones used by Orange S.A.

Uses of estimates and judgements

The preparation of the Group's financial statements in compliance with IFRS requires management to make certain judgments,

estimates and assumptions that affect the amounts reported in the financial statements and accompanying notes.

236

Judgments in applying accounting policies

The following are the critical judgements, apart from those involving estimations (which are presented separately below), that the

directors have made in the process of applying the group’s accounting policies and that have the most significant effect on the

amounts recognised in financial statements.

Significant judgments with regard to the application of IFRS 15 – Revenue from contracts with customers

Significant judgment is required in the following areas:

a.

Determination of the transaction price – more specifically the handset price in bundled offers:

The issue of the handset sales price at Orange Belgium S.A. is only applicable for bundled offers (equipment + service). For all other

offers, the performance obligation is directly related to the specific sale price. Orange Belgium S.A. excluded the evaluation method

based on market prices (IFRS 15.77) for the determination of the sales price of equipment in subsidized offers and more specifically

the standalone selling price. The standalone selling price could indeed –according to IFRS 15- be considered as “the market price”.

However, for Orange Belgium S.A. the standalone selling prices are impossible to identify as

-

Extremely varying: at any given time, the same standalone equipment can be sold at different prices. The sales strategy of

our shops, the type of distribution channel, … are examples of circumstances that vary the sale price from one shop to

another at a certain time.

-

Volatility: Orange observes that the prices of certain handsets equipment do vary quickly, even within one month.

Therefore, Orange Belgium S.A. decided that the upfront method plus the smart data option multiplied by the enforceable duration of

the contract, which is 24 months, was the most relevant calculation for the price per equipment.

b.

Determination of the duration of the contract in order to allocate the transaction price to the different performance

obligations:

The definition of the duration of a contract is only relevant for the subsidized bundled offers, the only contracts for which a revenue

relocation between the performance obligations is necessary. The period of which both parties’ rights and obligations are enforceable

never exceeds the nominal period in the contract. This is because, excluding modifications in the contract, enforceability of rights and

obligations is a matter of law. Hence, the enforceable period cannot extend beyond the nominal period. On the other hand,

enforceability of rights and obligations shall take into consideration business practices according to which one of the parties dismisses

the other party of its obligation. For Orange, this is typically the case when the Group authorizes or encourages early renewals.

Early renewals are renewals before the end of the contract (contract duration mainly 24 months). Orange Belgium's strategy is no

longer to encourage or give the possibility to customers to renew their contract without penalty before the end of the contractual

period which is mainly 24 months. The enforceable deadline was set at 24 months. Consequently, if a customer terminates or renews

their contract before the 24 months, except for rare exceptions, they will receive an invoice for prematurely ending the contract.

c.

Identification of performance obligations:

A contract as per IFRS15 is made of rights and obligations between the parties. The rights take the form of promises for Orange

Belgium to transfer goods and/or services to a customer.

Distinct goods and services

There are two criteria to determine whether goods and/or services are distinct:

-

The customer can benefit from the goods or services on its own or together with resources that are readily available.

-

The entity’s promise to transfer the good or service is separately identifiable from other promises in the contract.

It is clear that the mobile equipment (handset) is distinct from the access service. Those two elements therefore qualify as distinct

performance obligations within the contract.

The access service, which is made of voice, data and sms also includes distinct performance obligations. However, given that those

promises are over the same period of time (right) and paid together (obligation), there is no need to consider that they are distinct.

Significant judgments with regard to the application of IFRS 16 – Leases

Significant judgement is required in the determination of non-cancellable lease term and the assessment of the exercise or not of

termination, extension and purchase options.

Critical estimates and assumptions

Estimates made at each reporting date reflect conditions that existed at those dates (e.g. market prices, interest rates and foreign

exchange rates). Although these estimates are based on management's best knowledge of current events and actions that Orange

Belgium may undertake, actual results may differ from those estimates.

237

Impairment of non-financial assets

The impairment test for the goodwill in relation to Belgium is based on a value in use calculation using a discounted cash flow model.

The cash flows are derived from the financial projections for the next five years and do not include restructuring activities that the

Group is not yet committed to or significant future investments that will enhance the asset base of the cash generating unit being

tested. The recoverable amount is most sensitive to the discount rate used for the discounted cash flow model as well as the EBITDAaL

used for extrapolation purposes.

The key assumptions used to determine the recoverable amount for the different cash generating units are further explained in Note

5.

Note 3: Sales, trade receivables, other current and non-current assets


		in thousand EUR
	31.12.2025	31.12.2024
Belgium	1 901 262	1 933 563
Retail service revenues	1 525 290	1 551 263
Convergent service revenues	634 293	611 113
Mobile only service revenues	521 175	562 574
Fixed only service revenues	319 817	326 824
IT & Integration service revenues	50 005	50 752
Equipment sales	200 904	183 306
Wholesale revenues	149 914	155 058
Other revenues	25 154	43 936
Luxembourg	78 446	77 116
Retail service revenues	52 166	49 511
Convergent service revenues
Mobile only service revenues	41 326	40 283
Fixed only service revenues	10 747	9 129
IT & Integration service revenues	93	99
Equipment sales	13 543	14 335
Wholesale revenues	12 737	13 270
Other revenues
Inter-segment eliminations	-16 355	-16 936
Total	1 963 353	1 993 743

Orange Belgium’s total turnover in Belgium amounted to 1,901.3 million euros in 2025, compared to 1,933.6 million euros in 2024, a

decrease of 1.6% year-on-year. Orange Belgium’s total turnover in Belgium amounted to 1,901.3 million euros in 2025, compared to

1,933.7 million euros in 2024, a decrease of 1.6% year-on-year.

The Belgian retail service revenues (i.e. mobile-only services, fixed-only services, convergent services and IT & Integration services)

decreased 1.6% year-on-year: from 1,551.3 million euros in 2024 to 1,525.3 million euros in 2025. This decrease has been partly

driven by the non-renewal of the Belgian football rights and a decrease in low margin activities. The wholesale revenues declined by

3.3% year-on-year, impacted by the regulatory effect on 'voice' and a decrease in SMS volume (-5.1 million euros)

Equipment sales increased 9.6% year-on-year and the decrease in other revenues by 42.7%.

Trade receivables


		in thousand EUR
	31.12.2025	31.12.2024
Trade receivables -Gross value	279 838	320 274
Allowance for doubtful debtors	-34 826	-99 503
Total trade receivables	245 012	220 771

238

Ageing Balance


		in thousand EUR
	31.12.2025	31.12.2024
Not past due	198 229	177 542
Less than 180 days	36 855	28 883
Between 180 days and 360 days	10 048	7 792
More than 360 days	-120	6 554
Total trade receivables	245 012	220 771


		in thousand EUR
	31.12.2025	31.12.2024
Net trade receivables, depreciated according to their age	46 783	43 229
Net trade receivables, depreciated according to other criteria	0	0
Net trade receivables past due	46 783	43 229
Net trade receivables not past due	198 229	177 542
Net trade receivables	245 012	220 771
o/w short-term trade receivables	245 012	220 771
o/w long-term trade receivables

Change in Provision for Trade receivables


		in thousand EUR
	31.12.2025	31.12.2024
Allowances on trade receivables -Opening balance	-99 503	-147 771
Net addition with impact on income statement	-5 649	-11 571
Losses on trade receivables	70 326	59 839
Change in scope of consolidation
Allowances on trade receivables -Closing balance	-34 826	-99 503

For terms and conditions relating to related parties’ receivables, refer to Note 12.

Trade receivables are non-interest bearing and are generally paid via direct debits (68% of service revenues are collected by direct

debit in Orange Belgium S.A. and Orange Luxembourg (62% in 2024)/ 55.2% for VOO customers (55.9% in 2024)). Trade receivables

which are not paid via direct debits bear mainly a payment term of 10 days after invoice receipt for consumers and 30 days for

companies.

The Group is not dependent on any major customers, none representing more than 10% of the company’s consolidated revenues.

The customer risk is spread over more than 3.8 million customers.

Total Trade receivables amounted to 245 million euros at the end of 2025, compared with 220.8 million euros at the end of 2024,

which represents an increase of 11%.

Allowance for doubtful debtors – closing balance at year end 2025 – decreased to 34.8 million euros from 99.5 million euros. This

decrease of 64.7 million is essentially driven by cleanup of older balances in VOO without negative impact on the profit & loss

statement.

Impairment of trade receivables is based on three methods:

-

A collective statistical method: this is based on historical losses and leads to a separate impairment rate for each aging

balance category. This analysis is performed over a homogenous group of receivables with similar credit characteristics

because they belong to a customer category (mass-market, small offices and home offices).

-

A stand-alone method: the assessment of impairment probability and its amount are based on a set of relevant qualitative

factors (ageing of late payment, other balances with the counterparty, rating from independent agencies, …). This method is

used for carriers and operators (national and international), local, regional and national authorities; and

-

A provisioning method based on anticipated loss: IFRS 9 requires recognition of expected losses on receivables immediately

upon recognition of the financial instruments. In addition to the pre-existing provisioning system, the Group applies a

simplified approach of anticipated impairment at the time the asset is recognized. The percentage applied depends on the

maximum revenue non-recoverability rate.

The costs related to bad debts decreased to a loss of 5.6 million euros in 2025 (compared to a loss of 11.6 million euros in 2024).

239

Since 2017, Orange Belgium S.A. entered a factoring program with Belfius Commercial Finance. The eligible trade receivables were

related to the top 400 B2B Airtime debtors (factored receivables around 1.3 million euros as of 31 December 2025 compared to 1.4

million per year-end 2024).

Other assets


		in thousand EUR
	31.12.2025	31.12.2024
Advances and downpayments	5 874	509
Security deposits paid	1 668	2 383
Prepaid post-empl benefit costs	4 391
Other	5 444	5 204
Total other assets	17 377	8 096
o/w other non-current assets	6 059	2 383
o/w other current assets	11 318	5 713

Other assets contain essentially receivables for recharged costs & other amounts receivable. The increase in the advance and

downpayments accounts (+5.4 million euros) is due to a change in presentation following the migration of companies (VOO SA and

subsidiaries) to the new ERP (Oracle).

Supplier advances were previously deducted from suppliers’ invoices.

In 2025, these amounts

are recognized in the separate account ‘Advances and downpayment’ – integrated in the current other assets.

Asset ceilings were also recognised for the first time under ‘Prepaid post-employment benefit costs’ for an amount of 4.4 million euros

- integrated in other non-current assets.

Note 4: Expenses, payables, prepaid and inventory

Direct costs


		in thousand EUR
	31.12.2025	31.12.2024
Purchase of material	-226 503	-233 975
Other direct costs	-403 420	-414 825
Impairment loss on trade and other receivables, including contract assets	-5 649	-11 571
Total direct costs	-635 572	-660 371

The direct costs in 2025 decreased by 3.8% year-on-year.

Purchase of material

The costs related to the purchase of material decreased by 3.2% year-on-year and amounted to 226.5 million euros in 2025. This

reduction primarily reflects lower volumes, consistent with the ongoing slowdown in the handset market.

Other direct costs

The other direct costs, mainly consisting of interconnection costs, commissions, content and connectivity costs, decreased by 2.7%

year-on-year.

Interconnection costs

Interconnect expenses decreased by 11.6 million euros to 134.2 million euros. SMS interconnect costs decreased by 18.2 million

euros due to lower traffic. International roaming cost increased by 8.5 million euros, primarily due

to traffic data increase compared

to previous year.

Commissions

Commission expenses decreased by 1.6 million euros in 2025 to 25.6 million euros, mainly due to the integration of partners.

Content costs

Orange Belgium’s television content strategy is primarily based on developing partnerships with rights holders and service publishers.

Orange Belgium is mainly focused on its role of aggregating and distributing content to offer improved services to its customers. The

costs regarding television content amount to 98.1 million euros in 2025 compared to 116.2 million euros in 2024. This decrease is

mainly attributable to the non-renewal of Belgian football broadcasting rights in the second half of the year, as well as a decrease in

the customer base.

240

Connectivity

Connectivity costs increased by 20.7 million euros in 2025 to 126.1 million euros. This is primarily due to higher wholesale access fees

related to the convergent Love offer in the north, the ongoing growth of our customer base, and changes in cost presentation following

the VOO acquisition.

Others

Other direct costs decreased by 6.6 million euros in 2024 to reach 25.1 million euros, this was mainly due to lower bad debt expenses,

driven by the cleanup of older balances in VOO.

Prepaid expenses


		in thousand EUR
	31.12.2025	31.12.2024
Prepaid supplies and services	11 216	18 802
Prepaid spectrum fees
Total Prepaid expenses	11 216	18 802

The prepaid supplies and services decreased by 7.6 million euros compared to 2024. The prepaid expenses consist for the most part

of the prepayment sites rent. The main driver in the decreased prepaid expenses are the lower prepaid expenses related to the Jupiler

Pro League (non-renewal of the contract).

Inventories


		in thousand EUR
	31.12.2025	31.12.2024
Gross inventories	42 750	36 773
Depreciation	-4 437	-2 011
Total Inventories	38 313	34 762
Inventories -Cost recognized as an expense during the period	-221 496	-229 186

The inventory mainly includes handsets and network equipment, as this material will be used this year for the deployment of Orange

NetCo's network.

The reserve for obsolete and slow-moving items increased by 2.2 million euros to 4.4 million euro.

Trade payables and other current liabilities


		in thousand EUR
	31.12.2025	31.12.2024
Trade payables	335 679	286 070
Salaries and termination pay	3 154	2 165
Performance and profit sharing bonus, pensions	24 917	24 400
Social security contributions	5 124	5 122
Holiday pay	31 752	31 128
Other	501	414
Current employee benefits	65 447	63 228
Current restructuring provisions	7 921	5 872
Other current liabilities	8 557	10 970
Current tax payables	15 996	17 859
Deferred income	817	787

Trade payables

are non-interest bearing and are generally settled on 30 to 60-day terms. The trade payables increased by 49.6 million

euros or by 17.3% compared to 2024, mainly related to the accrual trade payable of Orange Belgium S.A. (timing effect)..

Current employee benefits

increased by 2.2 million euros in 2025 and is mainly due to the indexation, which also affects the bonus

provision.

On 1 July 2025, Voo employees were transferred to Orange Belgium SA with an alignment of salary packages (bonus,

insurances…).

241

Other current liabilities

are made of provisions for litigation, down payments received from customers and operating subsidies

received but not used yet at year end.

The current tax payables

are related to the tax calculation of the current year. The decrease is essentially due to Orange Belgium’s

tax loss position as at year-end 2025 (decrease of 1.9 million euros).

Pension obligations

With respect to the Belgian defined contribution and cash balance pension plans and considering the law on supplementary pensions,

the legal minimum rates of return are to be guaranteed by the employer, as long as the worker remains in service, as follows (Orange

Belgium S.A. and its Belgian subsidiaries):

For the contributions paid until end December 2015, the applicable legal rates of return (3.25% and 3.75% respectively on the

employer and employee contributions) continue to apply until the retirement date of the participants;

For the contributions paid as from 1 January 2016, a new variable minimum return is defined based on the average of Belgian

government bond (OLO) yields, subject to a minimum of 1.75% and a maximum of 3.75%. In view of the low rates of the

OLO in the recent past, the legal minimum return applicable was 1.75%;

For the contributions that are paid as from 1 January 2025, the legal minimum rate of return has been defined to 2.50%.

In view of these legal minimum rates of return to be guaranteed by the employer, those Belgian defined contribution plans embed

defined benefit features and therefore qualify as Defined Benefit plans under IAS 19.

To reflect the obligations linked to these defined contribution pension plans, Orange Belgium performed a complete actuarial

computation under the PUC method without projection of future premiums. The actuarial valuation covers the entirety of the pension

plan scope at Orange Belgium and its subsidiaries. The pension plans are financed externally through group insurance contracts of

which some are foreseeing contractual interest rates granted by the insurance companies and others are investing the premiums paid

directly in financial instruments/assets. The actuary performed projections according to the methodology prescribed by the accounting

standard under certain assumptions.

The most relevant assumptions used in the actuarial computation for the main plans at Orange Belgium SA and (former) VOO SA are:


Key assumptions made:	31/12/2025	31/12/2024
Demographic:
• Retirement age	Legal retirement age (OBE)	Legal retirement age (OBE)
	65 – 67 years (VOO)	65 – 67 years (VOO)
• Mortality tables	MR-5/FR-5	MR-5/FR-5
• Turnover tables	None (OBE)	None (OBE)
	Age dependent grids (VOO)	Age dependent grids (VOO)
Financial:
• Discount rate	4,30% (OBE)	3,40% (OBE)
	3,10% - 4,00% (VOO)	3,40% - 3,75% (VOO)
• Inﬂation	2,00%	2,00%
• Salary increase on top of inﬂation	0,50% (OBE)	0,50% (OBE)
	2,5% - 3,0% (VOO)	2,5% - 3,0% (VOO)
• Legal minimum rate of return	3,25%	2,75%

The results of these actuarial calculations have been reflected in the below table. These plans do not expose the group to any particular

plan or entity specific risks, or concentrations of risk.

Orange Belgium and its subsidiaries have as well in place a post-employment medical plan and a seniority plan which are valued and

reflected in the balance sheet of the company. Both plans are unfunded and are anticipated to phase out in the near future.

242

Please find below a reconciliation of the opening to the closing balance of the net defined benefit asset:

Movement in net defined benefit (asset) liability

				in thousand EUR
	Defined benefit	Fair value of	Effect of asset	Net defined
	obligation	plan assets	ceiling	(asset) liability
Balance at 1 January 2025	175 630	-177 117	4 641	3 154
Included in profit or loss
Current employer service cost	8 984			8 984
Past Service cost (credit)	-1 165			-1 165
Interest cost (income)	5 852	-6 058	164	-42
Actuarial loss (gain) recognized in the P&L
Included in OCI
Effect of changes in financial assumptions	-20 148			-20 148
Effect of changes in demographic assumptions
Effect of experience adjustments / Return on plan
assets excluding interest income	-774	20 186		19 412
Changes in asset ceiling/onerous liability
(excluding interest income)			-4 805	-4 805
Other
Contributions paid by the employer		-7 800		-7 800
Contributions paid by the participants	1 191	-1 191		0
Benefits paid, taxes, risk premiums and
administrative costs	-5 609	5 514		-95
Balance at 31 December 2025	163 961	-166 466	0	-2 505

				in thousand EUR
	Defined benefit	Fair value of	Effect of asset	Net defined
	obligation	plan assets	ceiling	(asset) liability
Balance at 1 January 2024	162 408	-164 259	4 836	2 985
Included in profit or loss
Current employer service cost	8 997			8 997
Past Service cost (credit)
Interest cost (income)	5 705	-5 928	182	-41
Actuarial loss (gain) recognized in the P&L
Total
Included in OCI
Effect of changes in financial assumptions	6 977			6 977
Effect of changes in demographic assumptions
Return on plan assets excluding interest income
Effect of experience adjustments / Return on plan
assets excluding interest income	-1 815	-5 722		-7 537
Changes in asset ceiling/onerous liability
(excluding interest income)			-377	-377
Other
Contributions paid by the employer		-7 786		-7 786
Contributions paid by the participants	1 146	-1 146		0
Benefits paid, taxes, risk premiums and
administrative costs	-7 790	7 724		-66
Total
Balance at 31 December 2024	175 630	-177 117	4 641	3 154

243

The contributions paid during 2025 for those plans amounted to 7.8 million euros paid by the employer and 1.1 million euros paid by

the employees. For 2026, the contributions are anticipated to amount to 7.8 million euros to be paid by the employer and 1.2 million

euros to be paid by the employees.

The plan assets of Orange Belgium S.A as of 31 December 2025 consisted of 166 million in total (177 million as of 31 December 2024),

being the sum of the collective financing fund and the present value of the reduced lump sums (as per IAS19§115).

Labour costs (excluding termination benefits)

Labour costs increased by 2.5% to 257.7 million euros in 2025, compared to 251.5 million euros a year ago. This increase has been

mainly driven by inflation.

Indirect costs, net of other indirect income


		in thousand EUR
	31.12.2025	31.12.2024
Commercial expenses	-53 540	-57 218
Other IT and network expenses	-196 445	-201 034
Property expenses	-25 785	-24 201
General expenses	-139 141	-147 913
Other indirect income	37 816	35 742
Other indirect costs	-63 202	-75 896
Depreciation of right-of-use of leased assets	-58 321	-61 239
Total indirect costs, net of indirect income	-498 618	-531 759
of which operational taxes and fees	-13 879	-32 845

The indirect costs, net of other direct income, decreased 6.2% year-on-year to 498.6 million euros in 2025 compared to 531.8 million

euros in 2024 driven by positive settlements, synergies following the acquisition of VOO and other cost efficiencies, partially offset by

inflation and new management fee contracts.

The commercial expenses decreased by 4.6 million euros in 2025 mainly due continuous cost efficiencies following VOO integration.

Other IT and network expenses increased by 27.0m year-on-year thanks to lower media costs.

Property expenses increased by 1.6m year-on-year mainly impacted by inflation partially offset by efficiency gains.

General expenses which include, amongst others, (i) outsourced labor and professional services, (ii) outsourced call center costs and

(iii) facility-related expenses, decreased by 8.7m year-on-year, mainly driven by lower workforce-related costs resulting from synergies

and efficiency gains.

Other indirect income increased by 2.1m year-on-year compensated by other indirect costs. Other indirect costs decreased by 12.7m

year-on year, with positive settlements more than offsetting new management fees.

Depreciation of right-of-use-assets decreased by 2.9m year-on-year, mainly due to a higher number of dismantled sites, resulting in

lower lease expenses.

Other restructuring costs

In 2025 Orange Belgium booked restructuring costs for 18.8 million euros out of which 2.3 million euros are costs related to acquisition

and integration.

In 2024 Orange Belgium booked restructuring costs for 19.4 million euros out of which 0.6 million euros are costs related to acquisition

and integration.

244

Note 5: Goodwill

Goodwill

Goodwill originates from the following historical transactions:


						in thousand
						EUR
	31.12.2025			31.12.2024
		Accum			Accumulat
	Acquisition	ulated	Net carrying	Acquisiti	ed	Net carrying
	Value	impair	amount	on	impairment	amount
		ment		Value	losses
		losses
Acquisition of Orange Communications Luxembourg S.A.
(2007 – 2008)	68 729	-17 865	50 864	68 729	-17 865	50 864
Acquisition of VOO SA (2023 – 2024)	684 138		684 138	684 138		684 138
Other goodwill	53 547	-37 370	16 177	53 547	-37 370	16 177
Total goodwill	806 414	-55 235	751 179	806 414	-55 235	751 179

The acquisition of Orange Communications Luxembourg S.A. was completed in two phases. 90% of the shares were acquired on 2

July 2007. The remaining 10% were acquired on 12 November 2008.

The acquisition of 75% of VOO S.A and its 100% subsidiaries was completed in June 2023.The remaining 25% was acquired in May

2024, when Nethys exercised its put option on the shares in VOO Holding SA it held, in exchange for shares in Orange Belgium (see

note 10).

Other goodwill includes goodwill resulting from past acquisitions of Mobistar Affiliate S.A. (completed in 2001, goodwill of 10,6 million

EUR – no change compared to 2023), A&S Partners S.A. (completed in 2017, goodwill of 4,8 million EUR – no change compared to

2023) and Mobistar Enterprise Services S.A. (completed in 2011, goodwill of 0,8 million EUR – no change compared to 2023).

An impairment test on goodwill is performed at least at the end of each financial year (or more frequently if there are indications that

goodwill might be impaired) to assess whether its carrying amount does or does not exceed its recoverable amount.

To this purpose, the carrying amount of goodwill has been allocated to the cash generating units (CGU’s) as follows:


						in thousand EUR
	31.12.2025			31.12.2024
		Accumulated	Net		Accumulated
	Acquisition	impairment	carrying	Acquisition	impairment	Net carrying
Goodwill CGU allocation	Value	losses	amount	Value	losses	amount
Belgium	737 685	-37 370	700 315	737 685	-37 370	700,315
Luxembourg	68 729	-17 865	50,864	68 729	-17 865	50,864

The recoverable amount of each cash-generating unit is determined based on a value in use calculation which uses discounted cash

flow projections based on the 5-year business plan approved by the appropriate governance structure. Discount rates represent the

current market assessment of the risks specific to the CGU, taking into consideration the time value of money and individual risks of

the underlying assets that have not been incorporated in the cash flow estimates. The discount rate calculation is based on the

specific circumstances of the Group and its operating segments and is derived from its weighted average cost of capital (WACC).

The WACC takes into account both debt and equity. The cost of equity is derived from the expected return on investment by the

Group’s investors. The cost of debt is based on the interest-bearing borrowings the Group is obliged to service. Segment-specific

risk is incorporated by applying individual beta factors. The beta factors are evaluated annually based on publicly available market

data.

Belgium

The recoverable amount of the ‘Belgium’ segment as a cash-generating unit is determined based on a value in use calculation which

uses cash flow projections based on the 5-year business plan approved by the directors.

The pre-tax discount rate applied to cash flow projections is 8.13% per annum (2024: 8.97% per annum) and cash flows beyond the

five-year period are extrapolated using a 0.75% growth rate (2024: 0.75%). Post-tax discount rates were 6.1%per annum (2024:

6.73%).

245

The key assumptions used by management in setting the business plan for the initial five-year period were as follows:

-

key revenue assumptions, which reflect market level, penetration rate of the offerings and market share, positioning of the

competition’s offerings and their potential impact on market price levels and their transposition to the Group’s offerings

bases, regulatory authority decisions on pricing of services to customers and on access and pricing of inter-operator

services, technology migration of networks, competition authorities’ decisions in terms of concentration or regulation of

adjacent sectors such as cable;

-

key cost assumptions, on the level of marketing expenses required to renew product lines and keep up with competition,

the ability to adjust costs to potential changes in revenues or the effects of natural attrition and committed employee

departure plans;

-

key assumptions on the level of capital expenditure, which may be affected by the roll-out of new technologies, by decisions

of regulatory authorities relating to licenses and spectrum allocation, mobile network coverage, sharing of network elements

or obligations to open up networks to competitors.

The business plan foresees a progressive increase of adjusted EBITDAaL over the period as the result of (i) a continuous top line

growth coming mainly driven by the growth of wholesales revenue through the utilisation of the HFC network in the south, but tempered

by increased competitions and decrease on incoming SMS revenues with the implementation of RCS (ii) costs managed through the

stabilisation of the direct margin and the management of indirect costs (iii) decrease of eCapex following the finalization of the Ran

sharing implementation in the first years of the plan. More precisely, the management ambitions a turnaround over this 5-year period

(2025-2030) with a 0.5% (compared to 1.2 % last year) and 2.2% (compared to 4.6 % last year) compounded annual growth rate

(CAGR) of revenues and adjusted EBITDA respectively, while capital expenses are expected to decrease by 3.5% (compared to

increased by 1.4% last year).

It was concluded that the value in use exceeds the carrying amount and that no impairment was required to be recorded. This was

also the conclusion in 2024.

Sensitivity of recoverable amounts

A sensitivity analysis on those parameters was performed, using a perpetuity growth rate varying from 0.25% to 0.75% (2024: from

0.25% to 0.75%) and a post-tax discount rate varying from 6.1% to 7.1% (2024: from 6.7% to 7.7%).The management believes that

such reasonably possible change in these key assumptions on which the recoverable amount of ‘Belgium’ is based would not cause

the carrying amount of the related net assets to exceed the aggregate recoverable amount of this CGU.

Luxembourg

The recoverable amount of the ‘’Luxembourg’ segment as a cash-generating unit is determined based on a value in use calculation

which uses cash flow projections based on the 5-year business plan approved by the Strategic Committee.

The pre-tax discount rate applied to cash flow projections is 6.80 % per annum (2024: 7.27% per annum) and cash flows beyond the

five-year period are extrapolated using a 1.25% growth rate (2024: 1.25%). Post-tax discount rate were 5.40% per annum (2023:

5.76%).

The key assumptions used by management in setting the business plan for the initial five-year period were as follows:

-

key revenue assumptions, which reflect market level, penetration rate of the offerings and market share, positioning of the

competition’s offerings and their potential impact on market price levels and their transposition to the Group’s offerings

bases, regulatory authority decisions on pricing of services to customers and on access and pricing of inter-operator

services, technology migration of networks, competition authorities’ decisions in terms of concentration or regulation of

adjacent sectors such as fiber;

-

key cost assumptions, on the level of marketing expenses required to renew product lines and keep up with competition,

the ability to adjust costs to potential changes in revenues or the effects of natural attrition and committed employee

departure plans;

-

key assumptions on the level of capital expenditure, which may be affected by the roll-out of new technologies, by decisions

of regulatory authorities relating to licenses and spectrum allocation, mobile network coverage, sharing of network elements

or obligations to open up networks to competitors.

The management of Orange Communications Luxembourg foresees a progressive increase of adjusted EBITDA over the period as

the result of (i) a continuous top line growth coming both from an increase in market share (mainly on broadband) and churn reduction,

and (ii) the increase in the direct margin mainly linked to the broadband network deployment which overcompensate the increase of

indirect costs related to automatic index, mainly on salaries and property costs. More precisely, the management ambitions a

turnaround over this 5-year period with a 3.0% (compared to 3.70 % last year) and 7.26 % (compared to 7.90 % last year) compounded

246

annual growth rate (CAGR) of revenues and adjusted EBITDA respectively, while capital expenses are expected to decrease by 5.80%

(compared to an increase of 6.40% last year).

It was concluded that the value in use exceed the carrying amount and that no impairment was required to be recorded.

Sensitivity of recoverable amounts

A sensitivity analysis on those parameters was performed, using a perpetual growth rate varying from 0.75% to 1.25% (2024: from

0.75% to 1.25%) and a post-tax discount rate varying from 5.40% to 7.25% (2024: from 5.76% to 7.25%). An additional sensitivity

analysis was performed on the EBITDAaL margin in the terminal value. I

The directors believe that such reasonably possible change in these key assumptions on which the recoverable amount of

‘Luxembourg’ is based would not cause the carrying amount of the related net assets to exceed the aggregate recoverable amount

of this CGU.

Note 6: Other intangible assets and property, plant and equipment

Depreciation and amortization

The depreciation and amortization charge (including impairment of fixed assets) for the year was 418.5 million euros, up by 7 million

euros compared to 2024.

Accelerated depreciations of fixed assets

The changes in useful life on intangible assets and property, plant and equipment recognized during the year were determined on an

asset-by-asset basis in order to consider technology and IT evolution. Obsolescence, dismantling or losses are also considered in this

exercise.

During 2025, the change in useful life and/or recognized impairment charges on property, plant and equipment totals 13.4 million

euros (compared with 17.1 million euros in 2024) and shown as expense on the line “Depreciation and amortization” and “impairment

of fixed assets” in the statement of comprehensive income.

The impact of this year is mainly due to the project RAN sharing Proximus including Sites dismantling & Ran material radio swapped

from Huawei to Nokia (13 million euros)

Other intangible assets


		in thousand EUR
	31.12.2025	31.12.2024
Net book value of other intangible assets in the opening balance	861 887	907 208
Acquisitions of other intangible assets	73 526	78 588
Depreciation and amortization	-121 489	-123 402
Impairment	-544	-506
Reclassifications and other items	-48	-1
Net book value of other intangible assets in the closing balance	813 332	861 887

Acquisition of other intangible assets are mainly software licenses (67.3 million euros).


				in thousand EUR
		Accumulated
	Gross	depreciation and	Accumulated	Net book
31.12.2025	value	amortization	impairment	value
Telecommunication licences	696 393	-186 370	0	510 023
Brand	20 072	-8 224	-4 172	7 676
Subscriber bases	143 539	-39 777	0	103 762
Software	926 478	-755 295	0	171 184
Other intangible assets	141 354	-120 667	0	20 687
Total	1 927 836	-1 110 333	-4 172	813 332

247


				in thousand EUR
		Accumulated
	Gross	depreciation and	Accumulated	Net book
31.12.2024	value	amortization	impairment	value
Telecommunication licences	696 393	-148 650	0	547 743
Brand	20 072	-5 044	-4 172	10 856
Subscriber bases	143 539	-31 316	0	112 223
Software	887 625	-724 015	0	163 610
Other intangible assets	134 328	-106 873	0	27 455
Total	1 881 956	-1 015 898	-4 172	861 887

Telecommunication and other licenses held by Orange Belgium Group:


	Acquisition	Net book	Net book
	cost	value end	value end			Start
Type of Licence	in	2025	2024	Useful life	Remaining	depreciation
	thousand	in thousand	in thousand	in months	months	period
	EUR	EUR	EUR
4G	20 020	2 549	4 372	Ended Jun-	17	Jun-16
				2027
800 MHz	120 000	47 863	53 920	238	95	Feb-14
IBPT autorisation 3 G	2 158	0	0	4	0	Sept-22
IBPT autorisation 2 G	4 193	0	0	4	0	Sept-22
IBPT autorisation 5 G 3600 Mhz	55 308	44 869	48 000	212	172	Sept-22
IBPT autorisation 5 G 700 Mhz	122 860	102 378	108 521	240	200	Sept-22
Spectrum RD 800 Mhz	17 542	11 695	13 157	144	96	Jan-22
Spectrum RD 2600 Mhz	5 897	1 608	2 680	78	18	Jan-22
Spectrum RD 700 Mhz	23 398	19 497	20 666	240	200	Sept-22
Spectrum RD 3600 Mhz	11 386	9 237	9 881	212	172	Sept-22
License 900/1800/2100 Mhz	214 198	182 068	192 779	240	204	Jan-23
License 1400 Mhz	89 135	77 974	82 431	240	210	Jul-23
OLU UMTS 2100 Mhz ( 4 G)	1 735	0	0	192	88	May-17
OLU 5G 700 Mhz + 3600 Mhz	13 504	9 498	10 506	180	116	Aug-20
BKM PPA - unused perpetual licences Voxx - Telepo	1 058	787	830	300	235	Aug-19
Total	702 392	510 023	547 744

Licenses acquired or granted have been capitalized as such:

-

One off amount paid or to pay at commencement

-

Net present value of the yearly fixed amounts of spectrum fees to be paid over the license period. A corresponding liability has

been recorded in current and non-current fixed assets payable. The net present value corresponds to the discounted value of the

fixed amounts of spectrum fee payable over the license period at the discount rate prevailing at the moment of the calculation for

the maturity of the debt. As from the booking of the debt, unwinding based on the original discount rate is recorded in financial

expenses and annual payments are applied against the debt itself.

Internally generated intangible assets

include software development costs generated by the Group staff.

The useful lives of intangible assets applied in 2025 remain comparable to those used in 2024.

Investments related to original software acquisition may be fully amortized as well but upgrades of these software, still in use, are not

fully amortized. The same applies to the original site’s research costs.

Intangible assets are not subject to title restriction or pledges as security for liabilities.

248

Property, plant and equipment


		in thousand EUR
	31.12.2025	31.12.2024
Net book value of property, plant and equipment in the opening balance	1 803 870	1 787 469
Acquisitions of property, plant and equipment	302 836	289 927
Depreciation and amortization	-293 777	-288 096
Reclassifications and other items	-150	14 847
Net book value of property, plant and equipment in the closing balance	1 812 353	1 803 870

The acquisitions of 2025 relate to investments into the network (275.5 million euros) and into terminals & set-top boxes (14.4 million

euros).


			in thousand EUR
		Accumulated
	Gross	depreciation and	Net book
31.12.2025	value	amortization	value
Land and buildings	187 648	-122 215	65 433
Networks and terminals	4 483 344	-2 769 975	1 713 369
IT equipment	209 351	-184 333	25 018
Other property, plant and equipment	27 946	-19 413	8 533
Total	4 908 289	-3 095 936	1 812 353


			in thousand EUR
		Accumulated
	Gross	depreciation and	Net book
31.12.2024	value	amortization	value
Land and buildings	177 731	-100 004	77 727
Networks and terminals	4 420 900	-2 757 795	1 663 105
IT equipment	211 591	-175 429	36 162
Other property, plant and equipment	51 222	-24 346	26 876
Total	4 861 444	-3 057 574	1 803 870

Provision for dismantling


		in thousand EUR
	31.12.2025	31.12.2024
Provisions for dismantling in the opening balance	59 774	61 951
Discounting with impact on income statement	2 154	2 016
Utilizations without impact on income statement	-4 594	-5 602
Changes in provision with impact on assets	1 931	1 409
Provisions for dismantling in the closing balance	59 265	59 774
o/w non-current provisions	55 149	54 209
o/w current provisions	4 116	5 565

The key assumptions used to measure the network sites dismantling provision are as follows:


	31.12.2025	31.12.2024
Number of network sites, Orange Communications Luxembourg S.A. incl. (in units)	3 160	3 515
Average dismantling cost per network site (in thousand EUR)	11.36 till 2026 and	11.08 till 2025 and 17.6
	18.51 from 2027	from 2026
Inflation rate	2.6% for 2026, 2.0%	4.3% for 2025, 2.0%
	from 2027	from 2026
Discount rate	3.631 %	3.244 %

Although size and installation on site may slightly vary from site to site, the provision was calculated on an average dismantling cost

based on the actual costs incurred in the past for similar activities till 2025. For 2024, those costs were estimated at K EUR 11.1 till

end of 2025 and K EUR 17.6 as from 2026.

During 2025 a refined typology of sites has been implemented refining the expected

dismantling cost per site’s type leading to an average of 11,360 euros per sites for the sites dismantled as from 2026 and 18,510 euros

as from 2027.

249

The increase of dismantling costs starting in 2027 is due to the cumulative inflation over the year 2025 to 2026 and the mix of sites

typologies that results into a higher average cost of dismantling.

For bigger sites, like MSC’s (Mobile Switching Centre), the provision is calculated on the surface area of the sites rented and an

average dismantling cost per m² based on past similar experience.

Although it is not feasible to estimate the timing of the cash outflows, all network sites are assumed to be dismantled in the future.

Since 2011, the duration of the rental contracts is capped at 15 years. The approach was maintained to evaluate the provision in 2025.

The dismantling provision decreased by 0.5 million euros.

This is linked to the dismantling of network sites for 4.6 million euros

(reversal), offset by the increase of the building price per m² for 4.1 million euros.

Network sites dismantling provision is adjusted when there is sufficient objective evidence that future change in technology or in

legislation will have an impact on the amount of the provision.

Besides network, the dismantling provision also includes 12.4 million euros of accruals related to buildings, Mobile Switching Centers

(MSC’s) and Point-of-Presence (POP’s).

Current fixed assets payable

Current fixed assets payable are non-interest bearing that are generally settled on 30 to 60 days term and are mostly related to

Property, Plant and Equipment investments. The balance increased compared to last year (67.2 million euros in 2025, compared to

59.5 million euros a year ago).

Non-Current fixed assets payable

Non-current fixed assets payable correspond to the discounted value of the fixed amount to be paid over the lifetime of the

telecommunication license.

Note 7: Taxes and levies

Income tax in profit and loss statement


		in thousand EUR
	31.12.2025	31.12.2024
Current tax income / (expense)	-3 837	3 352
Deferred tax income / (expense) arising to the origination and reversal of temporary differences	5 786	9 515
Total tax income /expenses	1 950	12 867

Relationship between tax expense and accounting profit


		in thousand EUR
	31.12.2025	31.12.2024
Earnings before income tax	39 358	4 285
Group income tax rate	25	25
Theoretical income tax	-9 840	-1 071
Effect of difference between local standard rate and Group rate (*)	-42	8
Effect of permanent differences and other reconciling items (**)	-1600	-2 117
Effect of tax (without base) affecting current tax (***)	12977	15 439
Effect of tax (without base) affecting deferred tax	455	608
Income tax	1 950	12 867
Effective tax rate	-5.0%	-300.3%

* local rate (Orange Communications Luxembourg S.A.= 26.12.19%) and Group rate (25.)

** consisting of permanent difference like disallowed expenses, other reconciling items like other non-taxable income

*** adjustment on prior years and the effect of application of R&D tax-related incentives

Tax income amounted to 2 million euros in 2025 compared to 12.9 million euros in 2024.

The theoretical amount of tax expense amounts to 9.8 million euros while in 2024 there was an expense in the amount of 1.1 million

euros.

250

In 2025, the permanent differences result in a net impact of -1.6 million euros versus a net impact of -2.1 million euros in 2024. This

variation is explained by a positive impact of the other non-deductible expenses, partially offset by other non-taxable income and

other permanent differences. Permanent differences resulted when an item of income and/or expense is treated differently for book

and tax purposes and the different treatment does not reverse in a subsequent year or result in a basis difference (for example:

disallowed expenses, effect on tax gain/loss on disposal of investments, asset retirement obligation, amongst others).

The effect of tax (without base) affecting current tax has decreased from 15.4 million euros in 2024 to 13 million euros in 2025.

The 13 million euros recorded in 2025 consist mainly of tax credits on Innovation Income Deduction, Investment Deduction on

environmentally friendly R&D and energy-saving investments.

Tax position in the statement of financial position

Movements in current tax balances


		in thousand EUR
	31.12.2025	31.12.2024
Net current tax payables -opening balance	8 650	16 191
Cash tax payments	-1 474	-4 189
Current income tax expense	3 837	-3 352
Changes in consolidation scope, reclassification and translation adjustments	-1	-1
Net current tax payables -closing balance	11 011	8 650

Cash tax payments in 2025 consist mainly of tax paid on the years 2021, 2022 and 2023 and tax prepayment for 2025.

Movements in deferred tax balances

Deferred taxes are determined based on temporary differences between the carrying values of assets and liabilities in the consolidated

financial statements and their corresponding tax bases, as well as on tax loss carryforwards.


		in thousand EUR
	31.12.2025	31.12.2024
Net deferred taxes -opening balance	-47 574	-58 723
Change in income statement	5 786	9 515
Change in other comprehensive income	-2 379	1 636
Changes in consolidation scope, reclassification and translation adjustments	0	-2
Net deferred taxes -closing balance	-44 167	-47 574

The deferred taxes can detailed as follows:


						in thousand EUR
	31.12.2025			31.12.2024
			Income			Income
	Assets	Liabilities	statement	Assets	Liabilities	statement
Fixed assets	8 076	90 216	3 998	0	86 138	1 537
Tax losses carryforward	50 272	0	2 885	47 388	0	23 588
Other temporary differences	68 742	81 041	-1 097	65 925	74 749	-16 749
Deferred taxes	127 090	171 257	5 786	113 313	160 887	8 376
Unrecognized deferred taxes assets						1 139
Netting	-119 738	-119 738		-105 766	-105 766	0
Total	7 352	51 519	5 786	7 547	55 121	9 515

Deferred taxes essentially relate to PPA adjustments on tangible and intangible fixed assets, tax losses carried forward and other

temporary differences including revenue from contracts with customers, other lease liabilities and the right of use of leased assets,

pension obligations and asset retirement obligations.

The 2025 other temporary differences on deferred taxes assets for a total of 68.7 million euros relate principally to other lease liabilities

for 49.1 million euros and to pension obligations for 7.9 million euros, compared to a total of 66 million euros in 2024 of which 46.2

million euros relate to other lease liabilities and 8.5 million euros to pension obligations.

251

The other temporary differences on deferred taxes liabilities for a total of 81 million euros relate mainly to the right of use of leased

assets for 46.8 million euros and to revenue from contracts with customers for 34.3 million euros compared to a total of 74.7 million

euros in 2024 of which 44.3 million euros relate mainly to the right of use of leased assets and to revenue from contracts with customers

for 30.5 million euros.

Current operating taxes and levies payables

The operating taxes and levies payables amounted to 146.2 million euros in 2025 and consist of VAT payables 37.6 million euros, 99.9

million euros taxes charged to pylons and masts -plus default interests calculated at the legal rate, 7.3 million euros of provisions for

contingencies and 1.4 million other taxes payable. Iin 2024, the operating taxes and levies payable amounted to 151.2 million euros

and consist of VAT payable 40.3 million euros, 100.7 million euros taxes charges to pylons and masts, 8.8 million euros of provisions

for contingencies and 1.4 million others taxes payable.

The decrease versus year-end 2024 of 5 million euros is mainly caused by a decrease in VAT payable (-2.6 million euros).

Operational taxes: pylon

Pylon taxes payable as at 31 December 2025 amount to 99.8 million euros. Versus year-end 2024 these taxes decreased by 0.9 million

euros or by 0.8%. Pylon taxes payable are included in the caption “Operating taxes and levies payable” on the balance sheet.

Since 1997, certain municipalities and four provinces have adopted local taxes, on an annual basis, on pylons, masts or antennas

erected within their boundaries. Orange Belgium continues to file fiscal objections against tax assessment notices received concerning

these local taxes on pylons, masts or antennas. These taxes are currently being contested before the Civil Courts (Courts of First

Instance - Tax Chamber and Courts of Appeal).

Walloon protocol agreement 2016-2019:

On 22 December 2016 the three mobile operators and the Walloon government had concluded an agreement in principle on the issue

of taxing mobile infrastructure in the Walloon region for the period 2016-2019 and agreed to settle the dispute on the Walloon regional

taxes for 2014.

Orange Belgium engaged itself to pay an amount of 16.1 million euros over 4 years (i.e. 2016-2019) and to invest an incremental

amount of 20 million euros in telecom infrastructure in the Walloon region in the period 2016-2019.

In turn, the Walloon Region undertook to no longer levy taxes on telecom infrastructure and to implement a legislative, regulatory and

administrative framework designed to facilitate the deployment of this infrastructure. Also, the Walloon Region would discourage

taxation by municipalities and provinces on telecom infrastructure.

In 2018 and 2019 several Walloon municipalities and provinces had levied taxes on telecom infrastructure.

The operators were entitled to deduct such local taxes levied in 2016-2019 by Walloon municipalities or provinces from the 2019

settlement and investment amounts.

The last instalment of the amount due by Orange Belgium on the basis of the 2016-2019 protocol agreement (4.5 million euros), from

which local taxes levied in 2016-2019 could be deducted, has not yet been paid.

In December 2022 Orange Belgium had been contacted by the Walloon Region about the outstanding amount to be paid. Orange

Belgium had informed the Walloon Region that, after deduction of the local taxes levied in 2016-2019 on Orange Belgium, the

outstanding amount still to be paid was to 0.4 million euros. Orange Belgium has not received an answer from the Walloon Region.

The final instalment under the 2016-2019 protocol agreement (4.5 million euros), from which local taxes for the same period could be

deducted, has not yet been settled.

Orange Belgium has communicated to the Wallon Region its calculation of the remaining amount

due, which, after deduction of the local taxes effectively levied, amounts to 0.4 million euros, Discussions with the Region are ongoing.

Walloon protocol agreement 2021-2022:

The mobile operators had concluded a protocol agreement with the Walloon government for the period 2021-2022. This agreement

stipulated that the mobile operators would pay a contribution to a governmental budget fund to be set up by the Walloon government

to support the digitalization of the Walloon region, and more specifically local initiatives of Walloon municipalities or provinces. Amount

of the operator’s contribution: 5 million euros (35,73% to be paid by Orange Belgium). The mobile operators would also do additional

network investments for a total amount of 11 million euros (35,73% for Orange Belgium). This agreement would ensure a financially

stable environment by reducing the proliferation of local taxes.

An amount of 0.5 million euros has been paid in December 2021 to the Walloon region. This was the first tranche of 0.9 million euros

from which the taxes received from local authorities for 2021 have been deducted.

After deduction of the local taxes levied for 2021 and 2022 to the second tranche of 0.4 million euros of the protocol agreement, no

contribution was due any more to the Walloon region in December 2022.

The contribution to be paid to the Walloon region in February 2023 was determined by the end of January 2023, considering all local

taxes 2021 and 2022 levied and/or known by that date. According to this analysis, the amount of local taxes exceeded the amount

252

due to the Walloon Region on 15 February 2023 and could be deducted. Consequently, there was no contribution to be paid to the

Walloon Region by 15 February 2023.

Walloon protocol agreement 2023-2026:

On 6 June 2024, the Walloon Government and the mobile operators Proximus, Telenet, Orange Belgium and Insky signed an

agreement concerning the tax on pylons in the Walloon Region for the period 2023-2026, extension possible for 2027 subject to

approval of all parties.

A new version of this Walloon Protocol Agreement 2023-2026 dated 24 April 2025 has been signed.

The agreed principles remain the

same, it concerns the adjustments of some modalities of payment.

The mobile operators commit to pay as a sector for 2023 2.5 million euros, and for the years 2024, 2025, 2026 an amount of 6 million

euros per year to the Walloon Region. Local taxes, which municipalities and provinces levy during these years, are deductible up to

certain annual limits. The key to determine which part of these annual amounts is due per operator is defined each year based on the

number of pylons and masts owned and the coverage of each operator in the Walloon territory. For 2023 the percentage for Orange

Belgium amounts to 37,24%; for 2024 34,74%. Exchanges to determine this allocation key for 2025 are ongoing via Agoria.

Between 1 January 2023 and 31 December 2026, Orange Belgium will invest an additional amount of 15 million euros in the telecom

infrastructure in the Walloon Region.

An agreement exists to not impose Walloon Regional taxes on the telecom infrastructure during the period 2023-2026. Also,

municipalities and provinces will be discouraged by the Walloon Region to levy local taxes on telecom infrastructure.

In August 2025, an amount of EUR 1,334,000.00 was paid by Orange Belgium to the Walloon Region for the years 2023 and 2024.

Given the uncertainties surrounding both the legality and the amount of the pylon taxes, and considering, among other factors, that

this tax is neither fully payable at the start of each fiscal year nor actually paid, the Group continues to treat it as a risk. Nevertheless,

the estimated full-year exposure is recognized upfront each year as both a liability and an expense. Interest charges on the unpaid tax

amounts continue to be recorded on a monthly basis.

The provision related to the pylon tax is reassessed every quarter using prudent best-estimate assumptions, considering

developments in the regional tax framework, the progress of ongoing legal proceedings, and newly received tax assessments.

Management updates these estimates whenever underlying circumstances change or when new information or experience becomes

available. As a result, estimates made as of 31 December 2025 may subsequently be revised.

Note 8: Interests in associates

In July 2012, the Group participated in the constitution of IRISnet S.C.R.L. The activity of IRISnet S.C.R.L. started on 1 November

2012. The Group owns 28.16% of IRISnet S.C.R.L. equity. The Group is represented on the Board of Directors by 2 out of 10 seats.

This company is consolidated using the equity method. The net result of the year amounts to 128 thousand euros, resulting in a net

carrying amount as at 31 December 2025 of 3,707 thousand euros . In comparison, the net result of previous year was 438 thousand

euros, resulting in a net carrying amount as at 31 December 2024 of 3,579 thousand euros.

Note 9: Financial assets, liabilities and financial result

Financial result

		in thousand EUR
	31.12.2025	31.12.2024
Financial Costs	-96 986	-114 563
Financial Income	2	2
Total Net Financial Costs	-96 984	-114 561

Net financial costs decreased from -€114.6 million in 2024 to -€97.0 million in 2025. The decrease is mainly due to lower interest rates

year-over-year.

253

Cash and cash equivalents, financial liabilities

		in thousand EUR
	31.12.2025	31.12.2024
Cash and cash equivalents
Cash equivalents	0	-19
Cash	-80 628	-58 226
Total cash and cash equivalents	-80 628	-58 245
Financial liabilities
Intercompany short-term borrowing	186 744	54 697
Third parties short-term borrowing	18 282	21 411
Third parties loans long term	22 689	40 997
Intercompany long-term borrowing	1 668 041	1 846 004
Total borrowings	1 895 757	1 963 110
Net debt (Financial liabilities-Cash and cash equivalents)	1 815 130	1 904 866

Changes in financial liabilities whose cash flows are disclosed in financing activities in the cash flow statement (see 1.3) are presented

below:

				in thousand EUR
Other changes with no impact on
cash flows from financing activities	31.12.2024	Cash Flows	Reclassification ****	31.12.2025
Intercompany short-term borrowing *	54 697	12 047	120 000	186 744
Intercompany long-term borrowing **	1 846 005	-57 963	-120 000	1 668 042
Third party borrowing ***	62 408	-21 437	0	40 971

*In the cash flow statement, short-term borrowing with Orange SA entities for 12.0 million euros is included in the headers “Increase

(decrease) of bank overdrafts and short-term borrowings” for an amount of 13.4 million euros related to cash-pool variation, and -1.4

million euros in the headers “Other net cash out / Interest paid.

**Long-term borrowing with Orange SA entities for -58.0 million euros is included in the header "Long-term debt redemptions and

repayments" for an amount of -60.4 million euros related to the repayment of a long-term loan with Atlas Services Belgium S.A., and

2.4 million euros in the headers “Other net cash out / Interest paid.

***Third party borrowing in the amount of -21.4 million euros is included for -18.3 million euros in "Long-term debt redemptions and

repayments" and for -3.1 million euros in "Increase (decrease) in bank overdrafts and short-term borrowings".

**** Reclassification of 120 million euros RCF loan with Atlas Services Belgium S.A. from long term to short term (maturing on 10

th

of

March 2026).

Financial risks

Liquidity risk

Orange Belgium’s results and outlook could be affected if the terms of access to funding becomes difficult

Orange Belgium is mainly financed through long-term credit facilities granted by Orange Group entities and is thus not directly exposed

to adverse changes in market conditions. On top of the credit facility agreement with Orange SA for an amount of 150 million euros

ensured until July 2026 (after which 80 million euros ensured until July 2027) and the refinanced loan with Atlas Services Belgium S.A.

for an amount of 120 million euros (maturity date March 2026 – to be renewed for another 5 years), Orange Belgium entered in 2023

into a new financing agreement for an amount of 1,731.6 million euros in the context of the VOO acquisition and spectrum purchase

(with Atlas Services Belgium S.A. maturing in 2028). In addition, Orange Belgium could evoke other sources of funding such as bank

loans or bonds should financing limitations be imposed by the Orange Group. A large part of these facilities has been used at the end

of December 2023 to finance the VOO acquisition and the remaining payment of the spectrum licenses. As of 31 December 2025, the

Group had unused credit lines under the credit facility agreement with Orange SA for an amount of 90.3 million euros (13.7 million

euros as of 31 December 2024). We refer to the following pages for the maturity analysis.

254

Interest rate risk

Orange Belgium’s business activities could be adversely affected by interest rate fluctuations

In the framework of the provision of funding by Atlas Services Belgium SA for the acquisition of VOO and for the purposes of spectrum

purchase, Orange Belgium concluded in 2022 a financing agreement, to be used at VOO closing date, based on floating interest rate.

In view of the amount borrowed and the variability of the interest rate, Orange Belgium decided to deploy a hedge strategy. To

operationalize this strategy, Orange Belgium entered a framework agreement intended to allow for interest rates hedges related to the

credit facility agreement referred to above. Orange Belgium proposed to use a hedging instrument to fix all or part of the effect of the

variability of the 6-month rate. The instrument chosen is the IRS (Interest Rate Swap). The main conditions of this IRS are interest to

be received by Orange Belgium on the basis of the 6-month EURIBOR rate and interest to be paid by Orange Belgium on the basis of

the 5-year fixed rate. The combination of the floating rate loan (paid by Orange Belgium), the floating rate IRS (received by Orange

Belgium) and the fixed rate IRS (paid by Orange Belgium), transforms the hedged portion of the floating 6-month rate loan into a 5-

year fixed rate loan. Hedge accounting is applied.

Credit rating risk

Downgrades of Orange Belgium’s credit rating or rating outlook could increase its borrowing costs and/or limit its financing

capacity

Orange Belgium is mainly financed through long-term credit facilities granted by Orange Group entities until August 2028. The current

funding agreements do not foresee rating-based funding adjustments. However, rating downgrades could negatively impact the

trading terms that range Belgium receives from its suppliers, thus increasing the operational financing needs and overall funding costs.

Counterparty risk on financial transactions

The insolvency or deterioration in the financial position of a bank or other institution with which Orange Belgium has a

financial agreement may have a material adverse effect on the company and its financial position

Orange Belgium does not have any derivative exposure with financial institutions but has an interest rate swap with Atlas Services

Belgium S.A.. In addition, the credit balances on its bank accounts are very limited given that it is operating a cash pooling structure

with automatic sweeping of excess funds to Orange S.A.

However, a default of one of its main banking partners would have a negative impact on its cash management operations. This risk

is mitigated by the fact that Orange Belgium’s Treasury policy foresees working with at least three different banking partners with an

investment-grade rating.

Customer credit risk

Customer payment defaults could adversely affect Orange Belgium’s financial results and liquidity position

Orange Belgium’s credit policy foresees that all customers who wish to trade on credit terms are subject to credit verification

procedures. If the risk is deemed not acceptable, payment terms are defined as prepayment or cash on delivery. Orange considers

that it has limited concentration in credit risk with respect to trade receivables due to its large and diverse customer base (residential,

professional, and large business customers) operating in numerous industries. In addition, the maximum value of the counterparty risk

on these financial assets is equal to their recognized net carrying value. An analysis of net trade receivables past due is provided in

Note 2.

The following percentages are used to cover the exposure on overdue: not overdue 1%, less than 60 days overdue 6.5%, between

60 & 90 days overdue 12.5%, between 90 & 120 days overdue 25%, between 120 & 360 days overdue 40%, between 360 days and

540 days overdue 75% and more than 540 days 100%. For loans and other receivables, amounts past due but not provisioned are

not material.

Foreign exchange risk

Exchange rate fluctuations could adversely affect Orange Belgium’s financial results and liquidity position

Given the mainly local nature of its business Orange Belgium is not exposed to significant foreign currency risk.

255

General risk management framework

A comprehensive, consistent and integrated risk management approach is in place to capitalize on synergies between Audit, Control

and Risk functions at all levels of the organization.

This approach is intended to provide reasonable assurance that operating and strategic targets are met, that current laws and

regulations are complied with, and that the financial information is reliable.

The most important components of the risk management framework are discussed in detail in section 2 of the Corporate Governance

Statement.

Interest-bearing loans and borrowings

						in thousand EUR
	Nominal	Nominal
	amount	amount	Interest
	end 2025	end 2024	rate	Maturity	31.12.2025	31.12.2024
Atlas Services Belgium RCF (revolving
credit facility)	120 000	120 000	EURIBOR 3M + 0.69	10.03.2026	0	120 000
Atlas Services Belgium CFA (credit facility		1 671
agreement)	1 671 190	190	EURIBOR 6M + 1.90	23.05.2028	1 671 190	1 671 190
Atlas Services Belgium CFA (credit facility
agreement)		60 402	EURIBOR 6M + 1.90	02.08.2028	0	60 402
Transactions costs on long-term loan						-5 588
Long-term loans (ex-BKM)	550	802	5.48%	01.08.2036	499	726
Long-term loans ( ex-VOO)	146 333	164 717	1.06% - 9.5%	31.07.2026 -	22 190	40 271
				31.12.2029
Total long-term loans and borrowings					1 690 730	1 887 001
Atlas Services Belgium RCF (revolving
credit facility)	120 000	120 000	EURIBOR 3M + 0.69	10.03.2026	120 000	0
Cash-pool related credit facility with Orange	150 000	60 000	ESTER + 0.29	on demand	59 682	46 310
Uncommitted credit lines with various
banks	20 900	20 900	determined upon withdrawal	on demand	0	0
Short-term loans MWINGZ	2 000		EURIBOR -0.25	on demand	2 000	2 150
			ST within 1 year related to LT
Short-term loans (ex-BKM)			loan	31.12.2026	51	76
			ST within 1 year related to LT
Short-term loans (ex-VOO)			loan	31.12.2026	18 082	21 063
Transactions costs on short-term loan					5 212	6 510
Total short-term loans and borrowings					205 027	76 109

256

Derivatives

As at 31 December 2025, the Group held hedging derivative financial instruments qualifying for hedge accounting. In the framework

of the provision of funding by Atlas Services Belgium SA for the acquisition of VOO and for the purposes of spectrum purchase,

Orange Belgium concluded in 2022 a financing agreement, to be used at VOO closing date, based on floating interest rate. In view of

the amount borrowed and the variability of the interest rate, Orange Belgium decided to deploy a hedge strategy. To operationalize

this strategy, Orange Belgium entered a framework agreement intended to allow for interest rates hedges related to the credit facility

agreement referred to above. Orange Belgium proposed to use a hedging instrument to fix all or part of the effect of the variability of

the 6-month rate. The instrument chosen is the IRS (Interest Rate Swap). The main conditions of this IRS are interest to be received

by Orange Belgium on the basis of the 6-month EURIBOR rate and interest to be paid by Orange Belgium on the basis of the 5-year

fixed rate. The combination of the floating rate loan (paid by Orange Belgium), the floating rate IRS (received by Orange Belgium) and

the fixed rate IRS (paid by Orange Belgium), transforms the hedged portion of the floating 6-month rate loan into a 5-year fixed rate

loan. The combination of the floating rate loan (paid by Orange Belgium), the floating rate IRS (received by Orange Belgium) and the

fixed rate IRS (paid by Orange Belgium), transforms the floating rate loan into a 5-year fixed rate loan. No major sources of hedge

ineffectiveness have been identified.

Hedge derivative instruments open at the end of the year 2025 are:

Start Date	End date	Option	Exercise price	Floating rate	Notional Amount
24/05/2023	24/05/2028	IRS	2.7778%	EURIBOR 6M	350 000 000
24/05/2023	24/05/2028	IRS	2.8640%	EURIBOR 6M	175 000 000
24/05/2023	24/05/2028	IRS	2.7660%	EURIBOR 6M	175 000 000
24/05/2023	24/05/2028	IRS	2.7010%	EURIBOR 6M	175 000 000

Hedge derivative instruments open at the end of the year 2024 are:

Start Date	End date	Option	Exercise price	Floating rate	Notional Amount
24/05/2023	24/05/2028	IRS	2.7778%	EURIBOR 6M	350 000 000
24/05/2023	24/05/2028	IRS	2.8640%	EURIBOR 6M	175 000 000
24/05/2023	24/05/2028	IRS	2.7660%	EURIBOR 6M	175 000 000
24/05/2023	24/05/2028	IRS	2.7010%	EURIBOR 6M	175 000 000

Fair value of financial instruments

The carrying amount of cash and cash equivalents, trade receivables and other assets, trade payables and other payables is deemed

to represent their fair value considering the associated short-term maturity.

Interest rate risk		in thousand EUR
	31.12.2025	31.12.2024
Balance at 1 January -Cash flow hedge reserve	-12 272	-6 658
Change in cash flow hedge reserve	0	0
Gain/loss recognized in other comprehensive income	5 772	-7 486
of which gain/(loss) arising on changes in fair value of hedging instruments during the period	8 686	-17 700
of which (gain)/loss reclassified to profit or loss -hedged item has affected profit or loss	-2 914	10 214
Income tax related to gain/(loss) recognised in other comprehensive income	-1 443	1 872
of which income gain/(losses) recognised in other comprehensive income during the period	-2 172	4 426
of which income tax related to amounts reclassified to profit or loss	729	-2 554
Balance at 31 December -Cash flow hedge reserve	-7 943	-12 272

257

Maturity

The following are the remaining contractual maturities of financial assets and liabilities at the reporting date. The amounts are gross

and undiscounted. They exclude the impact of netting agreements and considered contractual interest payments where appropriate.


				in thousand EUR
		Within	Within	More than
Year ended December 2025	Amount	1 year	2-5 years	5 years
Financial assets
Non-current financial assets	1 970			1 970
Non-current derivatives assets
Trade receivables	245 012	245 012
Current financial assets	1 998	1 998
Current derivatives assets	463	463
Cash and cash equivalents	80 628	80 628
Financial liabilities
Non-current financial liabilities	1 805 206	67 748	1 787 195	263
Non-current derivatives liabilities	11 089		11 089
Current financial liabilities	205 014	205 014
Current derivatives liabilities	463	463
Trade payables	335 679	335 679


				in thousand EUR
		Within	Within	More than
Year ended December 2024	Amount	1 year	2-5 years	5 years
Financial assets
Non-current financial assets	1 678			1 678
Non-current derivatives assets	0
Trade receivables	220 771	220 771
Current financial assets	2 125	2 125
Current derivatives assets	203	203
Cash and cash equivalents	58 245	58 245
Financial liabilities
Non-current financial liabilities	2 177 172	84 311	2 092 359	502
Non-current derivatives liabilities	16 861		16 861
Current financial liabilities	76 109	76 109
Current derivatives liabilities	203	203
Trade payables	286 070	286 070

Sensitivity

As indicated above, the main risk area related to external variable elements is the cost of borrowing. Considering an average long-

term debt of 1,791.2 million euros in 2025 (of which 875 million euros is covered by the IRS described above), a 1% variation of the

floating rate would have 9.2 million euros impact on the financing costs of the non-hedged portion of the long-term debt.

Considering an average long-term debt of 1,851.6 million euros in 2024 (of which 875 million euros is covered by the IRS described

above), a 1% variation of the floating rate would have 9.9 million euros impact on the financing costs of the non-hedged portion of

the long-term debt.

Non-current derivatives liabilities

In 2025 non-current derivatives liabilities amount to 11.1 million euros and correspond to the fair value of financial derivatives

instruments set in place in the context of the interests hedging strategy.

In 2024 non-current derivatives liabilities amount to 16.9 million euros and correspond to the fair value of financial derivatives

instruments set in place in the context of the interests hedging strategy.

258

Fair value of financial assets and liabilities

The table below is presented according to IFRS 9:

						in thousand EUR
				Level 1
	Classification under	Book	Estimated	and
31.12.2025	IFRS 9 (*)	value	fair value	cash	Level 2	Level 3
Trade receivables	AC	245 012	245 012		245 012
Financial assets		3 968	3 968			3 968
Equity securities	FVR	1 970	1 970			1 970
Financial assets at amortized cost	AC	1 998	1 998			1 998
Cash and cash equivalents		80 628	80 628		80 628
Cash	AC	80 628	80 628		80 628
Cash equivalents
Trade payables	AC	335 679	335 679		335 679
Financial debts	AC	1 895 744	1 856 460		1 856 460
Derivatives (net amount) (**)		11 089	10 848		10 848

* AC” stands for “amortized cost”, “FVR” stands for “fair value through profit or loss”

**IFRS 9 classification for derivatives instruments depends on their hedging qualification (the derivatives qualified as cash flow hedging instruments)

						in thousand EUR
	Classification under	Book	Estimated	Level 1 and
31.12.2024	IFRS 9 (*)	value	fair value	cash	Level 2	Level 3
Trade receivables	AC	220 771	220 771		220 771
Financial assets		3 803	3 803			3 803
Equity securities	FVR	1 678	1 678			1 678
Financial assets at amortized cost	AC	2 125	2 125			2 125
Cash and cash equivalents		58 245	58 245		58 245
Cash	AC	58 226	58 226		58 226
Cash equivalents	AC	19	19		19
Trade payables	AC	286 070	286 070		286 070
Financial debts	AC	1 963 110	1 912 043		1 912 043
Derivatives (net amount) (**)		16 861	16 327		16 327

*“AC” stands for “amortized cost”, “FVR” stands for “fair value through profit or loss”

**IFRS 9 classification for derivatives instruments depends on their hedging qualification (the derivatives qualified as cash flow hedging instruments)

The financial assets and liabilities measured at fair value in the statement of financial position have been classified based on three

hierarchy levels:

-

level 1: quoted prices (unadjusted) in active markets for identical assets or liabilities that the entity can access at the measurement

date;

-

level 2: inputs that are observable for the asset or liability, either directly or indirectly;

-

level 3: unobservable inputs for the asset or liability.

The fair value of investment securities uses a valuation technique determined according to the most appropriate financial criteria in

each case (comparable transactions, multiples for comparable companies, shareholders’ agreement, discounted present value of

future cash flows).

For financial assets at amortized cost, the Group considers that the carrying amount of cash and trade receivables provide a

reasonable approximation of fair value, due to the high liquidity of these elements.

For financial liabilities at amortized cost, the fair value of financial liabilities is determined using the present value of estimated future

cash flows, discounted using rates observed by the Group at the end of the period.

The Group considers the carrying value of trade payables to be a reasonable approximation of fair value, due to the high liquidity. The

fair value of derivatives is determined using the present value of estimated future cash flows, discounted using the interest rates

observed by the Group at the end of the period.

259

Note 10: Shareholders’ equity

Share capital

In 2025; There were no changes in capital.


	Share capital	Number of ordinary shares
	(in thousand EUR)	(in units)
As at 1 January 2025	148 149	67 412 205
As at 31 December 2025	148 149	67 412 205

All ordinary shares are fully paid and have a par value of 2.197 euros.

Dividends

The Orange Belgium Group policy is to balance the appropriate cash returns to equity holders with the requirement of maintaining a

balanced and sound financial position, while leaving sufficient leeway to continue to invest in its convergent strategy and the build-

out of its network. Management monitors the return on capital, as well as the level of dividends to ordinary shareholders.

Treasury shares

No Treasury shares were held at 31 December 2025 and at 31 December 2024.

Note 11: Commitments and contingencies

Operational activities commitments


				in thousand EUR
	31.12.2025	Less than one year	From one to five years	More than five years
Handsets purchases	89 313	89 313	0	0
Other goods and services purchases	64 030	23 264	20 052	20 714
Investment commitments	75 664	73 838	1 826	0
Operational activities commitments	229 007	186 415	21 878	20 714

The investment commitments consist mainly of investments into tangible fixed assets for 38.3 million euros and intangible fixed assets

for 22.5 million euros.

Guarantees granted


				in thousand EUR
	31.12.2025	Less than one year	From one to five years	More than five years
Guarantees granted	260 045	1 169	1 132	257 744

In 2025, the guarantees granted are mainly related to the pledge agreement with Enodia ( 250M€). As part of the demerger of VOO

S.A., Orange Belgium signed a pledge agreement with Enodia to replace the one initially signed between VOO SA and Enodia (in

accordance with the subcontracting agreement concluded on June 2, 2023).

The remaining of 10m€ consists of bank guarantees.

260

Note 12: (Non)-current provisions


							in thousand EUR
					Consolidation	Other
	31.12.2024	Additions	Utilisations	Reversal	scope	effect	31.12.2025
Provisions for dismantling	59 770	0	-4 594	0	0	4 089	59 265
Provisions for litigations	4 333	247	-897	-2 356	0	876	2 203
Total provisions	64 103	247	-5 491	-2 356	0	4 965	61 468


							in thousand EUR
					Consolidation	Other
	31.12.2023	Additions	Utilisations	Reversal	scope	effect	31.12.2024
Provisions for dismantling	61,951	0	-5,602	0	0	3,425	59 774
Provisions for litigations	3 051	2 211	-564	-465	0	100	4 333
Total provisions	65 102	2 211	-6 166	-465	0	3 425	64 107

Provisions for dismantling consist of current (4.1 million euros) and non-current provisions (55.1 million euros) (see also Note 6 –Other

intangible assets).

Provisions for litigations are recorded in other (non)-current liabilities.

Outstanding litigation

Orange Belgium is engaged in various judicial procedures whereby third-party individuals or entities are claiming repair of damages

they claim to have incurred. Each litigation is assessed on an individual basis in order to assess as to whether it is more likely than not

that an outflow of resources will be necessary to settle the litigation and ensures that the assumptions to quantify the provisions are

valid.

Outstanding claims are built up during the previous years and it can be reasonably assumed that they will be subject to a Court

decision or solved by means of a settlement agreement within the coming years.

Network sites dismantling provision

See Note 5 – Other intangible assets and property, plant and equipment.

Note 13: Related parties

Relationships with affiliated enterprises

Balance sheet and income statement


		in thousand EUR
	31.12.2025	31.12.2024
ASSETS
Current receivables	-36 010	-41 774
LIABILITIES
Current interest-bearing loan	183 589	49 130
Non-current interest-bearing loan	1 671 190	1 851 592
Current trade payables	1 634	1 449
INCOME AND CHARGES
Sales	35 699	35 235
Purchases	-102 570	-91 494
Interests	-80 352	-107 849

The ultimate parent entity of Orange Belgium S.A. is Orange S.A., 111 quai du Président Roosevelt, CS 70222, 92449 Issy les

Moulineaux Cedex, France.

261

Related party transactions


				in thousand EUR
	Sales to	Purchases from	Amounts owed by	Amounts owed to
31.12.2025	related parties	related parties	related parties	related parties
Orange Group* -Traffic and services	24 506	-48 907
Orange S.A.-Cash pool		-415	-36 327	62 014
Orange Group Affiliates -Traffic and services	10 565	-22 494	-1 430	5 252
Atlas Services Belgium -Loan	10	-79 958	28	1 785 829
Brand fees to Orange S.A.	531	-21 146
Mwingz	87	-10 002	1	2 005
Total	35 699	-182 922	-36 010	1 856 413

* Any entity within the Groupe Orange S.A


				in thousand EUR
	Sales to	Purchases from	Amounts owed by	Amounts owed to
31.12.2024	related parties	related parties	related parties	related parties
Orange Group* -Traffic and services	24 906	-39 619	0	0
Orange S.A.-Cash pool	0	129	-40 287	48 391
Orange Group Affiliates -Traffic and services	9 574	-20 914	-1 505	7 949
Atlas Services Belgium -Loan	11	-107 939	17	1 843 656
Brand fees to Orange S.A.	650	-21 159	0	0
Mwingz	94	-9 841	1	2 175
Total	35 235	-199 343	-41 774	1 902 171

* Any entity within the Groupe Orange S.A

Terms and conditions of transactions with related parties

Terms and conditions for the sale and purchase of traffic and services, to the centralized treasury management agreement and to the

revolving credit facility agreement are determined on an arm’s length basis according to the normal market prices and conditions.

Following the rebranding exercise in 2016, Orange Belgium benefited from a three-year grace period. As from May 2019, a brand fee

is charged on a yearly basis by the ultimate parent Orange S.A. which is mainly calculated as a percentage of retail service revenues.

Relationships with Board of Directors members and senior management


		in thousand EUR
	31.12.2025	31.12.2024
Short-term employees benefits	4 892	3 905
Post-employment benefits	507	503
Other long-term benefits	1 474	997
Termination benefits	0	0
Total	6 873	5 405

The total remuneration attributed to the Board of Directors (excluding the normal compensation of the CEO which is included in the

table above) is as follows:


		in thousand EUR
	31.12.2025	31.12.2024
Total Remuneration	345	318

262

Note 14: Liabilities related to contracts with customers and other assets

related to contracts with customers

Customer contract net assets and liabilities


		in thousand EUR
	31.12.2025	31.12.2024
Customer contract net assets (1)	120 384	109 703
Costs of obtaining a contract	7 056	8 164
Costs to fulfill a contract	23	27
Total customer contract net assets	127 463	117 894
Prepaid telephone cards	-8 984	-10 309
Connection fees	-388	-561
Other deferred revenue (2)	-60 570	-54 238
Other customer contract liabilities	-560	-512
Total deferred revenue related to customer contracts	-70 502	-65 620
Total customer contract net assets and liabilities	56 961	52 274

(1) Assets net of remaining performance

(2) Includes subscription fees

The amount of contract related net assets and liabilities (IFRS 15), in the balance sheet as at 31 December 2024 and taken into profit

& loss during 2025, amounts to -80.8 million euros (-62.1 million euros in profit & loss of 2024, on balance sheet as at 31 December

2023).

This is due to the increase in contracts in 2025.

The following tables give an analysis of the balances of customer contract net assets:


		in thousand EUR
	2025	2024
Customer contract net assets -in the opening balance (1)	109 703	88 653
Business related variations	10 681	21 050
Changes in the scope of consolidation	0	0
Customer contract net assets -in the closing balance	120 384	109 703

(1) Mainly includes the new customer contract assets net of related liabilities, the transfer of the net contract assets directly to trade receivables and

impairment of the period.

Recoverability of contract assets is assessed using a churn rate based on the ageing of the contract.

The change in deferred income on customer contracts (prepaid telephone cards, service access fees and other unearned income) in

the statement of financial position is presented below.


		in thousand EUR
	2025	2024
Deferred revenue related to customer contracts -in the opening balance	65 620	67 571
Business related variations	4 882	-1 951
Changes in the scope of consolidation
Deferred revenue related to customer contracts -in the closing balance	70 502	65 620

Trade receivables presented in the consolidated statement of financial position represent an unconditional right to receive

consideration (primarily cash), i.e. the services and goods promised to the customer have been transferred.

By contrast, contract assets mainly refer to amounts allocated per IFRS 15 as compensation for goods or services provided to

customers for which the right to collect payment is subject to providing other services or goods under that same contract (or group

of contracts). This is the case in a bundled offer combining the sale of a mobile phone and mobile communication services for a fixed

period, where the mobile phone is invoiced at a reduced price leading to the reallocation of a portion of amounts invoiced for telephone

communication services to the supply of the mobile phone. The excess of the amount allocated to the mobile phone over the price

invoiced is recognized as a contract asset and transferred to trade receivables as the service is invoiced.

Contract assets, like trade receivables, are subject to impairment for credit risk. The recoverability of contract assets is also verified,

especially to cover the risk of impairment should the contract be interrupted. Recoverability may also be impacted by a change in the

legal environment governing offers.

263

Contract liabilities represent amounts paid by customers to Orange before receiving the goods and/or services promised in the

contract. This is typically the case for advances received from customers or amounts invoiced and paid for goods or services not yet

transferred, such as contracts payable in advance or prepaid packages.

Customer contract assets and liabilities are presented, respectively, in current assets and current liabilities since they are normal part

of the Group’s operations.


		in thousand EUR
	2025	2024
Costs of obtaining a contract -in the opening balance	8 164	11 969
Business related variations	-1 108	-3 805
Costs of obtaining a contract -in the closing balance	7 056	8 164

Where a telecommunications service contract is signed via a third-party distributor, this distributor may receive business provider

remuneration, generally paid in the form of a commission for each contract or invoice-indexed commission. Where the commission is

incremental and would not have been paid in the absence of the contract, the commission cost is estimated and capitalized in the

balance sheet. It should be noted that the Group has adopted the simplification measure authorized by IFRS 15 to recognize the costs

of obtaining contracts as an expense when they are incurred if the amortization period of the asset, it would have recognized in respect

of them, would not have exceeded a year.

The costs of obtaining fixed-period mobile service contracts are capitalized and released to profit or loss on a straight-line over the

enforceable contract term, as these costs are generally incurred each time the customer renews the fixed-period.

There are no costs to fulfil a contract in Orange Belgium S.A.

The following table presents the transaction price assigned to unfulfilled performance obligations as at 31 December 2025. Unfulfilled

performance obligations are the services that the Group is obliged to provide to customers during the remaining fixed term of the

contract. As allowed by the simplification method procedure in IFRS 15, these disclosures are only related to performance obligations

with an internal term greater than one year.


			in thousand EUR
		Total	Total
		2025.12	2024.12
Less than one year	Y01	95 872	106 150
Between 1 and 2 years	Y02	34 181	38 609
Between 2 and 3 years	Y03	231	162
Between 3 and 4 years	Y04	25	20
Between 4 and 5 years	Y05	0
More than 5 years	Y99	0
Total		130 309	144 941

On the allocation of the total contract transaction price to identified performance obligations, a portion of the total transaction price

can be allocated to performance obligations that are unsatisfied or partially satisfied at the end of the reporting period. We have

elected to apply certain available practical expedients when disclosing unfulfilled performance obligations, including the option to

exclude expected revenues from unsatisfied obligations of contracts with an original expected duration of one year or less. These

contracts are primarily monthly service contracts.

In addition, certain contracts offer customers the ability to purchase additional services. These additional services are not included in

the transaction price and are recognized when the customer exercises the option (generally monthly). They are not therefore included

in unfulfilled performance obligations.

264

Note 15: Lease agreements

In the course of its activities, the Group regularly enters into leases as a lessee. The leases concern the following asset categories:

-

Land and buildings

-

Network and terminals

-

Other

Lease liabilities

As of 31 December 2025, lease liabilities amount to 192.2 million euros, including non-current lease liabilities of 162.7 million euros

and current lease liabilities of 29.5 million euros.


		in thousand EUR
	2025	2024
Lease liabilities – in the opening balance	180,073	204 769
Increase with counterpart in right-of-use	37 820	29 461
Changes in the scope of consolidation
Decrease in liabilities following rental payments	-54 697	-57 003
Impact of changes in assessments	12 730	2 836
Translation adjustment
Lease liabilities – in the closing balance	192 229	180 073
O/w non-current lease liabilities	162 717	150 351
O/w current lease liabilities	29 512	29 723

The increase in the lease liability and in the right of use assets balances comes from the re-assessment of the ending dates of the

contracts and the normal additions and payments following new contracts.

The interests on finance leases decreased from 5.8 million

euros to 5.4 million euros.

The following table details the undiscounted future cash flows of lease liabilities:


							in thousand EUR
	31 December						2031 and
	2025	2026	2027	2028	2029	2030	beyond
Undiscounted lease liabilities	190 393	40 813	32 437	26 713	18 431	14 365	57 634

265

Right-of-use assets


				in thousand EUR
	Gross	Accumulated	Accumulated	Net book
31.12.2025	value	depreciation	impairment	value
Land and buildings	367 737	-211 538		156 199
Networks and terminals	3 273	-2 488		785
IT equipment	0	0		0
Other right-of-use	50 860	-25 175		25 685
Total right-of-use assets	421 870	-239 201		182 669


				in thousand EUR
	Gross	Accumulated	Accumulated	Net book
31.12.2024	value	depreciation	impairment	value
Land and buildings	340 238	-191 704		148 534
Networks and terminals	2 884	-2 053		831
IT equipment	0	0		0
Other right-of-use	43 817	-20 792		23 025
Total right-of-use assets	386 939	-214 549		172 390


		in thousand EUR
	2025	2024
Net book value of right-of-use assets -in the opening balance	188 693	200 805
Increase (new right-of-use assets)	39 568	29 989
Impact of changes in the scope of consolidation
Depreciation	-58 877	-60 982
Impact of changes in the assessments	13 285	2 579
Net book value of right-of-use assets -in the closing balance	182 669	172 391

The total expenses relating to short-term leases or low cost items for which the recognition exemption is applied is very limited in both

years presented.

Note 16: Significant changes to the consolidation scope

There were no significant changes in the consolidation scope for the year 2025 that have an impact on the financial statements

compared to the consolidation scope of 2024.

Note 17: Significant accounting policies

Summary of significant accounting policies

Transactions in foreign currencies

On initial recognition in the functional currency, a foreign currency transaction is recorded by applying the spot exchange rate between

the functional currency and the foreign currency at the date of the transaction. At each balance sheet date, foreign monetary assets

and liabilities are translated using the closing rate.

Exchange gains and losses are recognized as operational income and expenses when they are related to the operational activities.

Exchange gains and losses are recognized as financial income and expenses only when they are related to the financing activities.

Business combinations, goodwill and goodwill impairment

Business combinations are accounted for applying the acquisition method:

-

the acquisition cost is measured at the acquisition date at the fair value of the consideration transferred, including all

contingent consideration. Subsequent changes in contingent consideration are accounted for either through profit or loss or

through other comprehensive income in accordance with the applicable standards;

266

-

if the initial accounting for a business combination is incomplete by the end of the reporting period in which the combination

occurs, the Group reports provisional amounts for the items for which the accounting is incomplete. Those provisional

amounts are adjusted during the measurement period, or additional assets or liabilities are recognized, to reflect new

information obtained about facts and circumstances that existed at the acquisition date that, if known, would have affected

the amounts recognized at that date;

-

Goodwill is the difference between the consideration transferred and the fair value of the identifiable assets and liabilities

assumed at the acquisition date and is recognized as an asset in the statement of financial position.

For each business combination with ownership interest below 100%, non-controlling interests are measured:

-

either at fair value: in this case, goodwill relating to non-controlling interests is recognized; or

-

at the non-controlling interest’s proportionate share of the acquiree’s identifiable net assets: in this case, goodwill is only

recognized for the share acquired.

Acquisition related costs are directly recognized in the income statement during the period in which they are incurred.

When a business combination is achieved in stages, the previously held equity interest is re-measured at fair value at the acquisition

date through profit or loss. The attributable other comprehensive income, if any, is recognized on the same basis as would be required

if the previously held equity interests would have been disposed.

Goodwill is not amortized but tested for impairment at least annually or more frequently when there is an indication that it may be

impaired. Therefore, the evolution of general economic and financial trends, the different levels of resilience of the telecommunication

operators with respect to the decline of local economic environments, the changes in the market capitalization values of

telecommunication companies, as well as actual economic performance compared to market expectations represent external

indicators that are analyzed by the Group, together with internal performance indicators, in order to assess whether an impairment

test should be performed more than once a year.

IAS 36 requires these tests to be performed at the level of each Cash Generating Unit (CGU) or groups of CGUs likely to benefit from

acquisition-related synergies. To determine whether an impairment loss should be recognized, the carrying value of the assets and

liabilities of the CGUs or groups of CGUs is compared to the recoverable amount. The recoverable amount of a CGU is its value in

use.

Value in use is the present value of the future cash flows expected to be derived from the CGUs. Cash flow projections are based on

economic and regulatory assumptions, license renewal assumptions and forecast trading conditions drawn up by the Group’s

management, as follows:

-

cash flow projections are based on five-year business plans;

-

cash flow projections beyond that timeframe may be extrapolated by applying a declining or flat growth rate over the next

two years (for some CGUs), followed by a growth rate to perpetuity reflecting the expected long-term growth in the market;

-

the cash flows obtained are discounted using appropriate rates for the type of business and the countries concerned.

Carrying values of CGUs tested include goodwill, intangible assets with indefinite useful life arising from business combinations and

assets with finite useful life (property, plant and equipment, intangible assets and net working capital, including intragroup balances).

Net book values are disclosed at the level of the CGUs and groups of CGUs, i.e. including accounting items related to transactions

with other CGUs and groups of CGUs.

For a CGU partially owned by the Group, when it includes a portion relating to non-controlling interests, the impairment loss is allocated

between the owners of the parent and the non-controlling interests on the same basis as that on which profit or loss is allocated (i.e.

ownership interest).

Impairment loss for goodwill is accounted for in the income statement and is never subsequently reversed.

The values in use of the businesses, which are most of the recoverable amounts and which support the book values of long-term

assets, are sensitive to the valuation method and the assumptions used in the models. They are also sensitive to any change in the

business environment that is different from the assumptions used. The Company recognizes assets as impaired if events or

circumstances occur that involve material adverse changes of a permanent nature affecting the economic climate or the assumptions

and targets used at the time of the acquisition. New events or adverse circumstances could conduct the Company to review the

present value of its assets and to recognize further substantial impairment losses that could have an adverse effect on its results.

Impairment test on the goodwill allocated to the segment “Belgium” is performed at least at the end of each financial year to assess

whether its carrying amount does not exceed its recoverable amount. Estimating the fair value less costs to sell will take into account

the Company’s share price as quoted on the stock exchange.

267

Intangible assets

This asset category includes intangible assets with a finite useful life such as the cost of the telecommunication licenses, the cost of

network design and development, the cost of purchased and internally generated software.

Intangible assets are measured on initial recognition at cost. The cost includes the purchase price, import duties, non-refundable

purchase taxes, after deduction of trade discounts and rebates, and any directly attributable costs of preparing the asset for its

intended use, i.e. costs of employee benefits, professional fees and testing costs.

When an acquisition of intangible assets includes a long-term payment plan of fixed amounts (meaning, predictable based on

calculation criteria which are not under the control of the entity (no variability depending on the activity) with a certain obligation of

payment (expected future minimum payment), the discounted value of the fix amounts over the plan are included in the acquisition

costs. This has been the case for the licenses acquired in 2022 for which the structure of the license fees payable over the lifetime of

the licenses includes amounts that are eligible to such a qualification. Consequently, licenses acquired in 2022 have been capitalized

as such:

-

One off amount paid at the time the license becomes available for use

-

Net present value of the yearly fixed amounts of spectrum fees to be paid over the license period. A corresponding liability

has been recorded in current and non-current fixed assets payable. This net present value corresponds to the discounted

value of the fixed amounts of spectrum fee payable over the license period at the discount rate prevailing at the moment of

the calculation over the maturity of the debt. As from the booking of the debt, unwinding based on the original discount rate

will be recorded in financial expenses and annual payments will be applied against the debt itself.

After initial recognition, intangible assets are carried at cost less any accumulated amortization and impairment losses. The residual

value of intangible assets is assumed to be zero unless the conditions provided for by IAS 38 are met.

Intangible assets are amortized over the useful life and assessed for impairment whenever there is an indication that the intangible

asset may be impaired.

The depreciable amount of an intangible asset with a finite useful life is allocated on a linear basis over its useful life. The amortization

of the mobile licenses starts when they are ready to operate.

Amortization of the licenses should start when the asset is available for use, i.e. when it is in the location and technical condition

necessary for it to be capable of operating in the manner intended by the management, even if the asset is actually not being used.

The license will be available for use when the first geographical zone will be declared “ready to launch” by the technical team. The full

amount will be amortized on a straight-line basis over its remaining useful life of that date.

The GSM and UMTS licenses have been granted for a period of 15 years (originally) and 20 years respectively.

In 2011, the 4G license has been granted for a period of 15 years, till the 1 of July 2027. The 800 MHz license was acquired in

November 2013 and is valid for a period of 20 years.

In the auction launched in 2022 on the primary phase, Orange Belgium won a total of 200 MHz of frequencies on the 700 MHz, 900

MHz, 1800 MHz, 2100 MHz and 3600 MHz bands. In the secondary phase of the auction, Orange Belgium won 30 MHz of frequencies

in the 1400 MHz band. The rights to use the 700 MHz and 3600 MHz bands started on 1 September 2022 for respectively 20 years

and 17 years and 8 months.) The rights of use for the 900, 1800, 2100 MHz bands will begin on 1 January 2023 for a period of 20

years. For 1400 MHz, the availability for use will start on 1 July 2023 for a period of 20 years.

The useful life of acquired and internally generated software is 5 years (network software) or 4 years (non-network software) and their

amortization starts when the software is ready for use.

The fair value of the customer relationships acquired in a business combination is determined using the multi-period excess earnings

method and is amortised over a useful life ranging from 10 till 20 years.

The amortization period and amortization method for an intangible asset with a finite useful life are reviewed at least at each financial

year-end. Any change in the useful life or in the expected pattern of consumption of the future economic benefits embodied in the

asset, is accounted for prospectively as a change in an accounting estimate. The changes in useful life on intangible assets recognized

during the year are determined on individual asset basis. Obsolescence, dismantling or losses are also considered in the exercise.

Amortization costs are recorded in the income statement under the heading “Depreciation and amortization of other intangible assets

and property, plant and equipment”.

Research costs are expensed as incurred. Development expenditure on an individual project is recognized as an intangible asset when

the Group can demonstrate the technical feasibility of completing the intangible asset so that it will be available for use or sale, its

intention to complete and its ability to use or sell the asset, how the asset will generate future economic benefits, the availability of

resources to complete the asset and the ability to measure reliably the expenditure during development.

Following initial recognition of the development expenditure as an asset, the cost model is applied requiring the asset to be carried at

cost less any accumulated amortization and accumulated impairment losses. Amortization of the asset begins when development is

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complete and the asset is available for use. It is amortized over the period of expected future benefit. During the period of development,

the asset is tested for impairment annually.

Property, plant and equipment

The following items of property, plant and equipment are classified under the tangible assets category: building, network infrastructure

and equipment, IT servers and personal computers, office furniture, leasehold improvements, equipment leased to customers.

Upon recognition, tangible assets are measured at cost. The cost includes the purchase price, import duties and non-refundable

purchase taxes, after deduction of trade discounts and rebates, and any costs directly attributable to bringing the asset to the location

and condition for it to be capable of operating in the expected manner. The cost of replacing part of an item of property, plant and

equipment is recognized as an asset when incurred and if the recognition criteria are met. All other repair and maintenance costs are

recognized in profit or loss as incurred. The cost also includes the estimated cost to dismantle the network sites and to refurbish the

rented premises when such obligation exists.

The costs related to the installation & activation of the cable and that are directly attributable to bring the asset into working condition

for its intended use, are recognized as an asset.

After initial recognition, tangible assets are measured at cost less any accumulated depreciation and impairment losses.

The depreciable amount of a tangible asset is allocated on a systematic and linear basis over its useful life. The depreciation of a

tangible asset starts when it is ready to operate as intended.

The useful life of each category of tangible assets has been determined as follows:


-	Building	20 years
-	Pylons and network constructions	20 years
-	Optical fiber	15 years
-	Network equipment	5-10 years
-	Messaging equipment	5 years
-	IT servers	5 years
-	Personal computers	4 years
-	Office furniture	5-10 years
-	Leasehold improvements	9 years or rental period if shorter
-	Cable equipment/modems & setup boxes	3-4 years

The residual value and the useful life of a tangible asset are reviewed at least at each financial year-end and, if expectations differ from

previous estimates, the changes are accounted for prospectively as a change in an accounting estimate. The changes in useful life on

tangible assets recognized during the year are determined on individual asset basis. Obsolescence, dismantling or losses are also

considered in the exercise.

The costs related to the activation of the cable also includes the costs related to installation work performed at the customer’s location

to install the modem and are amortized over three years, based upon stable historical usage data available within the Orange Group.

Depreciation costs are recorded in the income statement under the heading “Depreciation and amortization of other intangible assets

and property, plant and equipment”.

An item of property, plant and equipment is derecognized upon disposal or when no future economic benefits are expected from its

use or disposal. Any gain or loss arising on de-recognition of the asset is included in the income statement in the year the asset is

derecognized.

Accelerated depreciation is the depreciation of fixed assets at a faster rate early in their useful lives and is mainly used at the Company

when management decides to take assets out of service early (ex. dismantling of technical sites). The net book value of that asset will

then be depreciated over the remaining period (of service).

The asset retirement obligation (ARO) relating to the network sites is measured based on the known term of sites rental contracts,

assuming a high probability of renewal upon each renewal date and considering that the entire sites park will be dismantled in the

future. The dismantling asset is measured by using appropriate inflation and discount rates.

The Group is required to dismantle technical equipment and restore technical sites.

When the obligation arises, a dismantlement asset is recognized in compensation for the dismantling provision.

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The provision is based on dismantling costs (on a per-site basis) incurred by the Group to meet its environmental commitments over

the asset dismantling and site restoration planning. The provision is assessed on the basis of the identified costs for the current fiscal

year, extrapolated for future years using the best estimate of the commitment settlement. This estimate is revised annually and

adjusted where appropriate against the asset to which it relates. The provision is present-discounted.

Impairment of tangible and intangible items other than goodwill

The Group assesses at each balance sheet date whether there is an indication that an asset may be impaired. If any such indication

exists, or when annual impairment testing for an asset is required, the Company makes an estimate of the asset's recoverable amount.

An asset's recoverable amount is the higher of an asset's or cash-generating unit's fair value less costs to sell and its value in use and

is determined for an individual asset, unless the asset does not generate cash inflows that are largely independent of those from other

assets or groups of assets. Where the carrying amount of an asset exceeds its recoverable amount, the asset is considered impaired

and is written down to its recoverable amount. In assessing value in use, the estimated future cash flows are discounted to their

present value using a post-tax discount rate that reflects current market assessments of the time value of money and the risks specific

to the asset. Impairment losses are recognized in the income statement in the operating expenses under the heading “Impairment of

fixed assets” which also includes the losses on material never deployed on sites, IT project never put in service, site civil works never

finally deployed.

For assets excluding goodwill, an assessment is made at each reporting date as to whether there is any indication that previously

recognized impairment losses may no longer exist or may have decreased. If such indication exists, the Group estimates the asset's

or cash-generating unit's recoverable amount. A previously recognized impairment loss is reversed only if there has been a change in

the assumptions used to determine the asset's recoverable amount since the last impairment loss was recognized. The reversal is

limited so that the carrying amount of the asset does not exceed its recoverable amount, nor exceed the carrying amount that would

have been determined, net of depreciation, had no impairment loss been recognized for the asset in prior years. Such reversal is

recognized in the income statement unless the asset is carried at revalued amount, in which case the reversal is treated as a revaluation

increase.

Borrowing costs

Borrowing costs are capitalized after 1 January 2009. Evaluation of the need to capitalize borrowing costs is made at project level. Up

to end of 2008, borrowing costs were recognized as an expense in the period in which they occurred.

Government grants

A government grant is recognized when there is a reasonable assurance that the grant will be received, and the conditions attached

to them are complied with.

When the grant relates to an expense item, it is recognized as income over the period necessary to match on a systematic basis to

the costs that it is intended to compensate.

Where the grant relates to an asset, the fair value is credited to the carrying amount of the asset and is released to the income

statement over the expected useful life of the relevant asset by equal annual instalments.

Taxes

Current income taxes

Current income tax assets and liabilities for the current and prior periods are measured at the amount expected to be recovered from

or paid to the taxation authorities. The tax rates and tax laws used to compute the amount are those that are enacted or substantively

enacted by the balance sheet date.

Deferred income tax

Deferred income tax is provided using the liability method on temporary differences at the balance sheet date between the tax basis

of assets and liabilities and their carrying amounts for financial reporting purposes.

Deferred income tax liabilities are recognized for all taxable temporary differences, except:

-

where the deferred income tax liability arises from the initial recognition of goodwill or of an asset or liability in a transaction

that is not a business combination and, at the time of the transaction, affects neither the accounting profit nor taxable profit

or loss; and

-

in respect of taxable temporary differences associated with investments in subsidiaries, associates and interests in joint

ventures, where the timing of the reversal of the temporary differences can be controlled and it is probable that the temporary

differences will not reverse in the foreseeable future.

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Deferred tax assets are recognized for all deductible temporary differences, carry forward of unused tax credits and unused tax losses,

to the extent that it is probable that taxable profit will be available against which the deductible temporary differences, and the carry

forward of unused tax credits and unused tax losses can be utilized except:

-

where the deferred income tax asset relating to the deductible temporary difference arises from the initial recognition of an

asset or liability in a transaction that is not a business combination and, at the time of the transaction, affects neither the

accounting profit nor taxable profit or loss; and

-

in respect of deductible temporary differences associated with investments in subsidiaries, associates and interests in joint

ventures, deferred income tax assets are recognized only to the extent that it is probable that the temporary differences will

reverse in the foreseeable future and taxable profit will be available against which the temporary differences can be utilized.

The carrying amount of deferred income tax assets is reviewed at each balance sheet date and reduced to the extent that it is no

longer probable that sufficient taxable profit will be available to allow all or part of the deferred income tax asset to be utilized.

Unrecognized deferred income tax assets are reassessed at each balance sheet date and are recognized to the extent that it has

become probable that future taxable profit will allow the deferred tax asset to be recovered.

Deferred income tax assets and liabilities are measured at the tax rates that are expected to apply to the year when the asset is

realized or the liability is settled, based on tax rates (and tax laws) that have been enacted or substantively enacted at the balance

sheet date.

Deferred income tax assets and deferred income tax liabilities are offset, if a legally enforceable right exists to set off current tax assets

against current income tax liabilities and the deferred income taxes relate to the same taxable entity and the same taxation authority.

Sales tax

Revenues, expenses and assets are recognized net of the amount of sales tax except:

-

where the sales tax incurred on a purchase of assets or services is not recoverable from the taxation authority, in which case

the sales tax is recognized as part of the acquisition cost of the asset or as part of the expense item as applicable; and

-

receivables and payables that are stated with the amount of sales tax included.

The net amount of sales tax recoverable from, or payable to, the taxation authority is included as part of receivables or payables in

the balance sheet.

Operational taxes: IFRIC 21

The IFRIC 21 interpretation was adopted by the European Union in the first semester 2014. It defines the obligating event that gives

rise to a liability to pay a levy (as the activity that triggers the levy) and refers to other standards to determine whether the recognized

liability gives rise to an asset or expense.

The Company applies IFRIC 21 in the consolidated financial statements to a limited number of levies whose accounting is modified

by the interpretation: property withholding tax, tax on office space, tax on class 1/2/3 sites (hazardous and/or insalubrious sites), sites

tax and taxes on advertising boards, panels, etc.

Inventories

Inventories are assets held for sale in the ordinary course of business, i.e. handsets and accessories.

Inventories are measured at the lower of cost and net realizable value. The cost of inventories comprises all costs of purchase, cost

of conversion and other costs incurred in bringing the inventories to their present location and condition. The measurement of our

inventories is determined by the weighted average method. The weighted average unit cost is the total amount that has been paid for

the inventory divided by the number of units in the inventory. Net realizable value is the estimated selling price in the ordinary course

of business, less estimated costs of completion and the estimated costs necessary to make the sale.

Cash and cash equivalents

Cash and cash equivalents include cash on hand and cash deposits with a maximum term of 3 months. Cash and cash equivalents

held with financial institutions are measured at nominal value. Banks and intercompany cash pooling overdrafts are classified as short-

term financial liabilities.

Own shares (liquidity contract)

The purchase of own (Orange Belgium) shares or obligations in the framework of a liquidity contract are accounted for as a deduction

from equity.

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Long-term provisions

Provisions are recognized when the Company has a present obligation (legal or constructive) as a result of a past event, it is probable

that an outflow of resources embodying economic benefits will be required to settle the obligation and a reliable estimate can be made

of the amount of the obligation.

Where the Company expects some or all of the provision to be reimbursed, the reimbursement is recognized as a separate asset but

only when the reimbursement is virtually certain. The expense relating to any provision is presented in the income statement net of

any reimbursement.

If the effect of the time value of money is material, provisions are discounted using a current pre-tax rate that reflects, where

appropriate, the risks specific to the liability. Where discounting is used, the increase in the provision due to the passage of time is

recognized as a borrowing cost.

The estimate of the dismantling costs regarding the network sites and of the refurbishment costs related to the rented premises is

recognized as an item of tangible asset. This estimate is also recognized as a provision that is measured by using appropriate inflation

and discount rates.

Employee benefits

Short-term employee benefits, such as wages, salaries, social security contributions, paid annual leave, profit-sharing and bonuses,

medical care, company cars and others are recognized during the period in which the service has been rendered by the employee.

Short-term employee benefits are shown as liabilities as a result of a legal or constructive present obligation and when a reliable

estimate of such liabilities can be made.

As a consequence of the law of 18 December 2015, minimum returns are guaranteed by the employer as follows:

-

for the contributions paid as from 1 January 2016, a new variable minimum return based on OLO rates, with a minimum of

1.75% and a maximum of 3.75%. In view of the low rates of the OLO in the last years, the return has been initially set to

1.75%;

-

for the contributions paid until end December 2015, the previously applicable legal returns (3.25% and 3.75% respectively

on the employer and employee contributions) continue to apply until retirement date of the participants.

In view of the minimum returns guarantees, those plans qualify as Defined Benefit plans.

To ensure that the defined contribution pension plan in force guarantees its participants the minimum return required by law at the

date of departure regarding the access, the Company ordered a complete actuarial computation under the PUC method without

projection of future contributions.

Leases

The Company classifies as a lease, a contract that conveys to the lessee the right to control the use of an identified asset for a given

period, including a service contract if it contains a lease component.

The Company has defined four major lease contract categories:

-

Land and buildings: these contracts mainly concern commercial (point of sale) or service activity (offices and head office)

leases, as well as leases of technical buildings not owned by the Group. Real estate leases entered into in Belgium generally

have long terms (between 7 and 11 years).

-

Networks and terminals: the Group is required to lease a certain number of assets in connection with its mobile activities.

This is notably the case of lands to be used to install antennas, mobile sites leased from a third-party operator and certain

“TowerCos” contracts (companies operating telecom towers). Leases are also entered into as part of fixed wireline access

network activities.

-

IT (& network) equipment: this asset category primarily comprises leases of servers and hosting space in datacenters.

-

Other: this asset category primarily comprises leases of vehicles.

There are no real relevant differences in the four categories in the context of IFRS 16, the rules and calculation methods are identical.

Leases are recognized in the consolidated statement of financial position via an asset reflecting the right to use the leased assets and

a liability reflecting the related lease obligations. In the consolidated income statement, amortization and depreciation of the right-of-

use asset is presented separately from the interest expense on the lease liability. In the consolidated statement of cash flows, cash

outflows relating to interest impact operating flows, while repayments of the lease liability impact financing flows.

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Finally, the Company applies the following authorized practical expedients:

-

Exclusion of leases with a residual term expiring within 12 months of the first application data. This practical expedient is

applied for all contracts, including those with a tacit renewal clause at the transition date. In applying this practical expedient,

the Group calls on its judgment and experience gained in the previous years to determine whether it is reasonably certain to

exercise a renewal option, taking account of the relevant facts and circumstances.

-

Exclusion of leases of assets with a replacement value of less than approximately 5,000 euros;

-

Exclusion of initial direct costs from the measurement of the right-of-use asset at the date of first-time application; and

-

The inclusion in the opening balance sheet of provisions for onerous contracts measured as of 31 December 2018 pursuant

to IAS 37, as an alternative to impairment testing of right-of-use assets in the opening balance sheet.

d.

Accounting policies Lease Liabilities:

The Company recognizes a liability (i.e. a lease liability) at the date the underlying asset is made available. This lease liability is equal

to the present value of fixed and fixed in-substance payments not paid at that date, plus any amounts that Orange is reasonably

certain to pay at the end of the lease, such as the exercise price of a purchase option (where it is reasonably certain to be exercised),

or penalties payable to the lessor for terminating the lease (where the termination option is reasonably certain to be exercised).

The Company only takes into account the lease component of lease when measuring the lease liability. For certain asset classes

where the lease includes service and lease components, the Group may recognize a single contract classified as a lease (i.e. without

distinction between the service and lease component).

Orange systematically determines the lease term as the period during which leases cannot be canceled, plus periods covered by any

extension options that the lessee is reasonably certain to exercise and by any termination options that the lessee is reasonably certain

not to exercise.

For open-ended leases, the Company generally adopts the notice period as the enforceable period. The Group nonetheless assesses,

based on the circumstances of each lease, the enforceable period taking account of certain indicators such as the existence of non-

insignificant penalties in the event of termination by the lessee. The Group considers in particular the economic importance of the

leased asset when determining this enforceable period.

For each contract, the Company applies a discount rate determined based on the loan yield specific to each contract, according to

its term plus the Group's credit spread if the interest rate can’t be readily determined from the contract.

In order to determine the loan yield specific to each contract, the Company applies the following method:

-

Determination of a risk-free rate curve according to the currency and maturity based on government bond yields.

-

Application of the Company’s credit spread according to the currency and maturity.

-

Selection of the applicable rate for each lease contract, corresponding to the average maturity of the contract.

After the lease commencement date, the amount of the lease liability may be reassessed to reflect changes introduced in the following

main cases:

-

A change in term resulting from a contract amendment or a change in assessment of the reasonable certainty that a renewal

option will be exercised, or a termination option will not be exercised;

-

a change in the amount of lease payments, for example following application of a new index or rate in the case of variable

payments; and

-

any other contractual change, for example a change to the scope of the lease or the underlying asset.

e.

Accounting policies ROU assets:

A right-of use is recognized as an asset, with a corresponding lease liability. The right-of-use asset is equal to the amount of the lease

liability at inception.

Work performed by the lessee and modifications to the leased asset, as well as guarantee deposits, are not components of the right-

of-use asset and are recognized in accordance with other standards.

Finally, the right-of-use asset is depreciated in the consolidated income statement on a straight-line basis over the lease term adopted

by the Group.

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f.

Accounting policies Identified assets:

-

In certain circumstances, the Company rents a space to set up an antenna. Most often, the space is a piece of land or a part

of a rooftop or balcony etc.… The identified asset is the part of land which is rented per the terms of the lease contract. In

most circumstances, the lease contract does not allow the owner of the space to substitute it by another one. Consequently,

the contracts most often do not include a substitution right to the owner. All benefits from use of the part of the land rented

are obtained by the Company. In certain circumstances, the Company rents a space on the tower and/or in the shelter from

a third-party operator. This space can be defined as a dedicated space, volume or payload in the contract. The contract

conveys the right to use an identified asset. The space in the tower and granted by the third-party operator is physically

identifiable. Even in the case the space would not be explicitly specified in the contract, it will become identified at the time

the spot is made available for the Company to install its equipment. When the contract allows the owner of the tower to

substitute the space which is initially rented by the Company, this right either is generally exercisable only in very specific

cases (security, heightening of the tower…) which cannot be anticipated at the beginning of the contract, or is subject to the

pre-approval of Orange. Consequently, this substitution right is deemed not substantive for the supplier. All the economic

benefits from use of the space are obtained by the Company.

-

Fixed wireline: these leases mainly concern access to the local loop where Orange is a market challenger (total or partial

unbundling), as well as the lease of land transmission cables.

-

Regarding the access to the local loop, the identified asset is the dedicated pair of copper wires installed from the telephone

exchange / central office to the customer's premises. In most cases, the purchase order forms explicitly mention the specific pair

of copper wires related to Orange. Even if the pair of copper wires is not explicitly specified in the purchase order form, it will

become identified when the subscriber’s access is granted to Orange by the incumbent. Then Orange is able to connect the pair

of copper wires from its own DSLAM to the customer premises set-top box. The full unbundling contracts do not permit any

substitution right. All the economic benefits from the use of the dedicated pairs of copper are obtained by Orange. Indeed, Orange

has the exclusive use of the dedicated pair of copper wires to deliver retail telecommunication services (voice and broadband) to

its final customer in exchange for a subscription fee, which is determined by Orange.

However, as this is not material (only 10 lines are still in use representing a total yearly cost of approximately 2,000 euros) for the

Company, these contracts are not part of the IFRS16 calculation.

-

Regarding the lease of land transmission cables, the Company lease either a specific cable or a capacity portion of a cable.

o

In some cases, the supplier grants the Company the use of an identified and fully dedicated cable (for example dark fiber

cable) for a determined period. The Company is responsible for directing and operating the dark fiber with its own active

network equipment and resources. The identified asset is the dedicated dark fiber installed by the supplier from a point A to

a point B. In most cases, the contracts or the purchase order forms explicitly mention the specific dark fiber involved (usually

described by an identification number). Even in the case where the dark fiber is not explicitly specified in the purchase order

form, it will become identified at the time the access is granted to Orange by the supplier. Then Orange is able to connect

its own active equipment to the dedicated dark fiber. Unless a substantive substitution right is properly identified in a

contract, Orange considers that the dedicated dark fibers are identified assets. Furthermore, all the economic benefits from

the use of the dedicated dark fiber are obtained by Orange. Indeed, Orange has the exclusive use of the dedicated fiber

cable used for core network operations purposes.

o

In some cases, the supplier grants the Company a high-speed access link connecting two geographic points for a

determined transmission capacity and period. The supplier is responsible for directing and operating the lines and their

maintenance with its own active network equipment and resources. This form of capacity arrangement does not convey the

right to use an identified asset. This form of leased lines arrangement (capacity arrangement) only conveys to Orange a right

to access a capacity (i.e. a quantity) as mentioned in the offers. This kind of agreement does not fall within the scope of IFRS

16.

Loyalty commissions

Loyalty commissions earned by the distribution channels on post-paid contracts are recognized upfront upon contract subscription.

Financial discounts

Financial discounts granted to customers or received from suppliers for early payments are deducted from revenue and costs of sales

as incurred.

Dividend

A dividend declared by the General Assembly of the shareholders after the balance sheet date is not recognized as a liability at that

date.

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TV content contracts

Expenses related to acquired TV distribution rights are recognized in the profit and loss statement as incurred and not capitalized as

intangible asset and consequently amortized over the term of the contract. The Company believes that it only acquires the distribution

right to air a certain channel and has no view or influence on future scheduling and content. As such, there is only a limited ability to

predict significant audiences or revenues from future airings, which implies that the acquired TV distribution rights do not meet the

requirements to be recognized as an intangible asset under IAS 38.

Segment reporting

Decisions on allocation of resources and operating segments’ performance assessment of Group components are made by the Chief

Executive Officer (main operational decision-maker) at operating segments’ level, mainly composed by geographical locations. Thus,

the operating segments are:

-

Belgium; and

-

Luxembourg.

The use of shared resources is taken into account in segmental results based either on contractual agreements terms between legal

entities, or external benchmarks, or by allocating costs among all segments. The supply of shared resources is included in other

revenues of the service provider, and the use of the resources is included in expenses taken into account for the calculation of the

service user’s EBITDAaL (as from accounting year 2019). The cost of shared resources may be affected by changes in contractual

relationships or organization and may therefore impact the segment results disclosed from one year to another. Segment profit or

loss, segment assets and segment liabilities for each reportable segment are presented on the basis of the same accounting principles

applied for the presentation of the company’s financial statements

Financial instruments

IFRS 9 comprises three phases: classification and measurement of financial assets and liabilities, impairment of financial assets and

hedge accounting.

Classification and measurement of financial assets and liabilities

The classification proposed by IFRS 9 determines the way assets are recognized and measured. The financial asset classification

depends on the combination of the following two criteria:

-

the Group’s business model for managing financial assets; and

-

the contractual cash flow characteristics of the financial asset (whether or not solely payments of principal and interest).

Based on the combined analysis of these two criteria, IFRS 9 identifies three business models:

-

Financial assets measured at fair value through profit or loss (FVR)

Certain investment securities which are not consolidated or equity-accounted, and cash investments such as negotiable debt

securities and deposits, that are compliant with the Group’s risk management policy or investment strategy, may be designated by

Orange as being recognized at fair value through profit or loss. These assets are recognized at fair value at inception and subsequently.

All changes in fair value are recorded in net financial expenses.

-

Financial assets measured at fair value through other comprehensive income that may be reclassified (or not) to profit or loss

(FVOCI)

Investment securities which are not consolidated or equity-accounted are, subject to exceptions, recognized as assets at fair value

through other comprehensive income that may not be reclassified to profit/loss. They are recognized at fair value at inception and

subsequently. Temporary changes in value and gains (losses) on disposals are recorded in other comprehensive income that may

not be reclassified to profit/loss.

-

Financial assets measured at amortized cost (AC)

This category mainly includes loans and receivables. These instruments are recognized at fair value at inception and are subsequently

measured at amortized cost using the effective interest method. The group always measures the loss allowance for trade receivables

at an amount equal to lifetime expected credit loss. The expected credit losses on trade receivables are estimated using a provision

matrix by reference to past default experience of the debtor and an analysis of the debtor’s current financial position, adjusted for

factors that are specific to the debtors, general economic conditions of the industry in which the debtors operate and an assessment

of both the current as well as the forecast direction of conditions at the reporting date.

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Impairment of financial assets

In accordance with the requirements of IFRS 9, the impairment of trade receivables is based on three methods:

-

a collective statistical method: this is based on historical losses and leads to a separate impairment rate for each aging

balance category. This analysis is performed over a homogeneous group of receivables with similar credit characteristics

because they belong to a customer category;

-

a stand-alone method: the assessment of impairment probability and its amount are based on a set of relevant qualitative

factors (aging payment, other balances with the counterparty, rating from independent agencies, geographical area).

-

A provisioning method based on expected loss: IFRS 9 requires recognition of expected losses on receivables immediately

upon recognition of the financial instruments. In addition to the pre-existing provisioning system, the Group applies a

simplified approach of early impairment at the time the asset is recognized. The rate applied depends on the maximum

revenue non-recoverability rate.

Recognition of impairment losses for a group of receivables is the step preceding identification of impairment losses on individual

receivables. As soon as information is available (customers in bankruptcy or subject to court-ordered liquidation), these receivables

are then excluded from the statistical impairment database and individually impaired.

Hedge accounting

Derivative instruments are measured at fair value in the statement of financial position and presented according to their maturity date,

regardless of whether they qualify for hedge accounting under IFRS 9 (hedging instruments versus trading derivatives).

Derivatives are classified as a separate line item in the statement of financial position.

Trading derivatives are economic hedge derivatives not classified as hedges for accounting purposes. Changes in the value of these

instruments are recognized directly in profit or loss.

Hedge accounting is applicable when:

-

At inception of the hedge, there is a formal designation and documentation of the hedging relationship;

-

The effectiveness of the hedge is demonstrated at inception and it is expected to continue in subsequent periods: i.e. at

inception and throughout its duration, the company expects changes in the fair value of the hedged item to be almost fully

offset by change in the fair value of the hedging instrument.

There are three types of hedging accounting:

-

A fair value hedge is a hedge of the exposure to the changes in the fair value of a recognized asset or liability (or an identified

portion of the asset or liability) that are attributable to a particular interest rate and/or currency risk and which could affect

profit or loss. The hedged portion of these items is remeasured at fair value in the statement of financial position. Changes

in this fair value are recognized in the income statement and are offset by symmetrical changes in the fair value of financial

hedging instruments to the extent of the hedge effectiveness;

-

A cash flow hedge is a hedge of exposure to changes in cash flow attributable to a particular interest rate and / or currency

risk associated with a recognized asset or liability or a transaction believed to be highly probable (such as future purchase

or sale) which could affect profit or loss. As the hedged item is not recognized in the statement of financial position, the

effective portion of the change in fair value of the hedging instrument is recognized in other comprehensive income. It is

reclassified in profit or loss when the hedged item (financial asset or liability) affects the profit or loss or in the initial cost of

the hedged item when it relates to the hedge of a non-financial asset acquisition cost;

-

A net investment hedge is a hedge of exposure to changes in value attributable to the foreign exchange risk of a net

investment in a foreign operation, which could affect profit or loss on the disposal of the foreign operation. The effective

portion of the net investment hedge is recorded in other comprehensive income. It is reclassified in profit or loss on disposal

of the net investment.

For transactions qualified as fair value hedges and for economic hedges, the foreign exchange impact of changes in the fair value of

derivatives is booked in operating income when the underlying hedged item is a commercial transaction and in finance costs, net

when the underlying hedged item is a financial asset or liability.

Hedge accounting can be terminated when the hedged item is no longer recognized, i.e. when the Group revokes the designation of

the hedging relationship or when the hedging instrument is terminated or exercised. The accounting consequences are as follows:

-

Fair value hedge: at the hedge accounting termination date, the adjustment of the fair value of the liability is amortized using

an effective interest rate recalculated at this date. Should the item hedged disappear, the change in fair value is recognized

in the income statement;

276

-

Cash flow hedge: amounts recorded in other comprehensive income are immediately reclassified in profit or loss when the

hedged item is no longer recognized. In all other cases, amounts are reclassified in profit or loss, on a straight-line basis,

throughout the remaining life of the original hedging relationship.

In both cases, subsequent changes in the value of the hedging instrument are recorded in profit or loss.

Concerning the effects of the foreign currency basis spread of cross-currency swaps designated as cash flow hedges, the Group has

chosen to designate these as hedging costs. This option enables recognition of these effects in other comprehensive income and

amortization of the cost of the basis spread in profit or loss over the period of the hedge.

Interest-bearing loans and borrowings

Loans and borrowings are initially recognized at the fair value of the consideration received less directly attributable transaction costs.

After initial recognition, interest-bearing loans and borrowings are subsequently measured at amortized cost using the effective interest

method.

Gains and losses are recognized in income when the liabilities are derecognized as well as through the amortization process.

Trade and other short-term payables

Trade and other short-term payables with no stated interest rate are measured at the original invoice or nominal amount when the

effect of discounting is immaterial.

Offsetting a financial asset and a financial liability

Trade receivables and payables are offset and the net amount is presented on the face of the balance sheet when such amounts may

legally be offset and a clear intention to settle them on a net basis exists.

Revenue from contracts with customers

IFRS 15 establishes a comprehensive framework for determining whether, how much and when revenue is recognized. It replaces IAS

18 Revenue, IAS 11 Construction Contracts and related interpretations.

Most revenue falls within the application scope of IFRS 15 “Revenue from contracts with customers”. Orange’s products and services

are offered to customers under service contracts only and contracts combining the equipment used to access services and/or other

service offers. Revenue is recognized net of VAT and other taxes collected on behalf of governments.

1.

Standalone service offers (mobile services only, fixed services only, convergent service)

The Company proposes to Mass market and Corporate markets customers a range of fixed and mobile telephone services, fixed and

mobile Internet access services and content offers (TV). Some contracts are for a fixed term (generally 12 or 24 months), while others

may be terminated at short notice (i.e. monthly arrangements or portions of services).

Service revenue is recognized when the service is provided, based on use (e.g. minutes of traffic or bytes of data processed) or the

period (e.g. monthly service costs).

Postpaid mobile revenues are recognized without reference to actual data or voice usage/allowance. The voice or data allowance or

the postpaid tariff plan does not have any impact on the calculation of the transaction price or enforceable period. For limited data

offers however, any actual excess data usage is billed and recognized as revenue as incurred.

Under some content offers, Orange may act solely as an agent enabling the supply by a third-party of goods or services to the

customer and not as a principal in the supply of the content. In such cases, revenue is recognized net of amounts transferred to the

third-party.

Contracts with customers generally do not include a material right, as the price invoiced for contracts and the services purchased and

consumed by the customer beyond the specific scope (e.g. additional consumption, options, etc.) generally reflect their standalone

selling prices. Service obligations transferred to the customer at the same pace are treated as a single obligation.

When contracts include contractual clauses covering commercial discounts (initial discount on signature of the contract or conditional

on attaining a consumption threshold) or free offers (e.g. three months of subscription free of charge), the Company defers these

discounts or free offers over the enforceable period of the contract (period during which the Company and the customer have a firm

commitment). Where applicable, the consideration payable to the customer is recognized as a deduction from revenue in accordance

with the specific terms and conditions of each contract.

2.

Separate equipment sales

The Company proposes to Mass market and Corporate market customers several ways to buy their equipment (primarily mobile

phones): equipment sales may be separate from or bundled with a service offer. When separate from a service offer, the amount

invoiced is recognized in revenue on delivery and receivable immediately or in instalment over a period of up to 24 months. Where

payments are received in instalments, the offer comprises a financial component and interest is calculated and deducted from the

amount invoiced and recognized over the payment period in net finance costs. Such transactions are however limited.

277

When the equipment sale is combined with a service offer, the amount allocated to the equipment (bundled sale – see below) is

recognized in revenue on delivery and received over the service contract.

Where Orange purchases and sells equipment to indirect channels, the Group generally considers that Orange maintains control until

final resale to the end-customer (the distributor acts as an agent), even where ownership is transferred to the distributor. Sales

proceeds are therefore recognized when the end-customer takes possession of the equipment (on activation).

3.

Bundled equipment and service offers

Orange proposes numerous offers to its Mass market and Corporate market customers comprising equipment and services (e.g. a

communications contract).

Equipment revenue is recognized separately if the two components are distinct (i.e. if the customer can receive the services

separately). Where one of the components in the offer is not at its separate selling price, revenue is allocated to each component in

proportion to their individual selling prices. This is notably the case in offers combining the sale of a mobile phone at a reduced price,

where the individual selling price of the mobile phone is considered equal to its purchase cost plus a commercial margin based on

market practice.

The provision of Modems and decoders (For Internet / TV offers) is neither a separate component of the Cable access service nor a

lease, as Orange maintains control of the box and modems.

4.

Service offers to carriers (wholesale)

The Group has mainly the following possible types of commercial agreements entered into with Operator customers for domestic

wholesale activities and International carrier offers:

-

Pay-as-you-go model: contract generally applied to “legacy” regulated activities (roaming, data solution contracts,…), where

contract services are not covered by a firm volume commitment. Revenue is recognized as the services are provided (which

corresponds to transfer of control) over the contractual term; and

-

Send-or-pay model: contract where the price, volume and term are defined. The customer has a commitment to pay the

amount indicated in the contract irrespective of actual traffic consumed over the commitment period. This contract category

notably includes certain MVNO contracts. The related revenue is recognized progressively based on actual traffic during the

period, to reflect transfer of control to the customer. In case MVNO contracts are structured with a minimum commitment,

minimum commitments are recognized as revenue unless usage exceeds the minimum commitment.

Specific revenue streams and related recognition criteria are as follows:

Sales of equipment

Sales of equipment to the distribution channels and to the final customers are recognized in revenue upon delivery. Consignment

sales are recognized in revenue upon sale to the final customer.

Revenue from the sale of prepaid cards

Sales of prepaid cards are recognized at facial value as deferred income at the time of sale and released in the profit and loss statement

as revenue upon usage.

Interconnection revenue

Traffic revenue paid by other telecommunication operators for use of our network is recognized upon usage.

Revenue sharing

Revenue arising from contracts with third-party content providers is recognized after deduction of the fees paid to them in

remuneration of the product or service delivered.

Revenue deferred until payment for which collection is not considered probable

Revenue of which the collectability is not reasonably assured at the point of sale is deferred until the payment has been received.

Earnings per share

The Group discloses both basic earnings per share and diluted earnings per share for continuing operations:

-

basic earnings per share are calculated by dividing net income for the year attributable to the equity holders of the Group by

the weighted average number of ordinary shares outstanding during the period;

-

diluted earnings per share are calculated based on the same net income and weighted-average number of ordinary shares

outstanding after adjustment for the effects of all dilutive potential ordinary shares.

When basic earnings per share are negative, diluted earnings per share are identical to basic earnings per share. Treasury shares

owned, which deducted from the consolidated equity, do not enter into the calculation of earnings per share.

278

Joint operations

A joint operation is a joint arrangement whereby the parties that have joint control of the arrangement have rights to the assets, and

obligations for the liabilities, relating to the arrangement. Those parties are called joint operators.

A joint operator shall recognize in relation to its interest in a joint operation:

-

its assets, including its share of any assets held jointly;

-

its liabilities, including its share of any liabilities incurred jointly;

-

its revenue from the sale of its share of the output arising from the joint operation;

-

its share of the revenue from the sale of the output by the joint operation; and

-

its expenses, including its share of any expenses incurred jointly.

As joint operator, the Group accounts for the assets, liabilities, revenues and expenses relating to its interest in its joint operations in

accordance with the IFRSs applicable to the particular assets, liabilities, revenues and expenses.

Note 18: Subsequent events

Following the end of the fiscal year, Antoine Chouc, Chief Financial Officer (CFO), announced his decision to step down from his

position, effective April 1, 2026, to assume the role of Chief Financial and Strategy Officer at Orange France. Matthieu Bouchery has

been appointed as the next CFO and will start his role from 1 July 2026.

The Revolving Credit Facility (RCF) between Orange Belgium S.A. and Atlas Services Belgium S.A. for 120 million euros, signed in

2021 and maturing on 10

th

March 2026 will be renewed and is currently pending governance process.

279

Note 19: Glossary

Financial KPIs

Revenues

revenues in line with the offer

Provide Group revenues split in convergent services, mobile only services, fixed only services, IT & integration services,

wholesale, equipment sales and other revenues.

retail service revenues

Revenue aggregation of revenues from convergent services, mobile only services, fixed only services, IT & integration

services.

convergent services

Revenues from B2C convergent offers (excluding equipment sales). A convergent offer is defined as an offer combining

at least a broadband access (xDSL, FTTx, cable or Fixed-4G (fLTE) with cell-lock) and a mobile voice contract

(excluding MVNOs: Mobile Virtual Network Operator). Convergent service revenues do not include incoming and visitor

roaming revenues.

mobile only services

Revenues from mobile offers (excluding B2C convergent offers and equipment sales) and M2M connectivity, excluding

incoming and visitors roaming revenues.

fixed only services

Revenues from fixed offers (excluding B2C convergent offers and equipment sales) including (i) fixed broadband, (ii)

fixed narrowband, and (iii) data infrastructure, managed networks, and incoming phone calls to customer relations call

centres.

IT & integration services

Revenues from collaborative services (consulting, integration, messaging, project management), application services

(customer relationship management and infrastructure applications), hosting, cloud computing services, security

services, video-conferencing and M2M services. It also includes equipment sales associated with the supply of these

services.

wholesale

Revenues with third-party telecom operators for (i) mobile: incoming, visitor roaming, domestic mobile interconnection

(i.e. network sharing and domestic roaming agreement) and MVNO, and for (ii) fixed carriers services.

equipment sales

Revenues from all mobile and fixed equipment sales, excluding (i) equipment sales associated with the supply of IT &

Integration services, and (ii) equipment sales to dealers and brokers.

other revenues

Include (i) equipment sales to brokers and dealers, (ii) portal, on-line advertising revenues, (iii) corporate transversal

business line activities, and (iv) other miscellaneous revenues.

Profit & Loss

data on a comparable basis

Data based on comparable accounting principles, scope of consolidation and exchange rates are presented for

previous periods. The transition from data on an historical basis to data on a comparable basis consists of keeping the

results for the period ended and then restating the results for the corresponding period of the preceding year for the

purpose of presenting, over comparable periods, financial data with comparable accounting principles, scope of

consolidation and exchange rate.

The method used is to apply to the data of the corresponding period of the preceding year, the accounting principles

and scope of consolidation for the period just ended as well as the average exchange rate used for the income

statement for the period ended.

Changes in data on a comparable basis reflect organic business changes. Data on a comparable basis

is not a financial aggregate as defined by IFRS and may not be comparable to similarly-named indicators used by other

companies.

EBITDAaL

(since 1 January 2019)

EBITDA after lease is not a financial measure as defined by IFRS. It corresponds to the net profit before: taxes; net

interest expense; share of profit/losses from associates; impairment of goodwill and fixed assets; effects resulting from

business combinations; reclassification of cumulative translation adjustment from liquidated entities; depreciation and

amortization; the effects of significant litigation, specific labour expenses; review of the investments and business

portfolio, restructuring costs.

RouA

Right-of-use assets represents a lessee's right to use a leased asset over a lease term. The leased assets in question

are usually property or equipment. However, an Roua can be anything for which a lessee is granted the right to obtain

economic benefit from using an asset owned by another entity

Cash flow statement

Adjusted Operating cash flow

EBITDAaL minus eCapex.

Organic cash flow

Organic cash flows correspond to net cash provided by operating activities decreased by capex/eCapex and the

repayment of lease liabilities, increased by proceeds from sale of property, plant and equipment and intangible assets

and adjusted for the payments for acquisition of telecommunications licenses.

eCapex

Economic Capex is not a financial measure as defined by IFRS. It corresponds to capital expenditures on tangible and

intangible assets excluding telecommunication licenses and excluding investments through financial leases less

proceeds from the disposal of fixed and intangible assets.

licences & spectrum

Cash out related to acquisitions of licences and spectrum.

change in WCR

Change in net inventories, plus change in gross trade receivables, plus change in trade payables, plus

change in other elements of Working Capital Requirement (WCR).

other operational items

Mainly offset of non-cash items included in adjusted EBITDA, items not included in adjusted EBITDA but included in net

cash provided by operating activities, and change in fixed asset payables.

net debt

Financial liabilities minus cash and cash equivalents.

net debt variation

Variation of net debt level.

280

Operational KPIs

Convergent

B2Cconvergent customer base

Number of B2C customers holding an offer combining at least a broadband access (xDSL, FTTx, cable or Fixed-4G

(fLTE) with cell-lock) and a mobile voice contract (excluding MVNOs).

B2C convergent ARPO

Average quarterly Revenues Per Offer (ARPO) of convergent services are calculated by dividing (a) the revenues

from convergent offers billed to the B2C customers (excluding equipment sales) over the past three months, by (b)

the weighted average number of convergent offers over the same period. The weighted average number of

convergent offers is the average of the monthly averages during the period in question. The monthly average is the

arithmetic mean of the number of convergent offers at the start and end of the month. Convergent ARPO is

expressed as monthly revenues per convergent offer.

Mobile

mobile customer base

(excl. MVNOs)

Number of customers with active simcard, including (i) M2M and (ii) business and internet everywhere (excluding

MVNOs).

contract

Customer with whom Orange has a formal contractual agreement with the customer billed on a monthly basis for

access fees and any additional voice or data use.

prepaid

Customer with whom Orange has written contract with the customer paying in advance any data or voice use by

purchasing vouchers in retail outlets for example.

M2M (machine-to-machine)

Exchange of information between machines that is established between the central control system (server) and any

type of equipment, through one or several communication networks.

mobile B2C convergent customers

Number of mobile lines of B2C convergent customers.

mobile only customers

Number of mobile customers (see definition of this term) excluding mobile convergent customers

(see definition of this term).

MVNO customers

Hosted MVNO customers on Orange networks.

mobile only ARPO

Average quarterly Revenues Per Offer (ARPO) of mobile only services are calculated by dividing

(a) the revenues of mobile only services billed to the customers, generated over the past three months, by (b) the

weighted average number of mobile only customers (excluding M2M customers) over the same period. The

weighted average number of customers is the average of the monthly averages during the period in question. The

monthly average is the arithmetic mean of the number of customers at the start and end of the month. Mobile only

ARPO is expressed as monthly revenues per customer.

Fixed

number of lines (copper + FTTH)

Number of fixed lines operated by Orange.

B2C broadband convergent

customers

Number of B2C customers holding an offer combining at least a broadband access (xDSL, FTTx, cable or Fixed-4G

(fLTE) with cell-lock) and a mobile voice contract (excluding MVNOs).

fixed broadband only customers

Number of fixed broadband customers excluding broadband convergent customers (see definition of this term).

fixed only broadband ARPO

Average quarterly Revenues Per Offer (ARPO) of fixed only broadband services (xDSL, FTTH, Fixed-4G (fLTE),

satellite and Wimax) are calculated by dividing (a) the revenues from consumer fixed only broadband services over

the past three months, by (b) the weighted average number of accesses over the same period. The weighted

average number of accesses is the average of the monthly averages during the period in question. The monthly

average is the arithmetic mean of the number of accesses at the start and end of the month. ARPO is expressed as

monthly revenues per access.

281

Orange Belgium S.A. annual accounts 2025

Comments on Orange Belgium S.A.’s 2025 annual accounts prepared according

to Belgian accounting standards

The statutory income statement and balance sheet are presented hereafter. As for the exhaustive annual accounts of Orange

Belgium S.A., we refer you to the website of the Central Balance Sheet Office (

http://www.nbb.be

) or Orange Belgium website

(

https://corporate.orange.be/en/financial-information/shareholders-investors

).

282

Balance sheet after appropriation

in thousand EUR

31.12.2025

31.12.2024

ASSETS

Formation expenses

5 381

7 950

Fixed assets

3 291 085

3 176 871

Intangible fixed assets

776 565

676 819

Tangible fixed assets

849 963

687 887

Land and buildings

192 700

199 846

Plant, machinery and equipment

555 256

413 511

Furniture and vehicles

29 917

22 527

Other tangible fixed assets

31 487

20 467

Tangible assets under construction and advance payments made

40 602

31 535

Financial fixed assets

1 664 557

1 812 165

Affiliated enterprises

1 655 726

1 803 668

Participating interests

1 575 726

1 723 668

Amounts receivable

80 000

Other enterprises linked by participating interests

7 397

Participating interests

7 397

Other financial assets

1 433

1 100

Amounts receivable and cash guarantees

1 433

1 100

Current assets

408 547

241 551

Amounts receivable after more than one year

1

Other amounts receivable

1

Stocks and contracts in progress

36 624

29 506

Stocks

36 624

29 506

Goods purchased for resale

36 624

29 506

Amounts receivable within one year

306 921

194 438

Trade debtors

300 675

172 730

Other amounts receivable

6 246

21 708

Current investments

463

203

Own shares

0

Other investments and deposits

463

203

Cash at bank and in hand

52 137

14 211

Deferred charges and accrued income

12 401

3 193

Total Assets

3 705 012

3 426 372

283

in thousand EUR

31.12.2025

31.12.2024

EQUITY AND LIABILITIES

Equity

864 065

874 254

Capital

148 149

Issued capital

148 149

Reserves

14 815

Legal reserve

14 815

Reserves not available

0

In respect of own shares held

0

Accumulated profits (losses) (+) (-)

564 333

574 522

Investment grants

0

Provisions and deferred taxes

56 179

55 109

Provisions for liabilities and charges

56 179

55 109

Pensions and similar obligations

15

27

Other risks and costs

56 164

55 082

Amounts payable

2 784 768

2 497 009

Amounts payable after more than one year

1 824 269

1 989 769

Financial debts

1 693 381

1 855 892

Other loans

1 693 381

1 855 892

Other amounts payable

1 671 190

133 877

Amounts payable within one year

882 480

434 498

Current portion of amounts payable after more than one year falling due within one year:

142 133

2 621

Financial debts

114 725

46 305

Credit institutions

0

Other loans

114 725

46 305

Trade debts

448 920

238 819

Suppliers

448 920

238 819

Bills of exchange payable

0

Advance payments received on orders

1 552

1 464

Taxes, remuneration and social security

169 333

139 079

Taxes

108 958

98 339

Remuneration and social security

60 375

40 741

Other amounts payable

5 818

6 210

Accrued charges and deferred income

78 019

72 741

Total Equity and Liabilities

3 705 012

3 426 372

284

Income statement

in thousand EUR

31.12.2025

31.12.2024

Operating income

1 817 376

1 511 252

Turnover

1 668 578

1 419 729

Own construction capitalized

27 206

19 037

Other operating income

121 591

72 485

Non-recurring operating income

0

Operating charges

1 743 711

1 435 274

Raw materials, consumables

864 920

687 982

Purchases

872 147

695 477

Stocks: decrease (increase) (+) (-)

-7 227

-7 495

Services and other goods

350 129

288 074

Remuneration, social security costs and pensions

219 781

169 472

Depreciation of and amounts written off formation expenses, intangible and

290 296

249 935

tangible fixed assets

Amounts written off stocks, contracts in progress and trade debtors:

-25 169

16 913

appropriations (write-backs) (+) (-)

Provisions for risks and charges: appropriations (uses and write-backs) (+) (-)

-4 193

-1 581

Other operating charges

47 773

23 020

Non-recurring operating charges

173

1 461

Operating profit (loss) (+) (-)

73 665

75 978

Financial income

6 446

118 145

Recurring financial income

6 446

10 210

Income from financial fixed assets

879

2 575 040

Income from current assets

5 195

7 605

Other financial income

371

30

Non-recurring financial income

0

107 936

Financial charges

89 942

103 851

Recurring financial charges

89 942

103 851

Debt charges

89 033

102 851

Other financial charges

909

1 000

Non-recurring financial charges

0

Profit (loss) for the period before taxes (+) (-)

-9 831

90 272

Income taxes (+) (-)

358

-6 232

Income taxes

358

5 012

Adjustment of income taxes and write-backs of tax provisions

0

-11 244

Profit (loss) for the period (+) (-)

-10 189

96 505

Profit (loss) for the period available for appropriation (+) (-)

-10 189

96 505

285

Appropriations and withdrawings

in thousand EUR

31.12.2025

31.12.2024

Profit (loss) to be appropriated (+) (-)

564 333

576 338

Profit (loss) to be appropriated (+) (-)

-10 189

96 505

Profit (loss) to be carried forward (+) (-)

574 522

479 833

Transfers from capital and reserves

0

From reserves

0

Transfers to capital and reserves

0

1 643

To other reserves

0

Profit (loss) to be carried forward (+) (-)

564 333

574 522

Profit to be distributed

0

173

Dividends

0

Other beneficiaries

0

173

286

Orange Belgium SA/NV

Statutory auditor’s report to the shareholders’ meeting for the year ended 31

December 2025 – Consolidated financial statements

The original text of this report is in Dutch and French

287

Statutory auditor’s report to the shareholders’ meeting of Orange Belgium

SA/NV for the year ended 31 December 2025 – Consolidated financial

statements

In the context of the statutory audit of the consolidated financial statements of Orange Belgium SA/NV (“the

company”) and its subsidiaries (jointly “the group”), we hereby submit our statutory audit report. This report

includes our report on the consolidated financial statements and the other legal and regulatory requirements.

These parts should be considered as integral to the report.

We were appointed in our capacity as statutory auditor by the shareholders’ meeting of 3 May 2023, in

accordance with the proposal of the board of directors (“bestuursorgaan” / “organe d’administration”) issued

upon recommendation of the audit committee and presentation of the works council. Our mandate will expire on

the date of the shareholders’ meeting deliberating on the financial statements for the year ending 31 December

2025. We have performed the statutory audit of the consolidated financial statements of Orange Belgium SA/NV

for 3 consecutive periods.

Report on the consolidated financial statements

Unqualified opinion

We have audited the consolidated financial statements of the group, which comprise the consolidated statement

of financial position as at 31 December 2025, the consolidated statement of profit or loss and other

comprehensive income, the consolidated statement of changes in equity and the consolidated cash flow

statement for the year then ended, as well as the summary of significant accounting policies and other

explanatory notes. The consolidated statement of financial position shows total assets of

4 103 485 (000) EUR and the consolidated statement of profit or loss and other comprehensive income shows a

profit for the year then ended of 41 308 (000) EUR.

In our opinion, the consolidated financial statements give a true and fair view of the group’s net equity and

financial position as of 31 December 2025 and of its consolidated results and its consolidated cash flow for the

year then ended, in accordance with International Financial Reporting Standards (IFRS Accounting Standards) as

adopted by the European Union and with the legal and regulatory requirements applicable in Belgium.

Basis for the unqualified opinion

We conducted our audit in accordance with International Standards on Auditing (ISA), as applicable in Belgium. In

addition, we have applied the International Standards on Auditing approved by the IAASB applicable to the

current financial year, but not yet approved at national level. Our responsibilities under those standards are

further described in the “Responsibilities of the statutory auditor for the audit of the consolidated financial

statements” section of our report. We have complied with all ethical requirements relevant to the statutory audit

of consolidated financial statements in Belgium, including those regarding independence.

We have obtained from the board of directors and the company’s officials the explanations and information

necessary for performing our audit.

We believe that the audit evidence obtained is sufficient and appropriate to provide a basis for our opinion.

Key audit matters

Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of

the consolidated financial statements of the current period. These matters were addressed in the context of our

audit of the consolidated financial statements as a whole and in forming our opinion thereon, and we do not

provide a separate opinion on these matters.

288

Key audit matters

How our audit addressed the key audit matters

Revenue recognition from telecommunication activities

The accuracy of revenue is an inherent risk in the

telecommunications industry. This is driven by, amongst

others, the complexity of the billing systems, the

magnitude of volumes of data processed to determine

billing and revenue, the combination of different

products sold as well as price and promotion changes

introduced during the year.

The details on revenue recognition from

telecommunication activities are included in note 3

‘

Sales, trade receivables, other current and non-current

assets

’, note 14 ‘

Liabilities related to contracts with

customers and other assets related to contracts with

customers

’ and note 17.1.21 ‘

Revenue from contracts

with customers

’ of the consolidated financial

statements.

We addressed this key audit matter by applying the

following controls and substantive test procedures to

the material revenue streams:

•

We tested the design and operating effectiveness

of the relevant key controls in place in the revenue

cycle, as well as in the IT environment in which

billing, rating and other relevant support systems

reside, including the change control procedures in

place around systems that support material

revenue streams. We took into account the high

level of integration of the various information

systems involved in revenue recognition by

including members in our team with specific

expertise in information systems to support the

audit team in performing the above audit

procedures;

•

We performed a substantive analytical review;

•

We performed tests of details on a sample of

individual revenue transactions, tracing these back

to order documentation and cash receipts.

Additionally we assessed the appropriateness of the

group's accounting policies with respect to revenue

recognition from telecommunication activities and

assessed compliance with the applicable accounting

standards.

289

Goodwill impairment testing for Belgium

At 31 December 2025, the total goodwill recognized in

the consolidated statement of financial position

amounts to 751 179 (000) EUR.

As indicated in note 5, Orange Belgium has performed

its annual impairment test at the level of the cash

generating units (‘CGU’) ‘Belgium’ and ‘Luxembourg’ as

of 31 December 2025. An impairment loss is required to

be recognized if the recoverable amount is lower than

the carrying value. The recoverable amount is

determined by Orange Belgium based upon the value in

use. The estimate of value in use is the present value of

future expected cash flows.

The annual impairment testing of goodwill was

important for our audit because it relies on a number of

estimates and assumptions used in a discounted free

cash flow model to determine the CGU’s recoverable

value. The group uses a business plan reflecting the

future strategy and using external sources for macro-

economic assumptions such as inflation and long-term

industry growth rate, as well as group specific

assumptions on capital spending and discount rates.

Due to the inherent uncertainty involved in forecasting

and discounting cash flows, we consider the annual

impairment test of goodwill as a key audit matter. We

focused our audit efforts on the impairment assessment

of the ‘Belgium’ cash generating unit.

The details on the accounting for goodwill and the

disclosure requirements under

IAS 36 - Impairment of

assets

are included in note 5 ‘

Goodwill

’ of the

consolidated financial statements.

We gained insight into the procedure implemented by

Orange Belgium for carrying out the annual impairment

test and in particular the review of the cash flows used

in the calculation of the recoverable amount.

Supported by our valuation specialists, we challenged

the key assumptions, methodologies and data used by

the group in its determination of the recoverable

amount, for example by analysing sensitivities in the

group’s discounted cash flow model and benchmarking

with external macroeconomic data and peers to

determine if they were reasonable and consistent with

the current economic climate.

Furthermore, we assessed the determination of the

CGU’s and the historical accuracy of management’s

estimates.

We assessed the adequacy of the group’s disclosures in

note 5 ‘Goodwill’ of the consolidated financial

statements.

Responsibilities of the board of directors for the preparation of the consolidated financial

statements

The board of directors is responsible for the preparation and fair presentation of the consolidated financial

statements in accordance with International Financial Reporting Standards (IFRS Accounting Standards) as

adopted by the European Union and with the legal and regulatory requirements applicable in Belgium and for

such internal control as the board of directors determines is necessary to enable the preparation of consolidated

financial statements that are free from material misstatement, whether due to fraud or error.

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In preparing the consolidated financial statements, the board of directors is responsible for assessing the group’s

ability to continue as a going concern, disclosing, as applicable, matters to be considered for going concern and

using the going concern basis of accounting unless the board of directors either intends to liquidate the group or

to cease operations, or has no other realistic alternative but to do so.

Responsibilities of the statutory auditor for the audit of the consolidated financial statements

Our objectives are to obtain reasonable assurance about whether the consolidated financial statements as a

whole are free from material misstatement, whether due to fraud or error, and to issue a statutory auditor’s

report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an

audit conducted in accordance with ISA will always detect a material misstatement when it exists. Misstatements

can arise from fraud or error and are considered material if, individually or in the aggregate, they could

reasonably be expected to influence the economic decisions of users taken on the basis of these consolidated

financial statements.

During the performance of our audit, we comply with the legal, regulatory and normative framework as

applicable to the audit of consolidated financial statements in Belgium. The scope of the audit does not comprise

any assurance regarding the future viability of the company nor regarding the efficiency or effectiveness

demonstrated by the board of directors in the way that the company’s business has been conducted or will be

conducted.

As part of an audit in accordance with ISA, we exercise professional judgment and maintain professional

skepticism throughout the audit. We also:

•

identify and assess the risks of material misstatement of the consolidated financial statements, whether

due to fraud or error, design and perform audit procedures responsive to those risks, and obtain audit

evidence that is sufficient and appropriate to provide a basis for our opinion. The risk of not detecting a

material misstatement resulting from fraud is higher than for one resulting from an error, as fraud may

involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control;

•

obtain an understanding of internal control relevant to the audit in order to design audit procedures that

are appropriate in the circumstances, but not for the purpose of expressing an opinion on the

effectiveness of the group’s internal control;

•

evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates

and related disclosures made by the board of directors;

•

conclude on the appropriateness of the use of the going concern basis of accounting by the board of

directors and, based on the audit evidence obtained, whether a material uncertainty exists related to

events or conditions that may cast significant doubt on the group’s ability to continue as a going concern.

If we conclude that a material uncertainty exists, we are required to draw attention in our statutory

auditor’s report to the related disclosures in the consolidated financial statements or, if such disclosures

are inadequate, to modify our opinion. Our conclusions are based on the audit evidence obtained up to

the date of our statutory auditor’s report. However, future events or conditions may cause the group to

cease to continue as a going concern;

291

•

evaluate the overall presentation, structure and content of the consolidated financial statements, and

whether the consolidated financial statements represent the underlying transactions and events in a

manner that achieves fair presentation.

•

obtain sufficient appropriate audit evidence regarding the financial information of the entities and

business activities within the group to express an opinion on the consolidated financial statements. We

are responsible for the direction, supervision and performance of the group audit. We remain solely

responsible for our audit opinion.

We communicate with the audit committee regarding, amongst other matters, the planned scope and timing of

the audit and significant audit findings, including any significant deficiencies in internal control that we identify

during our audit.

We also provide the audit committee with a statement that we have complied with relevant ethical requirements

regarding independence, and we communicate with them about all relationships and other matters that may

reasonably be thought to bear on our independence, and where applicable, related safeguards.

From the matters communicated to the audit committee, we determine those matters that were of most

significance in the audit of the consolidated financial statements of the current period and are therefore the key

audit matters. We describe these matters in our report unless law or regulation precludes any public disclosure

about the matter.

Other legal and regulatory requirements

Responsibilities of the board of directors

The board of directors is responsible for the preparation and the content of the directors’ report on the

consolidated financial statements, including the sustainability statement and other matters disclosed in the

annual report on the consolidated financial statements.

Responsibilities of the statutory auditor

As part of our mandate and in accordance with the Belgian standard complementary to the International

Standards on Auditing (ISA) as applicable in Belgium, our responsibility is to verify, in all material respects, the

director’s report on the consolidated financial statements and other matters disclosed in the annual report on the

consolidated financial statements, as well as to report on these matters.

Aspects regarding the directors’ report on the consolidated financial statements and other

information disclosed in the annual report on the consolidated financial statements

The annual report contains the sustainability statement which is the subject of our separate limited assurance

report on the sustainability statement. This section does not pertain to the assurance on the consolidated

sustainability statement included in the annual report. For this part of the annual report on the consolidated

financial statements, we refer to our report on the matter.

In our opinion, after performing the specific procedures on the directors’ report on the consolidated financial

statements, this report is consistent with the consolidated financial statements for that same year and has been

established in accordance with the requirements of article 3:32 of the Code of companies and associations.

In the context of our statutory audit of the consolidated financial statements we are responsible to consider, in

particular based on information that we became aware of during the audit, if the directors’ report on the

consolidated financial statements and other information disclosed in the annual report on the consolidated

financial statements are free of material misstatements, either by information that is incorrectly stated or

otherwise misleading. In the context of the procedures performed, we are not aware of such a material

misstatement.

292

Statements regarding independence

•

Our audit firm and our network have not performed any prohibited services and our audit firm has

remained independent from the group during the performance of our mandate.

•

The fees for the additional non-audit services compatible with the statutory audit, as defined in article

3:65 of the Code of companies and associations, have been properly disclosed and disaggregated in the

notes to the consolidated financial statements.

Single European Electronic Format (ESEF)

In accordance with the draft standard on the audit of the compliance of the financial statements with the Single

European Electronic Format ("ESEF"), we have also performed the audit of the compliance of the ESEF format and

of the tagging with the technical regulatory standards as defined by the European Delegated Regulation No.

2019/815 of 17 December 2018 ("Delegated Regulation").

The board of directors is responsible for the preparation, in accordance with the ESEF requirements, of the

consolidated financial statements in the form of an electronic file in ESEF format (“digital consolidated financial

statements”) included in the annual financial report.

Our responsibility is to obtain sufficient and appropriate evidence to conclude that the format and the tagging of

the digital consolidated financial statements comply, in all material respects, with the ESEF requirements as

stipulated by the Delegated Regulation.

Based on our work, in our opinion, the format and the tagging of information in the digital consolidated financial

statements included in the annual financial report of Orange Belgium SA/NV as of

31 December 2025 are, in all material respects, prepared in accordance with the ESEF requirements as stipulated

by the Delegated Regulation.

Other statements

•

This report is consistent with our additional report to the audit committee referred to in article 11 of

Regulation (EU) No 537/2014.

Signed at Zaventem.

The statutory auditor

Deloitte Bedrijfsrevisoren/Réviseurs d’Entreprises BV/SRL

Represented by Nico Houthaeve

Deloitte Bedrijfsrevisoren/Réviseurs d’Entreprises BV/SRL

Registered Office: Gateway building, Luchthaven Brussel Nationaal 1 J, B-1930 Zaventem

VAT BE 0429.053.863 - RPR Brussel/RPM Bruxelles - IBAN BE90 4350 2974 5132 - BIC KREDBEBB

Member of Deloitte Touche Tohmatsu Limited

293

Declaration by the responsible persons

We, the undersigned, Xavier Pichon, CEO, and Antoine Chouc, CFO, declare that to our knowledge:

a) the financial statements drawn up in accordance with the prevailing accounting standards, give a true and fair view of the company’s

assets, liabilities, financial position and results of the issuer and the companies included within its consolidation;

b) the management report contains an accurate overview of the business activities evolution, the results and the financial situation of

the issuer and the companies included within its consolidation, and a description of the main risks and uncertainties they are

confronted to.

Xavier Pichon

Antoine Chouc

CEO

CFO

a registered trademark. The trademarks of commercial

products mentioned in this document are registered

and are the property of their various manufacturers. The

characteristics of the products and services mentioned

in this document may be changed at any time without

notice. Orange Belgium cannot be held liable for

printing errors in this document. The products of other

manufacturers are mentioned for information. The

manufacturers are solely liable for any and all warranties

concerning their products. Orange Belgium cannot be

held liable under any circumstances for data transmission

services, nor for the content, legality or accessibility

of these services, nor for the use made of them by the

customer, whether these services are provided by third

parties or by Orange Belgium.

Ce rapport annuel est également disponible en français.

Dit jaarverslag is ook verkrijgbaar in het Nederlands.

Shareholders and investors relations

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Press relations

press@orange.be

Responsible editor

Paul-Marie Dessart – Secretary General

Concept & layout

ChrisCom

Orange Belgium S.A.

Avenue du Bourget, 3,

BE-1140 Brussels – Belgium

T. +32 2 745 71 11 – www.orange.be

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Orange Belgium S.A.

Avenue du Bourget 3,

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Belgium

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