Saipem SpA

### 2. Saipem's engagement in dialogue with institutions and lobbying activity

Saipem has always been engaged in a constructive and transparent dialogue with central and local institutions, and with trade associations all over the world. By virtue of the strong international orientation of the Group, which is present in more than 50 countries, Saipem collaborates and maintains close relations with the Italian diplomatic network, engaging in a constant dialogue with the Ministry of Foreign Aff airs and International Cooperation and with foreign diplomatic institutions in Italy.

The Public Aff airs function is responsible for institutional dialogue, guaranteeing uniform and coherent relational strategies and communication to external parties and the Company manages its local, national and international stakeholder relations in line with the provisions of its Code of Ethics and its Business Integrity Guidelines and Policies, which require the adoption of behaviour based on correctness, transparency and traceability.

In 2023, Saipem did not engage in direct lobby with relevant institutional stakeholders and did not make direct or indirect contributions in whatever form to parties, movements, committees, political organisations and unions, to their representatives and/or candidates, unless required by local law, therefore this activity is not included in the scope of the analysis covered in this document. [...] ### 3. Saipem contribution to Climate policy objectives through associations' memberships

Saipem guarantees transparency by implementing and following a specifi c governance of associations memberships, that involves representatives of Saipem of diff erent functions/business lines, in coordination with Public Aff airs function.

In particular, every membership (renewal or new subscription) is subject to an internal process of approval that implies a due diligence on the association before the fi rst membership and an authorisation process, implemented at corporate level, that requires the fi nal approval of top management. Moreover, the participation in association life is subject to a continuous monitoring, in order to guarantee that this activity is in line with our targets and have a positive impact for our company. [...] ### 4. Assessment of Saipem's contribution climate related advocacy activities through associations

In order to evaluate the eff ectiveness of Saipem's commitment to climate-related advocacy activities through its participation in associations and organisations, starting

#### a. Evaluation pillars

The evaluation of associative memberships is based on 7 pillars, identifi ed by cross-checking relevancy to Saipem typical activities (past, current and planned ones), and for being areas related to climate advocacy interests and Saipem's targets. In particular, the memberships were reviewed in the light of:
1. Support to the goals of the Paris Agreement to achieve Net Zero by 2050.
2. Role of energy transition energies, in particular natural gas.

#### b. Assessment methodology

For this second year of assessment, based on 2023 data, we evaluated the full list of Saipem memberships, at group level, and selected 23 associations that are active in the debate on climate and energy subjects and in which Saipem plays an active role.

The review of positions was performed considering publicly available data such as reports, websites and public statements. More specifi cally, we assessed the alignment of the business associations on each of the 7 main pillars included in our evaluation model.

As a result of the fi nal evaluation, each association has been assigned with one of following three categories:

|Aligned|The stated positions of the association are aligned with the Paris Agreement goals and supports/are not in contrast with any of the 7 main pillars indicated in evaluation model.|
|---|---|
|Partially Aligned|The association does not explicitly support the Paris Agreement goals. Rather, it supports at least one of the 7 main pillars indicated in the paragraph before, and it is not in contrast with any of such main topics. Alternatively, the association explicitly supports the Paris Agreement goals, but it has a minor misalignment on at least one of the 7 main pillars indicated in the evaluation model and it is not in contrast with any of such main topics.|
|Not Aligned|The association does not support the Paris Agreement goals or the public position of the association is in contrast with at least one of the 7 main pillars indicated in the evaluation model.|

#### c. Assessment results

Out of 23 business associations selected, we found that 21 out of 23 are aligned with Saipem's position on climate-related advocacy and two (AERO and ANCE) are partially aligned. This partial alignment is due to a lack of a specifi c commitment to Paris Agreement targets. In fact, both associations do not explicitly express a position in contrast with them, while supporting energy transition and sustainable infrastructure solutions.

Some of the associations assessed have a specifi c focus on certain climate-related topics, and therefore may have not positioned themselves about other specifi c themes (for example an association of off shore wind contractors may not have a position about sustainable infrastructures); in such cases it has been taken in consideration whether the association is not actively opposed to the themes identifi ed in the 7 pillars to assessing its alignment, rather than focusing on the lack of a specifi c commitment to a topic which is not considered relevant to the association.

The assessment considers both global and regional/national associations.
The total amount of fees paid for the membership of the 23 associations considered amounts to €400,470 (for year 2023), which is about 35% of overall fees paid for by Saipem in the same year. Within the business associations which have been evaluated as partially aligned, Saipem will proactively engage with other members in order to drive and infl uence each entity's positions towards a more positive vision, and in particular, in any debate on climate and energy subjects, Saipem will pursue its positions as stated in its policies and strategies (such as the Net Zero plan).

Through the Sustainability, Scenarios and Governance Committee, the Board of Directors was able to examine and supervise the results of a set of processes, starting from the analysis of material sustainability issues – carried out in accordance with the most advanced criteria and directly involved the Directors – in order to identify the sustainability priorities in stakeholder expectations but also to evaluate their potential impact in the creation of company value (the so-called "double materiality", adopted by the company since 2021 ahead of the new European regulations and standards). The Board also examined and approved the first four-year Sustainability Plan in which the sustainability strategic lines and the criteria for integration with the business strategy were identified and the related short- and long-term objectives were defined. The Plan is an auspicious tool that is constantly monitored and adaptable to changing contexts, while at the same time it is also useful for defining incentive mechanisms based on a significant component of ESG factors, backed by accurate and verifiable indicators. The focus on business ethics and on programmes to combat corruption is also confirmed at the centre of the agenda together with risk management, developed with the aim for ever greater integration with sustainability issues. The entire Board, through three Committees (Sustainability, Scenarios and Governance - Audit and Risk - Compensation and Nomination) also discussed the sustainability disclosure which is enriched at Saipem by a broad discussion of the fight against climate change – carried out in line with the recommendations of the Task Force on Climate Related Financial Disclosure (TCFD) and integrated as of this year in the Consolidated Non-Financial Statement – and by the Modern Slavery Statement – a document that allows the company to provide a broad testimony on how the complex issue of human rights is managed, especially in some critical geographies and in its supply chain.

The Public Affairs function is responsible for institutional dialogue, guaranteeing uniform and coherent relational strategies and communication to external parties. [...] In 2023, Saipem participated in several institutional meetings and international round tables. Among the main memberships, we highlight that to industrial associations and specifically Assolombarda, aimed at receiving support mainly in industrial relations management, also at local level, and updates on operational issues in the sector, as well as at increasing the industrial system's knowledge of the company and of its services. As part of its membership in the World Energy Council (WEC), Saipem participates in the first bilateral workshop organised in Washington to establish a dialogue with US institutions, in particular the Department of State and the Department of Energy, on possible collaborations between Italy and the USA to face the challenges of the transition. Saipem also contributes to the dialogue with international stakeholders on the industrial and economic level through its membership in ISPI, in Associazione Italia ASEAN and in the Ambrosetti Forum. [...] Other participations worth mentioning are those in sector associations such as IADC (International Association of Drilling Contractors), IMCA (International Maritime Contractors Association), IOGP (International Association of Oil and Gas producers) and Windeurope. Total membership fees spent in 2023 amounted to €1.1 million."
"Saipem's participation in these events, carried out through its presence in associations, is shaped and evaluated on the basis of alignment with its objectives and policies. In fact, since 2023, Saipem has published the document 'Climate Policy Alignment', which reports the results of an analysis aimed at evaluating the contribution to climate advocacy activities through active participation in trade associations. In particular, the assessment was based on a control of the relevance of climate policies with respect to Saipem's typical activities and its targets (achievement of net zero, promotion of renewables, transparency and disclosure activities) and detected the degree of alignment with the relevant associations. Since 2018, Saipem has published a document on the Climate in accordance with the recommendations of the TCFD. From 2022, climate information is fully integrated in this non-financial statement. Active participation in associations allows Saipem to be involved in a dynamic network, promoting its own technological excellences and sharing information and experience on different topics, including sustainability, energy efficiency and climate issues.

The Sustainability, Scenarios and Governance Committee, in office until April 30, 2021, chaired by the then Chairman of the Board, who held the position until April 30, 2021, was originally responsible for assisting the Board of Directors by fulfilling a preparatory, consultative and advisory role in assessments and decision-making processes with regard to Saipem's business sustainability issues and its engagement with all stakeholders, the Corporate Governance of the Company and the Group, Saipem's Corporate Social Responsibility and the review of scenarios contemplated in the preparation of the Strategic Plan. From January 1, 2021, with the application in Italy of the new version of the Corporate Governance Code, the responsibility of the Sustainability, Scenarios and Governance Committee was extended and the Committee, in office until April 30, 2021, was responsible for assisting the Board of Directors by fulfilling a preparatory, consultative and advisory role in assessments and decision-making processes with regard to Saipem's business Sustainability issues and its engagement with all stakeholders, Saipem's Corporate Social Responsibility and the review of scenarios envisaged in the preparation of the Strategic Plan, based also on the analysis of significant issues for the creation of long-term value and the Corporate Governance of the Company and the Group. The Committee, in office until April 30, 2021, addressed the topic of climate change on several occasions during the meetings held in 2020, particularly on February 24, June 17, October 12 and November 17, discussing relevant issues, such as Saipem's disclosure of "Leading the path to energy transition", its implications on business strategies and the initiatives undertaken by the Company in this area. [...] The Shareholders' Meeting on April 30, 2021 appointed the new Board of Directors which, during the meeting of May 18, 2021, confirmed the establishment, among others, of the Sustainability, Scenarios and Governance Committee and confirming an even greater attention to Environmental, Social, Governance (ESG) issues, integrated the Committee's competences with the provisions highlighted below in bold: **>** has the task of assisting the Board of Directors with preliminary functions, proactive and consultative in nature, in evaluations and decisions relating to sustainability issues, also understood as environmental, social & governance, connected to the exercise of business activities and its interactions with all stakeholders, to corporate social responsibility, the examination of the scenarios for the preparation of the strategic plan, also based on the analysis of the relevant issues for long-term value generation and the corporate governance of the Company and the Group; **>** monitor the application of the sustainability vision approved by the Board of Directors, also within the broader concept of purpose, and propose the necessary actions to determine the value generated by the company for stakeholders, also in the context of stakeholders engagement activities, contributing to the definition and adoption of a model to measure the value; **>** monitor the positioning of the Company's Code of Ethics with national and international regulations and best practices, formulating proposals to the Board of Directors; **>** examine scenarios and guidelines for the preparation of the strategic plan, also based on the analysis of the relevant issues for the generation of long-term value, expressing an opinion to the Board of Directors.