Basis of Preparation

General basis of preparation

ESRS 2 BP-1

CSRD journey

Alpiq’s obligation to be compliant with the Corporate Sustainability Reporting Directive (CSRD) by the financial year 2025 was postponed in the context of the Omnibus proposal. The Sustainability Report 2024 was already prepared in alignment with the structure of the 2023 European Sustainability Reporting Standards (ESRS). Likewise, for the 2025 report, Alpiq is making a voluntary effort to follow the current ESRS structure but does not claim to be fully CSRD-compliant at this point in time. As part of the ongoing regulatory transition, Alpiq is closely monitoring the evolution of the reporting requirements both at Swiss and EU level and will be gradually developing towards a CSRD-compliant report, should such obligation come into effect for Alpiq in the coming years. For the time being, although a significant simplification of the ESRS was carried out by EFRAG in 2025, the final version of the revised standard has not yet been adopted, and Alpiq continues to refer to the 2023 version of the standards currently in force; the ESRS Index in the Appendix gives an overview of the CSRD requirements that are already addressed in the Sustainability Report 2025.

Operational control approach

On its journey towards a CSRD-compliant Sustainability Report, Alpiq adapted its reporting boundaries in 2024. The following section explains these reporting boundaries:

CSRD requires companies to report based on operational control; therefore, Alpiq has introduced this logic as of 2024. Following this approach, the KPIs for majority-owned assets are calculated as if Alpiq held 100% ownership of these assets (consistent with the financial consolidation process under IFRS and Alpiq’s Financial Statements), rather than being based on Alpiq’s proportional ownership share, as was the case in Sustainability Reports prior to 2024.

In Alpiq’s case, operational control is generally applied to entities in which Alpiq holds a majority stake, with two exceptions:

• Grande Dixence hydropower plant: With an ownership share of 60%, Alpiq is the majority shareholder of the legal entity that holds the Grande Dixence hydropower plant. However, due to the governance structure of Grande Dixence SA which limits Alpiq from exercising sole control over key operational and financial decisions, Alpiq does not have operational control over the Grande Dixence hydropower plant; therefore, this asset is not fully consolidated.
• Emosson hydropower plant: With an ownership share of 50%, Alpiq is not the majority shareholder of the legal entity that holds the Emosson hydropower plant. However, Alpiq does hold 100% of the energy rights and operational control over the Emosson hydropower plant; therefore, this asset is fully consolidated.

Due to the complex partner power plant structure in Switzerland and Alpiq’s many minority shareholdings in partner plants, as well as the special case of Grande Dixence, which is not fully consolidated, the strict financial consolidation approach does not fully reflect Alpiq’s energy production portfolio and thus creates an incomplete picture of the company’s business. Therefore, Alpiq has also voluntarily decided to provide information on environmental KPIs for assets not under its operational control (minority shareholdings and Grande Dixence), even though this is not required by CSRD. This is also in line with Alpiq’s Financial Statement, which is reported in accordance with IFRS.

A list of all Group companies (fully consolidated assets) and minority shareholdings that are reported as investments in partner power plants (non-consolidated assets) can be found in the Notes to the Consolidated Financial Statements (5.4 Group companies and investments) of the Financial Report.

Country- and Asset-Specific Disclosures

The sustainability report was prepared on a consolidated basis at the Alpiq Group level, including all legal entities in Switzerland and the European countries where Alpiq is present.

Nevertheless, some requirements contain information on specific countries, due to one of the following two reasons:

• The information available at a country level cannot be summarised on a Group level without compromising its meaningfulness, given country-specific circumstances such as differences in national asset portfolios and local regulations. In this case, reporting at a country level is preferred to create an unbiased picture.

• The information is only available for certain countries but not for all countries in which Alpiq operates. In order to report as transparently as possible, the information is disclosed for the countries for which it is available.

Value Chain Coverage

The Sustainability Report considers both Alpiq’s upstream (suppliers) and downstream (customers) value chains. The upstream value chain mainly entails suppliers of power (including Alpiq’s minority shareholding in assets), suppliers of physical trading power, and sellers of Power Purchasing Agreements (PPAs). The downstream value chain entails the business-to-business relationships with transmission system operators (TSOs), distribution system operators (DSOs) and PPA buyers, as well as the business-to-customer relationships in France. Information is not provided on every actor in the value chain, but on the upstream and downstream actors identified as material during the Double Materiality Assessment (DMA).

Disclosures in relation to specific circumstances

ESRS 2 BP-2

Some metrics for the Sustainability Report 2025 have already been calculated in line with CSRD requirements. If a metric has been replaced by a new metric to align with CSRD requirements, this is clearly stated, and the new metric is identified as not being comparable with that used in the previous reporting period. In particular, the calculation of CO₂ emissions (see chapter Gross Scopes 1, 2, 3 emissions, total GHG emissions, and GHG intensity) has changed significantly due to the application of CSRD guidelines in 2024 (operational control methodology). CO₂ emissions and KPIs related to CO₂ emissions have therefore also been calculated according to the previous equity share methodology, and two sets of figures are disclosed to allow comparability with the previous reporting period.

In addition to the topics identified as material during the DMA, this Sustainability Report addresses other non-financial reporting requirements. Due diligence in the supply chain in relation to Conflict Minerals and Child Labour, as required by the Swiss Ordinance on Due Diligence and Transparency (DDTrO) in relation to Minerals and Metals from Conflict-Affected Areas and Child Labour, based on Article 964j paragraphs 2-4 and Article 964k paragraph 4 of the Swiss Code of Obligations, is covered in this report. It also covers the non-financial reporting requirements of Articles 964a-c of the Swiss CO, as well as the requirements of the Swiss Climate Ordinance (SCO), which were formerly addressed under the Task Force on Climate-Related Financial Disclosures (TCFD). In line with the SCO, this report outlines a transition plan setting out key milestones for achieving Alpiq’s net-zero target for Scope 1 and 2 emissions by 2040. The specific chapters related to the above-mentioned non-financial reporting requirements are listed in the respective index in the Appendix.