32816-Lucy-Group-AR-2025 web ready spreads_FINAL

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STRATEGIC REPORT

Social responsibility Social responsibility is embedded across the Group and integral to our culture. We manage people related risks, impacts and opportunities across our operations and value chain, while actively supporting the communities we serve through long-standing programmes of community investment, charitable giving and employee volunteering that focus on education, health, the environment, biodiversity, disadvantaged children and homelessness.

Governance and people Strong governance underpins how Lucy Group cares for its people and operates responsibly. Clear accountability, effective oversight and robust management systems enable us to manage health, safety, wellbeing and workforce risks across the Group. Through recognised standards and regular performance reviews, we support safe, engaging workplaces, skills development and consistent, compliant decision-making across our operations.

The anti-bribery, corruption and conflict of interest policy and associated training were updated with: expanded guidance on red flags to look out for when engaging agents and intermediaries; updated processes for the giving and receiving of gifts and hospitality; and more focus on conflicts of interest. A separate financial crimes policy and associated training provides: more information on money laundering and terrorist financing; information on tax evasion and the facilitation of tax evasion; and an updated reporting procedure. A new Code of Conduct was also developed, with links to key supporting policies. It explains the core standards and policies under which we operate and describes how we should conduct ourselves in the workplace and marketplace to ensure we are living by our core values. Health and safety Protecting the health, safety and wellbeing of our employees, contractors and those affected

by our activities is our top priority. We manage this through established health and safety management systems aligned with ISO 45001:2018. These systems provide a clear, practical approach to identifying and managing risk, supported by defined processes for compliance, training, documentation and communication. Certification at applicable locations strengthens accountability and supports ongoing improvement, alongside a structured assessment against 24 critical safety criteria that help us understand our current performance and set clear priorities for progress. Culture and leadership: BE SAFER The Lucy Group Safety Rules, BE SAFER, set clear expectations for how safety is managed across the business. They encourage employees to take personal responsibility for their own safety and to work closely with colleagues and supervisors to recognise hazards linked to their day‑to‑day activities. Safety is treated as a shared responsibility, with everyone expected to stop, assess risks, and put the right controls in place before starting work. This practical approach helps reduce incidents and creates working environments where people can carry out their roles safely, without putting themselves or others at risk. Our aim is simple: to provide safe workplaces

Wates Principles As a private company, we report in accordance with the Wates Corporate Governance Principles for Large Private Companies. We therefore Composition, Director Responsibilities, Opportunity and Risk, Remuneration, and Stakeholder Relationships and Engagement. These are covered in the sections on Corporate Governance (pages 84 to 89), Risk Management (pages 60 to 65), and Relations with Stakeholders (pages 92 to 93). Fair labour The Group is committed to fostering a workplace built on integrity and respect. Robust policies and controls are in place to prevent corruption and discrimination, with zero reported incidents in 2025. Employee training supports a vigilant, accountable culture, while a comprehensive supplier audit programme is being introduced to promote fair labour practices and uphold high ethical standards across our supply chain. apply the six Wates Principles of Purpose & Leadership, Board

CSR area

Target/KPIs

Education

| Complete a minimum of one education-focused CSR initiative per site every six months. | Complete a minimum of one health and wellbeing-focused CSR initiative in the community per site every six months. | Complete a minimum of one BNG or environmental project per site every six months.

Health and Wellbeing

Biodiversity

Our CSR performance is measured through a comprehensive CSR Scoring Matrix aligned with the ISO 26000 Social Responsibility standard. This framework assesses seven core elements and 274 attributes, ensuring our activities align with our priority Sustainable Development Goals (SDGs). By understanding the social impacts of our decisions, we are better positioned to strengthen our approach to social responsibility and deliver meaningful, long-term change. Our work in 2025 In 2025, we supported 95 charities, community projects

| Volunteering - by visiting schools to explain the world of work, teach about engineering and sustainability or help to refurbish premises or land (Thailand, UK, Romania, India, Saudi Arabia). | Supporting orphanages and children in care – with much needed clothes, school equipment, food and other resources (Brazil, Saudi Arabia, South Africa, Thailand, Malaysia, UK). | Running health-related activities - such as blood donations, charity runs raising money for various organisations (India, Malaysia, UAE, UK, Thailand). | Promoting biodiversity within schools and the community - by providing hedgehog houses, planting sensory gardens in schools, supporting school eco groups, visiting schools (UK, India, Malaysia, Thailand); cleaning up beaches, rivers, forests, local environments and removing plastics and rubbish from the streets (India, Saudi Arabia, Thailand, Romania); tree planting (UK, India, Saudi Arabia); donations to local wildlife charities and reserves (Brazil, UK, South Africa); recycling and reducing food waste (Thailand, UK, UAE, Brazil, Malaysia, India).

and environmental organisations and participated in 224 CSR activities worldwide. Recognising the challenges charities face without enduring partnerships – particularly the uncertainty that limits their ability to plan and invest sustainably – we introduced a new target in 2025 requiring each site to commit to at least one long-term charity partnership. As a result, we selected 17 charities globally to support as long-term partners. This progress reflects growing engagement across our teams and a shared commitment to creating positive, lasting impact in the communities we serve. We are really proud of the work we have been doing across our communities in 2025: | Fundraising and donations – supporting local and national charities, local community activities and cultural events across all our locations for an array of causes covering health, youth and children, veterans, hospice care, the elderly, cancer charities and food banks (all countries). | Undertaking vital work with local schools – supporting young people in education, work experience and apprenticeships; assisting young people with technology needed to receive an education (UK, India, UAE, Romania, Malaysia, Saudi Arabia). | Aiding youth organisations – with their education and by providing essential equipment and supplies (India, Brazil, South Africa, UK, UAE).

while maintaining high safety standards across the Group.

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Lucy Group Ltd Annual Report & Accounts 2025

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