Orano - Annual Activity Report 2025 83 RISK CONTROL AND VIGILANCE PLAN 3 Risk factors parties to the dispute have worked to find a resolution via court mediation, which has not been successful, despite the efforts made by AREVA and Orano to reach a compromise. The main proceeding, therefore, resumed in 2020 and was concluded by a hearing on December 3, 2024. The deliberation, initially expected in March 2025, was postponed following new requests made by the other party. Even if the court does not accept the Orano group’s position, the financial impact would be limited, though it could entail other, indirect, consequences, in the media for instance. Mongolia At the end of several years of cooperation between Orano and the judicial authorities, a Public Interest Judicial Agreement (CJIP) was signed on December 2, 2024, with the French National Financial Prosecutor’s Office and then approved on December 9, 2024, by the President of the Court of Justice of Paris, for a project in Mongolia between 2013 and 2015, before the creation of Orano. This agreement holds no liability against Orano and closes any judicial investigation in France. This agreement does not constitute a judgment or a conviction. It provides for the French Anti-Corruption Agency to review, over a period not exceeding three years, the implementation of the group’s compliance plan rolled out since Orano’s creation in 2018 and acknowledges its cooperation with the French judicial authorities. This review is ongoing. 3.3.5.3 Tax issues Description of the risk The group, comprising entities located in different countries, regularly faces controls by local tax and customs authorities. Several audits and tax-related proceedings or disputes have been initiated or are currently being conducted by those authorities or in the courts. However, none are expected to give rise to, or have given rise to, a material tax expense that could have a significant impact on the financial statements. The group considers that it has sound means of defense and that it employs the legal procedures at its disposal to prevent any unfavorable outcome. [A description of the most significant ongoing litigation is provided in Note 34 to the consolidated financial statements as of December 31, 2025] Risk management measures In every country and region where it does business, the group ensures that it complies with the applicable tax laws and that, in accordance with the applicable regulations, the right amount of tax is paid. It further ensures that the principles enunciated by the OECD, as written into national legislation, are observed whenever it undertakes cross-border transactions. The group does not use structures that are opaque or lack real economic substance, nor entities in tax havens in order to conceal useful information from the tax authorities. It applies a policy based on compliance and transparency in tax matters. This policy is implemented by a Tax Department located in France, which relies on the Finance Departments supported, as necessary, by local experts in the countries where the group operates. The management of tax risks that may arise from differences in interpretation of the applicable rules is part of the overall risk management process. Internal control procedures and whistleblowing mechanisms ensure the correct application of ethical principles, including tax principles. The group’s companies submit their tax returns and pay their taxes on time. Each year, the group informs and declares its country-by-country tax returns (CbcR) to the French tax authorities. Each year, Orano Mining publishes separately the payments made to foreign governments according to the EITI (Extractive Industries Transparency Initiative) standard. In this context, the group specifies that it holds, following the acquisition of Uramin, all the capital of a holding company established in the British Virgin Islands. This holding company only holds shares in the group’s Namibian subsidiaries, which it does not finance or manage. In October 2023, the British Virgin Islands were removed from the European Union’s blacklist, then on February 18, 2024, from the French list of non-cooperative States or Territories. As a result, the group no longer holds subsidiaries established in a non-cooperative state.
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