Risk Identification, Assessment, and Management Measures Implemented on C2E Market

C2E Market provides tools and processes to enable members to comply with the requirements of Articles L 221-8 and R. 221-14-2 of the Energy Code, as well as with the decree of October 9, 2026, regarding risk identification, assessment, and management mechanisms designed to detect fraudulent acquisition.

First, buyers may rely on this to describe “the internal procedures implemented that led to the selection of the seller ” (I-1° of the decree) on the fact that, to be a member of C2E Market, one must meet membership requirements (Article 3 of the market regulations), including, in particular:

• minimum length of time on the market,

• no criminal, civil, or administrative convictions related to EECs,

• maintaining, at all times, risk identification, assessment, and management systems compliant with EEC requirements, in order to ensure that the EECs it acquires have not been obtained fraudulently.

• If the member is the primary filer, adherence to the principles set forth in the GPCEE’s Code of Ethics and the permanent maintenance of a system for monitoring transactions for which EECs are issued—for which the member is the primary depositor—as well as compliance rates for these checks conducted at the time of issuance of the EECs in question.

Second, the “required due diligence by the purchaser” prior to the purchase decision (Section II, Paragraph 1 of the Decree) is implemented, in particular, through the following mechanism (Article 10.2.3 of the Market Rules):

1. The ability to execute transactions on C2E Market is contingent upon having established limits with the counterparty that has posted a sell offer.

2. These limits are set after reviewing and analyzing the information contained in the potential seller’s “Member Passport” (as well as any other information the Member may request from their future counterparty).

3. When information in the Member Passport is modified, it is no longer possible to transact with the seller until the buyer has reviewed and analyzed this new information.

In other words, no sale contract may be concluded on C2E Market if the seller’s Member Passport is not up to date or if the buyer has not previously reviewed the latest available information regarding the seller.

The content of the Member Profile is set forth in Article 10.2.1 of the Market Regulations and includes the following elements (as referred to in paragraphs II 1°, 2°, and 3° of the decree and in Article 1 of the order of October 9, 2026):

• the Member’s identification details;

• equity interests of 25% or more between the selling Member and any principal holder, supervisory body, or professional involved in the execution of transactions that led to the issuance of CEE;

• the Member’s financial statements for the last three fiscal years;

• whether or not insolvency proceedings are pending;

• certificates regarding the existence of professional liability insurance, tax compliance, labor compliance, and the absence of criminal convictions for officers and beneficial owners

• whether or not there are any final convictions or sanctions against the transferor related to its activities carried out under the energy savings certificate program;

• whether or not there is a continuous improvement policy (satisfaction surveys, feedback, incident handling, certification, etc.) and a quality management system covering the transferor’s activities related to the energy savings certificate program

• a description of the procedures implemented by the Member for the purposes of applying the Risk Control Decree

• a description of the resources allocated to activities related to the Energy Savings Certificates program, taking into account the volume of certificates sold over the past twelve months as well as their characteristics

Article 12.2 of themarket regulationss provides that every Sales Contract must include an annex specifying the legal form, name, registration number, and address of the transferor’s principal office (I-1° of the decree).

Article 12.3 of themarket regulationsmarket regulations provides that this annex shall be replaced, prior to the actual transfer of the EECs, by a final annex comprising (I-2° of the decree):

• the decision number for the issuance of the EECs covered by the Sales Contract;

• the identifying information of the selling Member and the First Depositor Passport(s) relating to the EECs covered by the Sales Agreement, as well as information regarding the EECs submitted

• the form described in the annex to the order of October 9, 2026, detailing the characteristics of the transferred EECs

The “First Depositor Passport” includes the identifying information of the first holder of the transferred EECs (Article 10.2.2 of theshuttle form [market regulations]).

The preliminary verification of the EECs delivered pursuant to the Sales Agreement, in particular with respect to paragraphs II 4° and 5° of the decree, is performed by the Introducer of these EECs on the Marketplace (Articles 10.2.2, 15 and 16, and Annex I, Article 5 of theR. 221-14-2market regulations). In particular, any Introducer:

• shall ensure, with respect to the EECs it introduces to the Marketplace, that it has received and evaluated in advance the information referred to in the Risk Control Decree concerning (i) the Initial Depositor of the EECs in question and (ii) if different from the Initial Depositor, the transferor from whom they were obtained;

• refrain from introducing any CEE onto the Marketplace if it has detected any signs of fraud regarding the issuance of said CEEs or suspects the existence of such fraud;

• provide the Operator with a document titled “First Depositor Passport”

• provide the Operator with a “fiche navette” summarizing, for the delivered EECs, the information required by sections II 2° (specifically regarding EECs), II 4°, and II 5°, as well as by the form annexed to the decree of October 9, 2026

The cross-reference table between the obligations arising from the regulations, the Market Rules, and the provisions of the latter can be summarized as follows: