Aalberts

The role of the administrative, management and supervisory bodies

Reference: page 41 (sustainability governance, indexed as GOV-1 on the chapter cover page p.39); composition and experience datapoints incorporated by reference to pages 108-111 and 114; GOV-1 is also indexed against the governance chapter IROs (p.79, content p.80).

Aalberts N.V. has a two-tier board: a Supervisory Board and a Management Board, supported by an Executive Team.

• The Supervisory Board "continuously supervises the sustainable long-term value creation strategy, the establishment and implementation thereof by the Management Board and the Executive Team and the impacts, risks and opportunities and associated targets, related to sustainable entrepreneurship, people & culture and governance topics" (p.41).
• The Audit Committee "monitors the ESG reporting process and risks associated with it, the internal control systems and implementation of the CSRD"; the NSR Committee monitors the people & culture strategy (p.41).
• "Given Aalberts' focus on sustainability, overall ownership of sustainability is with the CEO" (p.41). Health & safety, sustainability, people & culture and governance are monthly Executive Team agenda items.
• Day-to-day work sits with the director sustainable entrepreneurship (head-office sustainability team), executed through the HSRS network in which each business team is represented by its COO or equivalent; the chief people & culture officer heads the P&C network; governance counsels in the legal & governance team run the governance plans (p.41).
• ESG reporting "is supervised by the director sustainable entrepreneurship, who is part of the Executive Team and discusses this at least quarterly with the Management Board" (p.40).

The EU legislation datapoints table indexes GOV-1 paragraph 21(d) to pages 110, 111 and 113 and 21(e) to page 114 (p.87). Diversity and experience of the Supervisory Board are incorporated by reference (p.40).

Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies

Reference: page 41 (indexed as GOV-2 on the general disclosures cover page, p.39).

Aalberts describes the flow of sustainability information to its bodies rather than a calendar of agenda items.

• The Management Board and Executive Team "take the impacts, risks and opportunities into consideration while overseeing strategy and risk management. These were taken into account in long-term financial planning, scenario analysis and the development of the strategy 'thrive 2030', leading to updated action plans and targets on sustainability, health and safety, innovation and people & culture topics" (p.41).
• "Performance and progress of the HSRS improvement plans are monitored via quarterly HSRS network meetings and more frequently if deemed necessary" (p.41). The main environmental KPIs "are shared and discussed within the HSRS network quarterly" (p.56).
• The P&C network meets quarterly; "Progress and performance on selected KPIs (page 75) are measured quarterly" (p.41).
• The DMA results "have been reviewed and validated by the Management Board" (p.47).
• From the Supervisory Board's own report: "An update on the implementation of the CSRD, the ESG dashboard and progress and performance on the ESG KPIs were recurring items on the agenda of the Supervisory Board in 2025", and "health & safety continues to be a recurring item on the agenda of all Supervisory Board meetings" (pp.110).

The Supervisory Board "can leverage the expertise of the director sustainable entrepreneurship, chief people & culture officer and general counsel, who directly engage with the impacts, risks and opportunities in daily strategy implementation" (p.41).

Integration of sustainability-related performance in incentive schemes

Reference: page 42 (indexed as GOV-3 on the general disclosures cover page, p.39), incorporated by reference to the remuneration report; content at page 118. Aalberts lists "how sustainability is integrated in incentive schemes (GOV-3)" among the disclosures incorporated by reference (p.40).

"In 2025, sustainability related performance is integrated in incentive schemes, performance under the long-term incentives (LTI) is being assessed against specific sustainability metrics and targets" (p.42). The remuneration report confirms this was new: "In 2025, sustainability targets were included in the LTI for the first time, marking a significant step in aligning executive remuneration with the company's long-term environmental and social objectives" (p.115).

LTI 2025-2027 performance criteria and weightings (p.118):

"For the 2025-2027 series, the sustainability performance criteria are set for reduction of scope 1 & 2 emissions and separately the scope 3 emissions. Per performance objective the threshold, at target and maximum are set" (p.118). Numerical ESG targets are withheld: "Detailed numerical targets will not be disclosed before vesting of the plan as these are share price and competition sensitive" (p.118). The same criteria and weightings carry into LTIP2026-2028.

The 2025 short-term incentive carried a 20%-weighted block of "non-financial objectives" scored as an average of 3 out of 5, without naming the objectives (p.117); the 2026 CEO non-financial objectives include a "sustainability commitment" (p.117).

Statement on due diligence

Reference: page 42 (indexed as GOV-4 on the general disclosures cover page, p.39); the EU legislation datapoints table indexes GOV-4 paragraph 30 to page 42 (p.87).

Aalberts prints the mapping table required by GOV-4, giving the report location of each of the five core due-diligence elements (p.42):

Supporting narrative (p.42): "We are actively working to align our due diligence on human and environmental risks with the Corporate Sustainability Due Diligence Directive (CSDDD), expected to be required by 2028." In 2025 Aalberts "has become a signatory of the UN Global Compact (UNGC)" and joined its Business & Human Rights accelerator training, working "towards alignment with the United Nations Guiding Principles on Business and Human Rights (UNGP) and the OECD Guidelines for Multinational Enterprises". "In 2025, we received no evidence of any human rights violations or abuses." Supplier due diligence runs through the Supplier Code of Conduct, purchase terms in the semicon segment and a sustainable procurement policy in the building segment, with ESG assessments by online questionnaire in the building segment.

Risk management and internal controls over sustainability reporting

Reference: page 40 (basis for preparation, indexed as BP-1, BP-2 and GOV-5 on the general disclosures cover page, p.39), incorporated by reference to the risk and opportunity management section on page 94 for datapoints 36 a, b and c (p.40).

• "For a general description of our risk and internal control processes, reference is made to the paragraph risk and opportunity management (page 94)" (p.40).
• "The sustainability data for our reporting is obtained and validated by our local business teams, in accordance with the ESG reporting manual, which outlines definitions, scope and procedures. Periodically, the sustainability data is submitted via our global consolidation and reporting system, where it is consolidated, reviewed and validated by the ESG reporting manager and the finance/group control team" (p.40).
• "The controls in place are embedded within our risk and control framework, which define the scope, key features and components of our risk management and internal controls for sustainability reporting" (p.40).
• Oversight: "ESG reporting is supervised by the director sustainable entrepreneurship, who is part of the Executive Team and discusses this at least quarterly with the Management Board" (p.40); the Audit Committee "monitors the ESG reporting process and risks associated with it" (p.41).
• "The data presented in the sustainability statement is not validated by an external body other than the assurance provider" (p.40).

The link from the DMA to enterprise risk management is made explicit: "The link between material risks and opportunities resulting from the DMA and our overall risk and opportunity management is shown on page 48, in the last column of the figure" (p.40). The Supervisory Board reports that the 2025 Dutch Corporate Governance Code requires a Verklaring Omtrent Risicobeheersing covering "sustainability reporting (limited assurance)" (p.110).

Strategy, business model and value chain

Reference: pages 44 (our value chain) and 45 (sustainable entrepreneurship), both indexed as SBM-1 on the general disclosures cover page (p.39); products, services, customers and revenue per segment incorporated by reference to pages 4 and 134 (p.40).

Aalberts describes itself as engineering "mission-critical technologies enabling a clean, smart and responsible future" across three segments - building, industry and semicon - with sustainability framed as a growth driver under the strategy 'thrive 2030' (p.45). "By innovating in customer-centric solutions, we realised an innovation rate of 20%" (p.45).

Value chain (p.44): "Our upstream value chain supplies the essential inputs, like raw materials and energy, to manufacture products and perform services such as heat and surface treatments. Our key materials used are brass, steel and plastics." Downstream, "Our downstream value chain illustrates how the Aalberts mission-critical technologies enable our customers to make impact in the respective end markets." "At Aalberts, approximately 12,943 people work together to deliver solutions to our customers, measured in FTE" (p.44). The reporting scope "on impacts, risks and opportunities that are material for Aalberts covers the entire value chain, as shown on page 44" (p.40).

ESRS sector mapping (p.45): building relates to Machinery and Equipment (MME), industry to Manufacturing Metal Processing (MMP) and semicon to Manufacturing Electronics and electrical equipment (MEL). All three "relate to ESRS sectors (page 136) that are considered high climate impact sectors" (p.56 footnote 3).

Scale figures elsewhere in the statement: 12,221 FTE at year-end across 127 locations and over 50 countries (pp.75-76), with Europe 62%, Asia 19% and America 19% of FTE (p.76).

Interests and views of stakeholders

Reference: page 43 (indexed as SBM-2 on the general disclosures cover page, p.39).

"Aalberts identifies its key stakeholders as parties directly or indirectly affected by our activities or those who have a direct interest in or who can have an impact on our long-term business success. Through stakeholder mapping, Aalberts has identified five main stakeholder groups with highest impact and/or influence: (i) shareholders covering investors, financial analysts and other financial stakeholders (i.e. banks and other financial institutions); (ii) customers; (iii) employees; (iv) suppliers and partners and (v) society covering regulatory bodies, governmental agencies, local communities and other organisations" (p.43).

A table on page 43 sets out, per group, the engagement method, key interests and the effect on strategy. Examples as printed: shareholders engage through "(annual) meetings, Capital Markets Day, webcasts, conference calls, site visits, roadshows and broker conferences" with the effect "alignment on priority ESG topics, inclusion in ESG funds, ESG taken into account for USPP"; employees through "day-to-day operations, feedback surveys, sessions, webinars, events, network meetings, speak up!, training and leadership programmes" with interests "health and safety, employee satisfaction"; suppliers and partners through "day-to-day operations, audits and workshops" on the "Supplier Code of Conduct, ESG due diligence".

How the results are used: they are "(i) communicated to and discussed by the Management Board and Supervisory Board; (ii) used to identify possible impacts, risks and opportunities...; (iii) used to determine the materiality of ESG topics...; (iv) used to set ESG targets and (v) used to conduct and improve sustainability due diligence" (p.43). "The frequency, level and method of engagement is tailored to the goal of the dialogue and the relationship with the stakeholder" (p.43). Engagement fed the 2025 DMA directly through online interviews and in-person workshops (p.46).

Material impacts, risks and opportunities and their interaction with strategy and business model

Reference: pages 45-48 (double materiality assessment, indexed as SBM-3, IRO-1 and IRO-2 on the general disclosures cover page, p.39); also indexed as SBM-3 against climate change IROs (p.49, content pp.50-51) and against both social topics (p.67, content pp.68 and 71).

Aalberts performed a new DMA in 2025: "Based on the ESRS developments, dialogue with peers and learnings of the past two years, Aalberts performed a new Double Materiality Assessment (DMA), to align its reporting with ESRS 1 of the CSRD. The new DMA enabled us to be more granular about which ESG impacts, risks and opportunities are material for Aalberts" (p.45).

Outcome (p.45): "Resulting from the DMA, Aalberts reports on (parts of) ESRS E1 Climate Change, E5 Resource Use and Circular Economy and S1 Own Workforce. Since 2025, Aalberts reports on two entity-specific topics: employee attraction and retention and export control & sanctions and fair competition."

Material IROs are described per chapter: climate change (own scope 1, 2 and 3 emissions as a material negative impact and a physical risk; technology, reputation and market transition risks; the market opportunity in energy-efficient solutions and the positive impact of customer emission reductions, pp.50-51); circular economy (resource depletion, transition and procurement cost risks, the circular opportunity and the positive impact of circular waste handling, p.60); own workforce (harm to employee health and safety as a material negative impact, p.68; five attraction and retention risks and seven opportunities, p.71); and the governance topic (violations of sanctions, export control and fair competition as a material risk, p.80).

"The corresponding current and anticipated effects of the material impacts, risks and opportunities for Aalberts and how we approach these effects, is discussed in the individual chapters... Reporting on the anticipated financial effects of the material impacts, risks and opportunities will be phased-in the coming years" (p.45). The consolidated IRO overview sits in a figure on page 48 that is not machine-readable in the published PDF text layer.

Description of the processes to identify and assess material impacts, risks and opportunities

Reference: pages 45-48 (indexed as SBM-3, IRO-1, IRO-2 on the general disclosures cover page, p.39); also indexed as IRO-1 for climate change (p.49, content p.50), resource use and circular economy (p.49, content p.60) and the governance topic (p.79, content p.80).

Methodology (p.45): "The DMA methodology was developed with reference to the principles in the final ESRS and the EFRAG Implementation Guidances." The process covered "own operations and in our upstream and downstream value chain"; for own operations Aalberts engaged employees, and for value chain assessments "(first-tier) suppliers, customers and investors". "The financial materiality assessment focused on the residual risk rather than the inherent risk, considering the organisational context and policies in place" (p.46).

Threshold (p.46): "Scale, remediability, scope, likelihood and financial magnitude were all scored on a scale of 0 to 10... An Impact, Risk or Opportunity (IRO) was considered material when it scored a total of 6.0 points or higher." "The scale and materiality threshold have changed compared to the previous DMA, where we uphold a scale between 0 to 5, with a materiality threshold of 2.5. The change in scale and materiality threshold was to bring strategic focus."

Three process steps (pp.46-47): identify the baseline and topic list (internal, external and sector development analysis, with "Each identified ESG topic... linked to the various underlying sub-topics described in the ESRS 1, Application Requirement 16"); perform stakeholder engagement (mapping, online interviews and in-person workshops with customers, shareholders, employees and suppliers); and plot the results. "Impact materiality was assessed on severity and likelihood, stemming from the OECD Guidelines for Multinational Enterprises and UN Guiding Principles on Human Rights. Severity was measured in scale, scope and remediability. Financial materiality was assessed with the help of a financial model... The following financial metrics were plotted in the model: Revenue, EBITDA, CAPEX and Free Cash Flow" (p.47). "The results of the materiality assessment have been reviewed and validated by the Management Board" (p.47).

"An annual assessment is conducted to identify any material changes that necessitate a reassessment of the DMA outcome. The acquisitions and divestments performed in 2025 did not have a material effect on the outcome of the DMA" (p.45).

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Reference: page 45, indexed as IRO-2 on the general disclosures cover page (p.39).

Aalberts does not print a single consolidated ESRS content index. Instead it states: "The ESRS disclosure requirements can be found on the cover pages of each chapter" (p.45). Those four cover pages carry the concordance used for this review:

• General disclosures (p.39): basis for preparation - BP-1, BP-2, GOV-5 (p.40); sustainability governance - GOV-1, GOV-2, GOV-3 (p.41); sustainability due diligence - GOV-4 (p.42); stakeholder engagement - SBM-2 (p.43); our value chain - SBM-1 (p.44); sustainable entrepreneurship - SBM-1 (p.45); double materiality assessment - SBM-3, IRO-1, IRO-2 (p.45).
• Environment (p.49): climate change - E1-1, SBM-3, IRO-1 (p.50); E1-4 targets (p.52); E1-2 policies (p.53); E1-3 actions (p.53); E1-5, E1-6 performance (p.56). Resource use and circular economy - IRO-1 (p.60); E5-3 targets (p.60); E5-1 policies (p.61); E5-2 actions (p.61); E5-4, E5-5 performance (p.62). EU taxonomy (p.64).
• Social (p.67): health and safety - SBM-3 (p.68); S1-5 targets (p.68); S1-1 policies (p.69); S1-4 actions (p.69); S1-14 performance (p.70). Attraction and retention - SBM-3 (p.71); S1-5 (p.72); S1-1 (p.72); S1-2, S1-3, S1-4 (p.73); S1-6, S1-8 (p.75).
• Governance (p.79): export control & sanctions and fair competition - GOV-1, IRO-1 (p.80); MDR-T, MDR-P (p.80); MDR-A, MDR-M (p.81). No G1 disclosure requirement is cited.

A second index, the EU legislation datapoints table (p.87), "outlines the data points derived from other EU legislation, as listed in ESRS 2 Appendix B... and which data points were assessed as 'not material'", adding page references for GOV-1 21(d) and 21(e), GOV-4 30, E1-1 14 and 16(g), E1-4 34, E1-5 37/38/40-43, E1-6 44 and 53-55, E5-5 37(d) and 39, S1-1 20-23, S1-3 32(c), S1-14 88(b)/(c)/(e) and S1-16 97(b).

Aalberts reports voluntarily: "In anticipation of the implementation of the CSRD in Dutch law, Aalberts continues to report voluntarily alongside the ESRS requirements" (p.40).

Transition plan for climate change mitigation

Reference: page 50 onwards (E1-1 is indexed on the environment cover page, p.49); the EU legislation datapoints table indexes E1-1 paragraph 14 to pages 50-59 and paragraph 16(g) to page 52 (p.87). The plan itself is described at pages 52-55.

"Aalberts is committed to be net zero carbon by 2050 or earlier" (p.52). "The Aalberts net zero carbon transition plan elaborates on the 'net zero carbon' principle of the environmental policy. The content of the transition plan is disclosed in the climate change chapter of the annual report and published on our website" (p.53).

Targets in the plan (p.52): scope 1 and 2 (market-based) combined - "decrease CO2 intensity by 50% by 2030 and decrease absolute emissions by 40% by 2030, taking 2018 as a base year"; scope 3 category 1 purchased goods and services - "decrease our CO2 intensity... by 30% by 2030, taking 2024 as a base year". "The targets are set to support our commitment to be net zero carbon by 2050 or earlier, calculated with the tools and methodology provided by the Science Based Target initiative."

Stated 1.5C position (p.52): "The targets follow a net zero carbon by 2050 trajectory. As the 1.5°C trajectory follows an exponential decay curve with steeper reductions by 2030, the reference target for absolute scope 1 and 2 emissions is a reduction of 50% by 2030. The targets have not been externally validated and we are not included in the EU Paris-aligned Benchmarks." So the disclosed absolute target (-40%) sits below the 1.5C reference the company itself names (-50%).

Six decarbonisation levers (p.53): improving energy efficiency; increasing renewable energy use; driving electrification; smart product design; acting on circular solutions; value chain collaboration.

Locked-in emissions (p.51): "some of our processes are reliant on a natural gas-powered infrastructure. Industrial equipment and machinery is designed for long-term use and expected to run for several decades, resulting in locked-in greenhouse gas (GHG) emissions, which decelerates the pace with which we can work towards net zero carbon operations."

Resourcing (p.55): "Sustainability benefits are often realised as part of broader investments... This makes it challenging to isolate financial investments with sole sustainability objectives." In 2025 the decarbonisation levers were integrated in forecasting and budgeting, and an internal carbon price was put into investment proposal sheets. Approval: targets are "approved by the Management Board and the Executive Team and have been highlighted in our environmental policy" (p.52). EU Taxonomy-aligned CapEx is 0.0% (p.86).

Identification of climate-related risks and scenario analysis

Back-filled from the climate change impacts, risks and opportunities section, which the environment cover page indexes as E1-1, SBM-3 and IRO-1 (p.49), and where this content is disclosed in the FY2025 report (pages 50-51). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risks classified as physical or transition (p.50). The report uses those two headings explicitly. Physical: "Aalberts recognises that its scope 1, 2, and 3 CO2 emissions contribute to global warming and considers this contribution a material negative impact as well as a physical climate risk to its business. Increased severity and frequency of extreme weather events such as extreme precipitation or hurricanes can affect our operations and supply chain." Transition: technology risk (capital expenditure for low-carbon manufacturing), reputation risk (loss of stakeholder trust from insufficient GHG performance), market risk (grid congestion and renewable energy shortage) and the market opportunity in energy-efficient solutions (pp.51).

Methodology and scope (p.50). "climate risk and vulnerability assessments were carried out in 2025 for all operational sites (excluding office locations), based on their geospatial coordinates. The acute and chronic physical risks and the potential financial implications for our operations were assessed using climate scenarios for the time horizons 2030 and 2050. The time horizons were based on a distributed future outlook rather than their link to asset lifetime, strategic planning or capital allocation plans." Acute risks analysed: extreme precipitation and wind. Chronic: temperature rise, drought and sea level rise. "Financial implications relate to direct damage to property value and business interruption. The findings indicate that our current exposure primarily pertains to climate perils such as flooding and hail." Value chain physical risk is not yet covered: "The next step is to assess the climate risks in our value chain" (p.50).

Scenarios named (p.50). Physical: IPCC RCP 2.6 and RCP 8.5 - "RCP 8.5 represents a high emissions climate scenario with continued rise of GHG emissions." Transition: IEA Net Zero Emissions by 2050 (NZE) and Stated Policies (STEPS) - "The NZE scenario is a high transition scenario, representing a global pathway towards limiting global warming to 1.5°C degrees."

Temperature projections (p.50). For NZE, "The World Energy Outlook 2025 predicts that global warming will peak over the 1.5°C degrees threshold in this scenario before falling back to 1.5°C degrees by 2100". STEPS is "projecting a global-average warming of 2.5°C degrees by 2100". No temperature projection is given for RCP 2.6 or RCP 8.5.

Key assumptions (p.50). For NZE: "the pace of annual efficiency improvements is doubled and the installed capacity of renewables is tripled by 2035"; for STEPS, "the continued effect of the current policies in place across the energy economy". Timing: the physical assessment was carried out in 2025; the transition analysis tests each named risk under both scenarios (pp.50-51).

Resilience in relation to climate change

Back-filled from the climate change impacts, risks and opportunities section (indexed as E1-1, SBM-3, IRO-1 on the environment cover page, p.49), where this content is disclosed in the FY2025 report (pages 50-51 and 55). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Results of the analysis (p.50). "Our existing risk profile with a broad spread in businesses, technologies, end markets and geographical regions reduces the impact because it limits our dependence on specific markets or customers and benefits our strategic objective to create sustainable and profitable growth." On the forward view: "The 2030 assessment result shows an increased exposure to chronic risks, including drought and sea level rise, which will elevate operational risks and exacerbate climate perils such as flooding, storms and wildfires. By 2050, these trends are expected to persist, with the disparity between scenarios becoming more pronounced. The assessment enables us to identify our gross physical risks and strengthen our climate resilience from a business-continuity perspective."

How the analysis informs the response (p.50). "Our business teams evaluate risks for their operations and assess their resilience in cooperation with our property risk insurer, using the IPCC warming scenarios. Based on the risks identified and the resilience established, follow-up climate related recommendations have been implemented or planned. These consist of human behaviour, engineering and technological solutions, such as implementing flood emergency plans or physical flood protection in areas with flooding or extreme precipitation or roof securement in hurricane zones." Adaptation policies and physical risks "are integrated in the business continuity plans to support effective operational response."

Business-model resilience against transition scenarios (pp.51). "Aalberts anticipates on this risk by actively building towards a more resilient business model. In 2025, we integrated the CO2 impact into our capital expenditure proposal plans". On technology-agnostic products: "The mission-critical technologies we engineer are independent of the power source and cover a broad range of possible applications." On grid dependency: "we are actively limiting our grid dependency through efficiency and storage solutions. In the Netherlands, we are collaborating with local business parks in energy hubs to use local solar energy and invested in energy storage with a battery to avoid net congestion."

Uncertainty stated (p.50). "Although physical risks cannot be fully predicted, the resilience analysis, follow-up recommendations and business continuity plans enhance our preparedness to manage potential events." Further uncertainty on adaptive capacity: "We acknowledge that future resource allocation will depend on external factors, such as regulation, market conditions and access to affordable financing" (p.55). Aalberts also names an "innovation gap" where electrification and low-carbon materials depend on external technological development (pp.51, 54).

Policies related to climate change mitigation and adaptation

Reference: page 53, indexed as E1-2 policies on the environment cover page (p.49).

"The Aalberts environmental policy shows our commitment on the themes on our sustainability agenda: SDGs, net zero carbon, circular economy and water use. The policy showcases how we address the material impacts, risks and opportunities through commitments, targets and actions" (p.53).

Scope of topics covered (p.53): "The policy covers topics such as climate change adaptation, climate change mitigation, energy efficiency, renewable energy, electrification, product design, circular solutions and value chain collaboration."

Basis, approval and availability (p.53): "The policy is based on the sustainability improvement plans within Aalberts and aligns with the sustainable entrepreneurship strategy, which is integrated in the overall strategy 'thrive 2030'." "The principles in the policy have been approved by the Management Board and the Executive Team and will be reviewed and revised when deemed necessary. The policy applies to Aalberts and its controlled subsidiaries anywhere in the world and can be found on at aalberts.com/sustainability."

Relationship to the transition plan (p.53): "The Aalberts net zero carbon transition plan elaborates on the 'net zero carbon' principle of the environmental policy." Monitoring of implementation is cross-referred: "The progress of the policy implementation can be found under 'performance' (page 56) and is reported on in line with ESRS."

Adaptation policies are described within the IRO section rather than the policy paragraph: "In addition to climate change adaptation policies (such as emergency response plans for flood, snow or earthquakes), physical climate change risks and climate adaptation measures are integrated in the business continuity plans to support effective operational response" (p.50). Energy management is backed by certification: "Several of our locations are ISO 14001 and ISO 50001 certified, demonstrating strong environmental management systems and effective energy management practices" (p.53). Energy efficiency plans are "in line with the Energy Efficiency Directive (EU/2023/1791) and ISO requirements" (p.53). No accountable individual below Management Board level is named for the policy, and third-party standards other than ISO and the Energy Efficiency Directive are not cited.

Actions and resources in relation to climate change policies

Reference: pages 53-55, indexed as E1-3 actions on the environment cover page (p.49).

"Aalberts identified six decarbonisation levers that can be applied in our own operations and our supply chain to achieve our CO2 emission targets and mitigate the climate-change impacts and risks" (p.53): improving energy efficiency, increasing renewable energy use, driving electrification, smart product design, acting on circular solutions, value chain collaboration.

2025 actions with disclosed effects:

• Energy efficiency: automation work with a supplier at "six of our sites in Germany", including "lowering process temperatures to the minimum required, optimising weekend operating modes"; a battery energy storage pilot in the United States that "reduces peak demand by approximately 80 kW, avoiding approximately an estimated 2.7 tonnes CO2 emissions annually", with "a second phase... planned for 2026" (p.53).
• Renewable energy: "66 of our buildings run on 100% renewable electricity. Across the Aalberts group, 33% of electricity is renewable." "We procured 100% renewable energy at one of our sites in Hungary, saving approximately 1,446 tonnes CO2 annually" (p.53).
• Electrification: "We transitioned the production of composite valves from hydraulic to fully electric machinery at one of our sites in the Netherlands, resulting in an approximately 50% reduction in energy consumption during manufacturing" (p.54).
• Smart product design: a redesigned ball valve in Germany that "lowers the product's carbon footprint by 240 tonnes of CO2 annually" (p.54).
• Circular solutions: multiple Netherlands sites aligned on one waste handler (p.54). Value chain collaboration: product carbon data from LCAs and EPDs submitted to the 2BA platform (p.55).
• A named site case: furnace batch-rate and cooling-control changes at the Dunningen heat treatment site in Germany "saved around 300 tonnes of CO2 per year" (p.54).

Resources (p.55): "The actions taken align with the priorities set in the sustainability improvement plans and the resources available of the Aalberts business teams, particularly regarding human capital and financial investments... This makes it challenging to isolate financial investments with sole sustainability objectives." In 2025 the levers were embedded in forecasting and budgeting, an internal carbon price was added to investment proposal sheets, and sustainability targets were put into Executive Team long-term incentives. No monetary CapEx or OpEx figure is given for the actions.

Carbon offsetting (p.55): "We are taking part in a CO2 offset programme through Verified Carbon Units 1,511 tonnes CO2 in 2025, which is 0.7% of our total carbon emissions... our Verified Carbon Units are verified under the Verra (VCS) standard. The offsetting is not taken into account calculating the gross carbon emissions as disclosed on page 59." Adaptation actions sit at page 50 (flood emergency plans, physical flood protection, roof securement in hurricane zones).

Targets related to climate change mitigation and adaptation

Reference: page 52, indexed as E1-4 targets on the environment cover page (p.49); the EU legislation datapoints table indexes E1-4 paragraph 34 to page 52 (p.87).

Targets as disclosed (p.52):

• Net zero carbon by 2050 or earlier.
• Scope 1 and 2 (market-based) combined: -50% CO2 intensity by 2030 and -40% absolute emissions by 2030, base year 2018.
• Scope 3 category 1 purchased goods and services: -30% CO2 intensity by 2030, base year 2024. "The scope of the target relates to the entire Aalberts group" (p.60).

"These targets are based on the sustainability improvement plans developed by our business teams and approved by the Management Board and the Executive Team and have been highlighted in our environmental policy. Progress is reviewed quarterly in the HSRS network, and plans are adjusted if necessary to reach our targets" (p.52).

Basis and validation (p.52): "The targets are set to support our commitment to be net zero carbon by 2050 or earlier, calculated with the tools and methodology provided by the Science Based Target initiative." "The targets follow a net zero carbon by 2050 trajectory. As the 1.5°C trajectory follows an exponential decay curve with steeper reductions by 2030, the reference target for absolute scope 1 and 2 emissions is a reduction of 50% by 2030. The targets have not been externally validated and we are not included in the EU Paris-aligned Benchmarks."

Progress measurement changed in 2025 (p.52): "Progress against the targets is measured on an accumulative basis, to account for the 'thrive 2030' growth agenda... From 2025 onwards, we focus on our organic year-on-year progress, by normalising the prior-year results for changes in company composition and emission factor revisions." Reported position: "The 29% reduction between 2018 and 2024 and the organic reduction of 5% between the 2024 normalised value and 2025, result in an accumulative progress of 34% against our target of -40% by 2030. The same approach is taken for CO2 intensity, resulting in an accumulative progress of 40% against our target of -50% by 2030."

Waste and resource targets are set separately under E5 (scope 3 category 1 intensity -30% by 2030 and waste disposed intensity -30% by 2030, both 2024 base, p.60). No adaptation target is disclosed, and no interim milestones between 2025 and 2030 are given.

Energy consumption and mix

Reference: page 56, indexed as E1-5 performance on the environment cover page (p.49); the EU legislation datapoints table indexes E1-5 paragraphs 37, 38 and 40-43 to page 56 (p.87). Accounting policies p.56; five-year series also at p.83.

Energy consumption and mix, reported in TJ (p.56):

The same table is restated in MWh (total 1,006,642 MWh in 2025) using a conversion factor of 277.78 (p.56).

Commentary (p.56): "Due to acquisitions, our absolute energy consumption increased by 2.3% compared to 2024 while our organic energy consumption decreased by 7.3%. Our renewable and self-generated electricity is now 33% of our total electricity consumption, compared to 41% in 2024. The share of renewable energy decreased to 15% in 2025 coming from 18% in 2024, due to change in company position and limited availability of renewable energy in certain regions." Energy intensity "increased by 6.1% compared to 2024"; the EUR 3,035 million revenue denominator is "normalised for changes in company composition".

Scope and method (p.56): "The scope 1 and 2 emissions and the (renewable) energy use cover 100% of our locations, as prescribed by ESRS 1 data requirement 5.2." DEFRA conversion factors, reviewed annually. Stated limitation: "we do not report a split in energy consumption from nuclear sources or fuel consumption from biomass, as this is not available" (footnote 2, p.56). High-climate-impact sectors: "all three Aalberts segments relate to ESRS sectors (page 136) that are considered high climate impact sectors. Therefore the total energy intensity and the total revenue can be associated with high climate sectors" (footnote 3, p.56).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 56-59, indexed as E1-6 performance on the environment cover page (p.49); the EU legislation datapoints table indexes E1-6 paragraph 44 and paragraphs 53-55 to page 59 (p.87).

Gross emissions, tonnes CO2e (p.59):

Intensities (p.59): scope 1 and 2 market-based 75 tCO2/EUR million revenue (2024: 70, +7.6%); scope 3 related to purchased goods and services 355 (2024: 550, -35.4%); scope 1, 2 and 3 market-based 462 (2024: 644, -28.3%).

Commentary (pp.57-58): "our scope 1 and 2 emissions organically decreased by 4.6% compared to the 2024 normalised value"; the scope 1 and 2 intensity shows "a 7.6% increase compared to the 2024 actuals and a 2.0% decrease compared to the 2024 normalised value". The scope 3 fall "is driven by a methodological shift from a spend-based to an activity-based approach, a reporting improvement project and driving our decarbonisation levers"; activity-based data rose to 35.0% of scope 3 (2024: 5.7%) and category 2 capital goods was added in 2025.

Method and boundary (pp.56-58): operational and financial control, additive approach, boundary aligned with financial reporting. "The GHG emissions we measure relate to CO2, other GHG emissions such as CH4, N2O, HFCs, PFCs, SF6 and NF3 are not material for Aalberts and are not reported." Market and location-based scope 2 both given; "We do not disclose the share between bundled and unbundled certificates, as we do not have the full data from our supplier grid mix." AIB and DEFRA factors. A spend-based screening was run on all 15 scope 3 categories; categories 13, 14 and 15 "were not considered applicable"; categories 4, 6, 7, 8, 9, 10, 11 and 12 were assessed in detail but are not reported (p.58). "we do not use scope 1 emissions from regulated emission trading schemes" and "we do not measure biogenic emission of CO2e" (footnotes, p.59). 2024 actuals are not restated: "Since the 2024 data is still accurate, we do not restate the 2024 actuals" (p.57).

Policies related to resource use and circular economy

Reference: page 61, indexed as E5-1 policies on the environment cover page (p.49).

"To support the implementation of circularity and waste management in our business, circular economy is a key topic in the Aalberts environmental policy. The main impacts, risks and opportunities related to circular economy and the key actions we take to mitigate those risks across our value chain are presented in the policy. The policy illustrates our approach to reducing use of virgin resources and stimulating the use of renewable resources" (p.61).

The policy is the same group environmental policy described under climate: "The Aalberts environmental policy shows our commitment on the themes on our sustainability agenda: SDGs, net zero carbon, circular economy and water use", covering "product design, circular solutions and value chain collaboration" among other topics; "The principles in the policy have been approved by the Management Board and the Executive Team and will be reviewed and revised when deemed necessary. The policy applies to Aalberts and its controlled subsidiaries anywhere in the world and can be found on at aalberts.com/sustainability" (p.53).

Scope is qualified by business type: "Aalberts acknowledges that circular economy is a material topic for the business teams that manufacture products rather than providing services. Our heat and surface treatment businesses provide services to our industrial customers, and therefore not involved in sourcing raw materials on a large scale" (p.60).

The report does not state whether the policy addresses the ESRS E5 sub-topics individually (resource inflows including circular use, outflows including products and materials, and waste), nor does it name a lower-level accountable owner for the circular-economy principle. Implementation is tracked through the same route as climate: sustainability improvement plans per business team, with progress "reviewed quarterly in the HSRS network" (p.60).

Actions and resources related to resource use and circular economy

Reference: page 61, indexed as E5-2 actions on the environment cover page (p.49).

"At Aalberts, we employ a comprehensive and tailored approach to circularity, reflecting the diverse nature of our business portfolio and recognising the varying levels of control we have across different value chains. To determine our approach, we consider the value of the product and the feasibility of retrieving it" (p.61). Three action streams are described.

Smart product design (p.61): "We perform LCAs in accordance with standardised and internationally recognised methods (ISO 14040 and ISO 14044 standards), resulting in Environmental Product Declarations (EPDs). We integrate LCAs in our design process to determine whether we can substitute materials with environmentally-friendly alternatives where possible, such as recycled materials or green steel." 2025 example: "an innovative reinforcement feature that enabled thinner-wall pipe fittings without compromising high-pressure performance. This design optimisation reduces material use, delivering a 14% reduction in weight and carbon emissions."

Acting on circular solutions (p.61): "our brass scrap is separated and sent to a recycling company or melted down in our own foundries as a raw material for reuse in our production process. The emulsion used in the process of turning and milling is also generating waste. We are investing in closed loop systems to recycle the emulsion internally, so the waste generated will be reduced." 2025 example: packaging for semicon robots changed so that "The new packaging solution replaces PU foam while maintaining the required level of product protection. This change eliminates PU foam waste and results in a 74% reduction in CO2 emissions from packaging."

Value chain collaboration (p.61): "A notable example is our reuse programme in our semicon segment, where we collaborate with a key OEM customer to facilitate the reuse of critical components. We reuse and refurbish subcomponents from returned lithography machine modules - such as bolts and panels - and deliver them back to our customer with as good as new quality or even an upgrade of the module to the latest standards."

Resources: no circular-economy CapEx or OpEx amount is disclosed. The report cross-refers to the climate resourcing paragraph instead: "Please refer to page 55 on how we consider acting on smart product design and circular solutions in financial planning" (p.61), where Aalberts states it is "challenging to isolate financial investments with sole sustainability objectives" (p.55).

Targets related to resource use and circular economy

Reference: page 60, indexed as E5-3 targets on the environment cover page (p.49).

Two targets, both voluntary and both on a 2024 base year (p.60):

• Resource inflows: "We set a target to decrease our scope 3 CO2 intensity related to purchased goods and services by 30% by 2030, taking 2024 as the base year. This is measured in tonnes CO2 related purchased goods and services divided by total revenue in EUR million... The scope of the target relates to the entire Aalberts group."
• Resource outflows: "For resource outflows, we set a target to decrease waste disposed intensity by 30% by 2030, taking 2024 as the base year. This is measured in kg waste disposed divided by total revenue in EUR million (page 126). With this target we steer on reducing the most harmful layer of the waste hierarchy: waste disposed. Waste disposed is defined as waste incinerated with or without energy recovery, waste ending up at landfill or handled by other disposal operations."

"We have voluntarily committed to these targets, covering all layers of the waste hierarchy. On business team level, operational KPIs have been set based on their specific products and services, such as the percentage of recycled materials purchased, carbon footprint of new product design, and more" (p.60).

Why a carbon proxy is used for material inflows (p.60): "As the majority of our scope 3 footprint relates to category 1: purchased goods and services (page 59), we monitor responsible material use through scope 3 CO2 intensity. We manage intensity to balance our growth agenda while efficiently using the materials required... This approach highlights the nexus between circularity and CO2 reduction."

Governance: targets "are based on the sustainability improvement plans developed by our business teams and approved by the Executive Team. Progress is reviewed quarterly in the HSRS network, and plans are adjusted if necessary to reach the targets" (p.60).

Progress against the two targets in 2025: scope 3 intensity related to purchased goods and services fell to 355 tCO2/EUR million, "a 35.4% decrease compared to the 2024 actuals and a 17.6% organic decrease compared to the 2024 normalised value" (p.58), while waste intensity moved the wrong way: "an increase in our KPI waste intensity this year of 19.3% compared to the 2024 actuals and a 13.2% organic increase compared to the 2024 normalised value" (p.63). No target is set on recycled content, product circularity or waste recovery rate.

Resource inflows

Reference: page 62, indexed as E5-4 performance on the environment cover page (p.49); accounting policies page 62.

"Resource inflows are measured through purchased goods necessary for manufacturing. Purchased goods are assessed across four inflow types: trade products, raw materials, components, and packaging. These inflow types were grouped into categories reflecting their relative importance and material characteristics, based on a structured assessment conducted jointly with a third-party and Aalberts' business teams. Metal alloys were the most common category measured across the four inflow types" (p.62).

Purchased goods, 2025 (p.62):

Footnote 2 completes the picture: "our activity-based reporting results in 117,150 tonnes purchased goods. Total purchased goods in weight is estimated at 243,406 tonnes, of which 42,285 tonnes are recycled (17.4%)" (p.62). Coverage: "2025 is the second year that our locations reported quarterly on purchased goods. In 2025, 63.1% of purchased goods and services were collected through activity-based data (weight). In 2026, we aim to enhance our reporting by increasing the data measured based on weight" (p.62).

Biological materials are a nil return: "we do not use biological materials to manufacture our products and services" (footnote 1, p.62).

Estimation uncertainty, graded by method (p.62): activity-based weight from invoices, supplier information and financial records has "low" uncertainty; spend converted to weight using average market prices has "medium" uncertainty; and the residual allocation "converted using average category conversion factors... has a high level of estimation uncertainty". "For material streams, a distinction is made between virgin and recycled origin, where information is incomplete, a conservative assumption is applied by defaulting to virgin material. Goods reported in the category 'other' are considered virgin."

Named key materials elsewhere in the statement: "Our key materials used are brass, steel and plastics" (p.44), with green steel and green aluminium cited as low-carbon substitutes being pursued (pp.51, 54).

Resource outflows

Reference: pages 62-63, indexed as E5-5 performance on the environment cover page (p.49); the EU legislation datapoints table indexes E5-5 paragraph 37(d) and paragraph 39 to page 63 (p.87); accounting policies page 63.

"Our locations report quarterly on waste. Primary data from waste handlers is available for most Aalberts locations. Where unavailable, we measure the waste ourselves. In 2025, waste measurements cover 100% of our revenue" (p.62).

Headline outflow results (pp.62-63): "In 2025, 69% of the total waste generated was recovered (2024: 75%). The main category of recovered waste was metal scrap, resulting from turning and milling within our locations processes." "31% of the total waste generated was disposed (2024: 25%). The main categories of disposed waste were chemical waste and emulsions. For some of our processes, hazardous waste like chemical or emulsions, which are more challenging to recycle are unavoidable."

"In 2025, total waste generated decreased with 9%. However, the mix of the waste generated changed due to, for example, change in company composition and operational waste resulting from closures of sites leading to 72% non-hazardous waste (2024: 79%) and 28% hazardous waste (2024: 21%). Recovery rate of hazardous waste is generally lower, leading to an increase in our KPI waste intensity this year of 19.3% compared to the 2024 actuals and a 13.2% organic increase compared to the 2024 normalised value" (p.63).

On products and materials: Aalberts reports no E5-5 product-level circularity metrics (recyclable content of products, recycled content in products, expected durability) and no rates of recyclable content in packaging. The design narrative instead sits under E5-2: "By designing our products for durability, reusability and recycling, we support that materials are used as long as possible" (p.54).

Method (p.63): waste is "divided into several categories, such as paper/cardboard, wood, plastic, electronic waste, metal scrap, chemical waste, emulsions and other. A distinction is made between hazardous and non-hazardous waste. Waste management concerns the treatment of waste by a third-party, either by recovery (preparation for reuse, recycling, other recovery operations) or disposal (incineration with or without energy recovery, landfilling, other disposal operations)." Two stated limitations: "in reporting hazardous waste, we do not have a split available in radioactive waste" and "we do not disclose waste streams per sector or activity, as this is not relevant for our operations" (footnotes 3 and 4, p.63). The full waste table is set out under the Waste entry.

Waste

Reference: page 63 (waste table, indexed as E5-5 performance on the environment cover page, p.49); the EU legislation datapoints table indexes E5-5 paragraph 37(d) and paragraph 39 to page 63 (p.87).

Waste, tonnes (p.63):

Read against the company's own target, the direction is adverse: waste disposed rose from 14,444 to 16,613 tonnes while total waste fell 9%, and "Recovery rate of hazardous waste is generally lower, leading to an increase in our KPI waste intensity this year of 19.3% compared to the 2024 actuals and a 13.2% organic increase compared to the 2024 normalised value" (p.63) against a target to cut waste disposed intensity 30% by 2030 from the 2024 base (p.60). Recovery fell from 75% to 69% of waste generated, and the largest single movement is a fall in preparation for reuse from 13,099 to 1,700 tonnes, which the report does not explain.

"Waste intensity is calculated based on net revenue as disclosed in the financial statement on page 124. For 2025, the revenue used is normalised for changes in company composition" (footnote 2, p.63). Hazardous waste has no radioactive split available (footnote 3). Waste is also a scope 3 driver: category 5 waste generated in operations fell from 44,502 to 21,003 tCO2e (p.59), calculated from "actual waste volumes, multiplied by relevant emission factors" using EcoInvent and ADEME and the GHG Protocol 100-0 recycled content method (p.58).

Policies related to own workforce

Reference: page 69 (health and safety policy) and pages 72-73 (attraction and retention policies), both indexed as S1-1 policies on the social cover page (p.67). The EU legislation datapoints table indexes S1-1 paragraph 20 to pages 42, 43, 72, 73 and 90, paragraph 21 to pages 42 and 90, paragraph 22 to pages 42, 72, 73, 89 and 90, and paragraph 23 to pages 68 and 69 (p.87).

Health, safety and well-being policy (p.69): "Providing a safe and healthy work environment is our key priority and safety is non-negotiable. This is the core objective of our health, safety and well-being policy. The policy covers all controlled subsidiaries worldwide and its content cover all of our personnel, including employees and non-employees working at our facilities. This policy is the foundation on which we prevent, mitigate, and remediate all of the impacts and risks related to health and safety. The policy has been approved by the Management Board and the Executive Team and will be revised when deemed necessary."

Workforce policies (pp.72-73), which "apply to the entire workforce and are overseen by the Executive Team":

• human rights policy - "Aligned with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises... This policy ensures a safe and respectful working environment and prohibits child labour, forced labour, and human trafficking."
• speak up! policy - "Provides a global mechanism for employees to report concerns confidentially, including those related to human rights and business integrity. Local confidentiality advisors and whistleblower protections are in place to prevent retaliation... we have policies in place to protect individuals, including workers' representatives, from retaliation."
• diversity, equity and inclusion (DEI) policy - "Promotes equal treatment and opportunities in recruitment, development, and promotion. We educate hiring managers on inclusive practices and ensure diverse candidate slates for all roles."

"All policies are available via our internal portal and are provided to onboarding employees and existing staff during annual compliance training. The Executive Team and chief people & culture officer, will conduct formal annual reviews of our global speak up! mechanism. These reviews will assess case volumes, timelines of response, remediation outcomes, and data on retaliation incidents. Confirmed discrimination cases trigger corrective action plans within defined timelines, and diversity metrics (e.g., gender representation in leadership) are monitored quarterly" (p.73). A stakeholder engagement policy is used to "ensure awareness of potentially vulnerable groups within the organisation" (p.72).

Processes for engaging with own workers and workers' representatives about impacts

Reference: page 73, indexed as S1-2 on the social cover page (p.67).

"At Aalberts, we prioritise engaging with our workforce and their representatives to address actual and potential impacts on our employees, to ensure their perspectives are included in the decision-making process. Locally, we often discuss and communicate these impacts through workers' councils and representatives, ensuring that concerns are heard and addressed appropriately. On a global level, we engage directly with our employees through biannual townhalls, providing a platform for information sharing and engagement. We have set-up an Aalberts employee social channel to further engage with them and to promote further share and learn of initiatives" (p.73).

Accountability is named (p.73): "Our chief people & culture officer, the most senior role with operational responsibility for this engagement, ensures that these interactions are meaningful and that the insights gained inform our approach." Indirect engagement runs "the P&C network within Aalberts to facilitate indirect engagement when applicable" (p.73).

A group-wide survey was introduced in 2025 (pp.72, 74, 77): "In October 2025 we conducted the first group-wide employee motivation & satisfaction (EMS) survey, with a participation rate of 69% and an overall motivation & satisfaction score of 68 (out of 100). The results are being translated into local action plans in collaboration with employees" (p.72). Scope: it "covered employees employed as of 31 May 2025. Employees of acquired entities that were not yet fully integrated at 31 May 2025 were excluded from the survey scope" (p.74). Findings fed back: "Key areas identified for improvement included enhancing transparency and effectiveness in internal communication, expanding career development opportunities, and enhancing the cascade of our strategy and updates to lowest levels in the organisation" (p.77). A second survey is planned for 2027.

Engagement also feeds the DMA: "Direct consultation occurred with Aalberts employees on material topics such as employee attraction and retention and employee health and safety to understand how they may be impacted by Aalberts business activities" (p.46). Collective bargaining is covered under S1-8: "We acknowledge, facilitate and respect our employees' right to collective bargaining" (p.78). Aalberts does not state how it assesses the effectiveness of the engagement itself, and topics such as employee representation "are managed locally" (p.41).

Processes to remediate negative impacts and channels for own workers to raise concerns

Reference: page 73, indexed as S1-3 on the social cover page (p.67); the EU legislation datapoints table indexes S1-3 paragraph 32(c) to pages 73 and 89 (p.87).

Grievance channel (p.73): the speak up! policy "Provides a global mechanism for employees to report concerns confidentially, including those related to human rights and business integrity. Local confidentiality advisors and whistleblower protections are in place to prevent retaliation... For speak up! specifically, we have policies in place to protect individuals, including workers' representatives, from retaliation. Meanwhile this responsibility is with the business segments for local policies."

How cases are handled (p.90): "our employees, but also external business parties, can report violations of the Code of Conduct or other misconduct via our speak up! procedure at aalberts.com/speakup (anonymously if desired). To make it even easier for everyone to report a (suspected) violation, we have focused in 2025 on further simplifying and improving reporting - also via local channels. An Ethics Committee has been established in line with the EU Whistleblower Protection Directive." "All relevant speak up! notifications have been investigated and followed up promptly. Where appropriate, necessary action has been taken. Relevant cases are reported to the Management Board and, when these occur, material violations will be immediately reported to the Audit Committee and the Supervisory Board."

Safety-specific channels (p.68): "local channels are established to report on unsafe situations and near misses. In addition, local grievance mechanisms are present to make sure that our employees can raise concerns or flag safety issues that are not properly addressed by management. Given our global presence and diverse workforce, we prioritise accessible health and safety communication, particularly for employees in our factories who may experience language barriers. We provide translations or use visual aids to ensure clarity and mitigate risks."

Remediation, including its limits (p.68): "When we record an LTI, we recognise that the negative impact cannot be remediated as we were unable to prevent an injury impacting the employee's ability to work. In addition, for an LTI or other safety incident, we have after incident remediation procedures and resources in place to mitigate or eliminate the effects of bodily harm. These corrective measures include accident alerts and intervention procedures, protocols for transporting injured personnel to medical facilities, trained first-aid responders capable of providing immediate care, first-aid equipment, and emergency response teams."

No number of grievances raised or resolved through speak up! is disclosed, and Aalberts does not state whether it assesses workers' awareness of or trust in the channel.

Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material opportunities, and the effectiveness of those actions

Reference: page 69 (health and safety actions) and page 73 (attraction and retention actions), both indexed as S1-4 on the social cover page (p.67).

Health and safety - five pillars, each with a 2025 action (pp.69-70):

• Awareness - talk safety: a communication campaign "across all group plants during European Safety Week. The campaign featured seven videos... the group health & safety policy, the five safety-first mindsets, and the ten absolute rules for factories."
• Organisation - lead by example: "In 2025, our director health and safety delivered training sessions covering 36 factories, reaching 121 participants."
• Monitoring - measure to improve: "We fully implemented a standardised safety alert format for each LTI, consisting of an analysis of the root causes."
• Compliance - stop and think: "We released our first group standards and best practices to prevent some of the most frequent risks in our factories, including slips, trips and falls and the use of two-hand control equipment."
• Action - good is never good enough: "We continued health and safety visits across our global facilities. Led by our director health and safety, these visits resulted in detailed risk assessments with actionable recommendations and planned follow-ups in coordination with local H&S experts."

Attraction and retention actions in 2025 (pp.73-74): "expansion of our succession planning approach, the continued rollout of leadership development programmes, continuation of our traineeship programme, launching the employer branding campaign (Go Ahead), and enhancing collaboration with (vocational) colleges, and universities." "In 2025, succession planning was completed for the top 100 leaders" and "selectively extended to key positions at the local business level, including technical personnel, engineers, and process owners" (pp.73-74). The global traineeship programme "offers early career professionals a two-year experience, with four diverse assignments" (p.74).

Effectiveness (pp.68, 73): LTIs are "categorise[d], monitor[ed] and review[ed]... quarterly through our HSRS network", with root-cause analyses discussed in quarterly HSRS meetings (pp.68-69); "Insights from quarterly target reviews, based on consolidated workforce data, are used to assess the effectiveness of actions and initiatives in achieving defined outcomes, and to refine global and local programs" (p.73). "If potential negative impacts on our workforce are identified the global P&C network convenes to determine appropriate follow-up actions" (p.73).

Resources: "We do not consolidate the capital and operational expenditures associated with the actions we take on employee attraction and retention, as we have decentralised and highly diverse businesses" (p.73).

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 68 (health and safety targets) and page 72 (attraction and retention targets), both indexed as S1-5 on the social cover page (p.67); summary table page 75.

Health and safety (pp.68-69): "The business teams have a joint responsibility to realise the group-wide average of a Lost Time Injury Frequency Ratio (LTIFR) target. We have set a target of reaching an LTIFR below 1.5 in 2030, with the ambition to work towards zero accidents." "At the same time, Aalberts is committed to avoid any fatalities and to drastically reducing the number of severe accidents." Targets are also set bottom-up: "Targets are set by the business teams in their health and safety improvement plans, they may vary per business team given the specifics of their operations and are monitored and reviewed through the HSRS network."

Attraction and retention targets versus 2025 performance (p.75):

The gender diversity target was reset during the year (p.72): "In Q4, 2025, the Management Board approved a revised definition of senior leadership... As a result, gender diversity within senior leadership decreased to 16%. The original target of 30% by 2026 will be adjusted to an appropriate and ambitious target of 20% by 2030." Under the revised definition senior leadership is 81 employees, against 119 on the former definition (p.76). "While this impacts year-on-year comparability for gender diversity metrics, the revised definition enhances transparency and relevance for stakeholders" (p.72).

Targets were "defined... in collaboration with our people & culture (p&c) network, which have been approved by the Executive Team" and are "quarterly measured, consolidated, and reviewed against progress" (p.72). Aalberts states where it sets no target: "While we do not set formal targets for turnover or local training availability due to the diversity of our business segments, these indicators are monitored at segment level" (p.72). Workers were consulted on the topics but the report does not say they were involved in setting the targets.

Characteristics of the undertaking's employees

Reference: page 75, indexed as S1-6 performance on the social cover page (p.67); further breakdowns pages 76-77.

"In 2025, Aalberts employed 12,221 FTE's, are presenting a 2.4% decrease compared to 2024" (p.75). All figures are in FTE, "defined as 'Full-Time Equivalent of all employees at the end of the reporting period, who are drawing wages or salaries from the company and whose compensation is reflected as personnel expenses in the income statement'" (p.75).

Employees by gender and contract type, FTE (p.75):

By region, FTE (p.76): Europe 7,568 (62%), Asia 2,307 (19%), America 2,346 (19%).

By country where above 10% of the workforce (p.76): United States 2,274 (2024: 2,142), Germany 2,066 (2,263), the Netherlands 1,889 (1,994), other 5,992. Poland (1,527 in 2024) and France (1,340 in 2024) no longer meet the threshold and move into "other". Aalberts "operates from 127 locations with activities in over 50 countries" (p.76).

Age distribution (p.76): under 30 years 19.6% (2024: 14.8%); 30 to 50 years 47.9% (49.4%); over 50 years 32.5% (35.8%).

Turnover (p.77): "By the close of the reporting period in 2025, 1,956 FTE had departed, resulting in a turnover rate of 16.0%" (2024: 18.4% and 2,308 FTE). Voluntary turnover rose to 7.6% from 6.9%, 927 FTE (2024: 861). "The turnover percentage is not affected by employees who are no longer in service as a result of company divestments."

Reconciliation to the financial statements (p.75 footnote 1): "the most representative number in the financial statements is 13,271, refering to average total workforce (FTE) of 2025 (both employees and non-employees)." S1-6 headcount-basis figures and a permanent/temporary split by region are not given, and the employee numbers are in FTE rather than head count. "All own workforce data is collected through a systematic approach, with reporting entities submitting information in a central system, consolidated at the global level" (p.75).

Collective bargaining coverage and social dialogue

Reference: page 78, indexed as S1-8 performance on the social cover page (p.67).

"We acknowledge, facilitate and respect our employees' right to collective bargaining. In addition, to ensure frequent employee-management interactions and responsible labour practices. Aalberts hosts at least twice a year a global town hall meeting to update employees on safety, financial performance and other relevant topics. The businesses are required to brief their teams after being updated on Aalberts' results" (p.78).

Collective coverage and social dialogue table (p.78), reported as coverage bands rather than percentages:

Footnotes define the basis: the figures are "% of FTEs of our own workforce, who are covered by a collective bargaining agreement"; the EEA split is "by country within the European Economic Area (EEA) for countries that represent over 10% of our total FTEs"; "outside the EEA this split is made by region, for each region representing over 10% of our total FTEs"; and workplace representation is "% of FTEs of our own workforce with workplace representation for countries of the EEA representing over 10% of our total FTEs" (p.78).

Two points a reader should note. First, no group-level percentage of employees covered by collective bargaining agreements is given, only the banded country and region view, so the ESRS S1-8 headline datapoint cannot be read off the table. Second, the United States is 2,274 FTE, over 10% of the workforce (p.76), and appears only inside the "North & Central America" region row. Workers' representation is handled locally: "Topics such as employee representation are managed locally" (p.41), and "Locally, we often discuss and communicate these impacts through workers' councils and representatives" (p.73).

Health and safety metrics

Reference: page 70, indexed as S1-14 performance on the social cover page (p.67); the EU legislation datapoints table indexes S1-14 paragraphs 88(b), 88(c) and 88(e) to page 70 (p.87).

Health and safety, own employees (p.70):

"We measure the LTIFR as the number of lost time injuries per one million working hours. After a significant improvement in our LTIFR in 2024, we recorded a slight decline in our results (2025: 4.8 vs 2024 4.3). The number of LTIs increased (2025: 124 vs 2024: 109)" (p.70). Against the target of LTIFR below 1.5 by 2030 (p.68), 2025 moved the wrong way.

Days lost (p.70): "In accordance with ESRS S1, lost days due to LTIs are measured using calendar days, while Aalberts also tracks working days lost for health and safety performance monitoring. During the reporting period, the total number of days lost due to LTIs amounted to 3,095 calendar days and 2,047 working days, corresponding to an average of 25.0 calendar days and 16.5 working days per LTI."

Fatality (p.69): "Despite our commitment to safety, we deeply regret that a fatal incident involving a contracted worker occurred at one of our sites in 2025. Multiple investigations are still ongoing, and we are fully cooperating with the authorities." The fatality row in the table on page 70 carries no figure for any year, so the fatality count is given in narrative only.

Scope and stated limits (p.70 footnotes): "Aalberts employed 12,221 FTE in 2025"; "health and safety measurements cover lost time injuries, defined as work-related injuries that result in absence of an employee for a day or longer. Work-related ill health is not in scope of our health and safety measurements"; and "the health and safety measurements are not yet disclosed for non-employees". So the S1-14 datapoints on the percentage of own workers covered by a health and safety management system, cases of recordable work-related ill health, and days lost to ill health and fatalities from ill health are not provided. Safety KPIs are measured monthly (p.69) and reviewed quarterly through the HSRS network (p.68).

Remuneration metrics (pay gap and total remuneration)

Reference: the EU legislation datapoints table indexes ESRS S1-16 paragraph 97(b) to page 122 (p.87). Note for readers: printed page 122 is the financial statements contents page; the pay ratio itself is printed on page 120, in the remuneration report. Treat the index page reference as an error in the report and page 120 as the location of the disclosure.

Pay ratio as disclosed (p.120): "The pay ratio is defined as the ratio between the average annual employee compensation and the total annual CEO remuneration. The pay ratio in 2025 is 23.9. In the calculation of the pay ratio for 2025, we applied the calculation method as prescribed in the explanatory note to provision 3.4.1 sub iv of the Code, which is the total annual remuneration of the CEO divided by the average annual remuneration of the employees. The pay ratio decreased from 31.4 in 2024 to 23.9 in 2025. The decrease is mainly caused by lower LTI expenses."

Method (p.120): "The average annual employee compensation is calculated by dividing the total Aalberts' personnel expenses specified in note 21 of the financial statements - excluding the termination benefits and the total remuneration of the CEO - by the average number of employees minus 1 FTE for the CEO."

Two departures from the ESRS datapoint are worth flagging. First, the ratio is the Dutch Corporate Governance Code ratio built on the average employee compensation, not the ESRS 97(b) ratio of the highest paid individual to the median annual total remuneration of all employees. Second, the S1-16 gender pay gap datapoint (97(a)) is not disclosed anywhere in the statement: no percentage difference in average pay levels between female and male employees is given.

Supporting figures in the remuneration report: total remuneration of the current Management Board members including STI was EUR 2.7 million for 2025 (2024: EUR 3.4 million) (pp.115, 118); the CEO's 2025 base salary was EUR 884,000 and the CFO's EUR 669,500 from 10 April 2025 (p.115); base salary reviews take "into account developments in the market, practices of peer group companies and the results of Aalberts and the pay ratios within the Aalberts group" (p.115). Total Supervisory Board remuneration was EUR 450k (p.120).

Targets related to business conduct

Back-filled from the governance chapter of the sustainability statement, where business-conduct targets are disclosed under MDR-T rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS, and the governance cover page (p.79) cites MDR-T, MDR-P, MDR-A and MDR-M with no G1 code.

Read the scope first: ESRS G1 itself is not material to Aalberts. "The topics covered in the business integrity chapter are not considered material topics according to our Double Materiality Assessment (DMA), except for export control and sanctions & fair competition" (p.89). The targets below therefore belong to that entity-specific governance topic, which is where all of Aalberts' reported business-conduct targets sit.

Stated targets (p.80):

• "zero violations of sanctions & export control regulations and competition law."
• "100% completion of various mandatory training for key employees."
• "full integration of trade and competition compliance measures into the organisation."

"Aalberts has set targets to mitigate the risk of violations. The Management Board and Executive Team are involved in the target setting. Progress on the targets is tracked through the annual governance action plans in the legal and governance team" (p.80).

Measured outcome against target (p.81):

"98% of our key employees completed the e-learning module on sanctions and export control, and 99% of key employees completed the courses on avoiding anti-competitive conduct... Lastly, no material issues on sanctions & export control and un-fair competition were reported in 2025" (p.81). Tracking method: "The percentage of employees trained is tracked in our online e-learning portal. The portal is updated automatically once a training is completed. The VR training and governance visits are tracked manually" (p.81).

Consistent with MDR-T's second limb, effectiveness is also tracked without a numeric target: "we embedded sanctions and export control compliance and competition law compliance as key action items in the governance action plans, with quarterly reviews, risks sheets and KPIs" (p.81), and "We do not measure and consolidate the capital and operational expenditures required to execute our actions on sanctions & export control and fair competition" (p.81). No target is set for the non-material G1 sub-topics such as corruption and bribery, supplier relationships or payment practices.