Acomo

The role of the administrative, management and supervisory bodies

Reference: pages 84-85, 133. Composition, diversity and independence datapoints (21(d), 21(e)) are incorporated by reference to Corporate Governance pages 59 and 63 (index, page 136).

Acomo has a one-tier Board. Key roles (page 84):

• "The Board of Directors formally approves our sustainability strategy. Within the Board there is a broad range of competencies including ESG."
• The Sustainability Committee "is chaired by a non-executive director and is responsible for the Group sustainability framework". It "was formalized in September 2024 and met twice in 2025".
• Sustainability Managers embed sustainability in each operating company (page 85).
• The Group Sustainability Team, led by the Group Sustainability Manager, "started with quarterly meetings in the second half of 2025 and is still in the process of formalizing and further developing its approach and structure" (page 85).

Accountability is devolved: "The Board of Directors and the management of each operating company are responsible and accountable for the effective implementation of policies across the Group" (page 84). Under G1: "Of our non-executive Board members for 80% qualifies as independent per the definition of the Dutch Corporate Governance Code" (page 133). Acomo adheres to the Dutch gender quota of "at least 1/3 men and 1/3 women" for non-executive directors (page 59).

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

Reference: pages 84-85.

"In 2025, sustainability remained a standing agenda item in all Board meetings, ensuring the Board and non-executive directors were consistently informed about the material IROs and sustainability progress" (page 85).

The Sustainability Committee met twice in 2025 and its agenda is disclosed: the first meeting "focused on SBTi, and lessons learned from the limited assurance trajectory of 2024-2025"; the second "aimed to validate the double materiality update results and discussed sustainability performance" (page 84).

Stakeholder input reaches the same body: "we communicate the interests and concerns of affected stakeholders regarding our sustainability impacts to our Sustainability Committee in regular committee meetings" (page 88).

On controls, the Group Internal Audit assessment was "presented and discussed with the Executive Directors", and oversight "was discussed with the Audit Committee during its scheduled meetings throughout the year. The Audit Committee reported on this oversight to the Board of Directors and discussed relevant matters with the external auditor" (page 85).

Acomo does not disclose which specific IROs were addressed at which meeting, nor how trade-offs between them were considered.

Integration of sustainability-related performance in incentive schemes

Reference: pages 85, 95. Incorporated by reference: "ESRS 2 - 29: Remuneration report - Long-term incentive plan (LTI) page 70" (page 136), plus the Remuneration Report pages 66-72.

"Sustainability-related performance is integrated into the incentive schemes of the Executive Directors of Acomo" (page 85). The LTI's purpose "is to retain key personnel, and to drive long-term sustainable value creation" (page 85).

The climate detail sits in the E1 chapter and is explicitly qualified (page 95):

• "30% of the variable bonus is determined by a number of qualitative and quantitative business improvement targets focused on long-term value creation. These elements include driving the ESG agenda."
• "Nevertheless, the performance has not been directly assessed against the GHG emission reduction targets of the Company."
• "The existing GHG emission reduction targets (Scope 1 & 2) are part of the Sustainability Linked Loan. The performance on the KPIs of the Sustainability Linked Loan are considered within the remuneration of the Executive Directors of Acomo."

Climate performance therefore enters remuneration indirectly, through sustainability-linked financing KPIs. No percentage of variable remuneration tied to GHG targets is quantified.

Statement on due diligence

Reference: page 85. The datapoint "ESRS 2 GOV-4 30 Statement on sustainability due diligence" is marked material (page 139).

Acomo presents the required mapping: "The table below provides a map to the information provided throughout our sustainability statement about our due diligence processes and their application" (page 85). The five core elements map as follows:

• a) Embedding due diligence in governance, strategy and business model - Acomo's sustainability strategy; Sustainability governance; Double materiality assessment.
• b) Engaging with affected stakeholders in all key steps - Stakeholders dialogue; Double materiality assessment.
• c) Identifying and assessing adverse impacts - Double materiality assessment.
• d) Taking actions to address those adverse impacts - Environmental; Social; Governance.
• e) Tracking the effectiveness of these efforts and communicating - Environmental; Social; Governance.

The operational process sits in S2: the Acomo Corporate Sustainability Due Diligence Procedure, built on the Supplier Code and SEDEX Risk Radar supplier risk classification (pages 124-125). Acomo notes "our operating companies have varying levels of maturity and structure in their due diligence systems" and that it has "adopted a broad approach to identifying general risks across the Group" (page 89).

Risk management and internal controls over sustainability reporting

Reference: page 85, cross-referring to Risk management and control, pages 73-80.

"In 2025, we introduced a Group-wide internal control framework, including controls over sustainability reporting as part of our internal risk management and control systems. An assessment was performed by the Group Internal Audit function and the results... were presented and discussed with the Executive Directors of the Acomo Group. No major deficiencies in the internal risk management and control systems related to sustainability were identified during the financial year" (page 85).

"In addition, similar to prior years, an assurance readiness project for sustainability KPIs was conducted by the Group Internal Audit. The project aimed to ensure that the reported non-financial information by operating entities are CSRD compliant, as part of the limited assurance engagement" (page 85).

Acomo also notes that controls "are dependent on the area of reporting, as multiple internal functions contribute to our sustainability reporting, depending on the topic" (page 85). Oversight was discussed with the Audit Committee, which reported to the Board.

The scope, key components and identified risks are not restated in the sustainability statement; they are cross-referred to pages 73-80.

Strategy, business model and value chain

Reference: page 82; strategy matrix page 83; business context page 84. Incorporated by reference: "ESRS 2 - SBM-1 - 38-42: How We Create Value page 16-25" (page 136). Paragraph 40(b) is phased in (page 86).

"Acomo is the leading partner in plant-based ingredients solutions in conventional and organic specialty markets. Our mission is to build routes to healthier foods by creating pathways that connect natural ingredients from origins to consumers' tables worldwide" (page 82).

"In 2025, Acomo updated its value-creation tree." The trunk is scale; the branches are four strategic pillars - a diversified plant-based portfolio, resilient and responsible supply chains, value-adding capabilities, and passionate people; the soil "represents the ESG fundamentals underpinning our business" (page 82).

Business context (page 84): "The product range encompasses over 600 plant-based, natural and healthy products." Concentration is low - "larger product categories such as tea or nuts only account for around 5-10% of the Company sales", as do cocoa or coffee individually. So "impacts, risks and opportunities are assessed based on the products, geographies and supply chains to which they are applicable".

Acomo operates in 19 countries and is active in more than 100 (page 132). Value chain stages mapped: inputs, growing, post-harvest, sourcing and trading, value-added processing, distribution, customers, consumers (page 90).

Interests and views of stakeholders

Reference: pages 87-88; S1 discussion page 114.

"As part of the 2025 DMA update, Acomo reviewed and refined its stakeholder universe" (page 87). The changes: "Two stakeholders, 'Media' and 'Society', were removed as they are now better represented through other categories such as 'NGOs' and 'Communities in the value chain'. One stakeholder, 'Communities in the value chain', was newly added as a distinct key stakeholder." Renames included "'Suppliers and contractors' became 'Farmers, suppliers and contractors'".

Seven groups are distinguished: "(1) Group entities and internal stakeholders, (2) Investors and financial stakeholders, (3) Suppliers and business partners, (4) Customers, (5) Communities and society, (6) Rating and benchmark agencies, and (7) Governments and institutions". Engagement priority "was maintained for stakeholders selected as 'partner with' and 'involve and consult'" (page 87). A table gives the channel and sought outcome per stakeholder.

Two examples of strategy change (page 88): the Sustainability Improvement Loan, whose sustainability-linked features "were made effective as of 28 August 2023", and "In 2025, Acomo hosted its first Capital Markets Day, further strengthening its dialogue with professional and institutional investors on sustainability and long-term value creation."

"The Board of Acomo is actively involved in these stakeholder dialogues" (page 88).

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

Reference: page 89; per-topic sections pages 94-95, 104, 115, 123, 128, 132-133; IRO tables pages 90-93.

Changes from the 2025 update (page 89): "One IRO was added as material under ESRS G1, namely 'Regulatory Sustainability Compliance Risks'. One IRO previously reported under ESRS G1, 'Continuous improvement of risk assessment in light of acquisitions', was removed, as it was reassessed as a general enterprise risk rather than a sustainability-specific risk. Lastly, one IRO 'Ensuring a healthy and safe work environment' was changed from a positive impact to a negative impact."

"All material IROs are covered under the ESRS framework" - there are no entity-specific matters (page 89).

Two limitations are stated by the company itself (page 89):

• the identified risks and opportunities affect financial position, performance and cash flows, but "their precise financial impacts are still unknown and in need of further assessment";
• "The same holds for a detailed analysis of the Company's strategy and business model related to its resilience... Acomo recognizes the importance of such analyses and plans to conduct them in the future."

Climate-specific risk identification is also presented under E1-2 and resilience under E1-3 (2025 ESRS numbering).

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

Reference: pages 88-89; per-topic IRO-1 sections pages 94, 104, 114-115, 123, 128-129, 132.

"Acomo's last full DMA was completed in 2023. In 2025, a light update of this assessment was performed to confirm the continued validity of previously identified material impacts, risks, and opportunities (IROs) and to integrate relevant business and regulatory developments" (page 88). It focused on reconfirming the 2023 matters in light of the CSRD quick fix and the Delinuts Nordics acquisition, updating stakeholder mapping, and re-evaluating selected IROs.

Five phases (page 88): benchmarking of peers and legislation; value chain map revision, where "no changes were made", and stakeholder list refinement; "a series of interviews with key stakeholders... to validate and challenge the current list of IROs"; review of the full IRO register by the Group Sustainability Team; and validation of changes by the Sustainability Committee.

A stated gap: "As part of this DMA update, direct consultation with affected local communities was not conducted. Instead, perspectives of affected communities in the value chain were incorporated through engagement with a global non-governmental organisation" (page 88).

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

Reference: pages 136-138 ("General disclosures index - Disclosure requirements and incorporation by reference"); EU legislation datapoints table pages 139-140. Signposted from BP-2: "For full incorporation by reference we refer to the Reference table on page 136-138" (page 86).

The index states its scope: "The following tables list all of the ESRS disclosure requirements in ESRS 2 and the six topical standards which are material to Acomo... In cases where we do not yet have any information related to a disclosure requirement, no reference is made" (page 136).

Listed with page references: ESRS 2 BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1; E1-1 to E1-8; E4-1 to E4-5; S1-1 to S1-6, S1-8 to S1-10, S1-13 to S1-17; S2-1 to S2-5; S4-1 to S4-5; G1-1 to G1-4. The index carries no row for IRO-2 itself, although the table is that disclosure.

The separate table "outlines the data points derived from other EU legislation as listed in ESRS 2 Appendix B... and identifies which data points are assessed as 'Not material'" (page 139). E2-4, the E3 and E5-5 datapoints and the S3-1/S3-4 datapoints are marked No.

Transition plan for climate change mitigation

Reference: page 95.

Acomo has no transition plan. "Acomo has not yet created and published a transition plan for climate change mitigation" (page 95).

Scope of the problem: "The most material emission categories for Acomo companies are purchased goods and services and (upstream) transportation. A majority of the GHG emissions within those indirect Scope 3 categories relates to the agricultural activities in the supply chain." And the prioritisation: "Although the Scope 3 emissions are material to Acomo compared to the Scope 1 and 2 emissions, our current actions are primarily focused on Scope 1 & 2 reductions as a reflection of the state of progress and as these emissions are in our sphere of control" (page 95).

The route disclosed (page 95): "Based on the insights from this calculation, Acomo did assess and discuss the full requirements of a SBTi commitment and its impacts for the Group in 2025. A SBTi commitment was done by one of the entities, Delinuts B.V., in 2025." Delinuts "started drafting a transition plan in 2025. This plan needs to be submitted, together with the targets, for validation by SBTi within 24 months after the date of commitment. In 2026, Acomo will use the learnings from this process to start similar trajectories for the other entities, resulting in a Group-wide transition plan."

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and SBM-3 as presented in the E1 chapter (pages 94-95) and the DMA process description (pages 88-89). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification (paragraph 15). Acomo identifies transition risk only: "Next to transitional risks, at this point in time, Acomo has not identified climate-related physical risks to its business operations that would necessitate a climate resilience analysis" (page 94). The E1 material IRO table carries no risk or opportunity rows - only an actual negative impact (Scope 3 GHG emissions) and a potential positive impact (plant-based products) (page 91).

Scenario analysis (paragraph 17). No climate scenario analysis is reported anywhere in the statement - no high-emission physical scenario, no 1.5C transition scenario, no temperature projection. Since Acomo used none, paragraph 17 does not apply and its absence is not a gap. The financial statements add a separate judgement: "the Group does not believe its operations are currently significantly exposed to physical risk", while value-in-use "may be impacted in several different ways by transition risk" (page 166).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 as presented in the E1 chapter (pages 94-95) and the DMA result (page 89). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Acomo states that no climate resilience analysis was required or performed. "Next to transitional risks, at this point in time, Acomo has not identified climate-related physical risks to its business operations that would necessitate a climate resilience analysis" (page 94). At Group level the same gap is recorded for all topics: "The same holds for a detailed analysis of the Company's strategy and business model related to its resilience in addressing material impacts, risks, and opportunities. However, Acomo recognizes the importance of such analyses and plans to conduct them in the future" (page 89).

Capacity to adjust and adapt (paragraph 19(c)) is addressed qualitatively through the business model: "As a trading company, Acomo maintains adaptability in supply chains, enabling adjustment to sourcing locations and partners in response to changing environmental conditions. Due to our diverse product portfolio and extensive sourcing networks, our inherent flexibility allows us to continue operations without significant disruptions" (pages 94-95).

Policies related to climate change mitigation and adaptation

Reference: page 95.

"The Acomo Environmental Policy serves as the foundation for all Acomo companies, setting guidelines to minimize ecosystem impacts where we operate, and applies universally across our operations, contractors, and supply chain partners. The Acomo Environmental Policy is available for stakeholders on the Acomo website. Policy implementation is led by the individual companies" (page 95).

Two commitments address the material GHG emissions impact (page 95):

• "Measuring and analyzing the carbon footprint of our business activities as part of our broader climate change mitigation and adaptation efforts."
• "Implementing energy efficiency measures within company facilities and promoting efficient energy use across all business activities."

Scope covers both direct and indirect impacts "arising from its operations and across the value chain" (page 95).

A gap is stated for the second material climate IRO: "Acomo has not yet set a policy, action programme and targets on the impact of plant-based products. These will be determined in the coming years as part of the further expansion of the corporate (sustainability) strategy" (page 95). The positive-impact side of the E1 IRO table therefore has no policy behind it.

Actions and resources in relation to climate change policies

Reference: pages 95-96, 103; resources cross-referred to EU Taxonomy pages 109-113.

"In 2025, several actions were initiated by the Acomo companies on the decarbonization levers of energy efficiency and renewable energy aiming at the reduction of Scope 1 & 2 GHG emissions" (page 95). Main actions, in "our most energy intensive operations within Red River Commodities and Tradin Organic":

• "Red River Commodities started purchasing Renewable Energy Certificates for the electricity consumption of the facility in Lubbock, Texas (USA) per March 2025."
• "The sunflower oil factory of Tradin Organic in Bulgaria purchased renewable electricity in 2025."
• "Per July 2025 the cocoa factory of Tradin Organic in Middenmeer (NL) switched to renewable electricity by purchasing Renewable Energy Certificates."
• At King Nuts & Raaphorst, "another 452 solar panels were installed" on structurally weak roofs using the ballast-free RABLE system; "The PV systems are expected to generate 210 MWh, providing more than half of the electricity required for the warehouse operations".

No climate capex or opex figure is given; Acomo refers to the EU Taxonomy section (page 96), which reports 0% aligned Turnover, CapEx and OpEx (page 109).

Targets related to climate change mitigation and adaptation

Reference: page 96; target columns in the GHG table, page 98.

Scope 1 and 2: "The target is a reduction of -40% in 2030, compared to the baseline year 2022. The baseline year was chosen because this is the first year in which qualitative and comparable data was available for the whole Acomo Group. Limited assurance was achieved on this baseline data as part of the activation of the Sustainability Improvement Loan. In 2025, the baseline year was not reassessed following the acquisition of Delinuts Nordics as it was assed as not material" (page 96). The GHG table carries 2025 interim milestones - Scope 1 3,765 tCO2e and market-based Scope 2 7,236 tCO2e - and 2030 targets of 2,658 and 5,108 tCO2e (page 98).

Lever target: "On the related decarbonization lever of renewable electricity, Acomo has set a target of 100% in 2030" (page 96).

Scope 3: no target. "The Group has opted for a phased approach to Scope 3 target-setting, prioritising the SBTi commitment and validation process at entity level in 2025 to build robust data, methodology and trajectory insights before establishing a consolidated Group-wide target" (page 96).

Alignment: the Scope 1 and 2 target "is in line with the decarbonization targets set by sector peers and close to the SBTi target of -42%" (page 96). Validation sits at one entity only, through Delinuts' 2025 SBTi commitment.

Energy consumption and mix

Reference: pages 96-98. Datapoints E1-5 37, 38 and 40-43 are marked material (page 139).

Total energy consumption 40,690 MWh in 2025, up 2% (2024: 39,797; 2023: 42,355; 2022: 45,845) (page 97).

Mix in MWh, 2025 (2024), page 97: fuel from crude oil and petroleum products 1,950 (1,660), +17%; natural gas 18,826 (18,890), 0%; purchased electricity, heat, steam and cooling from fossil sources 5,042 (10,331), -51%; total fossil 25,818 (30,881), -16%; nuclear 433 (777), -44%; renewable fuel including biomass 975 (1,166), -16%; purchased renewable electricity, heat, steam and cooling 13,152 (6,683), +97%; self-generated non-fuel renewable 312 (290); total renewable 14,439 (8,139), +77%.

Shares: fossil 63% (78%), nuclear 1% (2%), renewable 36% (20%), renewable share of total electricity 71% (39%) (page 97). Driver: "One of the drivers is Tradin Organic, purchasing 100% renewable electricity for its operations as per July 2025" (page 96).

"All activities within the Acomo companies classify as high climate impact sectors as designated within the NACE Sections C (Manufacturing), G (Wholesale) and H (Warehousing)" (page 97). Energy intensity 0.028 MWh per EUR thousand, -5%, on net revenue of EUR 1,459,853 thousand.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 98-102 (table page 98, methodology pages 99-101, commentary page 102).

tCO2e, 2022 base / 2024 / 2025 (page 98):

• Scope 1 4,429 / 3,860 / 3,919, +2% year on year, -12% versus 2022. The 2025 figure sits above the disclosed 2025 interim target of 3,765, and the increase is not explained.
• Scope 2 location-based 8,029 / 6,315 / 5,509, -13%.
• Scope 2 market-based 8,513 / 4,730 / 2,112, -55%, -75% versus 2022. "The renewable power purchased by the Group accounts for 67.4% of the total power consumed" (page 99).
• Total Scope 3 - / 1,021,668 / 1,225,057, +20%.
• Total market-based 12,942 / 1,030,258 / 1,231,088, +19%. Scope 3 is about 99.5% of the 2025 market-based footprint.

Largest Scope 3 categories in 2025: purchased goods and services 1,142,187 (+20%); upstream transport 51,834; downstream transportation 14,852; processing of sold products 9,302 and end-of-life treatment 178, both "calculated for the first time in 2025"; waste 1,254 (-47%). Categories 11, 13, 14 and 15 are "not applicable" (pages 98, 101-102).

The increase was "mainly driven by higher emissions from 'purchased goods and services' (category 1), reflecting the sourcing of higher product volumes in combination with a bigger share of higher-emission products within the portfolio (e.g. cocoa)" (page 102).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 102. Listed in the index as "[E1-7] Carbon credits, page 102" (page 137) and as datapoint "ESRS E1-7 56 GHG removals and carbon credits" (page 139).

A nil return: "Acomo did not engage in GHG removals and GHG mitigation projects financed through carbon credits during the reporting year" (page 102).

This is consistent with the rest of the climate disclosure. The Scope 1 and 2 target is a reduction measured against a 2022 baseline with no offsetting component, and no net-zero or carbon-neutrality claim is made anywhere in the statement; the 2050 target column in the GHG table is empty (pages 96, 98).

Carbon revenue is mentioned once, prospectively and outside Acomo's own accounts, in the Sierra Leone agroforestry programme, which "diversifies farmer incomes through fruit, annual food crops and future timber or carbon revenues" (page 108). The Indonesian cookstove project refers to "the valorization of emission reductions" for farmers (page 127). Neither is presented as a removal or credit recognised by Acomo.

Biogenic emissions are excluded from Scopes 1, 2 and 3 "in line with ESRS E1. The biogenic emissions from our own operations are not significant. Data about biogenic emissions in our value chain are not available yet, and will be further developed the coming years together with our partners in the value chain" (page 101).

Internal carbon pricing

Reference: page 102. Listed in the index as "[E1-8] Internal carbon pricing, page 102" (page 137).

A nil return: "Acomo did not apply an internal carbon pricing mechanism during the reporting year" (page 102).

No shadow price, internal fee or implicit price is disclosed, and none is said to be planned. Nothing in the E1 chapter links carbon to investment appraisal: the 2025 actions - renewable energy certificates at Lubbock and Middenmeer, renewable electricity in Bulgaria, the 452 solar panels at King Nuts & Raaphorst - are presented on operational and commercial merits, and in the King Nuts case explicitly on the energy-cost business case (pages 95-96, 103).

Related context from the same table: Acomo reports no figure against the "Percentage of Scope 1 GHG emissions from regulated emission trading schemes" line (page 98), so no external compliance carbon price flows through its own operations either.

Acomo does price climate performance into financing rather than into carbon: the Scope 1 and 2 reduction target forms part of the Sustainability Linked Loan KPIs, which in turn feed Executive Director remuneration (page 95). That is a cost-of-debt mechanism, not an internal carbon price, and Acomo does not present it as one.

Transition plan on biodiversity and ecosystems

Reference: page 105.

No biodiversity transition plan exists. "Currently, Acomo does not have a formal transition plan to align its business model and strategy with the Kunming-Montreal Global Biodiversity Framework, the EU Biodiversity Strategy for 2040, or the planetary boundaries framework. Recognizing the critical role biodiversity and ecosystems play in supporting agriculture and enabling our operations, we are still taking steps to build this alignment, as suggested by the CSRD" (page 105).

"In 2025, the nature and biodiversity working group continued its work by launching a biodiversity pilot with a data-based tool to generate more detailed insight into risks and dependencies for selected high-risk ingredients such as cocoa, coffee and tea. The insights from this pilot will inform future roadmap development and support the potential design of a structured transition plan... While no formal biodiversity transition plan has been initiated yet, this preparatory work represents an important step toward understanding Acomo's biodiversity footprint" (page 105).

Policies related to biodiversity and ecosystems

Reference: page 105. Datapoints E4-2 24(b) sustainable land/agriculture practices and 24(d) policies to address deforestation are marked material; 24(c) sustainable oceans/seas is marked not material (page 139).

No dedicated policy. "Currently, there are no separate policies specifically addressing the identified nature and biodiversity IROs (e.g., land-use change, deforestation, and plant-based products). However, aspects of these issues are covered under the Company's general Environmental Policy. Acomo continues to plan the development of dedicated policies, key actions, and, where relevant, targets... as part of the broader transition-plan process in the coming years" (page 105).

The reason given is data maturity: "Given the complexity of Acomo's global and multi-tier supply chains, additional time is required to complete these assessments" (page 105).

What binds suppliers is the Supplier Code of Conduct: "Principle 9 - Conduct operations with care for the environment, treat animals with respect and dignity and comply with all applicable environmental laws and regulations". "Acomo suppliers shall ensure that its operations do not directly contribute to deforestation or loss of nature and biodiversity" (page 105).

Actions and resources related to biodiversity and ecosystems

Reference: pages 105-106, presented jointly as "[E4-3, E4-4] Actions and targets"; outcomes page 108.

The 2025 action is an assessment, not a mitigation programme: "In 2025, one key action has been the launch of a Group-level biodiversity pilot with a data-based tool, involving several high-impact and high-risk ingredients currently represented by Tradin Organic and Royal Van Rees Group. The pilot aims to map biodiversity-related risks and dependencies for selected ingredients and to build a data-driven foundation for prioritising future actions" (page 106).

Acomo states the limit: "At this stage, no specific Group-wide policies or new actions have been established, and therefore, their effectiveness is not yet being tracked" (page 106).

Targets related to biodiversity and ecosystems

Reference: pages 105-106, presented jointly as "[E4-3, E4-4] Actions and targets".

No biodiversity targets have been set. "Due to Acomo's operations across a wide range of products and origins and given the limited data-backed insights into nature and biodiversity, we have not yet established formal biodiversity targets. We believe a more comprehensive understanding of biodiversity impacts and a thorough assessment of current and emerging methodologies, such as Science Based Target for Nature, are essential to set achievable goals, identify robust impact metrics and disclose anticipated financial effects" (pages 105-106).

A horizon is given: "Based on current progress, Acomo expects that this assessment phase will extend into the medium term, before biodiversity-specific targets can be responsibly defined" (page 106). The biodiversity working group's understanding "will form the basis for future roadmaps, action plans (such as nature-based solutions), and potential targets and ambitions" (page 106).

No ecological threshold, area-based target or deforestation-free volume target is claimed.

Impact metrics related to biodiversity and ecosystems change

Reference: pages 106-107. Flagged by the auditor as entity-specific information whose comparability may be limited (page 194).

Acomo states the baseline position: its working group "is currently researching methodologies and frameworks to measure its biodiversity impacts. Work on establishing a baseline is still ongoing, supported by the biodiversity pilot" (page 106). In place of ESRS impact metrics it reports certification coverage.

Responsible sourced products prioritized (% of volume, 2025 / 2024 / 2023), page 107: tea 60% / 57% / 57%; coffee 15% / 10% / 15%; cocoa 54% / 45% / 61%; palm oil 100% / 93% / 94%. "From the total sourced Acomo product volumes 8.4% can be counted as responsible sourced in 2025 (2024: 10.5%)". The movement is explained: after the 2024 price spikes "markets for those products normalised, farmers fullfilled their (certified) contracts again, and volumes of coffee and cocoa went up".

Portfolio metrics: organic certified products 32% of sales (2024: 28%) and plant-based products 97% of sales (2024: 97%) (page 107). On EUDR, "Tradin Organic will approach 2026 as a phased implementation year", with "temporary, time-bound exemptions for certain supply chains" (page 106). No land-use, species or ecosystem-condition metric is reported.

Policies related to own workforce

Reference: pages 115-116. Datapoints S1-1 20, 21, 22 and 23 are all marked material (page 140).

Policies named: the Acomo Code of Conduct, Diversity & Inclusion Policy, Human Rights Policy and Whistleblower Policy, implemented "through specific internal procedures, including clear standards set out in the Codes of Conduct, mandatory compliance with applicable labour and non-discrimination laws, and established grievance and whistleblowing mechanisms" (page 115).

On diversity: "employment with Acomo is based solely upon individual merit and qualifications directly related to the job. Acomo does not tolerate harassment of any kind, including on the grounds of race, colour, religion, gender, sexual orientation, national origin, age, disability" (page 116).

Gaps are disclosed by IRO. Talent: "no Group-wide policies or actions have been defined yet... At this stage effectiveness is not yet being tracked" (page 115). Diversity: "Currently, no Group-wide actions on diversity and inclusion have been defined as they are driven locally by our operating companies" (page 116). Health and safety: "Almost all of the Acomo companies have a workplace accident prevention policy or a health and safety management system in place. Currently there are no central Acomo Group policies in place that specifically focus on health and safety" (page 116).

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

Reference: page 116.

Acomo states the limits directly: "Acomo has identified and reported on actual and potential impacts on its own workforce through the DMA. The engagement of our own workforce has been limited to performing the DMA and partaking in the employee satisfaction evaluation. For participation in the (updated) assessment, we selected a range of employees from different Acomo companies to include consultation from this key stakeholder group in the update" (page 116).

Formal channels exist unevenly: "Acomo companies engage with their employees on strategic and operational topics via the workers' council, applicable for Tradin Organic, or workers representatives. Depending on the size of the company, engagement through those formalized channels may be direct or indirect, as the size and culture of smaller companies allow for more direct engagement... In addition, many of the Acomo companies engage regularly with their employees through employee satisfaction surveys" (page 116).

And the Group conclusion: "As engagement with the employees differs per company within the Group, Acomo has not adopted a Group-wide process for engagement with its own workforce" (page 116).

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

Reference: pages 116-117, cross-referring to Governance structure pages 58-62. Datapoint S1-3 32(c) grievance/complaints handling mechanisms is marked material (page 140).

"Acomo has a single and uniform whistleblower procedure that applies to all companies within the Acomo Group. This procedure ensures that all employees, interns, temporary staff, volunteers, trainees, freelancers, (sub)contractors, suppliers, shareholders, and applicants who perform work-related activities at the Acomo Group have the opportunity to confidentially report any alleged or suspected misconduct or wrongdoing" (page 116). The platform is branded SPEAK UP! and is publicly available on the Acomo and operating company websites (page 125).

Escalation: "Reported cases are followed up through internal escalation processes in line with local legal requirements and internal governance responsibilities" (page 115); "The number of reports and status are reported to the Audit Committee periodically" (page 134).

A stated gap: "Acomo does not currently measure the effectiveness of the channels neither the trust employees place in the structures or processes to raise their concerns" (page 134). Four complaints were filed in 2025 (page 122).

Taking action on material impacts on own workforce

Reference: page 117.

Acomo is explicit that actions sit with the operating companies: "most actions and associated operational investments to manage material sustainability matters are embedded within the regular budgets and management responsibilities of the individual operating companies, supported where relevant by the Group" (page 117).

The three actions disclosed (page 117):

• Employee satisfaction: "Employee satisfaction surveys are done on a sequent base by several of the Acomo companies. However, Acomo is considering a Group-wide initiative to not only measure the participation in the surveys, but also the actual satisfaction of the employees."
• Diversity and inclusion: "Acomo's main action is to drive awareness of the Acomo Code of Conduct and the Speak Up! platform. Acomo did select and implement a Group-wide training platform in 2025 and will start a training programme for all employees... next year."
• Health and safety: "In 2025, several investments have been made to improve safe and healthy working conditions... Those actions range from training of employees, procedures on preventing work-related injuries, improved ergonomic practices in the workplace and several initiatives on employee well-being."

No monetary resource allocation is quantified, and the diversity training programme had not started in the reporting year.

Targets related to own workforce

Reference: page 117; target list page 84.

One target, covering one of five material S1 IROs. "the Group has set targets and actions on IRO 'Lack of diversity and representation at management level'... Acomo aligns to the gender quota (at least 1/3 men and 1/3 women) for its non-executive directors. By 2030, we are aiming for at least 30% women in senior management positions, excluding the Executive Members of the Board. The target was established using 2022 as the base year, and no changes have occurred to the target, its measurement approach, or the underlying methodology" (page 117).

The gaps are stated plainly: "No Group-wide targets have been established for the following IROs: (1) 'Safe and inclusive workforce', (2) 'Unconscious bias in recruitment', (3) 'Exposure of workers to unsafe or unhealthy working conditions due to varying health and safety standards', and (4) 'Employee satisfaction'. These IROs are primarily managed at operating company level" (page 117).

Worker involvement: "At this stage employees were not directly engaged in the target-setting process, nor in tracking performance or in identifying lessons learned related to these targets" (page 117). Against the target, women in top management were 22% in 2025 (2024: 17%) (page 119).

Characteristics of the undertaking's employees

Reference: page 118, cross-referred to the financial statements on page 160.

Total employees 1,267 at year-end 2025 (2024: 1,138), headcount. By gender: male 882 (790), female 385 (348), other and not reported nil - "70% of the Acomo employees is male compared to 30% female employees. This is in line with general industry characteristics" (page 118).

Turnover: 348 left (2024: 434) against an average headcount of 1,207 (1,155), a ratio of 29% (2024: 38%). Acomo explains both: headcount rose "due to the integration of Delinuts Nordics and the new hires within Tradin Organic Sierra Leone"; "The labour market circumstances in the geographical and industry context of Red River Commodities are tight... The turnover of production employees is mainly contributing to the high total turnover ratio of the Group" (page 118).

Scope: "Excluded from the figures within the sustainability statement is Manuzzi S.r.l., representing 27 employees... The Group total of 1,294 employees (headcount), including Manuzzi S.r.l., is reflecting an average workforce of 1,221 FTE" (page 118). Non-guaranteed hours employees "are mainly employed in the factory operations within the US" (page 115). No FTE breakdown by gender or region, and no leavers by gender, is given.

Collective bargaining coverage and social dialogue

Reference: page 119.

"Collective bargaining coverage within the Group is 2.5% (2024: 0.0%). Except from Delinuts Nordics, the Acomo companies are not part of any agreement with its employees for representation by a European Works Council (EWC), a Societas Europaea (SE) Works Council, or a Societas Cooperativa Europaea (SCE) Works Council due to the fact that the Group companies are primarily active in niche markets" (page 119).

The increase from zero is therefore attributable to the Delinuts Nordics acquisition rather than to new arrangements in the existing businesses.

Coverage and workplace representation are presented in banded form - "Coverage rate 0 - 19% / 20 - 39% / 40 - 59% / 60 - 79% / 80 - 100%" - against employees in the EEA and outside it, split by the Netherlands, Europe excluding the Netherlands, Americas, Middle East/Africa and Asia Pacific, with workplace representation shown for the EEA only (page 119).

Elsewhere Acomo reports one works council in the Group, "applicable for Tradin Organic" (page 116).

Diversity metrics

Reference: page 119.

Top management gender distribution, 2025 (2024): male 38 (39), 78% (83%); female 11 (8), 22% (17%) (page 119). Acomo comments: "In 2025 the percentage of female employees in top management increased. This is in line with the Acomo ambition to achieve a more proportionate distribution of men and women in top management positions as expressed in the Diversity & Inclusion Policy" (page 119). This is the tracking metric for the 2030 target of at least 30% women in senior management (page 117).

Age distribution of employees, 2025 (2024) (page 119): under 30 16% (18%); 30 to under 40 32% (31%); 40 to under 50 25% (25%); 50 and over 27% (26%).

Definition: "Top (or senior) management is defined as the two levels below the administrative management and supervisory bodies. Gender distribution in top management is calculated by summing the total aggregated headcount of both women and men in top management... This calculation is on a year-end reporting base" (page 119). Note the age reporting principle describes three bands ("under 30 (29 or younger), employees between 30 and 50 (30 to 49), and employees aged 50 or above") while the table reports four.

Adequate wages

Reference: page 119.

A nil-exception return: "As Acomo, we are fully committed to meeting the expectations placed upon us to ensure equitable pay for all employees. These expectations are rightly evolving and becoming more demanding. All our employees are paid an adequate wage in 2025. There were no changes compared to 2024 when all employees were paid above the minimum wage benchmark as well" (page 119).

Because no employee falls below the benchmark, no country breakdown is required or given - the reporting principle anticipates this: "Where employees by country are not paid an adequate wage, the number and share in those countries are detailed" (page 119).

The benchmark method is disclosed: "Every year, we gather data in all our countries regarding the lowest wage paid. This data is benchmarked against national minimum wages where available, and credible (WageIndicator's-based) benchmarks of living wages where national minimum wages were not available. The wages of all headcount employees have been considered" (page 119).

Training and skills development metrics

Reference: page 120.

Employee training, 2025 (2024), page 120: male training hours per employee 6.47 (6.93); female 11.97 (8.15); average 8.14 (7.30); share of male employees trained 56% (65%); share of female employees trained 68% (70%). Performance and career development review: share of employees reviewed 60% (66%).

Acomo comments on both directions of travel and on a data-quality limitation: "The average training hours per employee increased in 2025, especially for the female employees. Training and performance and career development reviews saw a slight decrease compared to 2024. In practice not all training and performance and career development reviews are documented formally. We will continue to emphasize the importance of well-documented satisfaction reviews within the Group" (page 120). The decline in recorded coverage may therefore partly reflect documentation rather than activity; Acomo does not quantify which.

A Group-wide training platform was implemented in 2025, with mandatory compliance programmes starting early 2026 (pages 117, 135).

Health and safety metrics

Reference: page 120. Datapoints S1-14 88(b), (c) and 88(e) are marked material (page 140); non-employee coverage is phased in (page 86).

2025 (2024), page 120: own workforce covered by health and safety management systems 91% (88%); covered by internally audited and/or externally audited or certified systems 79% (80%); recordable work-related accidents 17 (28); rate of recordable accidents 7.01 (13.98) per one million hours worked; days lost 140 (255); fatalities in own workforce 0 (0); fatalities of other workers on the undertaking's sites 0 (0).

Acomo explains the fall without over-claiming it: "The number of recordable work-related accidents for own workforce decreased significantly in 2025 compared to the relatively high number of accidents in 2024. The majority of the accidents happened in the US operations, although less than last year. None of those accidents in 2025 caused high-consequence injuries... Nevertheless, the reported numbers underline the ongoing importance of extensive and up-to-date health and safety management systems" (page 120).

Ill health: "In 2025, there were no reported cases of recordable work-related ill health within the Group, subject to legal restrictions on the collection of data". Risk location: "Risks on work-related injuries is mainly present in the processing facilities of the Acomo companies" (page 120).

Work-life balance metrics

Reference: page 121.

Family-related leave, 2025 (2024), page 121: employees entitled to take family-related leave 89% (86%); entitled employees that took it 3% (4%); entitled male employees that took it 1% (3%); entitled female employees 2% (2%); entitled other employees 0% (0%).

Acomo's commentary is brief: "Acomo ensures that our employees are entitled to take family-related leave in accordance with employment terms and conditions described in employee handbooks and contracts. There were almost no changes in family-related leave in 2025 compared to 2024" (page 121).

Note that entitlement is reported at 89%, not 100%, and Acomo does not explain which employees or jurisdictions fall outside entitlement, nor why.

The strategy matrix lists "Work-life balance metrics" as an indicator under the Passionate people pillar with no target attached (page 83), consistent with S1-5, where Acomo reports no Group-wide targets for four of its five material workforce IROs (page 117).

Compensation metrics (pay gap and total compensation)

Reference: page 121. Datapoints S1-16 97(a) unadjusted gender pay gap and 97(b) excessive CEO pay ratio are marked material; 97(b) is incorporated by reference to "Remuneration report - Internal pay ratio page 71" (pages 138, 140).

2025 (page 121): gender pay gap 6.7%; total remuneration ratio 61. "The 2025 calculation showed a 6.7% difference of average pay between female and male employees. The annual total remuneration ratio for 2025 landed at 61. The table shows the unadjusted pay gaps, in which there is no correction made for the type of work, age and work experience."

No comparative is given, and Acomo explains why: "In 2024 the pay gap was calculated based on the population of Tradin Organic and Red River Commodities representing 68% of the total population, and the total remuneration ratio was based comparing the highest paid with the average... As ESRS was introduced last year, it was not possible to collect the necessary information. Due to the decentralized group structure it is impractical to obtain all necessary documentation to include the prior year figures. For 2025 a Company-wide gender pay gap analysis was performed including the full population. For the total remuneration ratio instead of the average, the median is now being used" (page 121). Both metrics therefore changed basis between years and are not comparable.

Incidents, complaints and severe human rights impacts

Reference: page 122. Datapoints S1-17 103(a) and 104(a) are marked material (page 140).

2025 (2024), page 122: incidents of discrimination including harassment 0 (0); complaints through own-workforce channels including grievance mechanisms 4 (2); complaints to the National Contact Points for OECD Multinational Enterprises 0 (0); fines, penalties and compensation relating to discrimination 0 (0); severe human rights incidents connected to the workforce 0 (0); fines, penalties and compensation for severe human rights incidents 0 (0).

"We address all discrimination incidents and complaints filed within our organization through formal channels. Our Speak Up! platform ensures that employees can report any incident confidentially and securely. Four complaints were filed through the grievance mechanism in 2025. No complaints were filed through the National Contact Points for OECD Multinational Enterprises. Furthermore, no incidents, fines and penalties related to discrimination were registered in 2025. In 2025, no severe human rights incidents relating to our workforce occurred" (page 122).

The subject matter of the four complaints is not disclosed here, but the G1 chapter adds that "In 2025, 4 reports were submitted via the whistleblower SPEAK UP! Platform compared to 2 in 2024. None of the 2025 reports concerned corruption or bribery" (page 134).

Policies related to value chain workers

Reference: page 124. Datapoints S2-1 17, 18 and 19 are all marked material (page 140).

Three instruments are described (page 124):

• Acomo Human Rights Policy - commits to "honouring ethical business practices, labour standards, and social and environmental aspects when purchasing products and services" and "describes Acomo's process to report human rights risks and seek remedy". A gap is stated: "The Human Rights Policy currently does not address specific human rights risks such as forced labour, human trafficking and child labour."
• Acomo Code of Conduct and Supplier Code of Conduct - "The Supplier Code further clarifies Acomo's expectations in the areas of business integrity, labour practices (including child labour), associate health and safety, and environmental management."
• Acomo Corporate Sustainability Due Diligence Procedure - "the cornerstone... is the risk classification of the suppliers", via "a Group membership of the Supplier Ethical Data Exchange (SEDEX) platform" and the SEDEX Risk Radar, which "uses hundreds of data sources to produce scores on a scale of 0 to 10 across 14 areas, including: forced labour; freedom of association; gender inequality; children and young workers; health, safety and hygiene; wages; working hours". Classification "applies primarily to tier 1 suppliers".

Processes for engaging with value chain workers about impacts

Reference: page 125.

Acomo states the position without softening it: "Acomo has no standardized process for direct engagement with value chain workers. Indirect engagement exists throughout the year via credible proxies with insight into their situation, such as Rainforest Alliance, Fairtrade and RSPO. As part of the certification process, all stakeholders are extensively consulted, including (representatives of) value chain workers" (page 125).

Forward commitments: "Moving forward, direct engagement with value chain workers will be further integrated... The Sustainability Committee is responsible for ensuring that these engagements inform Acomo's approach to due diligence and managing material impacts. As part of this effort, particular attention will be given to the perspectives of vulnerable and marginalized workers, such as women and migrant workers" (page 125).

The vulnerable groups are identified in the chapter introduction: "there are also particularly vulnerable workers who may be more exposed to negative impacts, including women, migrant workers, seasonal labourers, and young workers", and "women often take unpaid or underpaid roles in agriculture, while also bearing additional responsibilities like childcare" (page 123).

Processes to remediate negative impacts and channels for value chain workers to raise concerns

Reference: page 125, cross-referring to G1 pages 132-135.

The channel is the same platform used for own workforce: "both internal stakeholders (e.g. Acomo employees) as well as external (value chain) partners have the opportunity to confidentially report any alleged or suspected misconduct or wrongdoing through the Acomo SPEAK UP! platform. This platform is publicly available on the Acomo and Acomo companies websites... The whistleblower procedure is also accessible through a dedicated link on the website of each Acomo company" (page 125). The uniform procedure explicitly covers suppliers and (sub)contractors (page 116).

An acknowledged gap: "The remedy process is planned for review as part of Acomo's intended actions to manage material IROs, with the aim of identifying improvements in the system and ensuring the effectiveness of remediation measures" (page 125). Acomo reports no measure of worker awareness or trust in the channels (page 134).

Outcome for the year: "in 2025 no severe human rights issues in the value chain and no other cases of non-respect of the UN Guiding Principles... or OECD Guidelines for Multinational Enterprises have been reported" (page 125).

Taking action on material impacts on value chain workers

Reference: pages 125-126; value chain projects pages 123, 127. Datapoint S2-4 36 is marked material (page 140). Flagged by the auditor as entity-specific information whose comparability may be limited (page 194).

Implementation is incomplete and Acomo says so: all companies "had mapped and matched their supplier base in the system during 2024"; but "During 2025, discussions continued on the Group-wide framework for how these checks will be implemented... The Acomo Human Rights Working Group aims to finalise and roll out this framework in 2026" (page 124).

Entity-level projects address specific risks: "Based on prior risk assessments, Acomo identified several supply chains with elevated child labour risk. Tradin Organic continues to implement its project targeted on the prevention of child labour in the cocoa supply chain in Sierra Leone" (page 123). The Indonesian coconut sugar programme (2025-2028) reaches "2,275 coconut sugar farming households" and will disseminate 12,000 dwarf coconut trees in 2026, reducing climbing heights and "enabling women to participate directly in sap collection, previously a male-dominated task" (page 127).

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

Reference: page 126; Group target list page 84.

Two targets (page 126): "100% signed Supplier Code of Conduct in 2030" and "100% high-risk suppliers audited and approved in 2030". "The target on supplier audits was set using 2022 as the base year, for the signed Supplier Code of Conduct the year 2023 applies. No changes were made to the scope, ambition, measurement methodologies, assumptions or base years of the targets compared to the prior reporting period."

Performance (% of raw material suppliers), 2025 / 2024 / 2023 (page 126): suppliers that signed the Supplier Code of Conduct 79% / 76% / 77%; suppliers' social and environmental responsibility audit 29% / 24% / 21%.

A measurement caveat that bears on the target's meaning: "Acomo is currently only reporting the total audited suppliers. Once the full overview of the high-risk suppliers is available, we will update the disclosure accordingly" (page 126). So the 29% is not measured on the population the target names.

Policies related to consumers and end-users

Reference: page 129. Datapoints S4-1 16 and 17 are marked material (page 140).

The governing instrument is the Acomo Quality and Food Safety Policy, "available on our website, which aims to ensure food safety and quality for both Acomo's customers and respective consumers of ingredients supplied by Acomo. The Acomo Quality and Food Safety Policy describes how key human rights of consumers and end-users... are addressed through providing safe food for human consumption and the actions taken to protect the consumers, which aligns with internationally recognised instruments such as the OECD Guidelines and the UN Guiding Principles on Business and Human Rights" (page 129).

A gap covering two of the five material S4 IROs: "Acomo has not formulated a policy on the sustainability matters of health & nutrition, as the identified impact and opportunity relate to potential positive effects and market-driven opportunities that arise from Acomo's core business activities" (page 129).

Processes for engaging with consumers and end-users about impacts

Reference: page 129.

Acomo reports the position plainly and explains it by business model: "Almost all the activities of the Acomo companies are business-to-business and only a limited proportion is own branded. As such, direct engagement with consumers and end-users is very limited and mainly occurs through the SunButter(R) brand" (page 129).

Engagement is therefore intermediated: "Despite limited direct engagement and no Group-directed engagement process, the Acomo companies continuously engage with consumers and end-users indirectly through the business relationships within the value chain. Customer needs and specifications are translated throughout the supply chain all the way back to the ultimate source, the cultivation. Consumers and end-users are a key stakeholder in setting the food safety standards the Acomo companies adhere to" (page 129).

SunButter(R) is the one direct channel named, described through the product rather than a process: it "offers consumers a tasty product that is not only a healthy alternative to peanut butter through its nutritional composition, but also free of the top eight allergens" (page 129). No responsible executive, frequency or effectiveness assessment is disclosed.

Processes to remediate negative impacts and channels for consumers and end-users to raise concerns

Reference: pages 129-130, cross-referring to Governance pages 132-135.

Two layers are described. First, the statutory route: "Food safety regulators have formal mechanisms in place to raise concerns and remediate negative impacts in case of contamination of food products which may be harmful for consumers. As a food company, Acomo is obliged to report contamination within certain timeframes and take appropriate mitigation actions, including recalling the product if necessary. Any other stakeholder is also enabled to report a matter via Acomo's SPEAK UP! platform, which is available on Acomo's website" (page 129).

Second, the company's own systems: "On top of the basic food regulations all Acomo companies have complaint and incident management systems in place that are a critical element of the food safety management systems... Within the complaint and incident management systems a root cause analysis is done for every registered complaint and incident. Based on the outcomes measurements are taken to prevent those from happening in the future. These corrective actions may relate to the own operations or within the operations of the supply chain partners" (pages 129-130).

Taking action on material impacts on consumers and end-users

Reference: pages 130-131. Datapoint S4-4 35 is marked material (page 140). Flagged by the auditor as entity-specific information whose comparability may be limited (page 194).

Product quality and food safety. "Acomo companies apply the highest industry standards on food safety... more and more food companies and retailers are demanding compliance with food safety standards recognized by the Global Food Safety Initiative (GFSI)... Acomo companies monitor and seek to increase the number of internal and external (third party) facilities certified according to the GFSI recognized certifications" (page 130). Metrics, 2025 / 2024 / 2023: food safety own operations 85% / 83% / 84% of entities GFSI certified; third party operations 87% / 87% / 84%.

Acomo is explicit that these are business-as-usual activities: "The actions described above are embedded in Acomo's regular operational and quality management processes. They do not constitute a separate action plan requiring significant additional operational or capital expenditures beyond ordinary business activities" (page 130).

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

Reference: page 131; Group target list page 84.

Two targets (page 131): "100% GFSI certified own operations in 2030" and "90% GFSI certified third-party operations in 2030". "The targets relate to the sustainability matter of product quality and food safety, and more specific the GFSI certification of own and third-party operations where products owned by Acomo companies are processed and/or packed. The targets were set using 2022 as the base year."

Gaps are stated for the other material matters: "Acomo has not yet formulated a target on the sustainability matters of health & nutrition, product traceability & transparency and organic certifications nor addressed the related material impacts, risks and opportunities. These mainly relate to qualitative impacts and financial opportunities that are currently difficult to translate into meaningful and measurable Group-wide targets. In addition, elements such as organic certification and farm-level traceability are primarily relevant for specific operating companies, rather than across the Group" (page 131).

Business conduct policies and corporate culture

Reference: pages 133-134. Datapoints G1-1 10(b) UN Convention against Corruption and 10(d) protection of whistleblowers are marked material (page 140). GOV-1 for G1 is incorporated by reference to "Corporate governance - Roles and responsibilities page 58" (page 136).

"Acomo has a comprehensive set of business conduct policies, and codes of practice... These policies include the Acomo Code of Conduct, Acomo Supplier Code of Conduct, Anti-bribery and corruption policy, Anti-money laundering policy, Insider trading policy and Acomo Whistleblower Policy amongst others. These policies also extend to new acquisitions" (page 133).

The uniform whistleblower procedure "outlines which safeguards are in place while prohibiting any retaliation or disadvantage against whistleblowers", and "The number of reports and status are reported to the Audit Committee periodically" (page 134). A stated gap: "Acomo does not currently measure the effectiveness of the channels neither the trust employees place in the structures or processes to raise their concerns" (page 134). In 2025, 4 reports were submitted (2024: 2), none concerning corruption or bribery.

Management of relationships with suppliers

Reference: page 134.

"As reliability is one of the cornerstones of the Acomo business, Acomo companies tend to have long-term business relationships with suppliers. To avoid or minimize the impact of disruptions to the supply chain, the Group maintains a diverse portfolio of plant-based natural food products sourced across many countries of origin. Supply risks have been successfully managed in recent years owing to a reliable, diverse and long-standing global supplier base" (page 134).

Supplier management is devolved: "Supplier relationships are managed at an individual level within the Acomo Group. Each company follows a structured supplier approval procedure embedded within its quality management system. While the primary focus within these management systems is on food safety, sustainability criteria - such as environmental impact, labour conditions and ethical business conduct - are integral to supplier selection. These criteria are explicitly incorporated into the supplier evaluation process, including the signing of the Supplier Code of Conduct" (page 134).

No payment practices and no supplier vulnerability assessment are disclosed here.

Prevention and detection of corruption and bribery

Reference: pages 134-135.

"Acomo has several key procedures to prevent, detect and address allegations about corruption and bribery", resting on three policies: the Anti-bribery and corruption policy, Anti-money laundering policy and Insider trading policy (page 134).

"The Company has a zero-tolerance attitude towards bribery and prohibits employees, representatives or agents from engaging in any form of bribery or corruption, whether in the private or public sector. Acomo will investigate business conduct incidents, including incidents of corruption and bribery, promptly, independently and objectively. Acomo's G1-3 policies mentioned above are consistent with that of the United Nations Convention against Corruption" (page 134).

Training is not yet in place. "In 2025 Acomo selected and implemented a Group-wide training platform. All the Acomo companies are onboarded on the system and a training policy has been drafted. We are currently in the process of defining and establishing formal training programs, to be started early 2026. Trainings on the Acomo Code of Conduct, whistleblower, and anti-bribery & corruption will be mandatory for all Acomo employees and the Acomo Board... Furthermore we are defining the functions-at-risk within the companies" (page 135). No training coverage percentage is therefore reportable for 2025.

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS; this report is prepared under the 2023 ESRS, whose G1 had no targets DR.

Acomo discloses that it has set no business conduct targets, and says why. "For both material impact and risk, Acomo has not set a formal target. Corruption and bribery matters are currently managed through a zero-tolerance approach, supported by policies, internal controls and incident monitoring, rather than through quantitative targets. In addition, the regulatory compliance risk was newly identified in the 2025 double materiality update and therefore has no target" (page 132).

Consistent with MDR-T's second limb, effectiveness is tracked in the absence of targets: "Currently, Acomo tracks and reports on incidents related to corruption and bribery. The effectiveness of the actions on the IRO 'Potential irregularities related to corruption and bribery' is primarily evaluated through the results of the metric incidents of corruption or bribery" (page 132).

Incidents of corruption or bribery

Reference: page 135. Datapoints G1-4 24(a) fines for violation of anti-corruption and anti-bribery laws and 24(b) standards of anti-corruption and anti-bribery are marked material (page 140).

2025 (2024), page 135: total number of convictions on incidents of corruption or bribery 0 (0); total amount of fines for violation of anti-corruption and anti-bribery laws 0 (0).

Acomo states the assurance status of the figure: "Within this section, Acomo reports the number of convictions on incidents of corruption or bribery during the reporting period and the amount of fines for violation of anti-corruption and anti-bribery laws. This number is validated by Acomo's external assurance provider" (page 135).

The consequence for actions is drawn explicitly: "Consequently, as there were no reported cases of corruption or bribery, no actions were taken to address breaches in procedures and standards of anti-corruption and anti-bribery. Acomo continues to mitigate potential irregularities related to corruption and bribery through the described business conduct policies above and its Codes of Conduct... No other action plans related to our material impacts, risks and opportunities are planned" (page 135).

Corroborating data from the whistleblower channel: "In 2025, 4 reports were submitted via the whistleblower SPEAK UP! Platform compared to 2 in 2024. None of the 2025 reports concerned corruption or bribery" (page 134).