Alimak Group

Governance roles

Reference: pages 47-48. The ESRS index notes GOV-1 is "Partially answered by reference on pages 107, 111-113" (page 89).

Alimak Group states its interpretations explicitly: "Administrative body is the Board of Directors", "Management body is the Group Leadership Team", "Supervisory body is the Audit Committee" (page 47).

Composition (page 47):

• Board of eight directors elected by the April 2025 AGM, four women and four men, a 50/50 gender ratio; plus two employee representatives appointed by the trade unions.
• One elected director is employed by the Group, President & CEO Ole Kristian Jødahl. Five of the eight elected members (62.5%) are independent in relation to the Company and the shareholders.
• The Group Leadership Team has eleven members, three women and eight men, all employed by the Group.

Allocation of responsibility (pages 47-48):

• The Audit Committee (Tomas Carlsson, Helena Nordman-Knutson, Heléne Mellquist) "acts as the supervisory body for matters relating to sustainability reporting, i.e. including the IRO analysis and the double materiality assessment" and meets approximately four times a year.
• At Group level responsibility for sustainability rests with the President and CEO. The CTO is responsible for IROs related to E1, E5, S2 and S4, the CPCO for S1, and the CFO for G1. The three meet approximately monthly and are supported by a weekly internal expert team (Senior HSEQ Manager, Global Project Lead People & Culture, Lead Engineer Sustainability, Group Sustainability Engineer, Head of Group Tax & Legal, Head of Group Reporting).
• New targets for material IROs are proposed by the CTO, CFO or CPCO to the Group Leadership Team and then to the Board for approval.

Information provided to the administrative, management and supervisory bodies

Reference: page 48. The ESRS index adds cross-references to pages 55, 62, 70-71, 77, 82 and 85 (page 89).

"Two of the four Audit Committee meetings have sustainability-related topics on the agenda. One of the meetings addresses the topic sustainability reporting and the auditor's feedback and another one has sustainability targets and activities as an agenda item. The information is normally provided to the Audit Committee by the CTO, the CPCO and/or the CFO depending on the topic" (page 48).

How the bodies are informed (page 48):

• The CTO, CPCO and CFO monitor, manage and oversee IROs and report status to the Group Leadership Team, the Audit Committee and the Board.
• "The updated IROs identified through the DMA process and their level of materiality was discussed and approved by the Group Leadership Team in September 2025. When strategy and risks are being reviewed, the outcome of the DMA is used as input."
• Progress on the sustainability strategy and targets "forms a standing element of the monthly Group Leadership Team meetings", with updates to the Board "at least once per year" (page 48).
• The Global Leadership Team, Audit Committee and Board follow up on agreed actions and metrics, "otherwise corrective measures will be implemented".

The material IROs the bodies review are set out in the per-topic tables on pages 55 (E1), 62 (E5), 70-71 (S1), 77 (S2), 82 (S4) and 85 (G1).

Sustainability performance in incentive schemes

Reference: pages 48 and 56. The ESRS index also cross-refers to page 107 (page 89).

"Since 2024, the Group's Short-Term Incentive programme (STI) contains a sustainability target of 10% of the maximum STI outcome. In 2025, the sustainability target relates to the Group's commitment to Science-Based Targets and the progress to develop a transition plan to meet the CO2e SBTi emissions targets by 2031" (page 48).

Targets are proposed by the Group Leadership Team and approved by the Remuneration Committee; updates to existing targets follow the same route (pages 48-49).

The E1-specific disclosure is explicit about the limits of the link: climate factors are integrated into the STI for Group Leadership Team members and key managers, and "Up to 10% of the maximum remuneration is directly linked to the development of a comprehensive transition plan addressing Scope 1, 2, and 3 emissions... As such remuneration is not directly tied to the reduction of CO2e emissions in this reporting year" (page 56).

Statement on due diligence

Reference: page 49.

"Achieving sustainable business practices requires continuous due diligence efforts. The Group identifies and assesses adverse impacts in its operations, the supply chain and in business relationships. Actual and potential negative impacts inform the DMA process and material impacts are managed accordingly through appropriate measures to mitigate and prevent them, track implementation and communicate transparently" (page 49).

The mapping table on page 49 places the five core elements of due diligence as follows:

Risk management and internal controls over sustainability reporting

Reference: page 49, with the full risk management process on pages 97-103.

"Alimak Group has an annual risk management process that also covers risks in the sustainability area, including sustainability reporting... Each year, the identified risks are assessed and scored in terms of likelihood and financial impact. The initial assessment is made by the divisions and the Group functions. Subsequently, a prioritisation process is performed by the Group Leadership Team to determine which risks should take focus. Owners and timelines for mitigation actions are agreed upon" (page 49).

On controls over the data itself: "During the last couple of years, investments have been made in three web-based platforms to improve the collection, quality and control of sustainability metrics; one HR system, one system for supply-chain monitoring and one tool for environmental and health & safety data" (page 49). Those platforms are named elsewhere in the statement as the HR system under implementation through 2026-2027 (page 76), Worldfavor for supplier ESG assessment (pages 78-79) and CLEERIT for site sustainability data (pages 59, 64).

The MDR-M appendix records that "none of the KPIs presented in this table have been validated by any external party" (page 95).

Strategy, business model and value chain

Reference: pages 49-50.

The sustainability strategy rests on three pillars: "Promoting health and safety for its own personnel and workers across the value chain", "Reducing the carbon footprint throughout the full lifecycle of its products and operations" and "Fostering a corporate culture and leadership grounded in the Group's governance model" (page 49).

Business model (page 49): Alimak Group develops, manufactures, sells and services vertical access and working-at-height equipment in over 120 countries through five autonomous divisions - Facade Access, Construction, Height Safety & Productivity Solutions, Industrial and Wind - each responsible for its own supply, development, manufacturing, sales and service. Products include construction hoists, platforms, industrial lifts, building maintenance units and height safety equipment. The Group has 26 production and assembly facilities in 15 countries. For the Construction division, rental also forms a significant part of the model.

Value chain (page 49): raw material extraction and refining; supplier manufacturing (metals, plastics, electronics, packaging); transport and logistics; own manufacturing and assembly (cutting, welding, bending); intermediaries such as rental companies; end users; recycling and waste management. Relevant input materials are "steel, aluminium, copper, concrete, zinc, textiles, plastics, cardboard, wood, electronics, and hydraulic/lubricating oils".

The Group names five implementation challenges on page 50, including that "Achieving meaningful engagement with value chain workers is challenging due to limited direct access, resulting in continued reliance on proxy mechanisms such as supplier feedback, audits, and assessments".

Interests and views of stakeholders

Reference: page 50. Topic-level SBM-2 rows for S1, S2, S3 and S4 are all indexed to page 50 (page 89).

Engagement by stakeholder group (page 50):

• Own workforce - employee satisfaction surveys three to four times per year; results discussed at all management levels and action plans monitored through subsequent surveys. Responsibility: Chief People & Culture Officer.
• Value chain workers - considered indirectly through supplier ESG self-assessments and audits. Responsibility: Division Supply Chain Coordinators.
• Customers and end-users - each division's product management team collects feedback on functionality, cost and quality, feeding product roadmaps and R&D priorities. Responsibility: Division Head of Product Management.
• Investors - financial reports and presentations. Responsibility: CFO.

Effect on strategy (page 50): "Stakeholder input has driven increased focus on sustainability, including carbon footprint reduction, supplier engagement, workforce health and safety, and governance training. In 2022, new sustainability targets were set, and in 2024, the Group committed to Science-Based Targets. New financial and sustainability targets were presented in November 2025 for the coming three-year period." Stakeholder feedback "is regularly communicated to and discussed by the Board and the Group Leadership Team".

Material impacts, risks and opportunities

Reference: pages 50-51, with topic-level SBM-3 sections on pages 56 (E1), 63 (E5), 72 (S1), 77-78 (S2), 82 (S4) and 86 (G1).

"The Group's strategy focuses on health and safety for employees and value chain workers, reducing carbon emissions across the full lifecycle, and fostering governance-driven leadership... Even though Alimak Group has not yet conducted a formal ESRS resilience analysis, these actions address key risks such as human rights compliance, workforce stability, and Scope 3 emissions, ensuring the business model remains ethical, and aligned with stakeholder expectations and long-term value creation" (page 50).

The value chain overview on page 51 plots where each material IRO sits across raw material, supplier manufacturing, transport to us, own factories, transport to customer, use phase, maintenance and end of life. It groups them as:

• Environmental - circular business models, after sales offering, products/solutions with low carbon footprint, value chain GHG emissions, Alimak Group direct emissions, energy efficiency in operations, material waste.
• Social - health and safety of end users, product quality, health and safety of employees, talent attraction, training/skill development, employment conditions, employee freedom of association, gender equality, child/forced labour in the supply chain, equal opportunities in the supply chain.
• Governance - corporate culture, whistleblower, corruption and bribery, supplier relationships.

Counting the individually typed rows in the per-topic IRO tables gives 36 material IROs: E1 9 (pages 55), E5 8 (page 62), S1 10 (pages 70-71), S2 3 (page 77), S4 3 (page 82) and G1 3 (page 85). No material opportunities were identified for S1 (page 72) or S2 (page 78).

Process to identify and assess material IROs

Reference: page 52.

"The first double materiality process was conducted in 2024, and in 2025 it was updated with more precise scoring methodology" (page 52).

Method (page 52): one or more internal experts were assigned to each of environment, social and governance; they familiarised themselves with CSRD/ESRS and stakeholder views; potential and actual financial and impact materiality "were identified using a risk-based approach prioritising the most severe or likely effect". Scoring: "Each IRO was assigned a score based on the severity of the impact or financial magnitude multiplied by the likelihood. Whenever the score of an IRO or a collection of IROs connected to a topic was equal to or higher than the set threshold, the topic was deemed material."

Assumptions declared (page 52): "Alimak Group is a global company with low vertical integration in its supply chain. Hence the Group cannot have a perfect overview of its entire value chain and must use qualified assumptions... Where detailed data is missing, the Group relies on country or sometimes region-wide averages and expert opinions."

Focus areas (page 52): environmental screening followed the highest-impact parts of the value chain identified by Life Cycle Assessment; social focused on activities with potential and actual negative impact on people and on high-risk countries in the value chain; governance focused on suppliers, own operations and the distributor network.

Approval: "The Group Leadership Team decided on the final DMA results in September 2025. The DMA is updated on an annual basis" (page 52). Inputs included GRI, TCFD and the GHG Protocol, employee surveys, supplier ESG self-assessments, audits and ILO material, internal expertise, customer dialogue via standards committees, and Board and quarterly-report engagement with owners.

Disclosure requirements covered

Reference: page 52, with the full ESRS index on pages 89-91.

"The materiality assessment resulted in the following topics being assessed as material, ESRS 2, E1, E5, S1, S2, S4 and G1. List of relevant IROs is disclosed under each topical standards" (page 52). The index adds that IRO-2 is "Partially answered by reference on pages 97-103" (page 89).

The report prints a genuine ESRS content index, "ESRS index - Disclosure Requirement / Page number / Additional information" (pages 89-91). It lists:

• ESRS 2 - BP-1, BP-2 (47), GOV-1 (47), GOV-2 (48), GOV-3 (48), GOV-4 (49), GOV-5 (49), SBM-1 (49), SBM-2 (50) plus SBM-2 rows for S1, S2, S3 and S4 (50), SBM-3 (50), IRO-1 (52), IRO-2 (52).
• E1 - GOV-3:E1, IRO-1:E1, SBM-3:E1 (56), E1-1 (57), E1-2 (58), E1-3 (58), E1-4 (59), E1-5 (59), E1-6 (60), E1-9 (61). E1-7 and E1-8 are not listed.
• E5 - IRO-1:E5, SBM-3:E5 (63), E5-1 (63), E5-2, E5-3, E5-4, E5-5 (64). E5-6 is not listed.
• S1 - SBM-3:S1 (72), S1-1, S1-2 (73), S1-3, S1-4 (74), S1-5 (75), S1-6, S1-8, S1-9, S1-14, S1-16 (76). S1-7 and S1-10 to S1-13, S1-15 and S1-17 are not listed.
• S2 - SBM-3:S2 (77), S2-1 (78), S2-2, S2-3 (79), S2-4, S2-5 (80).
• S4 - SBM-3:S4 (82), S4-1 to S4-5 (83).
• G1 - GOV-1:G1, IRO-1:G1 (85), SBM-3:G1, G1-1, G1-3 (86), G1-4 (87). G1-2, G1-5 and G1-6 are not listed.

Two further appendices support it: the list of datapoints deriving from other EU legislation (pages 92-94) and an MDR-M methodology, estimation and uncertainty table (pages 95-96), which the Group consolidated because of "the extensive amount of information required under the Minimum Disclosure Requirements for Metrics (MDR M)" (page 47).

Transition plan for climate change mitigation

Reference: pages 57-58.

Alimak Group describes a preliminary plan: "This is a preliminary transition plan, and most likely the plan will be further updated and improved during the implementation. The plan is being progressively incorporated across all divisions and into the Group's 2030 strategy, ensuring that investments support the transition" (page 58). It "has been approved by the Group Leadership Team and was developed in close collaboration with each division" (page 57).

Targets and ambition (page 57): the current target is to cut Scope 1-3 GHG emissions relative to revenue by 30% by end-2025 against 2019. The company qualifies it plainly - the target "does not require an absolute reduction and may not fully align with the IPCC cross-sector emission pathways compatible with limiting global warming to 1.5°C or well below 2°C climate action pathways if market share were to grow significantly". Scope 1 and 2 intensity is already down "approximately 53% compared with 2019". A science-based target for 2030-31 is under development "aiming for alignment with the 1.5°C pathway and verification by the Science Based Targets initiative (SBTi)".

Levers, with estimated contribution to a ~55% intensity reduction versus 2023 by 2031 (page 58): raw materials -23%, use phase -17%, additional measures -10%, transports -2%, supplier manufacturing -2%, installation -1%, maintenance -1%, end-of-life -1%. The Scope 1 and 2 chart on page 57 attributes -3,743 tCO2e to renewable electricity and -4,525 tCO2e to electrifying fossil-powered equipment against a 12,188 tCO2e 2019 baseline.

Locked-in emissions (page 58): "The locked-in emissions found in Scope 1 and 2 are not large enough to pose a risk that the Group will not reach its GHG emissions reduction target." Factories are named as the largest share of site emissions.

Fossil exposure (page 58): "Although the industrial division has some sales to customers operating in coal, oil and gas, it is not large enough that Alimak Group as a whole is at risk of jeopardising our green transition. Furthermore, the Group is not excluded from EU Paris-aligned Benchmarks under the Climate Benchmark Standards Regulation."

No CapEx or OpEx is attached to the plan; the Group states sustainability spend is "not tracked or managed as stand alone categories" (pages 47, 61).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 IRO table, where this content is disclosed in the FY2025 report (pages 55-56). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Physical / transition classification (page 56). SBM-3:E1 labels each material climate risk: declining revenue in oil and gas customer segments (transition), extreme weather exposure at factories and offices (physical), CBAM costs on imported steel and wrought aluminium (transition), reduced market attractiveness if the portfolio is not seen as sustainable (transition), and higher-than-necessary energy costs from inefficiencies at major production sites (transition).

Methodology for exposure and sensitivity (page 56). "Data regarding physical climate risks has been compiled in collaboration with the Group's insurance provider. Based on this analysis, we have identified six sites where potential action may be required: two in China, two in Spain, one in Italy, and one in the United States. The specific measures to be undertaken by the Group are currently under review and will be determined next year." For transition risk, "Alimak Group has implemented a structured process to identify and assess climate-related transition risks and opportunities across its operations and value chain. This includes analysing exposure and sensitivity to regulatory, market, and technological changes over the short, medium, and long term."

Emissions exposure across the value chain is estimated with an activity-based approach: LCAs for major product categories linked to sales data, "enabling a comprehensive calculation of total value chain emissions from material acquisition, manufacturing, transport, installation, operation, maintenance, to end-of-life" (page 56).

Scenario analysis: none. "The Group has not yet conducted a climate change scenario risk analysis" (page 56). No high-emission physical scenario, no 1.5°C transition scenario and no temperature projections are therefore disclosed, and the scenario-analysis limb of the requirement does not attach.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and E1-1, where this content is disclosed in the FY2025 report (pages 50, 57). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Alimak Group states plainly that no resilience analysis has been performed. "Alimak Group has not yet conducted a resilience analysis of its business strategy, but this is expected to be completed by 2026" (page 57). The general SBM-3 repeats it: "Even though Alimak Group has not yet conducted a formal ESRS resilience analysis, these actions address key risks such as human rights compliance, workforce stability, and Scope 3 emissions, ensuring the business model remains ethical, and aligned with stakeholder expectations and long-term value creation" (page 50).

What the report offers in place of a resilience analysis is the strategic response set out under E1 SBM-3 and E1-1: transitioning to renewable energy, electrifying the vehicle fleet, improving energy efficiency at key sites, and LCAs on major product groups to inform lower-impact sourcing, design for energy efficiency and durability, and life extension through refurbishment and modular upgrades (page 56). Adaptation capacity is addressed only for the six sites flagged as exposed to extreme weather, where "These sites are located in areas where local authorities have made some investments in protective infrastructure against extreme weather events. The Group is evaluating the need for additional measures to protect its assets and ensure operational resilience" (page 55), and through business continuity planning built into the Environmental Policy "to address risks associated with extreme weather events, ensuring resilience across operations" (page 58).

No uncertainty analysis and no assessment of the capacity to adjust or adapt over short, medium and long term are disclosed, because the underlying analysis has not been carried out.

Policies related to climate change mitigation and adaptation

Reference: page 58, with the policy matrix on page 53.

Climate is governed by a single Environmental Policy that "integrates both climate change and circular economy principles" and "provides a structured framework for managing impacts related to climate and resource use throughout the value chain. It ensures compliance with all relevant legislation and promotes the adoption of ISO-aligned management systems at manufacturing sites" (page 58).

"The policy emphasises a precautionary approach, aiming to minimise greenhouse gas emissions through sustainable sourcing, product development, and maintenance practices... The Group is firmly committed to transitioning to renewable energy, enhancing energy efficiency, and collaborating with suppliers that have science-based climate targets" (page 58). Adaptation is covered too: "This policy also incorporates business continuity planning to address risks associated with extreme weather events, ensuring resilience across operations."

The policy matrix (page 53) records the MDR-P detail: the policy's purpose is "to ensure compliance, drive circular economy principles and support the transition to a low-carbon future in line with the Paris Agreement while creating long-term value for stakeholders"; scope is "all employees, subsidiaries and partially owned companies"; the owner is the CTO; and connected IROs are "ALL IROs under E1 & E5". Availability is limited - the policy is "Available to all employees internally, and provided to external parties upon request" rather than published.

Actions and resources in relation to climate change policies

Reference: page 58.

Manufacturing sites (page 58): "Focus on energy efficiency via energy mappings, transitioning to renewable energy by purchasing certified renewable energy or investing in rooftop solar, and replacing fossil-powered vehicles and machinery with electric alternatives. These efforts have already delivered significant reductions and will continue to be prioritised."

Scope 3 decarbonisation (page 58): sourcing recycled materials, "especially metals like steel and wrought aluminium"; advancing sustainable product design; reducing raw material use and building more energy-efficient machines; adopting circular business models; and "Utilising digitalisation and connected machines/equipment to extend the life of our products via improved predictive maintenance and spare parts logistics".

Refurbishment programmes (page 58): "The Facade Access, Industrial, and Construction divisions operate refurbishment programmes to extend the life of installed equipment, meeting customer demand for cost-effective and sustainable solutions and reducing the Group's climate footprint."

The Group is candid about the limits of this disclosure: "While Alimak Group's climate-related actions are not yet fully aligned with MDR-A standards, the Group is actively working across multiple areas to reduce emissions and strengthen environmental performance" (page 58). The reason is given in BP-1: because the Group runs a divisional structure, "MDR A cannot be applied exactly as described. Group sets the overall direction, but divisions make the relevant decisions and prioritise actions based on their own operational needs" (page 47). No resources, CapEx or OpEx are attached to any action (pages 47, 61).

Targets related to climate change mitigation and adaptation

Reference: page 59.

"Alimak Group has set a measurable, time-bound climate target: to reduce total greenhouse gas emissions (Scopes 1, 2, and 3) relative to revenue by 30% by the end of 2025, using 2019 as the baseline year. This target is global in scope and applies across all operations and the value chain" (page 59).

Boundary and limitations stated by the company (page 59): "No absolute target has been set yet, and the current target excludes scope 3 categories which are not relevant to the Group such as: Fuel and energy related activities, upstream leased assets, processing of sold products, downstream leased assets, franchises, and investments. Furthermore, the boundary of the GHG emission target does not diverge from the GHG emissions reported under E1-6." Progress is measured on market-based Scope 2.

Progress by scope (page 59):

• Scope 1 and 2 - "The Group has already exceeded its target by significantly increasing renewable energy use at manufacturing sites and reducing fossil fuel reliance through electrification and investments in energy-efficient equipment."
• Scope 3 - "Progress has been slower due to the complexity of mapping emissions across the value chain. Product life cycle assessments (LCAs) are now applied to the most sold product categories."

Ambition alignment (page 59): "The 30% reduction target roughly aligns with the 1.5°C to well below 2°C climate pathways, but has not yet been approved by a third party organisations such as the SBTi. Alimak Group is well-positioned to set a new, SBTi-verified short-term target by the end of Q1 2026."

No separate adaptation target is disclosed. Monitoring runs through the CLEERIT platform, with the CTO function coordinating site-level data collection and validation (page 59).

Energy consumption and mix

Reference: page 59.

Consumption (MWh), 2025 versus 2024:

Renewable energy is 33.5% of the 2025 total. Self-generated non-fuel renewable consumption rose more than tenfold, from 37 to 390 MWh, and renewable energy production rose from 46 to 704 MWh, with no non-renewable production in either year (page 59).

Energy intensity: 4.9 MWh per MSEK revenue in 2025 (4.8 in 2024). The Group identifies its high climate impact activity for paragraph 40 purposes as "C28.2.2 - Manufacture of lifting and handling equipment", with C33, C33.1.2 and C33.2.0 also relevant, and its rental activities (N77 and sub-classes) treated as low impact (page 59).

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 60-61.

Absolute emissions (tCO2e):

*"Includes more categories of Scope 3 than other years." The 2023 column is a one-off pilot: purchased goods and services 59,903, use of sold products 12,241, maintenance of sold products 6,684, downstream transportation 3,058, upstream transportation and distribution 2,723, end-of-life treatment 888, business travel 3,092. Every other Scope 3 category for 2024 and 2025 is marked "Next year". Scope 1 emissions from regulated emission trading schemes are 0% throughout.

Why the categories are missing (page 61): "During 2024, extensive work was done to map both upstream and downstream Scope 3 GHG emissions... During 2025, we have further quality assured the numbers and have drawn up plans for how these emissions will be reduced. From 2026 and forward, the numbers will be disclosed as part of the Sustainability statement." Categories treated as irrelevant are fuel and energy related activities, leased assets, processing of sold products, franchises and investments (page 60).

Intensity: 1.48 tCO2e per MSEK revenue in 2025 against 1.52 in 2024, calculated on market-based Scope 2, with the caveat that "next year, additional Scope 3 categories will be included, which may significantly change these values" (page 61). Revenue reconciles to the consolidated statements on page 116.

Method: Scope 3 uses "a scalable life cycle assessment (LCA) approach. Representative category level product models are developed for average products within each major product category... applied for the 2023 reporting year as a pilot and demonstration" (page 60).

Anticipated financial effects from physical and transition risks and climate-related opportunities

Reference: page 61.

Alimak Group discloses no quantified anticipated financial effects. Its stated reason is the same one given in BP-1: "As mentioned in ESRS 2, sustainability related capital and operational expenditures are embedded into Alimak Group's wider investment processes and are not tracked or managed as stand alone categories. As a result, the Group does not publish isolated CapEx or OpEx figures in this ESRS report. Instead, sustainability driven investments are reflected holistically through our strategic initiatives, performance development, and financial statements" (page 61).

Two quantitative datapoints are given for fossil-fuel exposure (page 61):

• "The Industrial Division has some revenue from customers in the oil & gas and coal sectors. The revenue from these customers in 2025 amounted to MSEK 569."
• "The Group's revenue amounted to MSEK 6,874 and the revenue from customers in these segments amounted to MSEK 569, i.e. approximately 8%."

On the opportunity side the disclosure is qualitative: "It is expected that the market for low-carbon products will gradually increase by working with: improving product design to reduce the impact of raw materials, energy use and maintenance emissions; increased lifetime of machines; sourcing reused, recycled or other sustainable materials; refurbishment of old machines; renovation and reselling of used equipment; expanding the rental business" (page 61). No monetary amount, time horizon or asset-level physical risk disaggregation is attached to any of these.

Policies related to resource use and circular economy

Reference: pages 63-64, with the policy matrix on page 53.

Circularity is governed by the same Environmental Policy that covers climate. "The policy clearly outlines the Group's commitment to transitioning away from virgin resource use. It emphasises the application of circular principles, 'Prevent, Reduce, Reuse, Recycle', across all operations and procurement, with a specific focus on minimising resource consumption and prioritising the use of secondary resources over virgin materials" (page 64).

The MDR-P detail sits in the policy matrix (page 53): the policy "incorporates circular economy principles by prioritising resource efficiency, reuse, and recycling to minimise waste and environmental impact"; its purpose is "to ensure compliance, drive circular economy principles and support the transition to a low-carbon future in line with the Paris Agreement"; it applies to "all employees, subsidiaries and partially owned companies"; the owner is the CTO; and the connected IROs are "ALL IROs under E1 & E5". As with climate, the policy is "Available to all employees internally, and provided to external parties upon request" rather than published.

The Supplier Code of Conduct carries the upstream limb, requiring compliance with REACH, RoHS and local chemical safety laws and covering responsible sourcing (page 53).

Actions and resources related to resource use and circular economy

Reference: page 64.

Sourcing: "Alimak Group actively prioritises the sourcing of secondary (recycled) materials over virgin resources. This approach influences procurement decisions and supplier selection, favouring partners who are committed to circularity. By increasing the share of reused and recycled materials, such as steel, wrought aluminium, copper, concrete, textiles, plastics, and electronics, the Group reduces its environmental footprint" (page 64).

Refurbishment and reuse: "The Facade Access, Industrial, and Construction divisions are expanding refurbishment and reuse initiatives. These programmes extend product lifespans, reduce waste, and drive innovation in modular design, reparability, and material efficiency." The Industrial programme is described in SBM-3 as one "where old installations can be retrofitted with a new cage while keeping the mechanical structure with the mast, rack and tie-ins", and the Construction division "buys back older machines to be refurbished and sold on the market" (pages 62-63).

Design: "Circularity is integrated into product development through modular design, reparability, and disassembly features."

Waste: "The company works exclusively with reputable waste handlers and aligns its practices with EU Ecodesign requirements. This ensures proper disposal of waste, minimises environmental harm, and reduces compliance risks" (page 64).

No monetary resources are attached to these actions, consistent with the Group-wide position that sustainability CapEx and OpEx are not tracked as standalone categories (page 47).

Targets related to resource use and circular economy

Reference: page 64.

Alimak Group discloses that it has no circularity target. "Alimak Group does not currently have a specific quantitative target or group developed metrics for circularity. To date, efforts related to the circular economy have been integrated into the Group's broader decarbonisation strategy. Divisions have focused on increasing the use of recycled materials and expanding refurbishment programmes as key actions" (page 64).

"Looking ahead, Alimak Group plans to evaluate the establishment of a dedicated circularity target" (page 64). No date, scope or baseline is attached to that intention.

The nearest quantified proxy sits inside the climate transition plan rather than under E5: raw materials are the largest single decarbonisation lever, estimated at -23% of the ~55% intensity reduction targeted for 2031, to be achieved by "increasing recycled metal content, refurbishing components to extend product life, and designing lighter products", with end-of-life circular models contributing a further -1% (page 58).

Resource inflows

Reference: page 64.

No quantitative inflow data is reported for 2025. "Waste-related KPIs are presented below, however, data on resource inflows and product outflows is not yet available as there are uncertainties in data quality due to differing data collection methodologies across the Group's manufacturing sites, therefore quantitative data is not reported for 2025. The Group is actively improving its data collection and reporting processes and aims to disclose this information in the 2026 Annual Report" (page 64).

The material categories are named, even where the tonnages are not. IRO-1:E5 records that LCAs "enabled the company to determine the most environmentally significant material categories. These include steel, wrought aluminium, copper, concrete, textiles, plastics, electronics, wood, cardboard, bioplastics, other biomaterials, and hazardous substances" (page 63). The E5 IRO table adds "mainly polyester" for textiles (page 62), and SBM-1 lists the same set plus zinc and hydraulic and lubricating oils (page 49).

The material inflow impact is stated as an actual negative one sitting upstream: "Actual negative impact on the environment due to use of non-recycled inflow materials in the Group's upstream value chain", mitigated by the Group aiming "to cut environmental impact by increasing reused and recycled materials in its supply chain" (page 62). No weight or volume of products and materials used, and no share of biological or secondary reused or recycled components, is disclosed.

Resource outflows

Reference: page 64.

No quantitative outflow data is reported for 2025, on the same stated basis as inflows: "data on resource inflows and product outflows is not yet available as there are uncertainties in data quality due to differing data collection methodologies across the Group's manufacturing sites... The Group is actively improving its data collection and reporting processes and aims to disclose this information in the 2026 Annual Report" (page 64).

What is disclosed is durability and reparability in qualitative form.

Product lifespan by division (page 64):

• Industrial - rack and pinion and traction industrial lifts, 20-25 years
• Construction - construction hoists, mast climbing platforms, transport platforms, 20-25 years
• Facade Access - BMUs and davits (Manntech, CoxGomyl, Tractel), approximately 25 years
• Wind - service lifts, ladders, climb assists, fall arrest systems, tower equipment, 20-30 years
• HSPS - safety gear, lifting equipment, control systems, 1-10 years depending on product type

Reparability (page 64): "An established third party reparability score does not exist for Alimak Group products. However, reparability is a core feature across all mechanical product categories, and refurbishment is often considered early in the design phase... The exception is safety-critical items such as safety harnesses and textile-based products, which typically must be discarded when damaged due to strict safety regulations."

Recyclable content: "we are currently unable to confirm the rates of recyclable content in products and their packaging, as data is still being collected and quality controlled" (page 64).

Waste

Reference: page 64.

Waste KPIs (tonnes):

Total waste rose 27% year on year while non-recycled waste more than halved, from 528 to 231 tonnes, taking the non-recycled share from 19% to 7%. Hazardous waste fell from 302 to 126 tonnes. No radioactive waste is reported.

The underlying IRO is a "Medium-term potential negative impact on the environment in case waste is not managed properly in own operations", with the Group aiming "to ensure proper waste management by only working with reputable waste management firms so that its waste is handled properly in all locations, especially in relation to hazardous materials" (page 62).

Data basis (page 64): "Waste data is collected from the waste management firms / local governments which we cooperate with", with site collection and validation coordinated by the CTO function through the CLEERIT platform. The non-recycled waste and hazardous waste datapoints are cross-referenced to SFDR indicators in the EU-legislation datapoint list (page 93).

Policies related to own workforce

Reference: page 73, with the policy matrix on page 53.

Two policies carry S1: the Code of Conduct, owned by the CFO and connected to "All IROs under S1 (Excluding H&S)", and the Health and Safety Policy, owned by the CPCO and connected to "All H&S IROs under S1" (page 53). The Health and Safety Policy "promotes a Zero Harm vision through proactive risk management, safe work systems, and employee engagement" and "adheres to ISO 45001 Occupational Health and Safety Management Systems" (page 53). Both are "Available to all employees internally, and provided to external parties upon request"; the Code of Conduct is "Publicly accessible to all via our website".

"Our policies are aligned with the United Nations Guiding Principles on Business and Human Rights and core conventions. These standards are embedded in our Code of Conduct Policy... Strict anti-discrimination practices prohibit any form of discrimination based on gender, age, ethnicity, religion, disability, or other protected characteristics... the policy explicitly states that the Group does not accept the use of child labour, bonded labour, or any form of forced labour" (page 73).

A gap the company states itself (page 73): "While the Group does not condone any form of human trafficking, this is currently addressed explicitly only in the Supplier Code of Conduct. The inclusion of an explicit reference to human trafficking in the Group Code of Conduct is planned for a future update."

The Global Health & Safety Policy is "approved by the CEO and Group Leadership Team" and covers roles and responsibilities, risk management, leadership and system requirements, legal compliance, emergency preparedness, incident reporting, performance monitoring and worker involvement (page 73). Grievance routes run through the Whistleblower Policy and local employee assistance channels.

Engaging with own workforce and workers' representatives

Reference: pages 73-74.

Channels (page 73): employee surveys two to four times per year; quarterly performance goal setting and conversations between employees and managers; quarterly town halls at Group and local level; and "Monthly management calls for the Group's 450 managers".

Representation: "Employee representatives participate in various functional or global department groups, such as the People & Culture Council and the Health & Safety Council, which meet regularly to ensure alignment on social, human rights, and health and safety requirements. These councils provide an additional voice in shaping global processes and influencing strategic direction" (page 73).

Accountability: "The most senior role in the Group with the operational responsibility to ensure engagement with the workforce occurs is the Chief People & Culture Officer" (page 73).

How input is used: "Feedback from surveys and risk assessments is systematically recorded and analysed using digital tools like Peakon, Cleerit, and Safety Observation apps. Health and safety results are communicated monthly to leadership teams and quarterly to the Board, with local action plans developed in response to feedback" (page 73).

Engagement explicitly covers "the impacts of carbon reduction initiatives, restructuring, employment changes, training and upskilling, gender and social equity, and health and safety" (page 73).

A limitation the company states (page 73): "Alimak Group does not currently have dedicated initiatives for vulnerable or at-risk worker groups, but aims to be an inclusive employer in all we do. Leaders are expected to identify and remove any barriers for these employees through targeted consultations, support services, and confidential reporting channels."

Remediation and channels to raise concerns

Reference: page 74.

Channels (page 74):

• Internal reporting - directly to line managers or human resources representatives.
• Whistleblower channel - "available in 16 different languages, employees have a channel where they can raise concerns anonymously by using this reporting channel, managed by a third-party, WhistleB... to communicate regarding suspected wrongdoings affecting people, our organisation, society or the environment, and to raise these concerns anonymously without fear of reprisal."
• Union and worker representation - "employees may also raise issues through union representatives or workforce committees, which liaise directly with management on behalf of members."
• Employee assistance programmes - "some local businesses within the Group have access to employee assistance programmes that offer confidential support and counselling services."

Anonymous engagement surveys with free-text comments and direct input during health and safety risk assessments supplement these.

Remediation (page 74): "Alimak Group provides formal processes for remediating negative impacts on its workforce, including corrective actions following survey feedback, incident investigations, and policy updates. Health and safety incidents are tracked, analysed, and addressed promptly." Concerns are "acknowledged promptly, with a standardised process for assessment and investigation. Progress is tracked through a case management system."

Effectiveness (page 74): evaluated through regular review of case outcomes, questions in the employee surveys on the Group's management of misconduct "to gauge satisfaction and trust in processes", and continuous training for managers and compliance staff. "Alimak Group prohibits retaliation against any employee who raises a concern in good faith", with anti-retaliation measures in the Code of Conduct and Whistleblower guidelines. No count of concerns raised or resolved is given.

Taking action on material impacts on own workforce

Reference: pages 74-75.

"Alimak Group has established a structured approach to address material impacts affecting its workforce. These plans are informed by regular risk assessment reviews, employee feedback, and industry benchmarks. Resources are allocated to ensure focus and effective implementation, including dedicated human resources teams, comprehensive training programmes, robust health and safety infrastructure, wide-reaching employee experience surveys, and ongoing professional development opportunities. The company's People & Culture strategy is reviewed annually" (page 74).

Negative impacts (page 74): comprehensive risk assessments to map hazards, "with mitigation strategies including enhanced safety protocols, regular training sessions, and strict enforcement of anti-discrimination policies. Some local companies also provide mental health support through employee assistance programmes and psychosocial hazard training."

Risk management (page 75): for the privacy risk specifically, "the Group provides GDPR training to managers and local assigned Data Protection Officers."

Effectiveness tracking (page 75): "Key performance indicators (KPIs) include incident rates, staff turnover, employee engagement scores, and diversity statistics. These metrics are reported to the Board and external stakeholders annually."

Worker involvement (page 75): "In many sites, the employees have elected union representatives, which enables the workforce representatives to participate in decision-making processes related to workplace changes, risk management, and opportunity identification."

No resources are quantified: "As stated in ESRS 2, sustainability related capital and operational expenditures are embedded into Alimak Group's wider investment processes and are not tracked or managed as stand alone categories. As a result, the Group does not publish isolated CapEx or OpEx figures in this ESRS report" (page 75).

Targets related to own workforce

Reference: page 75.

Two outcome-oriented targets are disclosed (page 75):

• "The Group aims for a zero-harm objective and a Lost Time Injury Frequency Rate (LTIFR) below 2, assuming continued investment in safety training and operational controls."
• "It also targets an employee net promoter score (eNPS) of 40, assuming enhanced leadership capability, increased satisfaction and engagement initiatives planned through involvement of local teams as well as Group level initiatives."

Progress against both is charted in the introduction to the statement, where eNPS is reported to have moved "from -2 to +35" over four years against a target of 40, while LTIFR stood at 5 in 2025 against 4 in 2024 and a target below 2 (pages 44, 76). The LTIFR target is therefore materially missed and moving in the wrong direction.

How targets were set (page 75): "Employees within Alimak Group are not actively involved in defining the targets aimed at managing material impacts, risks and opportunities. However, they are highly involved in the outcomes and actions taken to address them." Targets are "based on scenario analyses and data from employee engagement surveys and internal Health & Safety reporting", aligned with the UN Global Compact principles, ISO standards and SDGs 3 and 8, "reviewed annually, and benchmarked against sector best practice".

Accountability: "Each Division EVP is responsible for action planning and tracking of improvement plans for each division" (page 75). No targets are disclosed for the training, equal treatment or privacy IROs.

Characteristics of employees

Reference: page 76.

Headcount by gender: male 2,406 (2024: 2,488), female 522 (2024: 534), other N/A - "Information not collected" - and not reported 131 (2024: 20). Total employees 3,059 (2024: 3,042).

By contract type and gender (head count, 2025):

By region (head count, 2025): Americas 439 (432 permanent, 7 temporary, 1 non-guaranteed hours), EMEA 1,955 (1,880 / 75 / 3), Asia Pacific 663 (624 / 39 / 21).

Countries above 10% of Group headcount: Sweden 375 and Spain 314.

Turnover: 406 employees left during 2025, a turnover rate of 13.4%. Both are reported as "n/a" for 2024, so no comparative is available.

The Group notes in SBM-3 that it "experiences normal fluctuations in employee numbers due to regular turnover, occasional reductions in workforce, and the use of temporary workers during periods of increased production demand" (page 72).

Collective bargaining coverage and social dialogue

Reference: page 76.

The disclosure is presented as a banded table rather than as single percentages. Coverage-rate bands are 0-19%, 20-39%, 40-59%, 60-79% and 80-100%, across four columns: employees in the EEA, employees outside the EEA, workplace representation in the EEA, and workplace representation outside the EEA.

The regions named in the table are Sweden and Spain for EEA collective bargaining coverage and for EEA workplace representation, and APAC and the Americas and EMEA excluding the EEA for the non-EEA columns (page 76).

The stated basis is footnoted: EEA figures are given "For countries with > 50 employees representing >10% total employees" and non-EEA figures are an "Estimate for regions with > 50 employees representing >10% total employees" (page 76). Sweden and Spain are the only countries meeting the 10% threshold, with 375 and 314 employees respectively out of 3,059.

Social dialogue is described qualitatively elsewhere in S1: employee representatives sit on the People & Culture Council and the Health & Safety Council (page 73), employees may raise issues "through union representatives or workforce committees, which liaise directly with management on behalf of members" (page 74), and "In many sites, the employees have elected union representatives" (page 75). Two employee representatives appointed by the trade unions sit on the Board (page 47). No European Works Council or single Group-wide coverage percentage is disclosed.

Diversity metrics

Reference: page 76.

Top management (Group Leadership Team):

The share fell year on year, from 30% to 27%, because the Group Leadership Team grew to eleven members while the number of women stayed at three (pages 47, 76).

Age distribution of employees:

Board-level diversity is disclosed under GOV-1 rather than here: eight directors elected by the April 2025 AGM, four women and four men, "The gender ratio of directors elected by the Annual General Meeting is 50% women and 50% men", plus two employee representatives (page 47). The board gender diversity datapoint is cross-referenced to page 47 in the list of datapoints deriving from other EU legislation (page 92).

The material IRO behind this disclosure is a "Medium-term risk of female own employees leaving the Group if discriminated against", mitigated through "targeted employer branding to attract female employees and an HR system that provides global visibility on salaries by role and gender" (page 71).

Health and safety metrics

Reference: page 76.

The whole workforce is covered by a health and safety management system in both years and there were no fatalities. Every injury measure deteriorated: MTIs rose 67% (21 to 35), LTIs rose 26% (23 to 29), LTIFR rose from 4 to 5 and TRIFR from 8 to 11, against a stated target of LTIFR below 2 and a zero-harm ambition (page 75). Working hours rose 8.6%, so the rate increases are not explained by exposure alone. The introduction attributes the movement in part to reporting quality: "Improved reporting and targeted actions support a proactive culture" (page 44).

Days lost are not reported - both the LTI and work-related ill health day counts are shown as dashes - although the number of days lost is a datapoint the Group itself cross-references to page 76 in the list of datapoints deriving from other EU legislation (page 94). Health and safety results are "communicated monthly to leadership teams and quarterly to the Board" (page 73), and injuries and safety performance are "reviewed monthly by the Group Leadership Team and quarterly by the Board" (page 70).

Remuneration metrics (pay gap and total remuneration)

Reference: page 76. The ESRS index lists S1-16 - "Remuneration metrics (pay gap and total remuneration)" - at page 76 (page 90).

Alimak Group discloses the requirement but reports none of its metrics. "Gender equality is a key priority for the Group, and we have been actively working on this area for several years. However, due to the transition to a new global HR system during the reporting period, we were unable to obtain data of sufficient quality to accurately report on gender pay gap metrics. The Group plans to report on these metrics in the next reporting year" (page 76).

"The HR system implementation will continue during 2026 and 2027. The new system will enable further collection of data about our own employees' participation in regular performance and career development reviews, gender pay gaps and other self-service capabilities which will be included in the 2026 report" (page 76).

So no unadjusted gender pay gap and no annual total remuneration ratio between the highest-paid individual and the median are given, even though both are datapoints the Group cross-references to page 76 in the list of datapoints deriving from other EU legislation (page 94).

The gap matters against the S1 IRO it relates to: the material risk of female employees leaving if discriminated against notes that "A lack of gender balance and equality in compensation and representation across all roles further increases these risks", and names as mitigation "an HR system that provides global visibility on salaries by role and gender" (page 71) - the same system whose transition is given as the reason the metric cannot be reported.

Policies related to value chain workers

Reference: pages 78-79, with the policy matrix on page 53.

The governing instrument is the Supplier Code of Conduct, owned by the CTO, connected to "All IROs under S2" and "Publicly accessible to all via our website" (page 53). It "is contractually binding and applies to every supplier providing goods or services to any Alimak Group company. It emphasises respect for human rights and international conventions, including those established by the United Nations, International Labour Organization, UN Global Compact, and OECD. The Code strictly prohibits forced labour, child labour, discrimination, violence, and harassment, while it safeguards freedom of association and collective bargaining" (page 78).

"Suppliers are expected to provide fair compensation, maintain safe working conditions, and offer access to training. They are also required to cascade these standards to their own suppliers... The Code is available in multiple languages, and from 2026 onwards, must be signed by an authorised representative of each supplier" (page 78).

A gap the company states itself (page 78): "Although Alimak Group does not currently maintain a standalone human rights policy, its commitments are embedded in the Group's Supplier Code of Conduct."

Accountability: "The most senior role within Alimak Group that is accountable for implementing the policy is that of Executive Vice-President of divisions" (page 78).

Risk identification (pages 78-79): ESG self-assessments through the Worldfavor platform cover suppliers representing approximately 80% of direct material spend, aligned with the OECD Due Diligence Guidance, the UNGPs and ILO conventions, with scoring against external indices including the Human Rights Index, Corruption Index and Modern Slavery Index. "While no formal violations have been reported, the Group continues to monitor supplier performance."

Engaging with value chain workers about impacts

Reference: page 79.

Engagement is indirect, through suppliers rather than with workers. "Alimak Group engages with its suppliers through a structured ESG self-assessment process using the Worldfavor platform, covering approximately 80% of its direct material spend. This process includes a comprehensive questionnaire with 45 questions - ranging from yes/no and multiple choice to document uploads - and features 17 flagged questions for ESG-risk assessment, developed by both Worldfavor and Alimak Group. Key topics addressed include compliance with the Supplier Code of Conduct, equal rights and treatment, freedom of association, minimum age and wage compliance, employment contracts, and environmental incidents" (page 79).

"Based on their responses, suppliers are scored and categorised into risk-level assessment (low, medium, high, or extreme), which determines the frequency of audits... Suppliers identified as high or extreme-risk are subject to on-site audits at least every three years. During these audits, feedback is gathered directly from workers or their representatives, which ensures that their perspectives inform Alimak Group's risk management and decision-making" (page 79). Self-assessments run annually. Operational responsibility sits with the Executive Vice-Presidents of divisions.

Vulnerable groups (page 79): "Currently, Alimak Group does not implement specific initiatives targeting vulnerable or marginalised worker groups, such as women, migrant workers, or workers with disabilities. However, these groups are included in the supplier self-assessment questionnaire... While direct engagement with these groups remains limited, their inclusion in the ESG risk assessment framework enables responsive and preventive actions where needed."

SBM-1 states the same limitation more bluntly: "Although direct engagement with value chain workers remains limited, their perspectives are considered through proxy mechanisms such as supplier feedback, audit findings, and sustainability assessments" (page 49).

Remediation and channels for value chain workers to raise concerns

Reference: page 79.

"Central to this approach is a risk-based supplier audit programme, which prioritises high and extreme-risk suppliers. These audits cover working conditions, health and safety, and social and environmental compliance. Where non-conformities are identified, corrective action plans are implemented and followed up by re-audits to ensure that improvements are sustained. In cases of major violations, such as child labour or forced labour, suppliers may be removed from the supplier panel to uphold the Group's ethical standards" (page 79).

Channel (page 79): "Alimak Group provides an external whistleblowing channel (WhistleB), accessible to all stakeholders - including employees, suppliers, and third parties. This channel supports reporting in 16 languages and is available via the company's external website. All messages are encrypted and handled confidentially, with access restricted to appointed individuals authorised to manage whistleblowing cases at WhistleB. The whistleblowing team within Alimak Group, comprising senior leaders from key functions, reviews each report and determines the need for investigation... Feedback is provided to the whistleblower, and follow-up questions can be submitted anonymously."

The Group draws a specific conclusion from anonymity: "Anonymity is a core function of the whistleblowing channel, meaning there is no possibility of retaliation against individuals reporting. As such, Alimak Group has deemed its Code of Conduct sufficient and a specific policy covering retaliation against individuals is not necessary" (page 79).

S2-4 records the limit on how far this reaches actual workers: "Although we do not have oversight about the level of information that workers have of this possibility" (page 80).

Taking action on material impacts on value chain workers

Reference: page 80.

Suppliers are scored on the country of their headquarters and their answers on human rights, working conditions, environment, health and safety, business ethics, material compliance and responsible sourcing. "High- or extreme-risk suppliers undergo on-site or remote audits" (page 80).

Audit outcomes (page 80): "Approved" (no follow-up), "Conditionally Approved" (clear improvement plans with follow-up in a defined timeframe) and "Rejected" (fail and show no willingness to improve).

Findings: "No severe human rights issues or incidents were identified in the Alimak Group's due diligence process when assessing its suppliers. The main findings include issues related to having their own supplier code of conduct and whistleblowing policy, and the ability to cascade their commitments to their direct suppliers" (page 80).

Results for 2025 (page 81): 63 audits (2024: 12), of which 14 approved, 44 conditionally approved and 5 suppliers terminated. 580 significant suppliers represent 80% of direct material expense (2024: 479), and 90% fully replied to the ESG self-assessment questionnaire (2024: 77%). Risk distribution: low 32.4%, medium 55.6%, high 11.9%, extreme 0.17% - not comparable with 2024 because "The rating calculation method was updated in 2025 to take into account both country risk and ESG risks".

High-risk geographies named (page 78): Mexico (2 suppliers), India (2), Turkey (3), Colombia (1), identified using the World Bank Worldwide Governance Indicators, the Minderoo Foundation Global Slavery Index and Save the Children's End of Childhood Index.

A limitation the company states (page 80): "Alimak Group acknowledges that it currently lacks direct engagement mechanisms with value chain workers and their legitimate representatives. The whistleblowing channel is accessible but there is limited visibility into how workers' perspectives are integrated into decision-making processes."

Targets related to value chain workers

Reference: page 80.

Two time-bound targets are disclosed (page 80):

1. "Alimak Group's current target, set by the Board, is to ensure that, from 2026 onwards, all of our suppliers (across manufacturing, distribution and services sites), who represent around 80% of the Group's direct material spend, have conducted ESG self-assessments covering environmental, social and governance aspects. Compared to our base year 2025 when the scope of the suppliers' ESG self-assessment only included Alimak Group manufacturing sites, we successfully involved suppliers that covered approximately 81% of our direct material spend."
2. "We have also set a target for 2026 and onwards that suppliers corresponding to at least 90% of the Group's direct material spent should sign our Supplier Code of Conduct. Our current ESG self-assessment process, which is carried out through the Worldfavor platform, will include this new requirement."

Both are coverage targets rather than outcome targets for working conditions. Progress "is continuously monitored and reported annually in the Group's Sustainability Report", and the Group "continue[s] measuring annually and follow[s] up on the number of suppliers audited on social or environmental issues, including the number of suppliers that are approved, conditionally approved, or rejected" (page 80).

Worker involvement in setting them (page 80): "Workers and their representatives within Alimak Group's value chain are not actively involved in defining the targets aimed at managing material impacts, risks, and opportunities. However, the outcomes of audits and the actions taken to address identified impacts, risks and opportunities affecting workers in the value chain are integrated into the decision-making process for setting related targets."

S2-4 records that the Group is "developing time-bound, outcome-oriented targets to better measure progress in addressing material impacts, risks and opportunities" (page 80).

Policies related to consumers and end-users

Reference: page 83, with the policy matrix on page 53.

The governing instrument is the Code of Conduct, owned by the CFO, connected to "All IROs under S1 (Excluding H&S), All IROs under S4 and G1", and "Publicly accessible to all via our website" (page 53). It "is based on the UN Global Compact Ten Principles and aligns with OECD Guidelines for Multinational Enterprises, ILO Core Conventions, and the UN Guiding Principles on Business and Human Rights".

"Alimak Group is committed to meeting and exceeding customer expectations by ensuring that our products, solutions, and services are designed to fulfil the highest standards of quality, functionality, safety, and environmental responsibility. These commitments, as well as human rights, are embedded in our Code of Conduct policy, which guides our approach to product development and service delivery towards all consumers and end-users installing, using or servicing our products. We prioritise product safety and quality throughout the entire lifecycle - from design and manufacturing to installation, maintenance, and service" (page 83).

Standards participation as a policy instrument (page 83): "To advance product safety, quality, and innovation, Alimak Group actively participates in standard committees at both national and international levels who represent the voice of consumers and end-users. This involvement enables us to contribute to the definition and continuous improvement of relevant product standards worldwide."

No consumer-specific policy exists beyond the Code of Conduct, and the Group states under S4-2 that as a B2B business it "does not maintain a dedicated policy for direct engagement with consumers and end-users" (page 83).

Engaging with consumers and end-users about impacts

Reference: page 83.

"Alimak Group operates primarily as a B2B company and, as such, does not maintain a dedicated policy for direct engagement with consumers and end-users. Instead, the company ensures that its products and solutions are certified to applicable international standards, which have been developed in collaboration with relevant stakeholders to guarantee safety and effective use" (page 83).

"The primary channel to end-users is through customers. To gather insights and drive continuous improvement, Alimak Group conducts annual surveys to learn from customers' experiences and opinions regarding their interactions with the company and its products and services. Customers are also engaged directly in feedback discussions, which help identify areas for enhancement, particularly in relation to product safety. The feedback collected is systematically integrated into product development roadmaps" (page 83).

Accountability and effectiveness measure: "The EVPs of each respective division are responsible for the effectiveness of this process, and the outcome is measured in terms of the market success of the respective product line" (page 83).

Limitations the company states (page 83): "Although there is no specialised process for people with disabilities, Alimak Group's products inherently improve access to construction and industrial sites, supporting inclusivity as part of their design. The company does not currently operate direct consumer-facing grievance mechanisms; instead, it relies on customer relationships to channel feedback from end-users."

One internal shortcut is noted: "the Group's own rental business serves as an internal customer, helping to shorten feedback loops, especially for products in the construction sector" (page 83).

Remediation and channels for consumers and end-users to raise concerns

Reference: page 83.

"Alimak Group designs its products with safety as a top priority, resulting in a very low incidence of accidents involving end-users. In the rare event that an accident does occur, a dedicated team of experts is immediately assigned to investigate the root cause and, if necessary, implement corrective actions. These actions may include modifications to product design, updates to manuals, or other relevant measures to prevent similar incidents in the future" (page 83).

Channel (page 83): "To ensure that consumers and end-users have a secure and confidential way to raise concerns, Alimak Group provides access to an external whistleblower channel. This channel is available to all stakeholders and enables end-users to report potential issues or breaches anonymously. All reports are handled confidentially and reviewed by authorised personnel, ensuring that concerns are addressed promptly and appropriately and to protect individuals from retaliation if used." The channel is the WhistleB service described under G1-1 on page 86, available via the external website in 16 languages.

Effectiveness (page 83): "Alimak Group considers these processes to be effective and demonstrates our commitment to continuous improvement in product safety and responsiveness to stakeholder concerns, supporting both regulatory compliance and customer trust." No count of reports, complaints or remediations is given, and the Group states under S4-2 that it "does not currently operate direct consumer-facing grievance mechanisms" beyond the whistleblower channel, relying instead on customer relationships to channel end-user feedback (page 83).

Taking action on material impacts on consumers and end-users

Reference: page 83.

"Alimak Group places the highest priority on safety throughout its entire value chain, encompassing design, manufacturing, installation, operation, and service. The overarching objective is to ensure that machines cannot be operated incorrectly, and that any unsafe actions automatically halt operation. Safety considerations are embedded in every stage of product development, with systematic risk analyses guiding each design decision" (page 83).

Actions (page 83):

• "All products are certified to relevant standards", with participation in national and international standards committees.
• "Alimak Group also provides comprehensive product safety training and, in certain cases, certifies users based on completed training."
• "To support safe and informed use, machines are equipped with QR codes and other digital tools that make product information readily accessible."
• "Proactive risk management is further enhanced through online monitoring of machines, enabling rapid identification and remediation of negative impacts."
• "Recently, digital service logs and daily checks have been implemented because of actual incidents to ensure ongoing safety and operational reliability."

Tracking and outcome (page 83): "All issues are tracked via a Non Compliance Reporting system, and the effectiveness of actions taken is qualitatively monitored via customer dialogues. No issues related to human rights have ever been reported related to consumers and end-users."

The disclosure remains qualitative: no number of product safety incidents, recalls, non-compliance reports or training participants is given, and effectiveness is monitored "qualitatively" by the Group's own description.

Targets related to consumers and end-users

Reference: page 83.

Alimak Group discloses that it has set no targets and plans none. "Given Alimak Group's business model, no specific quantitative targets or metrics for consumers and end-users have been established or are planned. Instead, the Group's commitment to safety, functionality, and efficiency is embedded within its overarching strategy to deliver certified products and solutions that enable vertical transport of people and materials, and support safe, productive, and efficient work at heights" (page 83).

This stands against three material S4 IROs (page 82): a "Potential negative short-term impact on end-users working at height in the event of breach of safety", where "Safety problems or incidents could potentially lead to serious end-user bodily injury or death"; a "Short-term risk of regulatory fines, prosecution and loss of licence to operate in the event of lack of end-user safety"; and an "Actual positive impact on industrial, wind and construction workers in the downstream value chain by providing safe and easy vertical access to working at heights".

In the absence of targets, effectiveness is tracked through the routes described under S4-2 and S4-4: annual customer surveys, direct feedback discussions, the Non Compliance Reporting system, and online machine monitoring, with the outcome "measured in terms of the market success of the respective product line" (page 83). No numerical threshold, deadline or baseline attaches to any of these.

Business conduct policies and corporate culture

Reference: page 86, with the policy matrix on page 53.

The framework (page 86): the Code of Conduct with accompanying Ethical Business Guidelines; the Whistleblower Procedure including the Whistleblower Guidelines and the WhistleB reporting tool; and the Group's Vision, Strategy House and Core Values. The Group Authorisation Policy, Corporate Governance Policy and Internal Control Framework are named as further components.

Training (page 86): "The Code of Conduct is available in nine languages, and e-learning is mandatory for all new hires and is repeated for all staff every two years. Completion is tracked via the company's Learning Management System (LMS). Dilemma-based training is offered annually, particularly for high-risk roles in procurement, sales, and management, to strengthen ethical decision-making and integrity."

Monitoring (page 86): "Compliance with the Group Policies and Guidelines are monitored through the annual board meetings held in each operating subsidiary and through activities carried out within the internal control framework. Areas for improvement and issues discussed during board meetings are recorded as actions in the meeting minutes. These actions are then monitored to ensure that necessary corrections are made."

Whistleblower protection (page 86): the Whistleblower Guideline "has been established to comply with EU Directive 2019/1937 as well as its implementation within Swedish legislation". Reporting can be open, to a manager or People & Culture, or anonymous through WhistleB, which "ensures anonymity by using encryption and removing metadata". The whistleblower team is "the Head of Group Tax & Legal, the Chief People & Culture Officer, the Group CFO, and the Chair of the Audit Committee". Information about the channel "is displayed at all company sites".

Employee surveys are used as a culture control: they "serve as a valuable tool for pinpointing areas within the organisation where business practices may not align with our corporate culture" (page 86).

Prevention and detection of corruption and bribery

Reference: pages 86-87.

"Alimak Group has established a comprehensive system to prevent, detect, investigate, and respond to allegations or incidents related to corruption and bribery. The foundation of this system is the Group's Code of Conduct and Ethical Business Guidelines... Additionally, the Group Authorisation Policy, the Corporate Governance Policy, and the Internal Control Framework constitute essential components of the overall governance framework" (page 86).

Training coverage (page 87):

Training reached 63% of the workforce in 2025 against 12% in 2024. Classroom training "was targeted at functions at risk, i.e. employees working in sourcing, sales and management roles", and its hours are "Based on the assumption that each workshop lasted for one hour" (page 87).

"All employees are required to complete Code of Conduct training, which consists of e-learning modules and classroom-based ethical dilemma training. The latter is specifically designed for employees who face greater corruption risks, such as members of the Group Leadership Team, senior managers, and employees in sales and sourcing positions... new employees completing training at the start of their employment and all staff retaking it every two years" (pages 86-87).

Independence of investigation (page 87): the Whistleblower Team "ensures that investigations are conducted impartially and that individuals subject to allegations are not involved in the process. A whistleblower update is a standing item on the agenda of each Audit Committee meeting, and the Chair of the Audit Committee provides regular updates to the Board of Directors."

Planned change (page 87): "In 2025, the Code of Coduct training was sent out to all employees, and the dilemma discussions were promoted during sustainability week. In 2026, we plan to convert the Ethical Business Guidelines into an Anti-Bribery and Corruption Policy."

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.

Alimak Group discloses no measurable outcome-oriented business conduct target. The G1 chapter (pages 85-87) sets out policies, training and incident metrics but attaches no threshold, deadline or baseline to any of them, and the ESRS index carries no targets row for G1 (page 91).

Consistent with MDR-T's other limb, effectiveness is tracked in the absence of a target:

• Training completion is measured: "Completion is tracked via the company's Learning Management System (LMS)" and "Compliance with Code of Conduct training requirements is tracked through the company's Learning Management System, with new employees completing training at the start of their employment and all staff retaking it every two years" (pages 86-87). The resulting metrics move materially - 1,920 employees trained in 2025 against 358 in 2024, out of 3,059 (page 87).
• Policy compliance is monitored through governance: "Compliance with the Group Policies and Guidelines are monitored through the annual board meetings held in each operating subsidiary and through activities carried out within the internal control framework. Areas for improvement and issues discussed during board meetings are recorded as actions in the meeting minutes. These actions are then monitored to ensure that necessary corrections are made" (page 86).
• Whistleblowing is reviewed at Board level: "A whistleblower update is a standing item on the agenda of each Audit Committee meeting, and the Chair of the Audit Committee provides regular updates to the Board of Directors" (page 87).
• Culture is surveyed: employee surveys "serve as a valuable tool for pinpointing areas within the organisation where business practices may not align with our corporate culture" (page 86).

One forward commitment is stated without being framed as a target: "In 2026, we plan to convert the Ethical Business Guidelines into an Anti-Bribery and Corruption Policy" (page 87). The only quantified business-conduct-adjacent target in the report sits in the incentive scheme and is climate-related, not conduct-related (page 48).

Confirmed incidents of corruption or bribery

Reference: page 87.

A complete nil return across both years. The disclosure is a full answer to the requirement rather than an omission: every line of the table is populated, with no "not reported" or dash entries.

The fines and standards datapoints are cross-referenced to page 87 in the list of datapoints deriving from other EU legislation (page 94).

Context for the return sits in the material risk it relates to - a "Short-term risk of reputational damage and financial damage (fines) if Group employees or third-party sales channels commit acts of bribery or corruption", where "Risk of corruption and bribery exists in many countries where the Group operates" and the Group is "present in more than 120 countries, either through its own subsidiaries or through third-party sales channels" (pages 85-86). The 2023 country risk assessment underpinning the IRO rating used turnover, whether the Group operates through its own subsidiary or a third-party sales channel, and Transparency International's Corruption Index (page 86).