ALK-Abelló

Governance roles

Reference: page 39. Composition and diversity datapoints (paragraphs 21 a-e, 23 a-b) are incorporated by reference to Corporate matters (pages 30, 33-34).

ALK's sustainability governance runs through the Board of Directors, "Overall responsible for ALK's sustainability strategy and targets"; the Executive Leadership Team (ELT), which "Approve all sustainability related policies and strategy"; and a Sustainability Committee that oversees legal reporting requirements and "Make recommendations to Executive Leadership Team on matters with strategic impact on the global organisation" (page 39).

Three committees carry defined roles (page 39):

• Audit Committee - "Oversee sustainability disclosures, processes, controls and assurance"
• Remuneration Committee - "Oversee sustainability related remuneration"
• Risk Committee, chaired by the CFO, which "reports ERM risks to the Board of Directors"

Delivery sits with the Sustainability department, the Corporate Finance department (accounting policies, internal controls, data processes) and corporate functions.

Board composition (page 30): 11 non-executive members, seven shareholder-elected and four employee-elected. Of the shareholder-elected members "five are men (71%)", which ALK states "is not considered an equal gender representation as defined by the Gender Balance Act". The Board of Management has three members, one (33%) female.

Information provided to and matters addressed by the administrative bodies

Reference: pages 39, 42-43.

"Material impacts, risks and opportunities (IROs) are managed by the relevant corporate functions and overseen by the Sustainability Committee. The Sustainability department submits quarterly reports to the Committee, which oversees the setting of targets and monitors progress and effectiveness of due diligence, policies, actions, metrics and targets" (page 39).

The escalation route is stated explicitly: "The Sustainability Committee Chair regularly updates the Executive Leadership Team, while the Audit Committee oversees progress on sustainability reporting on a quarterly basis. The Board of Directors is informed on material IROs as a part of the strategy updates" (page 39). Material risks reach the Board separately through the Enterprise Risk Management process via the CFO-chaired Risk Committee.

The 2025 double materiality assessment result "was presented and approved by the ELT, the Audit Committee and the Board of Directors" (page 42). The Sustainability Committee and the Audit Committee also "receive an annual update on potential critical issues related to risk management and internal controls through the management letter from the Independent Auditor" (page 40).

ALK does not list the specific sustainability matters addressed by the bodies during the year, or when each was addressed.

Integration of sustainability performance in incentive schemes

Reference: page 45; incorporated by reference to Corporate matters, "Remuneration" (pages 30-31).

"In 2025, the KPIs for the STI included a sustainability target on CO2 emission reduction, aligned with ALK's science-based target on own emissions, which accounts for 10% of pay to the CEO and 5% for the remainder of the Board of Management" (page 31).

The climate chapter describes the same link from the other side: "ALK's commitment to emission reduction is further reinforced by sustainability-related incentives included in the remuneration schemes for the Executive Leadership Team, ensuring that priority is given to decarbonisation" (page 45).

Board of Management pay combines fixed elements with short-term (cash bonus) and long-term incentive plans that "reward the attainment of pre-defined financial and non-financial targets linked to the company's strategy, as approved annually by the Board of Directors" (page 31). Total remuneration excluding extraordinary elements was DKK 43.4 million (2024: DKK 41.2 million), of which short-term incentives were DKK 14.7 million and long-term incentive grant value DKK 7.4 million (page 31).

No sustainability-linked element is disclosed for the Board of Directors, whose members receive fixed base and committee fees only (page 31).

Statement on due diligence

Reference: pages 40, 78.

"As an integral part of its core processes, ALK performs due diligence activities relating to people and the environment" (page 40). The mapping sits in the appendix "Core elements of due diligence" (page 78), which "maps the core elements of ALK's due diligence process, cross-referencing the impacts on people and the environment with the relevant disclosures in the sustainability statement".

The five core elements and the sections given against each (page 78):

• Embedding due diligence in governance, strategy and business model - Sustainability governance (39-40), Stakeholder engagement (41), Materiality assessment process (42)
• Engaging with affected stakeholders in all key steps - Sustainability governance (39-40), Materiality assessment process (42), Material impacts, risks and opportunities (43), and the environmental (44-58), social (59-71) and governance (72-76) sections
• Identifying and assessing adverse impacts - Materiality assessment process (42), Material impacts, risks and opportunities (43), and the three topical sections
• Taking actions to address those adverse impacts - the three topical sections
• Tracking effectiveness of these efforts and communicating - the three topical sections

The statement is also flagged in the list of datapoints deriving from other EU legislation, at ESRS 2 paragraph 30 (page 81).

Risk management and internal controls over sustainability reporting

Reference: page 40.

"The Sustainability department is responsible for overseeing the DMA process, advising on data collection and preparing the sustainability statement. The Corporate Finance department collaborates closely on numeric data collection and gathers data quarterly for ongoing progress tracking and verification. All data complies with the principles outlined by the ESRS" (page 40).

The reporting risks are named plainly: "Key challenges in providing unified sustainability disclosures across different business units and locations include human error and data misalignment." The stated mitigations are automated data transfers and reporting processes "being introduced", internal controls and standard operating procedures "established for critical metrics", and "a four-eye principle is systematically applied" (page 40).

"The Sustainability Committee and the Audit Committee receive an annual update on potential critical issues related to risk management and internal controls through the management letter from the Independent Auditor" (page 40).

No scoring of these risks by likelihood or magnitude, no description of the control activities themselves, and no account of how findings are integrated into internal functions and processes is given beyond the above.

Strategy, business model and value chain

Reference: page 41; incorporated by reference to Introduction "Business model" (page 8) and "Sustainability highlights" (page 10), and Financial performance "Sales and market trends" (page 20). Headcount is cross-referenced to note 2.4 (page 96).

"ALK's activities cover the entire value chain of developing, sourcing, producing, and marketing a diversified portfolio of products for diagnosing and treating allergies, allergic asthma, and acute anaphylactic reactions. Natural allergenic source materials are the basis for manufacturing active pharmaceutical ingredients in ALK's core allergy immunotherapy (AIT) products" (page 8).

The value chain is drawn in four stages under a band labelled "Safety, quality, and business ethics compliance": research and development; externally sourced products; manufacturing (cultivate allergenic source materials, standardise allergen extracts, production at 9 sites); and distribution and sales (page 8).

Scale in 2025 (page 8): approximately 2,700 employees, around 420 million AIT doses produced (excluding SCIT bulk extracts in the USA), presence in 44 markets, roughly 48% global market share in AIT, and 500,000 additional patients treated, bringing the total to 3.1 million.

Revenue by ESRS sector (SBM-1 paragraph 48(b) and (c)) is omitted under the phase-in provisions (page 77).

Interests and views of stakeholders

Reference: pages 41-42.

"Active engagement with stakeholders is a fundamental aspect of ALK's Allergy+ strategy. The interactions shape the understanding of material issues and support the sustainability initiatives" (page 41). Internal engagement runs across finance, legal, environment, health and safety, procurement, people and organisation, research and development, commercial operations and the ELT. "The Board of Directors and ELT are informed about the views and interests of affected stakeholders through the sustainability strategy updates" (page 41).

Six stakeholder groups are tabulated with how engagement is organised, its purpose, example outcomes and the Allergy+ pillar it informs (page 41): employees (engagement survey, employee-elected Board members, workers' councils, development dialogues, sounding board); consumers and general public; healthcare professionals; suppliers and contract manufacturers; investors and shareholders; and authorities.

Within the materiality assessment itself the engagement was indirect: "ALK engaged with relevant internal subject matter experts through DMA workshops, to review, assess, refine and consolidate the IROs. The views and perspectives of affected stakeholders are represented by proxy through the knowledge of ALK's internal subject matter experts" (page 42).

Material impacts, risks and opportunities

Reference: page 43, with the IRO tables at the head of each topical chapter (pages 45, 50, 51, 53, 54, 60, 61, 63, 65, 67, 72, 75).

"Of 122 identified IROs, 21 were deemed material, comprising 17 negative impacts, 1 positive impact, 1 risk and 2 opportunities" (page 43).

"ALK's 2025 DMA revealed no changes in materiality at the topic level compared to the previous reporting year. However, Own workforce was moved from double material to being impact material, due to the fact that the risk related to 'employee attraction and retention' has decreased in 2025" (page 43).

Changes against 2024 (page 43): new material IROs were added for S1 "Inclusive culture" and S4 "Affordability" and "Innovation"; "Emissions from own operations" now includes refrigerants in E1; and the impact of pharmaceutical standards on circularity was folded into the single-use materials IRO in E5. Descriptions were broadened for Biodiversity, Workers in the value chain, "Patients safety" (S4) and "Potential bribery of healthcare professionals" (G1).

"All material IROs from ALK's own operations cover all production sites, with the exception of water use in water-scarce regions that applies only to ALK's production site in Madrid (Spain)" (page 43). Affected communities (S3) is the only topical standard placed in the non-material quadrant. Anticipated financial effects (SBM-3 paragraph 48(e)) are omitted under the phase-in provisions (page 77).

Processes to identify and assess material impacts, risks and opportunities

Reference: page 42.

"In 2025, ALK reviewed its double materiality assessment (DMA), conducted in accordance with the double materiality criteria outlined in ESRS 1 and the implementation guidance from EFRAG. This review followed the same process as in 2024" (page 42).

Four steps are described (page 42): identifying sustainability matters (2024 matters reviewed plus a peer analysis for gaps; "ALK's activities are screened at site level"); stakeholder engagement through DMA workshops with internal subject matter experts; approval, where "Workshop results were captured using a scoring tool" with "detailed justifications", validated by the experts and then "presented and approved by the ELT, the Audit Committee and the Board of Directors"; and annual review.

Scoring is "inspired by ALK's Enterprise Risk Management (ERM) framework". Medium-term is 1-3 years and long-term beyond 3 years, and "all IROs in the DMA are evaluated at a gross level". Impact materiality is assessed on severity (scale, scope and, for negative impacts, irremediability) and likelihood, with severity taking precedence for potential negative human rights impacts; financial materiality on magnitude, likelihood and nature of the financial effect (page 42).

Climate and water IROs rest on WWF risk filters rather than scenario analysis (page 42).

Disclosure requirements covered by the sustainability statement

Reference: pages 43, 78-82.

ALK prints a full content index of ESRS disclosure requirements (pages 78-80), listing ESRS 2 and the topical requirements it covers against page references, followed by a list of datapoints that derive from other EU legislation (pages 81-82) marking each as a page number, "Not material" or "Phase-in".

"The list of material disclosure requirements and datapoints was based on the ESRS issued by the European Commission July 2023 and the revised Appendix C to ESRS 1" (page 43).

Phase-in provisions are declared twice. Page 43: "The phase-in provisions have been applied for Biodiversity E4 as well as the numeric data for Own Workforce S1." Page 77 lists the phased-in requirements individually: ESRS 2 SBM-1 paragraph 48(b),(c) revenue by ESRS sectors; ESRS 2 SBM-3 paragraph 48(e) anticipated financial effects; E1-9; E4 as a whole; S1-7; S1-13 paragraph 83(b) average training time; and S1-14 paragraphs 88(d) and (e) work-related ill-health and lost days.

The index is the authority used for this review. Requirements that carry no page reference in it - E1-7, E1-8, E2-4, E2-6, E3-5, E5-6, S1-8, S1-10, S1-11, S1-12, S1-15, the five S3 requirements, G1-2, G1-5 and G1-6 - are not claimed as reported.

Transition plan for climate change mitigation

Reference: pages 44-46; CapEx and OpEx incorporated by reference to the income statement and note 3.2 (pages 87, 103).

"ALK recognises the need to address climate change in alignment with the goals of the Paris Agreement and has established greenhouse gas emission reduction targets, approved by the Science Based Targets initiative (SBTi) and consistent with a 1.5˚ pathway. To meet these targets, ALK has developed a transition plan outlining decarbonisation levers through 2030. The plan factors in projected company growth and locked-in emissions linked to long-term energy-intensive assets" (page 44).

"Focusing on emissions from ALK's own operations, the transition plan is embedded within the company's overall strategy, supported by annual business and financial planning processes and approved annually by the Investment Portfolio and Sustainability Committees" (page 45).

"Key actions require investments, such as decarbonising boilers across production sites, a taxonomy-eligible activity. As these measures will be implemented over time, the reduction pathway is not expected to be linear, but will deliver stepwise reduction" (page 45).

ALK "is not excluded from the EU Paris-aligned benchmarks" (page 45). The plan is scoped to own operations; scope 3 is addressed through a supplier science-based-target commitment rather than an absolute reduction target (page 46). No net-zero target year is disclosed.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the climate double materiality section, where this content is disclosed in the FY2025 report (page 42). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

No scenario analysis underpins the 2025 assessment. "ALK is in the process of conducting an in-depth climate-related scenario analysis for all sites to support the identification and assessment of physical and transition risks and opportunities across the short, medium, and long term. As the in-depth climate risk assessment is still underway, current material impacts, risks and opportunities (IROs) related to climate change are based solely on the risk assessment using the World Wildlife Fund (WWF) risk filters, which did not identify any material climate-related physical or transition risks" (page 42).

Because no scenario analysis was used, ESRS E1 paragraph 17 does not apply: no high-emission physical scenario, no 1.5°C-aligned transition scenario, no temperature projection and no assumption set is disclosed, and their absence is not a gap.

The physical/transition classification is implicit rather than stated, and the E1 IRO table carries two actual negative impacts and one opportunity, with no climate risk row (page 45). A separate "climate risk assessment has been initiated in 2025" for EU Taxonomy purposes (page 56).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the E1 chapter, where this content is disclosed in the FY2025 report (pages 42-45). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

ALK discloses no climate resilience analysis as defined by the ESRS. The statement contains no results of a resilience assessment, no statement of the areas of uncertainty in one, and no description of the capacity to adjust or adapt strategy and business model over the short, medium and long term.

What it does say is that the underlying analysis is still being built. The in-depth climate-related scenario analysis for all sites is "still underway", and the 2025 climate IROs rest solely on WWF risk filters, "which did not identify any material climate-related physical or transition risks" (page 42). No climate risk appears in the E1 IRO table, which carries two actual negative impacts and one opportunity (page 45).

Two forward-looking elements sit closest to resilience: the transition plan "factors in projected company growth and locked-in emissions linked to long-term energy-intensive assets" (page 44), and "A climate risk assessment has been initiated in 2025" for EU Taxonomy purposes (page 56). A planned "comprehensive biodiversity resilience analysis" (page 53) is a nature assessment, not a climate one.

Policies related to climate change mitigation and adaptation

Reference: page 45.

"ALK's transition plan is supported by a framework of policies focusing on company fleet (part of scope 1) and business travels (scope 3, category 6). In 2025, an update of local company car policies was initiated across European countries, introducing requirements for either electric-only or electric and hybrid vehicles" (page 45).

"Regarding scope 3 emissions, the global travel policy was also updated. The purpose of the policy is to ensure that all employees have a clear and consistent understanding of general rules and procedures for business travel. It applies to all employees as well as any external party travelling at ALK's expense, requiring alternatives to business travel to be considered first. Oversight rests with the Executive Leadership Team (ELT)" (page 45).

The disclosed policy scope is narrow relative to the material impacts. Company fleet and business travel account for 1,219 and 1,861 tCO2e of a 71,662 tCO2e market-based total (page 48). No climate policy is disclosed covering energy procurement, production emissions, purchased goods and services, or climate change adaptation.

Actions and resources in relation to climate change policies

Reference: pages 45-46; CapEx and OpEx incorporated by reference to note 3.2 (pages 87, 103).

Four decarbonisation levers carry 2025 actions (pages 45-46):

1. Decarbonising boilers. "In 2025, the gas boiler at the French production site was replaced with heat pumps, with full operational impact in 2026. The remaining boiler decarbonisation initiatives are currently planned for full implementation by 2030." ALK "allocated DKK 5 million in CapEx" to the French project; "The ability to implement the action does not depend on specific preconditions."
2. Electrifying the company fleet, focused first on Europe; "Some countries now only allow electrical vehicles, while others are waiting for infrastructure improvements."
3. Substituting refrigerant chemicals in coolers, on a "substitution timeline based on legal requirements, equipment lifecycle and costs", supported by a cross-departmental programme.
4. Transitioning towards renewable energy. Third-party audited Renewable Energy Certificates cover "100% of ALK's electricity consumption at production sites where direct renewable energy sourcing is not possible"; 2025 OpEx DKK 0.8 million.

Value chain actions in 2025: a vendor remediation exercise and reclassification of the supplier portfolio for a more accurate scope 3 calculation, a global travel management platform, and wider supplier screening on carbon-reduction targets (page 46).

Targets related to climate change mitigation and adaptation

Reference: pages 46-47.

Two targets are set (page 46). ALK will "reduce its absolute carbon emissions by 42% between 2022 and 2030 in its own operations (market-based scope 1 and scope 2)" and "have 80% of its emissions from suppliers with science-based targets by 2028 (scope 3)".

"The targets were approved by the Science Based Targets initiative in January 2024 and align with the global 1.5°C trajectory" (page 46).

Baseline and boundary: "In 2022, ALK's scope 1 and 2 (market-based) baseline accounted for 5,492 tCO2e, with scope 1 representing 90%. The boundaries for this target exclude ALK's sales offices, which account for less than 5% of its total emissions" (page 46). The 2030 endpoint is 3,185 tCO2e, and the roadmap chart attributes the movement to business growth offset by the four decarbonisation levers.

Progress (page 47): scope 1+2 market-based 4,883 tCO2e, -11% against the 2022 baseline (2024: -2%); suppliers with science-based targets 50% of scope 3 emissions (2024: 35%, restated from 37%) against 80% by 2028.

No adaptation target, no net-zero target year and no absolute scope 3 reduction target are disclosed.

Energy consumption and mix

Reference: page 49; accounting policy page 57.

"ALK's activities are in a high climate impact sector. Energy intensity is therefore calculated on the total revenue" (page 49).

"In 2025, ALK reduced its total energy consumption, while delivering significant business growth... Natural gas consumption decreased to 13,816 MWh (2024: 14,524) following the electrification of the boiler in France" (page 49).

Fuel consumption from renewable sources is nil in both years; the renewable share comes entirely from purchased electricity and heat. Sales offices are excluded from energy reporting "due to the low materiality of their environmental footprint" (page 57).

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 47-48; accounting policies pages 57-58.

Scope 3 covers categories 1-7, 9 and 12; the largest are purchased goods and services 47,164 tCO2e, employee commuting 5,491 and downstream transportation and distribution 3,593 (page 48).

"The decommission of refrigerant equipment caused an unforeseen leak, increasing refrigerants emissions to 509 tCO2e (2024: 217)" (page 47).

Data quality is disclosed: unbundled energy attribute claims 88%, and scope 3 calculated using primary data 16% (2024: 17%). 2024 scope 3 categories 1-4 and 9 were restated after the supplier portfolio reclassification (total previously 74,506 tCO2e); 2022 scope 3 was not restated and "are not fully comparable" (page 48).

Policies related to pollution

Reference: page 50.

ALK discloses that it has no pollution policy, and gives its reason. "ALK ensures compliance with REACH and local regulations for responsible use and handling of chemicals in production. Relevant actions and resources are continuously evaluated and allocated at the operational level to maintain high environmental and safety standards. Given the local compliance framework and established operational controls, ALK has not identified a need for a centralised global policy on management of substances of concern" (page 50).

The single material E2 IRO is "Use of substances of concern", an actual negative impact in own operations across short, medium and long term: "All chemicals used by ALK are regulated under the Registration, Evaluation, Authorisation, and Restriction of Chemicals (REACH) Regulation. Some chemicals are classified as Substances of Concern (SoCs) or Substances of Very High Concern (SVHCs) due to their potential environmental and human health impacts. Improper handling, application, transport, or disposal can have adverse environmental effects" (page 50).

Air, water and soil pollution, pollution of living organisms and microplastics are not among ALK's material E2 sub-topics, and no policy is disclosed for them.

Actions and resources related to pollution

Reference: page 50.

"ALK continuously evaluates opportunities to reduce or substitute SoCs or SVHCs. Substitution is sometimes limited by pharmaceutical regulatory requirements, as specific chemical properties are necessary to ensure product quality and compliance with pharmaceutical standards" (page 50).

"Initiatives are also directed at ensuring safe handling, storage and use of regulated chemicals on all production sites, regularly updating procedures to reflect evolving regulations. In 2025, ALK successfully met all requirements and inspections from local environmental authorities. Building on efforts started in 2024, ALK further enhanced its mapping and reporting of SoCs and SVHCs" (page 50).

The reported outcome: "As a result of ALK's continued focus on SoCs and SVHCs, the amount of SoCs procured decreased to 3.0 tonnes (2024: 5.0), with SVHCs accounting for 0.6 tonnes (2024: 0.9)" (page 50).

No resources are quantified against these actions. No CapEx, OpEx or headcount is attached, and the actions are described as evaluated and allocated "at the operational level" rather than through a central programme with a stated scope or time horizon.

Targets related to pollution

Reference: page 50.

No pollution target is set, and ALK states why. "ALK remains flexible and responsive to changes in regulatory requirements, ensuring continued compliance and a commitment to reducing environmental impact as new phase-outs and restrictions are adopted. Due to this, ALK has not had the need to set specific reduction targets" (page 50).

Under MDR-T the alternative limb is a description of how effectiveness is tracked in the absence of a target. ALK's tracking is the annual substance volume itself, disclosed against a prior year and moving in the intended direction - 3.0 tonnes of substances of concern procured in 2025 against 5.0 in 2024, and 0.6 tonnes of substances of very high concern against 0.9 - together with the regulatory inspection outcome: "In 2025, ALK successfully met all requirements and inspections from local environmental authorities" (page 50).

No target year, baseline or measurable outcome-oriented objective is disclosed for pollution.

Substances of concern and substances of very high concern

Reference: page 50.

ESRS E2 paragraph 34 asks for two things joined by "and": the total amounts of substances of concern generated, used or procured, and the total amounts leaving facilities as emissions, as products, or as part of products or services, split into main hazard classes. Paragraph 35 asks for substances of very high concern to be presented separately.

ALK answers the first limb and separates SVHCs; it does not answer the second. Amounts procured are given for both categories, but no outflow figure is reported and neither category is split into main hazard classes.

Context for the trend is disclosed: "Building on efforts started in 2024, ALK further enhanced its mapping and reporting of SoCs and SVHCs", and substitution "is sometimes limited by pharmaceutical regulatory requirements, as specific chemical properties are necessary to ensure product quality" (page 50). The material impact sits in ALK's own operations (page 50), so the ESRS 1 value chain relief does not reach it.

Policies related to water and marine resources

Reference: page 51.

ALK discloses that it has no water policy, and gives its reason. "ALK monitors water use across its production facilities to ensure compliance with local regulations and has therefore not had the need for a formal water management policy, neither globally nor for water-scarce areas like Madrid (Spain)" (page 51).

Two material E3 IROs are identified (page 51). "Water consumption in production facilities", an actual negative impact in own operations: "The consumption of water in production facilities can contribute to local water scarcity, impacting availability and increasing water costs for surrounding communities. Reduced water availability may also impact local ecosystems and agriculture and increase wildfire risks." And "Use of water in water-scarce regions", a potential negative impact: "ALK's Madrid (Spain) production site operates in a high-water stress area. Climate change and periodic droughts could further constrain water resources, potentially affecting the local population."

Marine resources are not addressed. The datapoint list marks "Sustainable oceans and seas" as "Not material" (page 81).

Actions and resources related to water and marine resources

Reference: pages 51-52.

"Water management is an integral part of the role of the Environmental, Health and Safety department and water meters have been installed at all production sites to monitor usage. In 2025, the purified water system was upgraded at one production site, reducing water consumption" (page 51).

For the site in the high-stress basin: "At ALK's Madrid production site, located in the water-scarce Tagus river basin, ALK has developed a 4-year water management plan, which focuses on employee training, promoting best practice via the Good Practice Manual, improving leak reporting, and continuing the rollout of water saving devices" (page 52).

A constraint on circular water use is disclosed: "Strict pharmaceutical regulations on product quality and manufacturing equipment cleanliness limit the potential for water reuse and recycling, as this would require advanced water treatment and regeneration systems. Going forward, ALK plans to explore opportunities such as new technologies and process optimisations to further enhance sustainable water management" (page 52).

No monetary or human resources are quantified against the actions.

Targets related to water and marine resources

Reference: page 52.

No water target is set. "ALK has not set global targets for reducing water consumption beyond local legal requirements" (page 52).

The nearest thing to a tracked commitment is the four-year water management plan for the Madrid site in the Tagus river basin, described by its activities - employee training, best practice through the Good Practice Manual, improved leak reporting and continued rollout of water saving devices - rather than by a quantified objective (page 52).

Effectiveness is therefore visible only through the metrics against the prior year: total water consumption fell to 181,102 m3 (2024: 405,306) and domestic water use to 80,625 m3 (2024: 92,533) after the purified water system upgrade, while consumption in areas of high water stress was broadly flat at 11,716 m3 (2024: 11,495) (page 52). ALK attributes most of the fall to crop rotation rather than to management action: "The crop rotations meant that fewer fields required irrigation" (page 52).

Water consumption

Reference: page 52; accounting policy page 58.

"In 2025, irrigation of allergenic source materials on ALK leased and owned farmland accounted for 55% of total water use (2024: 77%). The crop rotations meant that fewer fields required irrigation, reducing water used for irrigation to 100,477 m3 (2024: 312,773 m3)" (page 52).

"The remaining water consumption covers water for domestic use (production, drinking, sanitary) and decreased to 80,625 m3 (2024: 92,533), due to the upgrade of a purified water system. 15% of the domestic water use (2024: 12%) originates from the Madrid production site" (page 52).

Irrigation and water reused and recycled are both flagged as significant estimates in the basis of preparation (page 38). No water discharge or water storage figures are reported.

Policies related to resource use and circular economy

Reference: page 54.

"To address operational waste, ALK introduced a global waste policy in 2025 with the aim of reducing environmental impact, promoting resource efficiency and ensuring alignment with regulatory, technological and strategic developments. The policy establishes a common framework for waste handling across all ALK production sites and sets out a commitment to reduce landfill disposal. ALK will actively seek and implement environmentally responsible and compliant alternatives following the European waste hierarchy" (page 54).

Its scope extends into procurement and product design: "Waste requirements will be integrated into supplier evaluation, contracting, and performance management. Manufacturing processes for new products will be designed to minimise waste and incorporate materials that are non-hazardous and easy to manage at end of life" (page 54).

Accountability: "The overall responsibility rests with ALK's Board of Directors, who have delegated this responsibility to the Executive Leadership Team. Day-to-day management is carried out by Global Product Supply Business Support and EHS in coordination with local EHS site managers" (page 54).

The policy addresses waste. No policy is disclosed on resource inflows, sustainable sourcing or product end-of-life recovery.

Actions and resources related to resource use and circular economy

Reference: page 54.

"Waste management is embedded in site-level operations, ensuring compliance with local legal requirements and continuously assessing opportunities for recycling and reuse throughout the product lifecycle. In 2025, efforts focused on operational waste, by developing the global waste policy and preparing site-level action plans for 2026" (page 54).

Further actions are named but not yet taken: "Over the coming years, ALK plans to implement waste management requirements in supplier selection", and waste requirements "will be integrated into supplier evaluation, contracting, and performance management" (page 54).

The three material E5 IROs the actions respond to are the use of non-recycled paper, aluminium and single-use plastic; operational waste partly disposed in landfills; and end of life of products, all actual negative impacts (page 54). ALK sets out the constraint on all three: "The pharmaceutical industry is highly regulated, requiring high standards for quality and sterility, which results in limited possibilities for circularity" (page 54).

No monetary or human resources are quantified against the 2025 actions.

Targets related to resource use and circular economy

Reference: page 54.

No target is set for FY2025, and ALK states why. "To support the global waste policy objective, ALK's focus in 2025 has been on improving its mapping of waste types and fractions in line with the EU waste hierarchy and the ESRS, and so the company has not yet established a target" (page 54).

The policy carries a directional commitment without a figure or a date: it "sets out a commitment to reduce landfill disposal", and ALK "will actively seek and implement environmentally responsible and compliant alternatives following the European waste hierarchy" (page 54).

Effectiveness is therefore observable only through the reported metrics against the prior year: total waste generated 2,096 tonnes (2024: 2,882), of which 75% (2024: 81%) was recycled or prepared for reuse, and non-recycled waste 25% (2024: 19%) (page 55). No baseline year, target year or measurable objective is disclosed for resource inflows, outflows or waste.

Resource inflows

Reference: page 55.

A nil return, given as an answer rather than a silence. "ALK does not currently gather global data on material resource inflows, or on the rate of recyclable content, and does not at this stage have data in place to provide a reliable estimate" (page 55). E5-4 is listed in the content index against page 55 (page 79).

No total weight of products and technical or biological materials used, no share of biological materials, and no share of secondary reused or recycled components is therefore reported.

The materials driving the material impact are named qualitatively elsewhere in the chapter: "The use of single-use plastic, aluminium containers and non-recycled paper in production have environmental impacts during manufacturing and disposal" (page 54). The waste disclosure identifies the streams in which those materials reappear - product-related material comprising "plastics, metals, glass, and transportation boxes", and agricultural streams of mite media and organic materials "such as hay and wood trimmings" (page 55).

Resource outflows

Reference: page 55.

ALK reports outflows entirely as waste. No information is given on products and materials designed for durability, reusability, repairability or recyclability, and no recyclable-content rate is disclosed - the same gap flagged for inflows: ALK "does not currently gather global data on material resource inflows, or on the rate of recyclable content" (page 55).

Waste is separated into two streams (page 55). Pharmaceutical waste comprises "chemical waste and medical waste (residues from APIs, solvents, and reagents used in production processes)" and product-related material "(plastics, metals, glass, and transportation boxes)". Agricultural waste comes "from ALK's source materials used in the allergen production" and includes mite media "(residual materials from the cultivation and extraction of allergenic source materials)" and organic materials "such as hay and wood trimmings".

Diverted from disposal in 2025: preparation for reuse 964 tonnes and recycling 612 tonnes, together 1,576 tonnes or 75% of waste generated (2024: 2,337 tonnes, 81%) (page 55).

The end-of-life impact is acknowledged but not quantified: "recycling infrastructure for medical products remain[s] limited in some countries" (page 54).

Waste

Reference: page 55.

"Total waste generated in 2025 was 2,096 tonnes (2024: 2,882). 75% (2024: 81%) of total waste was either recycled or prepared for reuse. Waste reused or recycled decreased to 1,575 tonnes (2024: 2,337), largely due to a reduction in organic material such as hay (non-hazardous waste prepared for reuse). The waste incinerated or landfilled remained stable" (page 55). The narrative figure of 1,575 tonnes differs by one tonne from the 1,576 total in the table.

The fall in total waste is therefore driven by agricultural volumes rather than disposal performance: the recycled share fell six percentage points and non-recycled waste rose from 19% to 25%.

Policies related to own workforce

Reference: pages 59, 61, 63.

"ALK supports the UN Guiding Principles on Business and Human Rights and is a signatory to the UN Global Compact. Commitments to health, safety, and human rights are integrated into ALK's Code of Conduct, which applies to all employees. The Code of Conduct explicitly prohibits any involvement in child or forced labour" (page 59).

A second policy covers inclusion: "ALK's Diversity & Inclusion (D&I) policy aims to eliminate discrimination and promote equal treatment and opportunities for all employees... The most senior level accountable for implementing the policy is the ELT, which receives regular reports on the company-wide diversity performance" (page 61). Its limit is stated: "While ALK's D&I policy prohibits discrimination on grounds such as age, gender, race, ethnicity, religion, sexual orientation, disability and other characteristics... it does not include specific commitments to include people from particularly at-risk or vulnerable groups" (page 61).

On health and safety: "The Code of Conduct sets out ALK's commitment to preventing workplace incidents, fostering a strong safety culture, and promoting both physical and mental wellbeing... ALK adheres to national legislation and regulatory health and safety requirements in all countries in which it operates and complies with OSHA standards in the USA" (page 63).

Processes for engaging with own workforce and workers' representatives

Reference: page 59.

"Through engagement with workers' councils, a global sounding board and the annual engagement survey, ALK fosters a culture of open communication, engagement and collaboration" (page 59).

"Workers' councils are established at all European sites where legally required, providing a forum for employees and management to discuss various topics, ranging from competitiveness to employee engagement. Council meetings are held several times a year, with engagement tailored to the topic and local legal requirements. In the USA and China, dialogues are facilitated through the People & Organisation departments" (page 59).

"This year's participation rate remained high at 94% (2024: 95%). The overall engagement score increased to 8.6 (2024: 8.3), positioning ALK in the top 5% against the international healthcare benchmark for the second year in a row" (page 59).

Results feed decisions: "The ELT reviews company-wide results and integrates relevant actions into the People & Organisation roadmap. At function and team levels, the results are analysed to identify specific challenges and opportunities and implement tailored actions" (page 59). Four of the eleven Board members are employee-elected (page 30).

Processes to remediate negative impacts and channels to raise concerns

Reference: pages 59, 63, 74.

"All employees can raise concerns through the whistleblower platform ALK Alertline" (page 59), which is "accessible to internal and external stakeholders via ALK's intranet and public website... Available by phone or online in eight languages, ALK Alertline is confidential and offers the option of anonymous reporting, as a protective measure against retaliation" (page 74).

"Reports are entered directly into an independent company's secure server. Legal & Compliance manages the access, and the reports are made available only to pre-appointed individuals within ALK who are responsible for evaluating reports." "Legal & Compliance also provides the Audit Committee with quarterly updates on ALK Alertline activity" (page 74).

Effectiveness is tracked: "ALK assesses awareness and trust in the processes for raising concerns by including questions in the annual engagement survey on employees' confidence that ALK will address serious misconduct and the importance managers place on employee well-being" (page 74). Managers "are offered training on handling whistleblower reports and ensuring reporter protection, including against retaliation" (page 74).

For safety: "In the event of an accident or a near miss, a risk evaluation is conducted and relevant actions are taken accordingly to prevent any recurrence" (page 63).

Taking action on material impacts on own workforce

Reference: pages 60-61, 63.

Competence development. "As part of the global People Performance process, all ALK employees must draw up a personal development agreement with their leader... The 70–20–10 learning model is used: 70% on-the-job learning, 20% peer learning, and 10% formal training" (page 60). "ALK also identified a need to strengthen AI skills across the organisation. A global training programme was launched in 2025, offering both basic and advanced modules for all leaders and employees. The programme was well received, with more than 1,000 participants" (page 60). Leadership development continued through the "Leading with Impact" programme and the ASPIRE talent initiative.

Inclusive culture. "In 2025, the D&I strategy was updated to further integrate diversity and inclusion into ALK's business strategy and operations", on three priorities: inclusive environments, gender balance, and a global workforce. Key initiatives are "leadership training on inclusivity and unconscious bias, analysis of progression barriers for senior female leaders, and the development of a more equitable, global recruitment process" (page 61).

Health and safety. "Risk assessments are conducted at all production sites to identify hazards, implement preventive measures, and evaluate their effectiveness, with employee input playing a key role" (page 63).

Targets related to own workforce

Reference: pages 61-62.

"ALK has set a target to have at least 40% of the underrepresented gender in the ELT and their direct reports in managerial positions, by 2028. ALK has not involved its own workforce or workers' representatives in the target setting. The development is tracked quarterly as a part of the internal reporting" (page 61).

Performance moved away from the target in 2025: the share fell to 38% (2024: 45%), "falling below the 40% target. This change reflects adjustments at ALK's top management level, with Europe and North America now elevated to ELT representation. This regional reorganisation is a key step in evolving ALK's operating model to support the Allergy+ strategy and enhance commercial execution" (page 62). The population was 55 people, 34 male and 21 female (2024: 47, of whom 26 male and 21 female).

This is the only S1 target disclosed. No target is set for competence development or for health and safety, the two other material own-workforce impacts, and no baseline year is stated for the gender target.

Characteristics of the undertaking's employees

Reference: page 64; the most representative headcount is incorporated by reference to note 2.4 (page 96).

"ALK employs 2,711 employees (2024: 2,812), of whom 96% (2,613) are permanently employed (2024: 2,574). The employee turnover was 12% in 2025 (2024: 17%), of which 172 (2024: 283) employees left voluntarily and 150 (2024: 180) involuntarily" (page 64).

By region (page 64): Europe 2,161 - Denmark 969, Spain 391, France 363, Germany 143, Poland 106, other Europe 189; North America 533 - USA 503, other 30; international markets 17 (2024: 178).

"The decrease in number of employees primarily relates to the transfer of ALK's employees in China to the biopharmaceutical company GenSci as part of the partnership agreement as well as other organisational adjustments relating to the implementation of the Allergy+ strategy" (page 64).

By contract and gender: 2,613 permanent (970 male, 1,640 female, 3 not self-identifying) and 98 temporary (29 male, 69 female); 31 employees on non-guaranteed hours (page 64). Female employees are 63% of the workforce (page 62).

Diversity metrics

Reference: page 62.

Gender distribution (page 62): male 999 (2024: 1,065), female 1,709 (1,743), chooses not to self identify 3 (4), total 2,711 (2,812). "Percentage of females in total workforce 63%" (2024: 62%).

Top management: the Executive Leadership Team and their direct reports in managerial positions totalled 55 in 2025 (34 male, 21 female) against 47 in 2024 (26 male, 21 female), so the share of the underrepresented gender fell to 38% from 45%.

Age distribution, reported for the first time in 2025 with no comparative (marked N/A for 2024): under 30 years old 301; 30-50 years old 1,539; over 50 years old 871 (page 62).

Board-level diversity sits outside the statement and is incorporated by reference: of the seven shareholder-elected Board members "five are men (71%)", which ALK states "is not considered an equal gender representation as defined by the Gender Balance Act"; the Board of Management has three members, one (33%) female (page 30).

Training and skills development metrics

Reference: page 60.

"As part of the global People Performance process, all ALK employees must draw up a personal development agreement with their leader... Development agreements are reviewed and updated annually, and this process applies exclusively to ALK employees" (page 60).

Average training hours are not reported. ALK applies the phase-in for S1-13 paragraph 83(b), "Average training time per employee and by gender" (page 77), so the disclosure covers the performance-review limb of the requirement only.

"In 2025, ALK updated its People Performance process to reflect results, behaviours and overall performance. Insights from this process will inform development programmes and individual development agreements" (page 60).

Health and safety metrics

Reference: page 63.

"ALK decreased its total work-related accidents to 78 (2024: 112). ALK had 4 accidents with lost time absence ordinated by a medical professional in 2025 (2024: 6). This resulted in an accident rate of 1.0 (2024: 1.5), also commonly referred to as Lost Time Injury Frequency Rate (LTIFR)" (page 63).

Coverage is partial: 78% of employees are covered by a health and safety management system, up from 74%.

Two datapoints are omitted under the phase-in provisions and named as such on page 77: S1-14 paragraph 88(d) "Cases of work-related illness" and 88(e) "Lost time due to work-related injuries, fatalities, and illness", the latter also marked "Phase-in" in the list of datapoints deriving from other EU legislation (page 82). No figures are given for non-employee workers.

Compensation metrics (pay gap and total compensation)

Reference: page 62.

"In 2025, the unadjusted gender pay gap has been revised to include additional components such as bonuses, sales incentives and LTI grants. The 2024 gender pay gap has been restated to reflect the additional components (previously 17%)" (page 62).

"This year, ALK reported the adjusted gender pay gap for the first time, using weighted average pay data that accounts for differences in country and grade. When these factors are considered, most of the unadjusted gap is explained, leaving a residual adjusted gender pay gap of 3% (2024: 3%). Action plans to strengthen equitable rewards for all employees even further are guided by the requirements of the EU Pay Transparency Directive" (page 62).

The unadjusted gender pay gap is flagged in the basis of preparation as a significant estimate (page 38). The adjusted gap is not an ESRS datapoint; the 23% unadjusted figure is the one answering paragraph 97(a).

Incidents, complaints and severe human rights impacts

Reference: pages 63, 74, 76.

"In 2025, ALK was not liable for any fines, penalties, or compensation for damages as a result of work-related Alertline reports or severe human rights incidents" (page 74).

The accounting policy sets the counting basis: "Work-related complaints and reports refer to allegations registered on Alertline which involve ALK's own workforce. Severe human rights incidents refer to substantiated incidents of human rights violations pertaining to ALK's own workforce." Fines and compensation count "only when such allegations and complaints are substantiated and undisputed" and are reported "when they are imposed and final" (page 76).

Note the asymmetry that creates: discrimination reports are counted as allegations, human rights incidents only once substantiated.

Policies related to value chain workers

Reference: page 65.

"ALK's Third-Party Code of Conduct outlines the standards of behaviour that ALK expects from all third parties globally when it comes to business conduct and treatment of employees. The Third-Party Code of Conduct is aligned with the Ten Principles of the United Nations Global Compact and follows the UN Guiding Principles on Business and Human Rights (UNGP), as well as applicable laws, regulations, standards and labour agreements" (page 65).

"Key areas covered include health and safety, animal welfare, anti-corruption, environmental practices, working conditions, human rights (including child and forced labour, anti-discrimination and fair pay), interaction with healthcare professionals and patient organisations. The policy does not specifically mention human trafficking" (page 65).

Implementation: "The Third-Party Code of Conduct is an integral part of ALK's GxP (good practice) supplier agreements. All new suppliers must commit to the Code as a prerequisite for collaboration with ALK. The Chief Financial Officer is the most senior-level executive accountable for the implementation" (page 65). "In addition... ALK also adheres to the UK Modern Slavery Act and publishes an annual statement of compliance" (page 65).

Processes for engaging with value chain workers

Reference: page 66.

ALK states that no direct engagement process exists. "While ALK does not have a formal process in place to engage with workers in the value chain on impacts, its sustainable procurement programme seeks to ensure that potential negative impacts on these workers are addressed. The Senior Vice President (SVP), Global Procurement bears the overall responsibility for the supplier engagement programme" (page 66).

The substitute is supplier-level assessment rather than worker-level engagement: "Through a partnership with an external evaluation platform, ALK assesses environmental, labour, and human rights risks. During 2025, ALK assessed over 1,400 of its suppliers, covering 97% of the procurement spend. The suppliers assessed are considered strategic to ALK and consist of both direct suppliers who supply materials included in ALK's products and indirect suppliers who supply products or services to support ALK's business operations" (page 66).

No workers' representatives, trade unions or credible worker proxies are named as engagement partners, and the stage, type and frequency of engagement required by S2-2 are not disclosed. ALK also states it "does not currently have any mechanisms to assess whether these workers are aware of or trust ALK Alertline" (page 66).

Processes to remediate negative impacts and channels for value chain workers

Reference: pages 65-66, 73.

"Value chain workers can raise concerns through ALK's whistleblowing platform, ALK Alertline, which can be accessed via ALK's website. No complaints involving workers in the value chain were substantiated in 2025. ALK does not currently have any mechanisms to assess whether these workers are aware of or trust ALK Alertline" (page 66).

"Potential necessary actions to remediate any negative impacts will be discussed at the regular business relationship meetings" (page 66) - a forward-looking process rather than remediation actually provided.

"No severe human rights issues and incidents connected to ALK's upstream and downstream value chain were reported in 2025" (page 66; metrics page 74).

Any breach of the standards in the Third-Party Code of Conduct "can be reported through the whistleblower platform" (page 65), and ALK's Whistleblowing policy "also applies to external stakeholders" (page 73). No third-party grievance mechanism, worker helpline in supplier locations, or mechanism operated jointly with worker representatives is disclosed.

Taking action on material impacts on value chain workers

Reference: pages 65-66.

"ALK prioritises reputable suppliers that uphold high standards, reducing the risk of serious breaches of labour or compliance standards. Long term contracts provide financial stability and encourage sustained commitment to responsible working conditions, as stable revenue enables suppliers to invest in infrastructure, training and safety" (page 66).

The principal 2025 action is the supplier assessment programme: "During 2025, ALK assessed over 1,400 of its suppliers, covering 97% of the procurement spend... While no suppliers were identified as very high risk from an ESG perspective, ALK will continue to further its due diligence programme and potentially include additional categories going forward" (page 66).

The impacts these respond to are set out on page 65: workers in upstream production units exposed to hazardous substances, with "chemical exposure, operational hazards and ergonomic risks"; workers in downstream transportation facing "the risk of vehicle accidents... during loading, unloading and transit"; and workers handling hazardous waste facing "chemical burns, respiratory issues and toxic exposure".

No corrective action plan, supplier remediation case, or resource allocation is quantified.

Targets related to value chain workers

Reference: page 66.

No target is set, and ALK states why. "ALK continuously assesses its suppliers for potential human rights and health and safety risks. To date, no suppliers have been identified as very high risk in the ESG assessment. ALK has therefore not identified a need for specific targets related to formal engagement with workers within the value chain" (page 66).

Under MDR-T the effectiveness limb is served by the assessment programme itself: over 1,400 suppliers assessed in 2025 covering 97% of procurement spend, no supplier rated very high risk, and no substantiated Alertline complaint involving value chain workers (page 66).

Supplier engagement does carry a quantified target elsewhere - 80% of scope 3 emissions from suppliers with science-based targets by 2028, standing at 50% in 2025 (pages 46-47) - but that is an E1 climate target, not an S2 one. No baseline, target year or measurable outcome-oriented objective is disclosed for the material S2 impact.

Policies related to consumers and end-users

Reference: page 68.

Two policies are disclosed. The Access to Medicines policy "outlines the company's ambition to reach more patients by focusing on three core principles: improving quality of life through better treatment options and earlier diagnosis, supporting healthcare systems with training and education on allergy care, and forming partnerships to enhance access. The policy addresses the impacts Allergy treatment and Barriers to access and covers both patients and healthcare professionals. In January 2025, the ELT reviewed the policy to ensure continued alignment with the Allergy+ strategy" (page 68).

The global quality policy "formalises the company's commitment to delivering high-quality, safe and effective products and services for people living with allergy. The policy applies to all ALK operations... Oversight of the policy rests with the ELT, with daily management delegated to Global Quality. Quality objectives are reviewed at least annually" (page 68).

A gap is stated rather than left implicit: "As the pharmaceutical industry is heavily regulated, human rights topics like the right to health and informed consent in clinical trials are already embedded in legislation. Therefore, ALK does not have specific consumer policies aligned with the UN Guiding Principles on Business and Human Rights" (page 68).

Processes for engaging with consumers and end-users

Reference: pages 41, 68.

"ALK engages with patients through a comprehensive digital ecosystem of websites, social media and dedicated applications that provide educational content to the general public. These platforms help raise ongoing awareness of allergies, symptoms, their impact on quality of life, and, in some markets, available treatment options. ALK's digital channels offer guidance on recognising symptoms and on seeking appropriate medical advice. The Global Marketing function is responsible for expanding and maintaining ALK's digital ecosystem" (page 68).

The stakeholder table treats consumers and healthcare professionals as separate groups (page 41). For consumers and the general public, engagement runs through "various digital media platforms" and "consumer websites, apps, email flows", with the recorded outcome "improved awareness among consumers relating to allergies including symptoms, impact on quality of life, treatment options". For healthcare professionals it runs through "scientific webinars and symposia, scientific publications, clinical trial data sharing", with outcomes including "correct identification and diagnosis of people with allergy".

Engagement is described as communication and education. No process for gathering patients' own views is disclosed, and no patient organisation is named as an engagement partner.

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

Reference: pages 69, 74.

"ALK ensures patient safety and product quality through a robust, global pharmacovigilance system designed to identify, assess, and address side-effects and safety concerns, covering both clinical trials and marketed products" (page 69).

"Global Safety & Pharmacovigilance is responsible for monitoring benefit-risk profiles of ALK's products, handling adverse event reports, ensuring timely submissions to regulatory authorities worldwide and monitoring the performance and compliance of ALK's pharmacovigilance system" (page 69).

"Patients are informed on how to report potential side effects in the leaflets for all products. External stakeholders with a work-related connection to ALK can raise their concerns through the whistleblower platform ALK Alertline" (page 69), which is confidential, available by phone or online in eight languages and allows anonymous reporting (page 74).

Note the scope limit on the whistleblowing route: Alertline is open to external stakeholders "with a work-related connection to ALK", so for patients the operative channel is pharmacovigilance. No figures on adverse event volumes, complaints received or remedies provided are disclosed.

Taking action on material impacts on consumers and end-users

Reference: page 69.

"2025 marked significant milestones for ALK, advancing the Allergy+ strategy with major launches and approvals for children and adolescents. The house dust mite (HDM) tablet is now approved for paediatric use in 30 countries and launched in 21 of them. The roll-out of the tree pollen allergy tablet for children and adolescents also started in 2025, based on regulatory approvals from the EU and Canada. Year-end, the tablet was approved for children and adolescent use in 20 countries and launched in 12 of these markets. With these launches, ALK now offers four tablets, covering 80% of the most common respiratory allergies" (page 69).

"In addition, the approval and launch of EURneffy®, a needle-free nasal adrenaline spray, in the UK and Germany has addressed important gaps in anaphylaxis treatment for adults and children. Under co-promotion agreement with ARS Pharma, ALK is also responsible for selling neffy® to approximately 9,000 named paediatricians in the USA" (page 69).

"In 2025, the innovation agenda advanced with phase 2 clinical trials for the peanut SLIT tablet, with topline data expected in 2026."

Against barriers to access, "ALK expanded digital education for healthcare professionals through training sessions, targeted newsletters, large multi-market webinars, and enhanced healthcare professional portals" (page 69).

Targets related to consumers and end-users

Reference: pages 8, 69.

"ALK aims to help 5 million people with allergy annually by 2030 to advance its positive impact and opportunity. This aspiration covers ALK's downstream activities in the countries where ALK operates" (page 69).

Progress: "In 2025, the number of patients in treatment reached an estimated 3.1 million (2024: 2.6 million), as a result of ALK's commercial activities" (page 69) - a net increase of 500,000 patients (page 8). The chart on page 69 plots the trajectory from 2.6 million in 2024 to the 5.0 million target in 2030.

"Patients in treatment" is flagged in the basis of preparation as a significant estimate (page 38), with the method set out in the accounting policies for social information (page 71).

This is the only S4 target disclosed. Nothing addresses product safety and quality or affordability, two of the other material impacts in the S4 IRO table (page 67), and no baseline year is stated for the 5 million ambition.

Business conduct policies and corporate culture

Reference: pages 65, 72-75.

"ALK's approach to business conduct is grounded in a comprehensive framework of policies centred on its Code of Conduct. They apply to all ALK employees and are publicly accessible via ALK's website" (page 72).

• Code of Conduct - "sets the tone for business integrity and ALK's ethical principles. It affirms ALK's commitment to upholding human rights, safeguarding confidential business information, and promoting zero-tolerance for corruption and fraud." Oversight rests with the ELT, assisted by ALK's Compliance Committee (page 72).
• Policy for Anti-Corruption - covers general anti-bribery legislation and "industry-specific standards covering interactions with healthcare professionals. It is consistent with the United Nations Convention against Corruption" (page 73).
• Whistleblowing policy - "includes a non-retaliation commitment to protect any employee or stakeholder who raises a concern in good faith"; the Audit Committee holds overall responsibility, Legal & Compliance the day-to-day (page 73).
• Third-Party Code of Conduct - covers the value chain (pages 65, 73).
• Animal welfare policy, introduced in 2025: studies run "only when no scientifically valid alternative exists"; ALK "is committed to the principles of Replace, Reduce, and Refine", monitored "through quarterly inspections by an external veterinarian" (page 75).

Prevention and detection of corruption and bribery

Reference: pages 73-74.

"Employees are exposed to risks of bribery and corruption, particularly during interactions with healthcare professionals (HCPs). For ALK, the principal risk relates to potential bribery of HCPs, meaning improper influence to increase sales and cash flow. To address this, ALK provides annual online Code of Conduct training for all employees, including members of the Executive Leadership Team and employee representatives on the Board of Directors" (page 73).

"The training covers relevant business conduct topics including anti-corruption, ALK Alertline, communications, promotion and social media, competition law, conflicts of interest, political contributions, human rights, interaction with healthcare professionals, IT security, patient safety, and data privacy" (page 74). Training requirements are formalised in the "newly established Global Business Ethics Compliance Programme policy" (page 73).

Investigation is separated from the business: allegations "are investigated under ALK's Compliance Investigations process. Each case is overseen by an investigation supervisor, typically the Vice President, Legal & Compliance or their designee... The Chair of the Audit Committee is notified of reports concerning corruption and is responsible for approving recommendations on such cases" (page 74). Financial control systems "also act to prevent and detect any incidents".

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.

ALK discloses one quantified business conduct target. "ALK has set a global completion rate target of 95%" for Code of Conduct training. "In 2025, 99% (2024: 98%) of employees across all functions completed the training" (page 74).

The metric's definition changed this year and the comparative was restated: "In 2025, the metric has been revised to include all ALK employees. The 2024 figure has been restated to reflect this updated definition (previously 99%)" (page 74). The e-learning course "was rolled out between May and July 2025" (page 76).

Consistent with MDR-T's other limb, effectiveness is also tracked without a target: Legal & Compliance provides the Audit Committee with quarterly updates on Alertline activity, and awareness and trust are measured through questions in the annual engagement survey on employees' confidence that ALK will address serious misconduct (page 74).

No target is disclosed for the animal welfare impact or for supplier business conduct.

Incidents of corruption or bribery

Reference: pages 74, 76.

"ALK had no convictions or related fines for violations of anti-corruption and anti-bribery laws" (page 74).

The counting basis is set out in the accounting policies: "For purposes of the reporting, convictions in scope are final decisions or acts by courts of law, which constitute criminal convictions under applicable local law in the jurisdiction where the decision or act takes place. As required by the ESRS, only convictions where ALK or its employees are directly involved are considered within scope. Fines relating to such convictions are reported in the reporting year when they are imposed and final (i.e., no longer under appeal or in dispute)" (page 76).

Bribery is defined as "money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit", and corruption as "abuse of entrusted power by someone for personal gain" (page 76).

The number of confirmed incidents, incidents relating to contract breaches with business partners, and details of public legal cases are not separately reported; the nil convictions figure is the whole return.