Alleima

Governance roles

Reference: pages 97-98. Board composition, experience and diversity are incorporated by reference to the Corporate governance report, page 86 (page 96).

"Alleima's Board of Directors has the highest responsibility for the Group's sustainability work. This responsibility includes the governance and oversight of the processes needed to ensure efficiency and due diligence in various areas such as reporting, compliance with regulations and policies" (page 97).

Composition (page 97): seven members elected by the AGM, two employee representatives and two deputies. "Two of the seven members (approximately 29%) elected by the AGM are women." Except for the President and CEO, all AGM-elected members are independent. Rule 4.1 of the Code was applied as the diversity policy.

Allocation of responsibility (page 97): the Board has overall responsibility for sustainability reporting, "monitored by the Audit Committee"; Group Executive Management has overall responsibility for strategy and the sustainability agenda; the divisions handle implementation and follow-up. A Sustainability Council coordinates Group sustainability work, each division represented by its sustainability manager, and "The head of the governance and sustainability function chairs the Sustainability Council and reports to the President and CEO." Governance runs through the internal framework The Alleima Way.

Information flows to the Board and management

Reference: pages 97-99. GOV-1 and GOV-2 are disclosed together under one heading; the ESRS index lists both at pages 96-98 (page 123).

Reporting cadence (page 97): "The Sustainability Council reports to Group Executive Management quarterly. In these reviews, management is informed about issues related to sustainability as well as the company's progress towards its sustainability targets and plans for further progress towards reaching long-term targets. Sustainability work is reported to the Board in the same way twice per year."

Matters addressed during 2025 (page 97): Alleima "reviewed its Sustainability Policy and revised its sustainability targets, including introducing science-based targets approved by the Science Based Targets initiative". "An ongoing review of the Group's progress has been provided to management and the Audit Committee on a quarterly basis and to Alleima's Board."

Board involvement in the DMA (page 97): "The Board participates in the double materiality assessment and helps identify Alleima's impacts, risks and opportunities. Its sustainability review led, for example, to long-term sustainability risks being included in the risk management process." The Nomination Committee is responsible for ensuring Board members have the requisite expertise, and information from the sustainability function "allows the Board to continuously develop their sustainability expertise".

Sustainability in incentive schemes

Reference: page 98.

The AGM "has adopted guidelines for variable cash remuneration for senior executives, making it conditional upon the fulfillment of defined and measurable criteria. These criteria shall aim at promoting the company's business strategy and performance as well as its long-term interests, including sustainability." Criteria are proposed annually by the Remuneration Committee and approved by the Board, "including KPIs and the target ranges deemed relevant for the upcoming measurement period".

Weighting (page 98): "At least 80% of the variable cash remuneration shall be linked to the financial criteria." For 2025 short-term variable remuneration, "the CEO and the heads of Group functions are to be assessed on the basis of Group-level KPIs and the heads of divisions are to be assessed on the basis of a combination of Group-level and division-level KPIs."

Climate link (page 98): "Variable remuneration for the year was based on factors such as the company's reduction of CO2 emissions. To achieve maximum fulfillment of the GHG emissions reduction target, Scope 1 and 2 emissions must be reduced to 87,950 tons of CO2 by 2027, compared with 2025."

The statement does not give the percentage of variable remuneration that is climate-linked, nor the outcome of the sustainability criteria for 2025. Remuneration to key management personnel is set out separately in the financial statements (Note 3, page 54).

Statement on due diligence

Reference: page 98.

"Alleima's process for identifying, preventing and mitigating negative impacts from the company's operations are guided by internationally recognized principles, such as the ten principles in the UN Global Compact, the UN Universal Declaration of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, the Rio Declaration on Environment and Development, and the UN Convention Against Corruption." Alleima also follows the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights, the Responsible Minerals Initiative and the UN SDGs, and is a UN Global Compact signatory.

Mapping table of the five core elements to the statement (page 98):

Appendix 4 records GOV-4 paragraph 30 as a datapoint stemming from the SFDR, located at page 98 (page 127).

Risk management and internal control over sustainability reporting

Reference: page 98. Description of risk management and internal control processes including identified risks is incorporated by reference to the Corporate governance report, page 89 (page 96).

"The Board is ultimately responsible for establishing effective systems for risk management and internal control. Sustainability risks are managed in Alleima's overall risk management process" (page 98).

Division of responsibility (page 98): "The Sustainability Council helps develop the risk management process for climate-related risks and opportunities, while the HR function helps with social and workplace risk management and the compliance function helps with risks related to business ethics."

Identified risk in the control environment, stated plainly (page 98): "The top risk within internal controls constitute the fact that the program is limited given that it's new. A new risk assessment was conducted during the year which will be used to plan expansion of the program. The program for internal control also includes compliance follow-up, for example with Alleima's Code of Conduct."

The Board reviews internal control, risk management, sustainability and compliance annually, "with the latter including a review of the Group's Code of Conduct and other internal policies" (page 99). Concerns can be raised through the Speak Up whistleblower service (pages 99, 121).

Strategy, business model and value chain

Reference: pages 99, 100-101.

Alleima produces "tube products in advanced stainless steel and special alloys, products for industrial heating and resistance materials, and ultra-fine medical wire and wire-based components", plus precision strip steel, valve steel and coated strip steel for hydrogen applications. Customers are in the Energy, Chemical and Petrochemical, Industrial, Mining, Construction, Transportation and Medical segments, "spanning more than 80 countries" (page 99).

Value chain (pages 100-101): upstream is sourcing and buy-back of raw materials plus research and development; own operations are melting in electric arc furnaces, hot working and cold working, concentrated in Sweden, Germany, Czechia and the UK with major facilities in the US, India and China; downstream covers marketing and sales, logistics, product use and recycling. "100% fossil-free electricity and more than 80% recycled steel are used in the process."

Four sustainability focus areas (page 99): a responsible employer, climate, circularity and product offering. "Since 2013, all of Alleima's operations in Europe and approximately 98% of its operations worldwide use fossil-free electricity. In some heating processes, biofuels are also blended in. During the year, blended biofuels accounted for 16% of the energy used in direct combustion."

Interests and views of stakeholders

Reference: page 99.

"Alleima's main stakeholders are its employees, customers, owners and suppliers. The company also has common interests with the communities and organizations where it operates, both locally near its operations and at the national and global levels. There are also more distant stakeholders, such as the employees of its business partners."

Channels and purpose (page 99):

"The information is taken into account and serves as input for future analyses, such as materiality assessments. The Audit Committe and the CEO are informed of the stakeholders' views in connection with the annual materiality assessment" (page 99).

Material impacts, risks and opportunities

Reference: page 102 (the ESRS index also cites pages 104 and 107).

This is Alleima's first ESRS report, "which is why no changes compared to the previous year regarding the outcome of the materiality assessment are reported". The table lists 18 material topic rows with type, value chain position and time horizon.

"Sustainability topics are incorporated into Alleima's overall strategic work to ensure that the company's business model and strategy are resilient to the identified impacts, risks, and opportunities" (page 102).

Process to identify and assess material IROs

Reference: pages 103-104.

"In 2023, the company carried out its first double materiality assessment, where impacts as well as risks and opportunities were identified. Since then, the materiality assessment has been reviewed annually. The assessment is based on Alleima's own operations and value chain" (page 103).

Five steps (page 103): (1) mapping stakeholders and the value chain; (2) identifying impacts, risks and opportunities along the value chain; (3) assessment through workshops with internal stakeholders and interviews with Group Executive Management and the Board, with each topic "weighted based on scale, scope, irremediable character and likelihood"; (4) validation and documentation by the finance and corporate governance functions, Group Executive Management and the Board; (5) dialogue with stakeholders.

Thresholds (page 103): "Severity is then categorized based on a five-point scale: not applicable, minimal, important, significant or critical. Likelihood categorizes impacts as actual, likely or unlikely." Financial materiality "is assessed based on the likelihood and magnitude of the financial impact". The method and threshold "are approved annually by the Board and the Audit Committee".

Result (page 103): the material topics are "Climate and energy, Pollution, Water, Biodiversity, Circularity, Health and safety, Diversity, Business ethics, Growth in products that support increased sustainability".

ESRS content index

Reference: pages 123-124 (Appendix 1, "Disclosure requirements in ESRS covered by the undertaking's sustainability statement (IRO-2)").

The index is a genuine two-page concordance listing each covered disclosure requirement with its page location, grouped by standard: ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2), E1 (GOV-3, E1-1, SBM-3, IRO-1, E1-2 to E1-6), E2 (IRO-1, E2-1 to E2-5), E3 (IRO-1, E3-1 to E3-4), E5 (IRO-1, E5-1 to E5-5), an entity-specific disclosure ("Growth in products that support increased sustainability", page 114), S1 (SBM-2, SBM-3, S1-1 to S1-6, S1-9, S1-14), S2 (SBM-2, SBM-3 and five value-chain-worker disclosures) and G1 (GOV-1, IRO-1, G1-1 to G1-4).

E4 is absent from the index, consistent with the BP-2 statement that Alleima "has chosen to apply the phase-in rules presented by the EU in summer 2025" for the whole of E4 as well as for SBM-3 anticipated financial effects, E1-9, E2-6, E3-5 and E5-6 (page 96).

Appendix 2 lists Alleima's policies (page 125); Appendix 4 maps datapoints stemming from other EU legislation and marks several of them "Not material" or "Phase-in provisions" (pages 127-128).

Note for readers: in the S2 block of the index the five value chain worker disclosures are printed with S1 codes (S1-1 to S1-5) although the titles are the S2 titles ("Policies related to value chain workers" and so on), which appears to be a typographical error in the report (page 124).

Transition plan for climate change mitigation

Reference: page 106 (the ESRS content index lists E1-1 at page 105).

"Alleima has set net-zero targets to 2050 that were verified by the Science Based Targets initiative (SBTi) in 2025. The targets for Scopes 1 and 2 are in line with the 1.5°C target set by the Paris Agreement, and the target for Scope 3 is linked to the goal of limiting global warming to well below 2°C. A transition plan has been established to achieve these targets" (page 106).

Approval and funding (page 106): "The transition plan has been presented to the Board and approved for implementation. The investments required will be handled within the framework of the company's regular investment process." No monetary amount, capex envelope or funding schedule is given.

Levers named (page 106): transitioning to renewable energy sources in own operations, phasing out fossil fuels in transport, purchasing low-carbon products and services, and energy efficiency. The transition-plan waterfall chart on page 107 runs from the 2019 base year to a 2030 target of 68,423 (-54%) and a "beyond plan" 61,340 (-59%), with 2025 at 89,380 (-40%).

Locked-in emissions (page 108): "In Scopes 1 and 2, the company generates approximately 25,000 tons of process-related emissions per year, which could potentially give rise to a lock-in effect. These emissions are linked to the steel production process and stem from the blending of coal."

Identification of climate-related risks and scenario analysis

Back-filled from the ESRS 2 climate-related scenario analysis box and IRO-1 (pages 103-104). This DR did not exist under the 2023 ESRS the report was prepared against.

Classification (page 104): ten items are each labelled physical risk (extreme heat, heavy precipitation, drought, water stress, floods), transition risk (reputational damage, compliance costs including inconsistent regional regulation, insufficient investment in emission-reducing technologies) or transition opportunity (European Green Deal alignment and green financing; commercialisation of products supporting the transition).

Scenarios (page 104): "Transition risks were analyzed using the Net Zero (NZ) and Nationally Determined Contributions (NDC) Scenario from the Network for Greening the Financial System (NGFS), while RCP8.5 (continued high emissions) and RCP2.6 (significantly reduced emissions) were used for physical risks. The time horizons used were 2020, 2030 and 2050." A high-emission scenario is therefore used for physical risk.

Scope (page 104): the analysis covered "transition risks and opportunities in Alleima's own operations and value chain as well as physical risks in Alleima's own operations", across 55 facilities, over 2030, 2050 and 2100.

Gap: no global average temperature projection is stated per scenario, no date is given for when the analysis was carried out, and key assumptions are not set out.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the E1-3 actions section (pages 102, 107). This DR did not exist under the 2023 ESRS the report was prepared against.

No ESRS-defined resilience analysis is presented. The statement carries a general SBM-3 sentence rather than a climate-specific analysis: "Sustainability topics are incorporated into Alleima's overall strategic work to ensure that the company's business model and strategy are resilient to the identified impacts, risks, and opportunities" (page 102).

Capacity to adapt (page 107): "Alleima can become more resilient to climate risks and opportunities by implementing mitigation and adaptation actions. Previous actions and strategies can be incorporated into a climate transition plan that further develops Alleima's resilience strategy." Named responses match the physical risks identified: reviewing working hours and refrigeration for extreme heat; servicing drains, gutters and manholes for heavy precipitation and flooding; and water efficiency and reuse for drought.

Not disclosed: the results of a resilience analysis as such, the time horizons tested, the areas of uncertainty, or the flexibility of financial resources to redeploy or repurpose assets. The E1-1 challenges section (page 106) comes closest to naming constraints, citing scrap supply competition and the scarcity of low-climate-impact primary iron raw material.

Policies related to climate change mitigation and adaptation

Reference: page 107.

"Alleima's Sustainability Policy covers all units in the Group and describes the company's management and oversight of sustainability in order to ensure regulatory compliance. Alleima's material impacts, risks and opportunities are related to climate change mitigation and energy."

Policy content as disclosed (page 107):

• "All activities are to be incorporated into implemented programs aimed at improving energy efficiency and reducing GHG emissions. Improvement initiatives should not be solely limited to the company's manufacturing operations."
• Adaptation: "For facilities in high-risk areas with severe weather conditions or areas where other unplanned events linked to climate change could occur, the business continuity planning process should include adaptation actions or operational modifications."
• Energy: "As far as possible, the energy used should come from fossil-free sources."
• Transport: low-footprint transport modes are to be promoted.
• "The process for assessing the climate impact of suppliers is laid out in the Supplier Code of Conduct and the Procurement Policy."

The Board is responsible for the Sustainability Policy (pages 98, 125). "Policies and procedures are reviewed on an annual basis, including a follow-up of their appropriateness and effectiveness" (page 98). The policy summary table is in Appendix 2 (page 125).

Actions and resources for climate change

Reference: pages 107-108.

Adaptation actions (page 107) are set against the physical risks from the scenario analysis: reviewing working hours and providing refrigeration, water and cool rest areas for extreme heat; servicing drains, gutters and manholes plus building inspection for heavy precipitation and flooding; and water efficiency and reuse for drought.

Mitigation actions, Scopes 1 and 2 (page 108):

• "As of the start of 2025, the company's emissions had already been reduced by 37% compared with the base year... The main changes involved starting to blend in biofuels and making conscious choices when purchasing electricity."
• "In 2025, Kanthal completed its initiative regarding electricity procurement and achieved 100% fossil-free electricity."
• A Tube walking-beam furnace "has been prepared to handle fuels such as natural gas, hydrogen, and/or biogas... The project is currently paused and is planned to resume in 2027."
• A large furnace conversion at Sandviken "is expected to contribute to a reduction of 12,000 tons of CO2".

Scope 3 (page 108): the focus is "working with suppliers to gain access to alternative materials with a lower climate impact, while at the same time maintaining the quality of the end-products", including scrap with the right chemical composition and buy-back of Alleima's own products.

No monetary resources are attached to the individual actions (page 106).

Climate targets

Reference: page 108, with the base-year and 2050 columns in the E1-6 table on page 109.

"Alleima has set net-zero targets to 2050 that have been verified by the SBTi, a third party that reviews and confirms targets" (page 108).

The E1-6 table adds the base year and the long-term leg: own operations (Scope 1 and 2, market-based) base year 2019 of 149 thousand tonnes CO2eq, change against base year -40%, target 2030 -54%, target 2050 "-90 (net-zero)"; Scope 3 base year 595 thousand tonnes, change -18%, target 2030 -28%, target 2050 "-90 (net-zero)" (page 109).

Not disclosed: whether the targets are gross targets, any use or exclusion of carbon credits or removals, and the intermediate annual milestones between 2025 and 2030 other than through the transition-plan chart on page 107. A separate incentive-linked interim marker appears under GOV-3: Scope 1 and 2 emissions "must be reduced to 87,950 tons of CO2 by 2027" for maximum bonus fulfilment (page 98). Appendix 4 lists E1-4 paragraph 34 GHG emission reduction targets as an SFDR, Pillar 3 and Benchmark Regulation datapoint (page 127).

Energy consumption and mix

Reference: page 108. Reporting principles for E1-5 are on page 125.

"69% of the total energy consumption came from fossil-free energy sources in 2025, of which 51% from nuclear sources" and "In 2025, Alleima used 632 GWh of fossil-free electricity, corresponding to 98% of the total electricity purchased" (page 109).

Method (page 125): data is collected quarterly. "Fuels are reported by type and categorized as fossil or renewable. Electricity is reported as energy values, without attributing the electricity to source... Electricity with no guarantee of its origin is reported as fossil electricity."

Appendix 4 lists paragraphs 37, 38 and 40-43 as SFDR datapoints (page 127). Consumption is not disaggregated by high climate impact sector; 55 MWh per SEK million of revenue is the only intensity given.

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: page 109; reporting principles page 125.

Scope 3 by category (2025, 2024, thousand tonnes): purchased goods and services 384 (450); capital goods 11 (19); fuel- and energy-related activities 28 (28); upstream transport and distribution 40 (32); waste generated in operations 4 (5); business travel 4 (3); employee commuting 8 (8); processing of sold products 6 (7); end-of-life treatment 1 (1). Downstream transportation and distribution is marked "Not disclosed", because "No primary data was available, and no data model based on assumptions was set up" (page 96).

"CO2 emissions from the company's own operations in 2025 amounted to approximately 89 ktons... Compared with the base year 2019, the total decrease was 40%" (page 109). Scope 3 comparatives were restated, a "material reduction" (page 96).

Policies related to pollution

Reference: page 110.

"Alleima's Sustainability Policy covers all units in the Group and describes the company's management and oversight of sustainability in order to ensure regulatory compliance."

Policy content as disclosed (page 110):

• "Where applicable, the prevention of pollution from the company's operations and the mitigation of negative impacts related to air and soil pollution are included as part of the environmental management activities of all facilities with manufacturing activities. The environmental management system is to include relevant requirements and conditions for operation in accordance with the facility's permit."
• "Use of potentially harmful substances is to be minimized and efforts are to be made to find replacements. The use of substances of very high concern is to be phased out as far as possible. Chemical risks are to be identified and proactively managed."
• Supplier impacts are assessed under the Supplier Code of Conduct and the Procurement Policy.

The policy scope matches the E2 sub-topics the DMA found material - air, soil, and substances of concern and of very high concern - and does not extend to water pollution, which is not a material E2 sub-topic (page 102). Chemical management sits under the environmental management system and "is described in a chemical management procedure" (page 125). All major locations are covered by third-party verified ISO 14001 systems (page 97).

Actions and resources related to pollution

Reference: page 110.

"Alleima carries out systematic remediation work related to pollution and in accordance with its granted environmental permits where required. Engineering operations have traditionally generated large emissions of pollutants to air, soil and water. As technological developments and continuous improvements are made, more measures and resources related to monitoring and control are needed to ensure that the operations are conducted in accordance with applicable permits."

"The design of these control programs is based on the specific operations in question, following consultations regarding the principles and regulations in place in each location. For example, the largest operations in Sandviken, Sweden, have a rigorous self-inspection program in place that includes control procedures where responsibility, sampling programs and procedures for actions, training, etc. form part of a management system."

Monitoring practice is described in the reporting principles: "Emissions to air are monitored through continuous measurement of nitrogen oxide emissions, for example. Mercury is also continuously measured and monitored... These controls include sample testing of emissions from the steel mill, dust from mechanical processing, nitrogen oxides from combustion and pickling plants, and oil aerosol" (page 125).

No monetary resources are allocated to the pollution actions, which are described as continuing programmes.

Targets related to pollution

Reference: page 110, which states under "Targets related to pollution (E2-3)": "See page 98." The ESRS content index correspondingly gives page 98 as the location for E2-3 (page 123).

Page 98 discloses that no target has been set, and what is used instead: "Alleima has not set group-wide sustainability targets for the areas of pollution and hazardous substances, water, biodiversity, waste circularity, or areas encompassed by responsible business conduct. These are measured and monitored through the internal framework The Alleima Way."

"Along with the long-term sustainability targets adopted by the Board, The Alleima Way is a comprehensive framework designed to manage and monitor all topics defined as material in Alleima's double materiality assessment... The Alleima Way includes several mandatory KPIs that are measured and monitored. Policies and procedures are reviewed on an annual basis, including a follow-up of their appropriateness and effectiveness" (page 98).

This is the Minimum Disclosure Requirement on targets answered through its second limb - tracking effectiveness in the absence of a measurable target - rather than a quantified pollution reduction target. No baseline year, target value or target date is given for NOx, metals, zinc or substances of concern. Effectiveness is evidenced through permit compliance for the year: "The conditions for emissions to air were met in 2025, with a few exceptions" (page 110).

Pollution of air, water and soil

Reference: page 110. Reporting principles are on page 125.

"SOx, non-methane volatile organic compounds (NMVOC) and particulate matter are monitored and are below the reporting thresholds" (page 110).

Scope of the E-PRTR obligation (page 110): "Alleima's production facilities in Sandviken, Söderfors and Hallstahammar require permits and are subject to environmental legislation, including emissions rules. Several of the facilities release substances listed in Annex II of the EU Emission and Transfer Register Regulation, exceeding the reporting thresholds... In the Tube division, an investigation is ongoing to determine how many facilities are affected."

Outcome (page 110): "The conditions for emissions to air were met in 2025, with a few exceptions of elevated dust and metal levels in filters, elevated level of hydrogen fluoride from pickling plant and elevated nitrogen oxide emissions from a furnace... Continuous mercury measurements did not reveal any elevated levels."

Soil is a material sub-topic - "Alleima has an actual negative impact on soil, particularly in connection with its production facilities in Sandviken and Hallstahammar, where substances have been detected in the soil" (page 110) - but the table reports emissions to air only, with no quantified releases to soil or water.

Substances of concern and substances of very high concern

Reference: page 110, with the hazard-class table in Appendix 6 on page 131.

Headline amounts (page 110), tonnes for 2025: substances of concern 10,223; substances of very high concern 16. No comparative is given: "This is the first time Alleima has prepared a report in accordance with the ESRS... This applies to the reporting of indicators under E2-5 and G1-3" (page 96).

Both limbs of the requirement are answered. Appendix 6 splits the totals by ESRS category and hazard class (page 131). Substances of concern: produced at the facility none; used at the facility 10,220; generated at the facility none; leave facility as products none; leave facility as part of products 9,502; leave facility as emissions 3. Substances of very high concern: used 16; leave as part of products 0; leave as emissions 0.

Hazard classes covered include mutagenicity, carcinogenicity, reproductive toxicity, target organ toxicity, sensitisation, chronic aquatic hazard and PBT/vPvB (page 131).

Company commentary (page 110): "Nickel and cobalt are included in several classes of substances of concern... Endocrine disruptors or substances of very high concern to the environment are not handled at any of Alleima's facilities."

Method (page 125): quantities are "calculated based on the concentration of the substance... multiplied by the annual consumption of the product", and cover Alleima's own facilities.

Policies related to water and marine resources

Reference: page 111.

"Alleima's Sustainability Policy covers all units in the Group and describes the company's management and oversight of sustainability in order to ensure regulatory compliance."

Policy content as disclosed (page 111):

• "Where applicable, water sourcing, use, discharge and treatment are included as part of the environmental management activities of all facilities with manufacturing activities. The environmental management system is to include relevant requirements and conditions for operation in accordance with the facility's permit."
• "Commitments to reduce water consumption are to be established for the company's own operations as well as upstream and downstream in the value chain where there are water supply threats or for facilities located in areas of high water stress."
• Supplier impacts are assessed under the Supplier Code of Conduct and the Procurement Policy.

Appendix 4 records E3-1 paragraphs 9 and 13 (water and marine resources, and a dedicated policy) as SFDR datapoints located in the water chapter, while paragraph 14 (sustainable oceans and seas) is marked "Not material" (page 127). The policy therefore covers water sourcing, use, discharge and treatment but not marine resources, matching the material sub-topics of water withdrawals and water discharges (page 102).

An environmental impact assessment under Directive 2000/60/EC was carried out for the permit application (page 105).

Actions and resources related to water and marine resources

Reference: page 111.

"A previous reviews of water stress according to company geography was updated during the year. The outcome confirmed the previous understanding of the locations where we operate. Based on the results, resources have been allocated to additional studies to map out and understand the situation at our operations in the Gujarat and Tamil Nadu regions in India. The goal of the work is to establish accurate facts and provide local management with good knowledge. This would allow correct and appropriate measures to be decided on and implemented locally, if necessary."

The action is a scoping and study step rather than a water reduction project, and it is directed at the one site identified as sitting in a water-stressed area: "One of the facilities, in Mehsana, India, is located in an area of high water stress. The groundwater in the area was classified as overexploited in 2023, putting it at risk of a future water shortage" (page 111).

Related actions appear elsewhere. Under E1-3, drought response includes water efficiency and "reusing water, for example by installing solutions to collect water from production and stormwater" (page 107). "The majority of the water is recirculated in closed systems, with varying flows depending on the level of pollution" (page 111).

No monetary amount is attached to the allocated resources, and no time horizon or completion date for the India studies is given.

Targets related to water and marine resources

Reference: page 111, which states under "Targets related to water and marine resources (E3-3)": "See page 98." The ESRS content index correspondingly gives page 98 as the location for E3-3 (page 123).

Page 98 discloses that no target has been set: "Alleima has not set group-wide sustainability targets for the areas of pollution and hazardous substances, water, biodiversity, waste circularity, or areas encompassed by responsible business conduct. These are measured and monitored through the internal framework The Alleima Way."

The Alleima Way "is a comprehensive framework designed to manage and monitor all topics defined as material in Alleima's double materiality assessment" and "includes several mandatory KPIs that are measured and monitored"; policies and procedures are reviewed annually with checkpoints "that measure whether the policy in question has been implemented in the organization" (page 98).

This answers the Minimum Disclosure Requirement on targets through the effectiveness-tracking limb rather than through a measurable water target. There is no target for water withdrawal, consumption, reuse or discharge, and none for the water-stressed site at Mehsana. The policy does commit Alleima to establish reduction commitments "where there are water supply threats or for facilities located in areas of high water stress" (page 111), but no such commitment is quantified. Water use rose 7% year on year (page 111).

Water consumption

Reference: page 111. Reporting principles are on page 125.

"The water intensity, in cubic meters per million euro revenue amounted to 2,218" (page 111).

Outcome commentary (page 111): "During the year, water use increased by 7%, mainly due to higher intake at the operations in Sandviken. Water use in water-stressed areas accounted for just over 1% of total water withdrawal and amounted to 55 thousand cubic meters (51)."

Method (page 125): "Water consumption pertains to production units... Reported intake and discharge pertain exclusively to freshwater. No wastewater is discharged into the sea, discharged into groundwater or sent to third parties for use." Water-stressed areas are those "classified as having high or extremely high water stress based on the Aqueduct water tool from the World Resources Institute (WRI)".

Total water recycled and reused (paragraph 28(c)) is marked "Not material" in Appendix 4, while total water consumption per net revenue (paragraph 29) is reported (page 127). Water storage is not reported.

Policies related to resource use and circular economy

Reference: page 112.

"Alleima's Sustainability Policy covers all units in the Group and describes the company's management and oversight of sustainability in order to ensure regulatory compliance. Alleima's material impacts, risks and opportunities are related to waste and resource inflows."

Policy content as disclosed (page 112):

• "All facilities have a responsibility to use materials and other resources as respectfully and efficiently as possible in order to reduce the need for virgin materials and energy consumption."
• "At Alleima, 100% of recycled materials must be correctly sorted and labeled to maintain the high value and quality. All generated scrap shall remain within Alleima for recycling. The sale of secondary raw materials is not permitted unless approved by the direct purchasing organization."
• "All waste is to be recycled or reused. If neither recycling nor reuse is possible, the disposal of waste to landfill is to be kept to a minimum."
• Packaging materials should be "based on renewable and recyclable materials. The use of plastics should be avoided."
• Supplier impacts on resource use and circularity are assessed under the Supplier Code of Conduct and the Procurement Policy.

The policy addresses waste, recycling and packaging; it does not describe a policy on sustainable sourcing of renewable resources or on the phase-out of virgin non-renewable resources.

Actions and resources for resource use and circularity

Reference: page 112.

Buy-back (page 112): "To increase circularity, Alleima - in collaboration with customers - has set up buy-back programs where we buy back materials from end-of-life products and waste from customer manufacturing."

Slag reuse (page 112): "Slag from steel manufacturing is the largest waste category. Alleima works continuously to reduce the amount of slag that goes to landfill and to instead identify possible alternatives. Slag, for example, has been used as a replacement for sand in the steel mill and as a construction material for depot surfaces, both with good results."

Refractory reuse (page 112): "Another area where waste is reused is magnesite-based tundish lining, which is sent externally for processing. The material is then used together with lime as a substitute for dolomite."

Value chain (page 112): Alleima's ambition "includes taking responsibility for waste generated from purchased goods as well as downstream impacts from packaging materials and the company's products", through sourcing decisions that consider recyclability and "engaging with waste management suppliers to understand what recovery operations are accessible in different regions".

No monetary resources are allocated to these actions and no completion dates are given; the downstream and packaging work is described as an ambition rather than as a project under way.

Targets related to resource use and circular economy

Reference: page 113.

"Alleima strives to continuously increase the amount of recycled steel in the products it manufactures."

This is the one quantified E5 target. Its scope is resource inflows: the share of secondary metallic material in finished products. The reported outcome is unchanged from the prior year at 80.8% (page 113), and the commentary notes that "The circularity of input materials amounted to approximately 81%, which meant that the level from the previous year was maintained despite lower volumes and continued focus on high-alloy materials and specialty steels" (page 113).

No waste or circularity target is set. Page 98 states that "Alleima has not set group-wide sustainability targets for the areas of pollution and hazardous substances, water, biodiversity, waste circularity, or areas encompassed by responsible business conduct. These are measured and monitored through the internal framework The Alleima Way." Waste circularity is therefore tracked as an outcome measure rather than against a target: 36% for total waste in 2025 (41% in 2024) and 78% excluding slag (74%) (page 113).

No base year, no target year and no interim milestones are given for the recycled-steel target, and no target is set for resource outflows, packaging or the value chain.

Resource inflows

Reference: page 113. Reporting principles are on page 126.

The materials reported are the metal raw materials Alleima names for steel production: "primary and secondary raw materials (scrap)", with production "based on advanced materials technology, and its main inputs are various metals and alloys" (page 112). Secondary metallic material is the dominant inflow, and the company's end-products "consist of more than 80% recycled steel" (page 99).

Method (page 126): the metrics cover "the metal raw materials that Alleima uses for steel production", taken "directly from manufacturing production systems" and compiled quarterly. "A circularity measure is calculated as the percentage of total weight that consists of secondary raw material."

Scope limits. The table covers metallic raw materials only. It gives no total weight of technical and biological materials used, no share of biological materials, no packaging inflows, and no split between renewable and non-renewable sources. The E5 IRO text records that "There are currently no regulatory restrictions on these raw materials" and that Alleima faces "financial risks linked to the supply and price of scrap metal" (page 112).

Resource outflows

Reference: page 113 (the ESRS content index gives page 112; the table itself is on page 113). Reporting principles are on page 126.

Alleima's resource outflow disclosure is presented entirely as a waste table. Amounts for 2025 with 2024 in brackets, split hazardous / non-hazardous:

Diverted from disposal, by recovery operation: 10,477 / 31,564 (10,990 / 31,985), of which reuse 72 / 2,885 (73 / 3,390); recycling 9,052 / 27,048 (10,072 / 27,080); incineration with energy recovery 1,353 / 1,631 (845 / 1,516).

Directed to disposal, by treatment type: 6,364 / 69,282 (7,553 / 54,998), of which incineration 776 / 74 (781 / 18); landfill 5,317 / 68,869 (6,427 / 54,469); other management methods 271 / 339 (346 / 512).

Total hazardous / non-hazardous: 16,841 / 100,847 (18,543 / 86,984). Total waste 117,688 with circularity 36% (105,527, 41%); excluding slag 49,008 with circularity 78% (49,423, 74%).

"Waste circularity declined for total waste but continued to improve when slag volumes are excluded, reaching 78% (74). For total waste, the breakdown between circular and non-circular waste was 36% / 64%" (page 113).

Not disclosed: the expected durability of products, their reparability, recyclability rates and recycled content, and recyclable content in packaging. The products-and-materials limb of E5-5 is not answered; the disclosure is a waste disclosure. Appendix 4 records paragraphs 37(d) and 39 as SFDR datapoints (page 127).

Waste

Reference: page 113, reported within "Resource outflows (E5-5)". Reporting principles are on page 126, where the section is headed "E5-5 Waste".

Total waste generated in 2025: 117,688 (2024: 105,527), of which hazardous 16,841 (18,543) and non-hazardous 100,847 (86,984). Circularity, the share not disposed of, was 36% against 41%; excluding slag, waste was 49,008 with circularity of 78% (74).

Diverted from disposal 42,041 (hazardous 10,477, non-hazardous 31,564): reuse 2,957, recycling 36,100, incineration with energy recovery 2,984. Directed to disposal 75,646 (hazardous 6,364, non-hazardous 69,282): incineration 850, landfill 74,186, other methods 610. Landfilled non-hazardous waste rose from 54,469 to 68,869, which drives the fall in total-waste circularity while the ex-slag measure improved.

"Slag from steel manufacturing is the largest waste category" (page 112). Reuse routes named are slag replacing sand in the steel mill and as construction material for depot surfaces, and magnesite-based tundish lining processed externally (page 112).

Method and its limits (page 126): waste data is reported quarterly, "categorized based on the recycling or disposal operations that take place", and quantities are "to some extent, based on estimates and calculation models... since disposed quantities are not weighed".

Note on units: the table header reads "Thousand ton" while the total rows are labelled "1,000 ton"; figures are as printed.

Policies related to own workforce

Reference: page 115.

"Alleima has a workforce of approximately 6,800, including employees and third-party workers, in more than 25 countries... Alleima strives to offer a diverse and inclusive workplace with market-based remuneration and working conditions" (page 115). Material IROs "are related to working conditions, including health and safety, and diversity".

Policy content as disclosed (page 115):

• "Health and safety risks are to be identified and managed proactively... appropriate corrective and preventive actions are to be taken for all incidents, near misses and risks that arise."
• "Strategies and practices related to diversity and inclusion are established and implemented to support a workplace characterized by diversity."
• "Work is governed by the overall People Policy... The Board has delegated ownership of the People Policy to the CEO."

Group-level commitments (page 98): the Code of Conduct rests on the UN Global Compact, the UN Universal Declaration of Human Rights and the ILO Declaration, and "The company has zero tolerance for forced labor, slave labor, and child labor".

Accountability (page 115): "The Head of Human Resources has quarterly follow-ups with the CEO... The divisions report quarterly to Group Executive Management."

Appendix 4 locates the human rights policy commitments and accident prevention policy here, while trafficking prevention is marked "Not material" (page 127).

Engaging with own workforce and workers' representatives

Reference: page 115.

Channels listed (page 115):

• "Performance and development reviews, and regular employee reviews. All employees are offered reviews at least once a year."
• "Regular function and department meetings, quarterly Alleima Update webinars with leaders in the company with the opportunity to ask questions."
• "Cooperation with local trade union representatives, formation of the European Workers Council (EWC), trade union representation on the Alleima Board."
• "Regular employee survey with subsequent dialogue."

The survey (page 115): "Alleima's employee survey is conducted twice a year and aims to continuously measure employee satisfaction, engagement, and sense of belonging... Inclusion is a separate follow-up area in the survey, and concrete actions are taken where necessary to strengthen inclusion and diversity within specific employee groups based on the survey results."

The engagement index reached "77 of 100 which was higher than the benchmark" (page 116). Two employee representatives and two deputies sit on the Board (page 97).

Not disclosed: which member of senior management or the administrative bodies holds operational responsibility for engagement with the own workforce, whether any global framework agreement is in place, and how the effectiveness of the engagement itself is assessed beyond the survey score.

Remediation and channels to raise concerns

Reference: pages 115-116. S1-3 and S1-4 are disclosed under a single combined heading.

Grievance channel (page 116): "Violations are to be reported through Alleima's whistleblower tool, Speak Up." The channel is described in the business conduct chapter: "Employees and external stakeholders can file reports through Alleima's Speak Up whistleblower service. This online service is owned and managed by the compliance function... reports can be submitted anonymously if local laws permit... there will be no retaliation taken against an employee or business partner who, in good faith, provides information about a violation" (page 121).

Use in 2025 (page 122): "In 2025, a total of 69 reports were made through the Speak Up system. Of the 69 matters reported, 18 were predicated for investigation by the business integrity function, 48 were referred back to the relevant manager... 65 of the reports had been closed by year-end, while 4 were still open." The figures are not broken down between own workforce and other reporters.

Health and safety escalation (pages 115-116): health and safety committees sit "at several locations to promote participation and consultation on all levels", and "A system has been introduced for the dissemination and sharing of information about incidents and potentially serious incidents".

Appendix 4 locates the grievance mechanism datapoint (paragraph 32(c)) here (page 127).

Taking action on material impacts on own workforce

Reference: pages 115-116, disclosed with S1-3 under a combined heading.

Health and safety (pages 115-116): "Assessing and reducing risks is a part of the company's everyday work. It is the responsibility of each Alleima unit's management to ensure that this is carried out. A task-based risk assessment method shall be used to systematically examine a job and identify hazards, evaluate the risks and specify controls." Risk assessments must involve "a trained facilitator, the local manager in charge, and the operator", and be approved by that group plus a health and safety representative. "Review is conducted continuously to understand the effectiveness of measures."

Diversity (page 116): three focus areas are described - future skills, talent recruitment ("Alleima has developed a tool to support managers in evaluation of candidates"), and three leadership programmes, the most senior run with Stockholm School of Economics Executive Education. "In 2025, 23 managers completed the Accelerate and GoBeyond program." An ambassador programme runs in Sweden, and in India the company "offers diversity and inclusion courses in collaboration with Business Sweden".

Effectiveness (page 116): tracked through TRIFR, which fell to 5.1 from 7.1, leading indicators on local EHS plans, hazards and near misses "and the percentage of these that have been managed and closed out", and the engagement index of 77 of 100.

Targets related to own workforce

Reference: page 116.

Target setting (page 116): "The overall target in health and safety is to be ambitious and attainable and, over a long-term time horizon, help Alleima to make clear progress towards its vision of zero accidents. Proposed targets are prepared by the Sustainability Council... Proposals are decided on by Group Executive Management, and final approval is obtained from the Board."

Cascade and monitoring (page 116): "The divisions engage their units to prepare local plans with annual milestones... Implementation of the plans is followed up at the division level, and safety KPIs such as accident frequency are monitored by management teams at every level on a monthly basis." A dedicated environment, health and safety team addresses Group-wide improvement matters.

The second target is qualitative in wording but measured through the engagement index. No target is set for diversity as such, for training hours, turnover or pay equity. Nothing in the report states that the workforce was consulted in setting the targets.

Characteristics of employees

Reference: page 117. Reporting principles are on page 126, and further personnel information is incorporated by reference to Note 3, page 54 (page 96).

Head count 2025 (2024 in brackets): 6,696 (6,543). By gender: male 5,142 (5,098), female 1,550 (1,438), other 0 (0), not reported 5 (8).

By country, where Alleima has at least 50 employees representing at least 10% of the total: Sweden 3,494 (3,408), USA 789 (783), Czech Republic 748 (747), other countries 1,666 (1,606).

By contract type and gender: permanent 6,499 (6,347), temporary 197 (197), non-guaranteed hours 0 (0); full-time 6,447 (6,313), part-time 249 (230).

By contract type and region: Europe 5,137 (5,026), North America 819 (819), Asia 740 (699), other 0 (0); permanent 5,011 / 819 / 669, temporary 126 / 0 / 71.

Turnover: terminated positions 711 (779), giving an employee turnover rate of 10.6% (12.0%). The rate is defined as "number of terminated positions in relation to the average number of employees" (page 117).

Method (page 126): personnel data comes from a Group-wide system "as of December 31 of the financial year", and "Reported values pertain to head count unless otherwise stated".

The S1-1 policy section gives a wider figure of "approximately 6,800, including employees and third-party workers" (page 115); the S1-6 table covers employees only. No reconciliation to the financial statements is presented in the sustainability chapter.

Diversity metrics

Reference: page 117. Reporting principles are on page 126.

Top management by gender, % (2025, with 2024 in brackets):

Age distribution, number of employees (2025, 2024): under 30 - 781 (710); 30-50 - 3,300 (3,274); over 50 - 2,616 (2,560). Total 6,696 (6,543).

The female share of Group Executive Management fell year on year from 30% to 25%, while senior management rose from 42% to 45%. Board diversity is reported separately under GOV-1: "Two of the seven members (approximately 29%) elected by the AGM are women" (page 97), and Appendix 4 records the Board gender diversity datapoint at pages 90 and 97 (page 127).

Method (page 126): diversity data comes from the Group-wide personnel system "as of December 31 of the financial year", and reported values "pertain to head count unless otherwise stated". The reported information "is derived from established reporting processes for KPIs in S1-9 and S1-14, with these KPIs representing an important aspect of internal performance follow-up".

Gender is the only diversity dimension quantified for management. Diversity is one of the two material S1 sub-topics (page 102), and the qualitative actions supporting it are described under S1-4 (page 116), but no target is set against these metrics.

Health and safety metrics

Reference: page 117. Reporting principles are on page 126.

"During the year, TRIFR developed favorably, reducing to 5.1 (7.1). In 2025, 60 injuries were reported among employees and non-employees at Alleima's locations (85). The most common accidents were hand and finger injuries" (page 116).

Management system coverage is reported qualitatively rather than as a percentage: "All major facilities are certified according to ISO 45001, which also covers third-party workers" (page 115), and all major locations were covered by a third-party verified system at end-2025 (page 97).

Method (page 126): frequency rates are "normalized to express the number of accidents per million hours worked"; work-related accidents comprise fatal injuries, lost time injuries, restricted work injuries and medical treatment injuries.

Not reported: cases of recordable work-related ill health, and days lost to ill health as distinct from incidents.

Policies related to value chain workers

Reference: page 118.

"Alleima strives to ensure that human rights and good working conditions are respected throughout the value chain. The Supplier Code of Conduct sets out requirements for compliance with applicable legislation, including in areas such as health, safety and the working environment" (page 118).

Policy content as disclosed (page 118):

• "Sustainable procurement and sourcing practices are to be implemented in order to systematically evaluate and monitor suppliers... Efforts are to be made to get all suppliers to sign Alleima's Supplier Code of Conduct and to ensure their compliance."
• "Conflict minerals originating from conflict or high-risk areas must comply with the requirements of EU directives, OECD due diligence processes or national legislation... Alleima undertakes to refrain from any action that contributes to financing conflicts."

Group Executive Management owns the Supplier Code of Conduct and the Procurement Policy (pages 98, 125). The Codes of Conduct are grounded in the UN Global Compact, the UN Universal Declaration of Human Rights and the ILO Declaration (page 98).

Appendix 4 locates the S2-1 human rights policy commitments and the UNGP and OECD datapoints here, and the ILO due diligence policies at page 98 (page 128).

Index note: the S2 rows of the ESRS content index are printed with S1 codes although the titles are the S2 titles, which appears to be a typographical error (page 124).

Engaging with value chain workers

Reference: page 118, which states under "Processes for engaging with value chain workers about impacts (S2-2)": "For information on processes for engaging with value chain workers, see the section 'Sustainable sourcing' on page 121."

The cross-referenced material describes engagement with suppliers rather than with value chain workers or their representatives directly (pages 121-122): "Through a structured supplier evaluation process, Alleima works to identify, prevent, mitigate and address the supply chain's negative impacts on the environment and human rights. The process is based on the OECD Due Diligence Guidance for Responsible Business Conduct." The process "includes controls such as risk screening, sustainability performance evaluation and audits. The tools... are provided by EcoVadis." Audits "include document reviews, site visits and interviews with supplier employees".

The audit interviews are the only channel described that reaches workers themselves. Under SBM-2, "Local communities and workers in the value chain" are engaged through "Continuous dialogue, consultation committees" (page 99).

Not disclosed: which function or role holds operational responsibility for engagement with value chain workers, the stage and frequency of engagement, and how Alleima assesses the effectiveness of that engagement.

Remediation and grievance channels for value chain workers

Reference: page 118.

"Alleima's commitment to human rights covers the entire supply chain, Alleima's own operations and its dialogue with suppliers. Alleima's approach to responsible supplier management is based on the six stages of the OECD Due Diligence Guidance for Responsible Business Conduct" (page 118).

"Human rights due diligence (HRDD) is an integral part of the governance of Alleima's processes... such as having a safe and healthy workplace with fair wages and no harassment... with no child or forced labor. HRDD is also included in assessments of potential acquisitions, major investments and significant business restructuring" (page 118).

Verification (page 118): suppliers must "provide a safe and healthy work environment... Compliance is verified through multiple checkpoints, including but not limited to audits of the physical environment and equipment, procedures and control measures."

Channel (page 118): "Employees and partners are expected to alert Alleima to any violation of the company's Codes of Conduct and policies as well as applicable laws and regulations in countries where the company operates." Speak Up is open to external stakeholders, permits anonymous reports where local law allows, and carries a non-retaliation commitment (page 121).

Not disclosed: whether value chain workers are aware of and trust the channel, or whether remedy was provided during the year.

Taking action on material impacts on value chain workers

Reference: page 119.

"Work related to supplier sustainability evaluations continued during the year according to the defined procedures... This is a common process for the entire company and shall be carried out globally by purchasing organizations. Purchasers are to have the necessary training to effectively follow the company's procedure for sustainable sourcing" (page 119).

Corrective action and escalation (page 119): "The company continued with its active approach of using corrective action plans for managing improvement activities and deviations... Alleima applied an escalation process... in certain cases this process can result in the partnership being terminated. No contracts were terminated during the year as a result of violations of the Supplier Code of Conduct."

Effectiveness (page 119): "During the year, work on risks in the supply chain continued, resulting in increased compliance with the requirements of our Supplier Code of Conduct. This year's risk screening shows that supplier risks have decreased compared with the previous year."

Supporting figures sit under G1-2 (page 122): 346 EcoVadis evaluations covering 43% of the target group's purchasing value; six third-party audits in the year; 131 suppliers with potential significant negative environmental impact and 229 with social impact.

Targets related to value chain workers

Reference: page 119, which states under "Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities (S2-5)": "See page 98." The ESRS content index correspondingly gives page 98 as the location (page 124).

Page 98 discloses that no target has been set for this area: "Alleima has not set group-wide sustainability targets for the areas of pollution and hazardous substances, water, biodiversity, waste circularity, or areas encompassed by responsible business conduct. These are measured and monitored through the internal framework The Alleima Way." The Alleima Way "includes several mandatory KPIs that are measured and monitored", and "Policies and procedures are reviewed on an annual basis, including a follow-up of their appropriateness and effectiveness" (page 98).

This answers the Minimum Disclosure Requirement on targets through the effectiveness-tracking limb rather than a measurable outcome target for value chain workers. What is tracked, reported under G1-2 (page 122), is process coverage: Supplier Code of Conduct signed by contracted suppliers 91% of relevant spend (2024: 90); risk-screened suppliers 90% (87); complies with requirements 75% (63).

No target year, baseline or target value is given for any of these measures, and value chain workers were not involved in setting targets according to anything stated in the report.

Business conduct policies and corporate culture

Reference: page 120.

"At Alleima, ethical business conduct means a business that is conducted with honesty and integrity, where all employees, contractors and partners comply with legal requirements as well as the highest ethical standards" (page 120).

Policies (page 120): "Alleima's Code of Conduct describes the business principles in selected areas of the business operations. All employees, as well as consultants on long-term contracts, are to receive Code of Conduct training within 90 days of employment." Ethics programmes address "anti-bribery and corruption, trade, competition law and general data protection".

Governance of the policy (page 120): "The Board is responsible for the Ethics and Compliance Policy. Policy revisions are prepared by the Audit Committee and decided by the Board. The company's compliance function regularly reports to the Audit Committee about the implementation of the policy, including the effectiveness of the entire compliance program."

Monitoring corporate culture (page 120): the policy "is further supported by Compliance House, a tool used to monitor effectiveness and performance... the tool supports the organization in identifying and addressing any shortcomings."

Whistleblower protection (page 121): reports may be anonymous where local law permits, with no retaliation against anyone reporting in good faith.

Management of relationships with suppliers

Reference: pages 121-122 ("Long-term sustainable sourcing").

"Alleima has thousands of suppliers in nearly 60 countries... all our suppliers are expected to commit to, and comply with, Alleima's Supplier Code of Conduct" (page 121).

Process (page 121): supplier evaluation is "based on the OECD Due Diligence Guidance for Responsible Business Conduct" and includes "risk screening, sustainability performance evaluation and audits. The tools... are provided by EcoVadis."

Outcome 2025, percentage of relevant spend (2024 in brackets), page 122: Supplier Code of Conduct signed 91% (90); risk-screened suppliers 90% (87); complies with Code requirements 75% (63). Purchasers attending sustainability courses: overall 60% (57), supplier evaluation 68% (63), sustainability for sourcing 79% (56), circularity 78% (49), climate 77% (47).

Evaluations and audits (page 122): 346 EcoVadis evaluations "corresponding to 43% of the total purchasing value for the target group"; 13% of covered purchasing value audited so far, six audits during the year; 131 suppliers identified with potential significant negative environmental impact and 229 with social impact.

Responsible minerals (page 122): Alleima "sources minerals and metals exclusively from suppliers that are approved in RMI's third-party review", and 100% of suppliers surveyed returned Conflict Minerals Reporting Templates.

Prevention and detection of corruption and bribery

Reference: page 122.

"Alleima has business partners in many regions around the world and there is a risk of corruption and bribery in various parts of the company's value chain... The principle of the program stems from the US Foreign Corrupt Practices Act, the UK Bribery Act and other national legislation" (page 122).

The programme "includes risk identification and risk assessment, control elements such as policies, procedures and instructions, and control activities such as record keeping, advice, and support. Training is an important part of the program" (page 122).

Metric (page 122): employees trained in anti-bribery and anti-corruption, "Share trained in functions at risk: 71%". No comparative is given, because this is Alleima's first ESRS report and comparatives are unavailable for G1-3 (page 96).

Wider compliance programme (page 121): six areas - "anti-bribery and corruption, the Speak Up whistleblower mechanism, competition law, trade compliance and sanctions, customs, and data privacy". "A Compliance House review is carried out annually for the entire business... Any new compliance risks noted were assigned an action plan with a timeline for completion."

Method (page 126): training data is "documented in Alleima's personnel management system based on attendance records... Employees in at-risk functions have been marked in the reports from the personnel system."

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. G1-3 became a standalone targets DR only in the 2025/2026 ESRS.

The report carries the heading explicitly. On page 122, under "Targets and metrics", it prints "Targets related to business conduct (G1) - See page 98."

Alleima discloses that no group-wide business conduct target is set (page 98): "Alleima has not set group-wide sustainability targets for the areas of pollution and hazardous substances, water, biodiversity, waste circularity, or areas encompassed by responsible business conduct."

Consistent with the second limb of MDR-T, effectiveness is tracked in the absence of a target:

• The Alleima Way "includes several mandatory KPIs that are measured and monitored" (page 98).
• "Policies and procedures are reviewed on an annual basis, including a follow-up of their appropriateness and effectiveness" (page 98).
• "A Compliance House review is carried out annually for the entire business... Any new compliance risks noted were assigned an action plan with a timeline for completion" (page 121).
• Outcome measures without target values: 71% of employees in at-risk functions trained; 91% of relevant spend covered by a signed Supplier Code of Conduct; 69 Speak Up reports, 65 closed by year-end (page 122).

No target value, baseline year or target date is given for any of these measures.

Incidents of corruption or bribery

Reference: page 122.

"Incidents of corruption and bribery (G1-4): During the year, no convictions or fines regarding corruption and bribery were imposed on Alleima."

Whistleblowing volume and handling (page 122): "In 2025, a total of 69 reports were made through the Speak Up system. Of the 69 matters reported, 18 were predicated for investigation by the business integrity function, 48 were referred back to the relevant manager for appropriate investigation and action, and 3 were recorded but deemed not to require any further action. 65 of the reports had been closed by year-end, while 4 were still open." The reports are not classified by subject.

Method and its limits (page 126): whistleblower data is "treated with high level of confidentiality... This means that access to the original information is limited and the data is thus not subjected to further quality checks." Convictions data is "reported directly by the compliance function".

The nil return on convictions and fines is a complete answer to the paragraph 24 datapoints. Not separately reported are the number of confirmed incidents of corruption or bribery, the number of confirmed incidents in which own workers were dismissed or disciplined, and the number of confirmed incidents relating to contracts with business partners.

Appendix 4 records the G1-4 24(a) fines datapoint and 24(b) anti-corruption standards here (page 128).