Alm Brand

Reference: pages 44-46, 48.

The Board of Directors sets the strategy and overall risk appetite for sustainability topics through the policy and guidelines on corporate social responsibility, and mandates the Executive Management to execute it. Three of the nine Board members are elected by employees, and the Board has an equal gender distribution "as measured according to statutory requirements." The audit committee is authorised to examine audit, accounting and sustainability matters and reviews the sustainability reporting process, meeting at least four times a year. Day-to-day responsibility sits with the Executive Management and an ESG steering committee, which meets at least every two months and considered items including the ESG strategy, GHG emission targets, the climate transition plan and circular economy opportunities during the reporting period. Sustainability experts have been employed to support the ESG steering committee and Executive Management with the required skills and expertise.

Reference: pages 44-45, 47-48.

During the reporting period the Board of Directors considered material impacts, risks and opportunities including "human costs of climate challenges," a climate report on Danish consumers' preparation for extreme weather that the group co-funded, and "preventing claims, including claims caused by climate change." The audit committee receives sustainability reporting from the Executive Management and monitors the integrity of the sustainability reporting process, but "has not addressed any material sustainability impacts, risks or opportunities other than its work on the sustainability report." The ESG steering committee's 2025 agenda covered revisiting the double materiality assessment, the group's GHG emissions and targets, employee and customer satisfaction targets, the climate transition plan, circular economy opportunities and the Employee Code of Conduct.

Reference: page 46; corporate governance section, remuneration policy.

"Board members receive a fixed annual remuneration and do not receive variable remuneration," so no incentive scheme applies at Board level. The Executive Management is remunerated by a salary intended to be competitive with similar financial-sector positions, part of it paid in shares in Alm. Brand A/S, plus a pension contribution and other standard benefits; the remuneration policy is approved by the general meeting and reviewed annually. The report does not describe any element of Executive Management pay that is linked to sustainability-related performance indicators, and no sustainability-linked incentive scheme is otherwise disclosed in the 2025 statement.

Reference: page 49.

The purpose of the group's due diligence process "is to ensure that negative impacts on the environment and people are identified and addressed," with the aim of mitigating negative impacts and addressing derivative risks. A table maps the core elements of due diligence (embedding in governance/strategy, engaging affected stakeholders, identifying and assessing adverse impacts, taking action, tracking effectiveness) to the disclosure requirements where each is reflected, spanning ESRS 2 GOV-2/GOV-3/SBM-2/SBM-3/IRO-1 and the topical standards E1, E5, S1, S2 and S4, each with a page reference and a tag for whether it relates to people, the environment, or both.

Reference: pages 49-50.

The sustainability statement "is anchored in the Board of Directors and Executive Management," with transparency and measurability described as the cornerstones of the group's sustainability efforts. Data for sustainability reporting is initiated, registered and processed "according to a fundamental two-party approval principle," and follows the same approval process as financial reporting. "ESG-related transactions were not included in the periodic reporting to management in 2025," and no periodic reporting is carried out on the ongoing effectiveness of the internal control environment for the non-financial part of reporting, although some emissions data forms part of the financial control environment. Insurance exposure to climate-related risk is reviewed annually as part of the double materiality assessment process.

Reference: pages 50-53.

Alm. Brand Group is "one of the largest non-life insurance companies in Denmark with more than 800,000 customers and a market share of about 15%." The 2022 acquisition of Codan Forsikring's Danish business roughly doubled the group's size, and integration was completed in 2025 with synergies of DKK 618 million realised. In November 2025 the group announced strategic targets for the period to 2028 alongside a new ESG strategy that, "for the first time," sets targets for reducing GHG emissions from claims repair services and investments. Core values are described as "We are ambitious," "We demonstrate trust" and "We exercise proper conduct."

Reference: page 54.

Engaging with the interests and views of internal and external stakeholders is described as "an essential task" so these views can feed into the group's strategy, business model and double materiality assessment. A stakeholder table sets out five groups - customers, employees, suppliers, investors and society (authorities, regulators, staff associations) - together with the channels used (satisfaction surveys, hotlines, board and investor meetings, supplier screening, inspections and working groups) and the purpose of each engagement, for example strengthening customer satisfaction and retention or ensuring regulatory compliance. Material impacts, risks and opportunities identified through this engagement are cross-referenced to the IRO-1 matrix and the topical IRO tables from page 58.

Reference: pages 54-61.

The 2025 double materiality assessment confirms E1 Climate change, E5 Resource use and circular economy, S1 Own workforce, S2 Workers in the value chain, S4 Consumers and end-users and G1 Business conduct as material, with per-topic IRO tables running from page 58. S4 is new this year: "we chose to re-assess S4 on consumers and end-users in 2025... These interviews led to S4 being assessed as material, which means that the standard is included in this year's sustainability statement." E2 Pollution, E3 Water and marine resources, E4 Biodiversity and S3 Affected communities remain not material, largely because the group's own environmental footprint is small relative to Scope 3 and data on the value chain is limited.

Reference: pages 55-57.

The double materiality assessment follows "the methodology and recommendations of EFRAG and relevant legislation," unchanged in method from the prior year, screening topics for relevance to strategy, business model and value chain, then assessing impact materiality (scale, scope, irremediable character, likelihood) and financial materiality (potential scale, likelihood) on a 1-5 scale. Interviews with employees representing key stakeholders fed the assessment; last year's material standards were maintained except that new interviews led to S4 being reassessed as material in 2025. The group states it "did not identify any material impacts, risks or opportunities within the standards regarding E2 Pollution, E3 Water and marine resources, E4 Biodiversity and S3 Affected communities," citing limited data on indirect, value-chain-driven impacts and no standardised methodology for assessing them.

Reference: pages 41-45, 61-67.

The sustainability statement's contents list of disclosure requirements sets out the ESRS 2, E1, E5, S1, S2, S4 and G1 disclosure requirements covered, each with a page reference. Appendix B lists datapoints deriving from other EU legislation (SFDR, Pillar 3, Benchmark Regulation, EU Climate Law) and marks each "Material" or "Not material" with a page reference where material. Using the phase-in option of ESRS 1 Appendix C for undertakings exceeding 750 FTEs, the group has omitted ESRS 2 SBM-1 paragraph 40(b) (revenue breakdown by ESRS sector), ESRS 2 SBM-3 paragraph 48(e) (quantified financial effects), ESRS E1-9, ESRS E5-6 and ESRS S1-13 (training and skills development), citing sector standards not yet finalised or impracticability of quantification in the first years of reporting.

Reference: page 70.

The group has "established the framework for a climate change transition plan" aimed at a 42% reduction in Scope 1 and 2 CO2 emissions by 2030 against a 2024 base year. Notably, the report states plainly: "We are working to concretise the relevant actions in the preparation of the transition plan, so there is no transition plan aligned with the Paris Agreement. As this work remains pending, the transition plan in its current format is not aligned with the Paris Agreement." The new 2028 ESG strategy expands the plan with a stronger Scope 3 focus, covering investments and claims-repair materials. No OpEx or CapEx has yet been earmarked for the plan, and the group states it has not identified any locked-in GHG emissions that would block the targets.

Reference: pages 70-72.

The climate change section of the group's policy and guidelines on corporate social responsibility commits to reducing Scope 1 and 2 emissions through optimising leased premises and monitoring energy consumption, and sets a direction for reducing Scope 3 emissions from claims-repair materials and the investment portfolio, including a commitment to the UN Principles for Responsible Investment. The policy, updated and Board-approved at the end of 2025, added a "Customers and end-users" section reflecting S4's new materiality. A separate investment-area policy sets exclusion criteria, including companies where "more than 5% of the capital expenditure for expansion of production (CapEx) is spent in contravention of the IEA's Net Zero Emissions Scenario" or over 5% of turnover derives from thermal coal, unconventional oil and gas, or Arctic drilling.

Reference: pages 72-73.

For Scope 1 and 2, actions include connecting locations to district heating "where possible" and a gradual transition of the leased car fleet to electric vehicles, plus building and stationery efficiency measures; if these optimisations fall short the group may purchase "additionality or certificates of origin." For the investment portfolio, actions centre on monitoring the share of assets already covered by Paris-aligned benchmarks or other sustainability criteria and reallocating from more emission-intensive holdings where the monitoring indicates a need. For claims-repair emissions, the group is "actively working to reduce the climate footprint of our claims repairs through increased focus on using more CO2e-reducing materials" in partnership with repair suppliers.

Reference: pages 72-73.

Scope 1 and 2 targets: a 42% reduction by 2030 from a 2024 base year, set using the GHG Protocol and an Absolute Contraction Approach; the report describes these as "aligned with the provisions of the Paris Agreement and use a science-based approach," while separately noting the transition plan itself has "not been subjected to external validation." Two new Scope 3 targets use 2025 as base year: a 15% cut in the CO2e intensity of the investment portfolio by 2026-2028, covering about 90% of portfolio value (excluding illiquid assets); and a 6% cut in emissions intensity per claim for building claims repairs by 2028, calculated per repaired claim. No long-term or 2050 target is stated in the narrative, notwithstanding the ESRS datapoint index marking "Transition plan to reach climate neutrality by 2050" as material on this page.

Reference: pages 73-74.

Total energy consumption fell from 7,321 MWh in 2024 to 6,593 MWh in 2025, a 10% decrease "primarily due to efficiency improvements." Fossil energy consumption fell from 5,527 to 4,734 MWh (a 14% decrease), taking the fossil share of total consumption from 75.5% to 71.8%. Renewable energy consumption fell slightly, from 1,542 to 1,399 MWh, though the renewable share held at 21%; the decline is attributed to "external factors in the form of changes in the composition of external energy sources," reflecting the national grid mix rather than the group's own actions. As an insurer (NACE sector K), the group states lines 1-5 of the standard energy table (high climate-impact sector breakdown) "are not disclosed," and 2024 comparatives have been restated by 2,339 MWh.

Reference: pages 74-79.

Gross Scope 1 emissions fell 39% year on year, from 599 to 366 tCO2e; Scope 2 fell 15% location-based (255 to 218 tCO2e) and 7% market-based (1,591 to 1,485 tCO2e). Scope 3, calculated across three reported categories, rose 11% to 296,575 tCO2e (location-based total 297,159 tCO2e), representing "approximately 99% of our total reported emissions." Category 11 (use of sold products / claims repairs) fell 10% to 89,529 tCO2e; Category 1 (purchased goods and services) fell 2% to 46,118 tCO2e; Category 15 (investments) rose 32% to 160,928 tCO2e, mainly from covered and mortgage bonds. GHG intensity per net revenue rose from 24.24 to 25.21 tCO2e/DKKm (location-based). No external validation of the emissions measurement was performed, "as last year."

Back-filled from the E1-SBM-3 section (Material impacts, risks and opportunities and their interaction with strategy and business model), where this content is disclosed in the FY2025 report (pages 68-69, repeated at page 81). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Alm. Brand ran a climate scenario analysis in 2023/2024 using the IPCC's RCP scenarios: "RCP2.6 and RCP8.5, representing a 2-degree scenario and a high-emission scenario, respectively, with a time horizon up to 2050." Scope was product-level - building, personal accident, motor and liability insurance, across the Personal, Commercial, Agriculture and Industry business areas - covering both physical risks (temperature rises, increased precipitation) and transition risks (technological and fuel-related change). "No new climate scenario analysis was performed in 2025 as the available data used as a basis are not considered to have changed significantly since the analysis in 2023/2024, and the results are still considered valid." No 1.5°C-aligned transition scenario with limited overshoot is named, and no explicit global-average-temperature projection is given beyond the "2-degree" and "high-emission" labels - a gap against ESRS AR6(a)(ii)-(iii) worth noting.

Back-filled from the E1-SBM-3 and E1-IRO-1 sections, where this content is disclosed in the FY2025 report (pages 68-70). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The report does not state, either way, whether a formal resilience analysis "as defined under the ESRS" was performed - unlike the explicit disclaimer some peers give. The closest material is the 2023/2024 scenario analysis conclusion that "with our current governance, we are able to mitigate identified risks, but that, due to the assumption of more severe weather events, we must better ensure the right coverage in relevant products," and three resulting recommendations, of which only one (revising motor and building products) has been substantially addressed; the other two - preparing quantitative cross-product scenarios and updating the climate risk register - show "limited" progress. The 2025 ORSA report separately notes climate risk "has not yet had a significant impact on the company's profitability," managed through "preventive measures, correct risk assessment and continuous price adjustments" - evidence of an adjustment capacity, though not a formal ESRS resilience analysis.

Reference: pages 89-90.

Circular economy commitments sit in a dedicated section of the corporate social responsibility policy and in the group's Partner Code of Conduct. The CSR policy "outlines our commitment to promoting a circular economy in connection with claims repairs and our strategic focus areas of recycling and repair," on the basis that "as a non-life insurance company, our greatest potential for promoting the circular economy lies in claims repairs," which requires close supplier collaboration. The Partner Code of Conduct's climate and environment section asks suppliers "to prevent and reduce resource consumption" through reuse, recycling and material optimisation, and to promote sustainable solutions that reduce the climate impact of claims repairs.

Reference: page 90.

Actions centre on claims-repair partnerships: the group works with suppliers "to develop and use more sustainable solutions, including by increasingly repairing claims, increasing reuse, recycling and optimising materials in repairs," citing electronic-device repair as an example of favouring repair over replacement. The stated aim is to reduce the use of new materials, extend the life of existing products and thereby reduce the environmental footprint of claims handling, alongside E5-1's Partner Code of Conduct requirements on suppliers.

Reference: page 90.

No quantified target is set. The report states plainly: "the data underlying our efforts to promote repair and recycling are currently insufficient to measure and validate the actual impact, and therefore the group has not yet set specific targets or defined a timeframe for setting targets in this area." The group nonetheless commits to continuing its "strategic focus areas of repair and recycling" and says it is "looking into developing specific targets for our circular economy efforts in order to be able to track the effectiveness of our actions in this area."

Reference: pages 95-97.

Alm. Brand complies with the UN's Universal Declaration of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work, backed by a staff policy and recruitment policy that prohibit differential treatment on grounds including gender, age, ethnicity and disability, and the group "enforce[s] zero tolerance to human rights violations." In 2025 it introduced an Employee Code of Conduct, delivered through mandatory annual e-learning covering working conditions, human rights, business conduct and data ethics. New initiatives launched in 2025 address abusive behaviour from customers or partners towards staff, with managers required to brief customer-facing teams on how to respond, and a dedicated reporting channel involving HR and the manager together.

Reference: pages 97-98.

A consultation committee with employee-elected representatives from three staff associations must be notified of significant changes before implementation, and meets quarterly plus in extraordinary sessions. Engagement channels include an annual engagement survey, semi-annual and annual development interviews, and a quarterly "PULSE" pulse-check survey covering workload and wellbeing. "The Blue Hour," launched in 2023, is a quarterly dialogue format giving employees direct access to the Executive Management to discuss topics they find important.

Reference: page 98.

Employees are encouraged to raise concerns with their manager or HR, or through a whistleblower scheme run by an external legal adviser, covering matters "including financial crime, personal data breaches and severe harm to the environment." Reports are handled confidentially, and whistleblowers "are protected against retaliation under Danish law." A documented business procedure governs how reported concerns are handled, involving the external adviser plus compliance and HR staff, and HR "follows up on and monitors reported concerns to ensure they are handled properly and effectively."

Reference: pages 98-100.

Actions include health insurance extending to household members, flexible part-time working with full pension contributions, and an annual "Working Environment Camp" where staff and management representatives review incidents and plan the year ahead; the 2025 camp addressed "psychological first aid" and workplace threats, leading to a manager training course launching in early 2026. Effectiveness is tracked through the satisfaction surveys, interviews and PULSE checks described under S1-2. Guidelines on employee relationships require disclosure of workplace relationships to avoid conflicts of interest. The 2025 exit-interview process "was temporarily suspended, but it will be resumed again in 2026."

Reference: pages 100-101.

Two targets: a 40%-by-2030 target for the under-represented gender at senior management levels, set out in the CSR policy, which the report confirms "was still met on the balance sheet date, both at the top management level and at other management levels"; and an employee satisfaction target of 80 or above (on a 0-100 scale), against which the group scored 79 in 2025 at a 91% survey response rate, prepared with supplier Ennova and carried forward as the 2026-2028 group-strategy target.

Reference: pages 101-102.

Headcount fell from 2,356 (2024) to 2,245 employees in 2025, of which 1,436 male and 809 female. 91% were permanent employees (2,053 of 2,245). By age, 21% were under 30, 52% aged 30-50 and 27% over 50. Employee turnover rose from 20.3% to 21.5% (255 voluntary, 234 involuntary departures), which the report attributes "partly as a result of organisational changes," noting the 2025 figure "excludes divested business."

Reference: page 102.

"98% (2024: 96%) of Alm. Brand Group's employees are employed under prevailing collective agreements" negotiated between Forsikring og Pension and relevant trade unions, or between the group and local staff associations. The same 98% are represented by employee representatives through those agreements, covering the staff association for insurance-industry employees, Assurandørforeningen for tied agents and ABC-foreningen for managers and specialists, each with access to representation in individual cases subject to membership.

Reference: page 101.

At top management level (the six shareholder-elected Board members, excluding employee representatives), the split is 3 male / 3 female (50%). Including the three employee-elected Board members, the ratio moves to 5 male / 4 female (44%), as "two [of the three employee-elected members] are men." Other management levels (the four-member Group Executive Management) are 3 male / 1 female (25% under-represented gender), down from 40% in 2024.

Reference: pages 102-103.

"In 2025, there were no deaths among own employees due to work-related injuries or work-related ill health." The group recorded 11 work-related accidents, unchanged from 2024's 11. A health and safety manager, committee and organisation oversee physical and psychological working conditions; employees are "mainly office workers," so work-related injuries are described as rare. An electronic working-environment reporting channel is available via the intranet alongside the option to contact a manager or HR directly.

Reference: page 103.

8.6% of employees took family-related leave in 2025, down from 9.1% in 2024 (8.8% of men, 8.2% of women who took leave). Employees covered by the insurance-industry or ABC collective agreements receive up to 26 weeks of paid maternity/parental leave for both parents plus pension contributions during unpaid leave for up to 52 weeks after birth, in addition to statutory minimums, plus up to six care days a year and paid time off for child illness and family events.

Reference: page 103.

The unadjusted gender pay gap was 15.3% in 2025, narrowing from 16.7% in 2024. The annual total remuneration ratio of the highest-paid individual to the median employee, including the Executive Management, rose from 17.4 to 19.4. A group-wide job-architecture exercise is underway "to improve the quality, validity and transparency of pay setting," partly in preparation for the EU Pay Transparency Directive (2023/970), expected to be transposed into Danish law in 2026.

Reference: page 103.

The group received 6 allegations of discriminatory treatment in 2025 across structured and unstructured channels (down from 11 in 2024), of which one was reported through the whistleblower scheme, which sits with the compliance department. "We paid no fines, penalties or similar as a result of discriminatory treatment in 2025 (2024: 0)." Complaint channels include the whistleblower scheme, an internal psychological-working-environment channel, and a collective-agreement reporting channel.

Reference: pages 104-105.

The CSR policy and the Partner Code of Conduct together set requirements for value chain workers, based on the UN's Universal Declaration of Human Rights, the UN Global Compact and core ILO Conventions, covering working time, adequate wages, health and safety, gender equality, diversity, child and forced labour, and adequate housing, plus "a prohibition against making the group complicit in human rights violations." The Partner Code of Conduct was updated in early 2025 to add an explicit prohibition on human trafficking. The report notes the group has "not fully implemented" the UN Guiding Principles on Business and Human Rights or the OECD Guidelines, relying instead on supplier compliance with the Code.

Reference: page 105.

"In 2025, we had no direct engagement with value chain workers or their representatives about impacts." Any future engagement would follow "a situation-adapted approach," potentially via the whistleblower scheme; no timing, type or frequency of engagement has been determined, and no global framework agreements are in place. Responsibility sits with the Head of Procurement, and the group notes its Danish activities fall under "the Danish labour market model, which supports a high level of labour rights."

Reference: page 106.

Value chain workers can raise concerns primarily through the whistleblower scheme described under G1-1, which is publicly available and which suppliers must, per the Partner Code of Conduct, tell their own employees about. The updated Partner Code of Conduct is attached when new supplier agreements are concluded. The current status of the ESG screening process, intended to map and address value-chain ESG risks, is described in more detail under S2-4.

Reference: page 106.

The group states directly that "no specific actions or processes have been implemented to prevent, mitigate or remediate material negative impacts on value chain workers" beyond the general Partner Code of Conduct and whistleblower channel, and that there are "no reports of known severe human rights issues and incidents in our value chain" to date. An ESG supplier-screening process, planned for 2025, remains "in a development and data collection phase," targeted for structured implementation during 2026. Separately, the group joined the Danish Insurance Association's "ESG-Auto" initiative, launched September 2025, to standardise sustainability data collection from repair workshops across the motor insurance industry.

Reference: page 107.

No target has been set: "We have not yet established targets for workers in the value chain as we are in a development and data collection phase." The group links future target-setting to the rollout of the ESG supplier-screening process, expected during 2026, which it intends to use "to monitor impacts, risks and opportunities in connection with supplier agreements on an ongoing basis."

Reference: pages 109-110.

Policies cover complaints handling (overseen by the Head of Group Legal, following Danish Insurance Complaints Board guidelines, with dedicated complaints officers per business area), data ethics (a Board-reviewed policy governing GDPR-compliant processing, breach reporting to the Danish Data Protection Agency, and data-subject rights requests) and product oversight and governance, which sets out approval and ongoing review processes to ensure products match target-market needs. The CSR policy separately commits the group to customer satisfaction surveys and to treating customers "with respect, listened to and treated well in all their interactions."

Reference: pages 110-111.

Customers are reached via customer service and email hotlines, with satisfaction survey data collected continuously and consolidated into a quarterly score reported to senior management. New advisers complete structured onboarding at the Insurance Academy (ForsikringsAkademiet) with supervised exams; existing advisers are supported by team coaches, managers and digital tools, backed by spot checks and quality reviews, "and errors are corrected in order to meet internal standards and customer expectations."

Reference: page 111.

Complaint options "are clearly stated on our websites," with step-by-step guidance for customers, and complaints are used to identify and mitigate negative product impacts as part of product development. Customers "can submit reports anonymously via our whistleblower scheme," in addition to the usual complaints unit, and the group commits to handling all complaints "seriously and in accordance with applicable legislation and the group's values."

Reference: pages 111-112.

Prevention initiatives launched or continued in 2025 include an online prevention "universe" with guidance on weather, motor and identity-theft risks; "Klimaklar," a climate-resilience offer developed with NRGi that gives customers a property inspection and a tailored climate-proofing plan; "Forebyggelsestjekket," a prevention check for agricultural businesses covering fire, climate and cyber risk; and mandatory employee GDPR e-learning to reduce data-processing risk. Product oversight and governance processes continuously monitor product performance, satisfaction and complaints to inform systematic product reviews.

Reference: page 112.

The group targets raising customer satisfaction, measured on the CSAT method (0-10 scale), "from 73% to 77% by 2028." Data are collected annually via a web-based questionnaire developed internally and approved by the Group Executive Management, then reported internally on a quarterly basis, covering both personal and commercial customers "with the exception of a few segments where the portfolio is not large enough to perform a meaningful measurement."

Reference: pages 114-118.

Corporate culture rests on the purpose "We secure today. To create tomorrow. Together," developed through post-merger culture surveys of more than 1,200 colleagues from Codan and Alm. Brand and an employee pledge shaped by around fifty managers and staff. Business conduct is governed by the CSR policy, an operational risk policy, the 2025 Employee Code of Conduct, conflict-of-interest instructions, a gifts procedure and the whistleblower scheme, which operates through an external law firm's portal, allows fully anonymous reporting, and received one report in 2025. The report also states plainly that the group has "not established any specific anti-corruption systems or anti-corruption processes to prevent, detect, investigate and respond to allegations or incidents," beyond these general policies and channels.

Reference: page 119.

"At present, the company has not implemented a structured process for (i) assessing sustainability-related risks and (ii) assessing and selecting suppliers based on sustainability metrics, and there are no concrete plans to implement such a process." The group does run a targeted process to prevent late payments to small and medium-sized enterprises, supported by an automated invoicing system and a supplier video guide on correct invoicing, though "we do not have a policy on this."

Reference: pages 115-119.

Prevention relies on the Code of Conduct, Anti-Corruption content within the Employee Code of Conduct, the gifts procedure and the whistleblower scheme; the internal audit department "reviews business ethics and anti-corruption every three years across all our operations and brands." Detection channels include the externally-run whistleblower portal and an internal fraud-investigation function, though the report notes that function "is not independent of management." The group is explicit about a gap: "we do not have a specific risk management process for bribery and anti-corruption. Thus, we have no concrete overview of our risk exposure in relation to corruption and bribery, including a concrete overview of the most vulnerable functions."

Reference: page 119.

"Our control functions have not identified any confirmed and documented incidents of corruption or bribery during the reporting period, including operational incidents related to corruption or bribery." One report was received through the whistleblower scheme in 2025 (across all whistleblower categories, not corruption-specific), handled by the compliance department; the report does not separately break out corruption-related whistleblower cases or fines.

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 in this FY2025 report, prepared under the 2023 ESRS. G1-3 became a standalone DR only in the 2025/2026 ESRS.

No measurable, outcome-oriented business conduct target is stated. The only target referenced in the G1 chapter is a cross-reference to the climate-related investment-emissions target added to the CSR policy's business conduct section at the end of 2025 (page 116), which is not itself a business-conduct target. Consistent with MDR-T's other limb, effectiveness is tracked in the absence of one: the internal audit department "reviews business ethics and anti-corruption every three years across all our operations and brands," and the group reports that its control functions "have not identified any confirmed and documented incidents of corruption or bribery during the reporting period" (page 119). The group also states it has no dedicated anti-corruption risk-management process or overview of exposure by function (page 118), which limits how far this monitoring can be said to be targeted.