Alma Media

Governance roles

Reference: pages 40-41. Content index entry: "General Information - Governance, pp. 40-41" (page 78).

"In 2025, Alma Media's board consisted of seven members. The group's executive team included ten members involved in business management, including the CEO. None of the board members participate in business management" (page 40).

Diversity and independence datapoints (21(d), (e)): "The gender distribution of the board was 43% women and 57% men, and in the executive team, 40% women and 60% men. All board members are independent of the company, and 51.3% are also independent of significant shareholders" (page 40). Average executive team experience at Alma Media is 16 years.

Employee representation: from 1 January 2025 "different employee groups appoint a representative and a deputy to the expanded executive team in each business unit. The actual representative participates in the work at least once a year" (page 40).

Responsibility: the CEO monitors sustainability impacts, implements risks and opportunities in business management, reports to the board and is responsible for achieving targets; the CFO holds delegated responsibility for risk management and internal control; the EVP Communications and Brand monitors targets and stakeholder engagement. The board receives updates at least quarterly alongside interim reports (pages 40-41).

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

Reference: page 41. Content index entry: "General Information - Governance, p. 41" (page 78).

"In 2025, Alma Media's board met eleven times and addressed several sustainability topics. The CEO reported these to the board together with the group's other management." Topics listed include confirmation of short- and long-term sustainability targets and their linkage to remuneration, quarterly monitoring of targets in group performance reporting, stakeholder consultation and survey results, assessment and approval of the materiality analysis, review of reliable journalism and responsible advertising as part of the media business strategy, results of the employee survey, updates to the finance, tax and information security policies, a summary of Whistleblowing reports and a situation update on information security management (page 41).

The board and audit committee participated in the stakeholder survey, confirmed the targets and their remuneration linkage, monitored achievement quarterly with the interim reports, oversaw reporting preparation and approved the materiality analysis. "The audit committee guides and oversees the preparation of sustainability reporting."

The executive team addressed sustainability risks, stakeholder survey results, strategy progress and internal control "in four strategy meetings and seven other meetings" (page 41).

Integration of sustainability-related performance in incentive schemes

Reference: pages 41-43. Content index entry: "General Information - Governance, pp. 41-42" (page 78).

"In 2025, sustainability targets were included in Alma Media's staff performance bonus targets. The CEO's maximum short-term bonus level was 100% of the fixed annual salary, and for members of the group executive team, it was 70%... 10% of the performance bonus was tied to the achievement of sustainability targets. The performance bonus criteria in 2025 covered environmental, social responsibility, and good governance targets" (page 43).

"The company's long-term incentive system is based on the development of total shareholder return, earnings per share, and sustainability targets, with the bonus paid in shares... totaling less than 100 individuals. The weight of sustainability targets in the long-term incentive system is also 10%" (page 43).

The climate link is explicit: "The remuneration of Alma Media's employees, including the company's senior management, is thus also tied to the reduction targets for greenhouse gas emissions Scope 1, 2, and 3." Board members' own remuneration is not linked to company performance (page 43). The targets carried into the scheme are tabulated on page 42.

Statement on due diligence

Reference: page 43. Content index entry: "General Information - Governance, p. 43" (page 78), and flagged in the EU-legislation datapoint table as "ESRS 2 GOV-4 Statement on Sustainability Due Diligence Process (30)" at "p. 43 (GOV-4)" (page 79).

"Alma Media's due diligence process related to sustainability is based on the group's governance model, which combines the key principles of internal control, risk management, and responsibility." The board decides strategic directions and approves key policies, the audit committee oversees the effectiveness of risk management and internal control, and the CEO has delegated practical control measures to the finance and legal functions (page 43).

The company maps the core due diligence elements to the disclosures that carry them (page 43):

• Integration into governance, strategy and business model: GOV-1, GOV-2, GOV-3, GOV-4, SBM-3
• Interaction with affected stakeholders: GOV-2, GOV-4, SBM-2, IRO-1, MDR-P
• Identification and assessment of adverse impacts: GOV-4, IRO-1, SBM-3
• Measures to prevent adverse impacts: GOV-4, MDR-A
• Monitoring and communication of effectiveness: GOV-4, MDR-M, MDR-T

Internal control runs on "the principle of three lines of defense", with the operational level implementing and documenting processes, a controlling function monitoring as part of regular reporting, and senior management (CEO, CFO) directing control (page 43).

Risk management and internal controls over sustainability reporting

Reference: page 44. Content index entry: "General Information - Governance, p. 44" (page 78).

"Alma Media's internal control and risk management in sustainability reporting focus on the reliability, quality, and timeliness of the sustainability reporting process. The processes and controls related to sustainability reporting cover key stages from data collection to report compilation and approval" (page 44).

Risks identified: "Typical risks related to the sustainability reporting process include data completeness and integrity, uncertainty related to calculations and estimates, and the availability and timeliness of information from the value chain. Additionally, risks may be related to the interpretation of reporting requirements and the consistent application of reporting principles" (page 44).

Controls: "defining responsibilities and tasks related to reporting, principles for reasonable verification of reported data (e.g., checks and reviews), documentation, and scheduling of data collection and reporting." Deficiencies found during the year are addressed as part of continuous improvement, and the process is reported to management, the board and the audit committee as part of report approval (page 44).

No integration into an enterprise risk management framework by name and no findings from the year are quantified.

Strategy, business model and value chain

Reference: pages 45-46. Content index entry: "General Information - Strategy, p. 45" (page 78).

"Alma Media's business consists of digital marketplaces, media, and digital services. The reporting segments are Alma Career, Alma Marketplaces, and Alma News Media" (page 45). Revenue was EUR 327 million in 2025 with digital business at 86% of revenue (page 5); the E1 chapter states "over 85% of the company's revenue will come from digital business" (page 59). "In 2025, Alma Media had a total of 1,711 employees, 61% of whom were in Finland."

Datapoint 40(d): "The company does not operate in fossil fuels, chemicals, controversial weapons, or tobacco sectors" (page 45), recorded as "Does not participate" against all four activities (page 79).

Value chain (page 46): upstream covers cloud and data centre services, capacity and IT services, software and technology partners, external expert services, content production, energy, facilities and logistics, and printing materials and distribution. Own operations cover digital service development and security, content and journalism, moderation, sales, customer service and administration. Downstream covers business customers, consumers and end-users, digital distribution and service usage "(including trust, security, data protection)".

Interests and views of stakeholders

Reference: pages 46-47; page 53. Content index entry: "General Information - Strategy (Value Chain & Stakeholders), pp. 46-47" (page 78).

The stakeholder table on page 47 sets out four groups with expectations, responses, channels and metrics:

• Employees - well-being at work, equal opportunities, training and skill development; measured by employee engagement index, training feedback and retention.
• Shareholders and analysts - sustainable profitability, ESG risk management, responsible business; measured by share price development, ESG risk ratings and SBTi target tracking.
• Consumers and end-users - high-quality accessible content, responsible use of data, responsible journalism and advertising; measured by customer satisfaction and NPS.
• Partners - responsible subcontracting, data protection, high-quality services; measured by Supplier Code of Conduct training coverage, partner feedback and GDPR violations.

"In the spring of 2025, stakeholders were widely consulted through surveys - including employees, investors, customers, service providers, and the company's board as representatives of the owners. Previously, in 2022, service users and media readers were also consulted... End-users of services were not consulted as survey respondents in 2025" (page 50). Results reach the board, which has addressed the employee survey, stakeholder survey and materiality analysis (page 46).

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

Reference: pages 48-50; also pages 59 and 69. Content index: "Management of Impacts, Risks, and Opportunities (Materiality Assessment), pp. 50-53" (page 78).

Four material topics are named (page 48): "E1-1 Climate Change Mitigation", "S1-1 Own Workforce, Training, and Skill Development", "S4-1-1 Impacts on Consumer and End-User Data: Privacy" and "G1-1 Business Management - Corporate Culture".

The page 49 table types each one:

• E1 climate change adaptation - "Negative impact, actual, downstream value chain (Medium-term)"
• S1 training and skills development - "Positive impact, actual, upstream value chain (Short and medium-term)"
• S4 privacy - "Financial risk. Negative impact, potential, upstream and downstream value chain (Short and medium-term, increasing)"
• G1 corporate culture - "Financial risk, Negative impact, potential (Short and medium-term)"

"The analysis identified material financial risks... particularly related to consumer and end-user data protection (S4) and corporate culture and ethical business practices (G1)... However, during the financial year, no financial impacts from these identified risks have materialised on the company's cash flow, assets, or financial results" (page 48).

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

Reference: pages 50-52. Content index: "Management of Impacts, Risks, and Opportunities, pp. 50-52" (page 78).

"Alma Media identifies and assesses material impacts, risks, and opportunities through a double materiality analysis as part of the group's risk management process." Impacts are examined "from the perspectives of scale, breadth, and remediability, considering time horizons", and "The thresholds for defining materiality are derived from the criteria of the ESRS standards" (page 50). The process diagram sets the threshold at a score of 10 or more, with impact materiality scored as severity multiplied by probability and financial materiality as impact on cash flow (or opportunity) multiplied by probability (page 51).

"The assessment covers Alma Media's own operations and the entire value chain", with attention to the energy use of digital business, data centres and service usage (page 50).

Timing: the analysis was conducted in 2024 and "updated in the spring of 2025 based on new stakeholder surveys... The next comprehensive assessment will be carried out in connection with the 2027 strategy process" (page 51).

Limitation disclosed: the survey response rate was low, "particularly among investors, subcontractors, and also employees (20%)", so the determination emphasised the executive teams, at 60% (page 52).

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

Reference: page 53; index tables pages 78-81.

Page 53, under "ESRS Standard disclosure requirements considered in the company's Sustainability Report (ESRS IRO-2)", names the material topics: "Climate Change (E1-1 Climate Change Mitigation)", "Own Workforce (S1-1 Training and Skill Development)", "Impacts on Consumers and End-Users (S4-1 Impacts on Data: Privacy)" and "Business Management (G1-1 Corporate Culture)". It adds: "The disclosure requirements for reporting on these topics are presented in the ESRS content index at the end of the report."

The index itself is on page 78, "List of the location of disclosure requirements in the sustainability report", giving standard, disclosure requirement and location. It lists ESRS 2 BP-1, BP-2, GOV-1 to GOV-5, SBM-1, SBM-2, SBM-3, IRO-1 and IRO-2; E1-GOV-3, E1-IRO-1, E1-SBM-3 and E1-1 to E1-6; S1-1 to S1-6 and S1-17; and G1-GOV-1 and G1-1. No S4 disclosure requirement appears, consistent with the page 38 statement that a transition provision is applied to ESRS S4.

Pages 79-81 carry the datapoints derived from other EU legislation, each with a page reference or the marking "Not relevant".

Transition plan for climate change mitigation

Reference: page 59. Content index entry: "E1-1 Transition Plan, p. 59" (page 78).

The disclosure is a nil return, stated in full: "Alma Media has not prepared a separate, board-approved transition plan. The company will assess the need to prepare a transition plan as part of the development of its sustainability and strategic work in future financial years" (page 59).

What exists instead is an emission reduction plan behind the SBTi targets: "Alma Media is committed to the targets of the Science Based Targets initiative, which require the reduction of greenhouse gas emissions at all Scope levels. The targets and the underlying emission reduction plan cover the entire group and apply to both its own operations and the value chain" (page 59). The targets themselves were approved by the audit committee and confirmed by the board in spring 2025 (page 52), and monitored quarterly by management and the board (page 63).

The EU-legislation datapoint table records "ESRS E1-1 Transition Plan to Achieve Climate Neutrality by 2050 (14)" against "p. 59 (E1-1)", and marks "ESRS E1-1 Companies Excluded from Paris Agreement Benchmarks (16(g))" as "Not relevant" (page 79).

No decarbonisation levers are quantified within E1-1 itself; those sit under E1-4 on page 64. No locked-in emissions assessment, no CapEx alignment and no explicit board approval of a plan are disclosed.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 climate SBM-3 subsection, disclosed in the FY2025 report at pages 50-52, 59 and 63-64. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Scenario analysis was not used. "Alma Media has not conducted a separate, formal climate resilience analysis or used climate scenarios to assess the resilience of its strategy and business model during the financial year" (page 59). E1-4 repeats it: "The company does not have its own, separately prepared climate scenario or industry-specific decarbonisation pathway, as the climate impacts of the media and digital services sector are mainly related to energy use and are limited in nature compared to high-emission sectors" (page 63). Scenarios enter only through target setting, which "is based on the international climate scenarios and methodologies used by the SBTi (such as IPCC and IEA scenarios)" (page 64), with no named pathway, temperature projection or horizon. Paragraph 17 items are therefore not applicable.

Risk identification: "The key impacts of climate change on Alma Media relate to energy consumption and availability, tightening regulations, and achieving emission reduction targets... Transition risks... can, if realised, cause cost pressures, regulatory obligations, and reputational impacts" (page 59). No physical hazard is named.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3, disclosed in the FY2025 report at pages 48, 50 and 59. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

No ESRS-defined resilience analysis was performed. "Alma Media has not conducted a separate, formal climate resilience analysis or used climate scenarios to assess the resilience of its strategy and business model during the financial year. However, climate impacts and business adaptability are considered as part of the company's ongoing risk management, strategic work, and monitoring of sustainability targets... The need for a more systematic climate resilience analysis will be assessed in future financial years" (page 59).

Qualitative statements: "The resilience of the strategy and business model to material impacts and risks has been assessed as part of the materiality assessment, risk management, and strategic work" (page 48), and "Overall, Alma Media assesses its business model and strategy to be resilient to material sustainability impacts and risks in both the short and long term, provided that identified risks are actively managed" (page 48).

The mechanism claimed is structural: "The digital business model supports climate resilience, particularly by reducing emissions and material use associated with the production and distribution of printed media" (page 59). No areas of uncertainty and no capacity-to-adapt analysis appear.

Policies related to climate change mitigation and adaptation

Reference: pages 59-60. Content index: "E1-2 Mitigation and Adaptation, pp. 59-60" (page 78).

"Alma Media is committed to achieving science-based emission reduction targets and managing climate risks. The company's key principle of action is to minimize the climate impacts of its own operations, products, services, and supply chain. The principles of action related to climate change apply to the entire Alma Media group, all company employees, and, where applicable, business partners and suppliers as part of the value chain (MDR-P 65b)" (page 59).

Named policies (pages 59-60):

• Procurement Guidelines - "Practical guidelines for procurement from external suppliers and compliance with environmental and ethical principles."
• Company car guidelines - "Guidelines aimed at electrifying the vehicle fleet, prohibiting the purchase of cars that use fossil fuels."
• Renewable Energy Procurement Principle - the company ensures its own and partners' services, "including data centres and cloud services - are based on renewable energy whenever possible."
• Energy efficiency - "The optimisation of office space usage and the modernisation of server capacity used in digital services improve energy efficiency." Accountability: the finance department guides implementation and "the audit committee is responsible for oversight" (page 59). Adaptation has no separate policy.

Actions and resources in relation to climate change policies

Reference: pages 60-62. Content index: "E1-3 Actions and Resources, pp. 60-62" (page 78).

"Alma Media's climate actions are based on the company's SBTi targets and the underlying emission reduction plan. The actions consist of reducing emissions in high-emission areas, energy efficiency, reducing logistics emissions, and digitising products" (page 60).

Energy and business premises: "Alma Media has transitioned to using renewable energy in its office buildings in cooperation with property owners, and in Finland, electricity procurement has shifted to fossil-free sources", including "the solar power plant installed on the roof of the Helsinki office building"; impact runs "mainly from 2023 to 2030" (page 60).

Transport and logistics: "In Finland, the electrification rate of company cars rose to 77.6% in 2025, and in other operating countries, the low-emission rate rose to 84.5%" (page 60).

Digital business model: the shift from printed media to digital channels is "a key structural factor in the emission reduction pathway towards 2030" (page 60).

Resources - a nil return: "The measures implemented in 2025 did not require significant additional investments or increases in operating expenses"; and "Alma Media has not allocated separate financial or personnel resources for actions related to climate change mitigation" (page 60).

Targets related to climate change mitigation and adaptation

Reference: pages 62-64. Content index: "E1-4 Objectives, pp. 62-64" (page 78).

"Alma Media's emission reduction targets are externally validated by the Science Based Targets initiative (SBTi) and are in line with the 1.5-degree target of the Paris Agreement" (page 63).

Targets (page 63), base year 2019, target year 2030:

• Scope 1 and 2: "Reducing absolute emissions by 52% by 2030 from the 2019 level", annual pace -4.73%
• Scope 3: "Reducing indirect value chain emissions by 14% by 2030", annual pace -1.27%
• "They are gross targets without offsets", monitored quarterly by management and the board

2025 outcome (page 63): Scope 1 and 2 -11.8%; Scope 3 +2.2% against the -1.27% target, footnoted "The Scope 3 target was not fully achieved in 2025 due to business expansion through mergers and acquisitions."

Decarbonisation levers to 2030 (page 64): renewable energy in offices approximately 222 tCO2e; office space optimisation approximately 85 tCO2e; fleet electrification approximately 109 tCO2e; reduced printing approximately 1,200 tCO2e; logistics optimisation approximately 1,000 tCO2e; end-of-life treatment of printed products -55 tCO2e.

Assumptions (page 64): "the development of energy markets (availability and supply of renewable energy), the electrification of vehicle technology, and tightening regulations". No adaptation target is set.

Energy consumption and mix

Reference: pages 64-65. Content index entry: "E1-5 Energy Consumption, pp. 64-65" (page 78), and recorded as "ESRS E1-5 Energy Consumption and Energy Mix (37)" at "pp. 64-65" (page 79).

The table on page 65 gives, for 2025 with 2024 comparatives:

Energy intensity per net revenue and the fossil-source breakdown for high-climate-impact sectors are both marked "Not relevant" (page 79), on the basis given on page 68: "The companies in the Alma Media group are not classified as having significant climate impact based on Annex 2 of the Regulation 2013/34/EU... The Alma Media group belongs to the main category J Information and Communication, with activities falling under sections 58, 62, and 63."

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 65-67; accounting principles page 68. Content index: "E1-6 Scope 1-3 Emissions, pp. 65-66" (page 78).

2025 emissions, tCO2e (2019 base year / 2024 comparative), page 66:

• Gross Scope 1: 171.7 (423.0 / 189.8), -9.54% year on year; 0% from regulated emission trading schemes
• Gross Scope 2 location-based: 200.7 (488.4 / 213.0), -5.77%; market-based: 65.0 (371.3 / 78.6), -17.30%
• Total gross Scope 3: 14,375 (16,099 / 14,071)
• Total location-based: 14,748 (17,010 / 14,474), +1.89%; market-based: 14,612 (16,893 / 14,340), +1.90%

Scope 3 by category, 2025 (page 66): 1 purchased goods and services 12,850; 3 fuel and energy-related 54; 4 upstream transportation and distribution 1,298; 6 business travel 113; 7 employee commuting 43; 11 use of sold products 120; 12 end-of-life treatment 12; 15 investments 5.

Intensity (page 67): 0.00004509 tCO2e/EUR location-based and 0.00004467 market-based, both -2.6%, on revenue of EUR 327,076,435.

Coverage (page 68): "In 2025, categories 1, 3, 4, 6, 7, 12, and 15 were still considered material, covering 100% of emission sources." "The accuracy level of Scope 3 is medium" (page 37).

Policies related to own workforce

Reference: pages 69-70. Content index: "S1 - Own Workforce (Training and Skills Development), pp. 69-70" (page 78).

"Alma Media's workforce is guided by a human resources plan approved by the company's management, which covers skill development, compensation, and plans related to equality, non-discrimination, and diversity... The plan complies with key labour legislation, such as the Cooperation Act, the Equality Act, the Non-Discrimination Act, the Occupational Safety and Health Act, and the Employment Contracts Act" (page 69). It is available in full to all employees on the intranet.

Human rights commitments: the company "is committed to respecting human rights in accordance with the UN Guiding Principles on Business and Human Rights, the International Labour Organisation's (ILO) fundamental principles and rights at work, and the OECD Guidelines for Multinational Enterprises" and is a UN Global Compact signatory (page 70). The Code of Conduct, "approved by the company's board of directors", "prohibits all forms of discrimination, harassment, human trafficking, forced labour, and child labour". The Supplier Code of Conduct extends this to subcontracting.

Health and safety: "The company conducts a workplace survey in cooperation with occupational health services at least every five years to identify and assess physical, psychological, and social workload" (page 70).

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

Reference: pages 70-71. Content index entry: "S1 - Own Workforce, pp. 70-71" (page 78).

"Alma Media has several established processes, such as the Performance Management process, semi-annual Alma Voice employee surveys (response rate in 2025 approximately 80%), and cooperation committees, through which employees and their representatives can participate in discussions about the actual and potential significant impacts of the company's operations. The views of employees and representatives are also considered in semi-annual goal discussions, quarterly reviews, and annual meetings between management and trust representatives" (page 70).

Accountability: "The implementation of processes is ensured by the company's HR director together with the executive team" (page 70).

Effectiveness: "The effectiveness of communication is assessed through employee surveys, goal achievement monitoring, and reports received through the Whistleblowing channel" (page 70).

Vulnerable groups: "The views of particularly vulnerable groups, such as women, immigrants, and people with disabilities, are also considered through employee surveys and targeted training and coaching" (pages 70-71).

"Alma Media complies with local labour laws and collective agreements in all its operating countries" (page 70). No global framework agreement is disclosed.

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

Reference: page 71. Content index: "S1 - Own Workforce, p. 71" (page 78); also recorded as "ESRS S1-3 Grievance/Complaint Handling Systems (32(c))" at "p. 71 (S1-3)" (page 81).

"Based on the Code of Conduct and the human resources plan, there are confidential reporting channels (Whistleblowing), independent investigation procedures, and regular evaluations. The channel is maintained by an external party, multilingual, and easily accessible. All reports are independently investigated, and the consistency of actions is monitored by the audit committee. Employees can also raise concerns through supervisors, HR, and trust representatives" (page 71).

"Alma Media investigates all reported violations and suspicions independently, and neither the person concerned nor their supervisor participates in the investigation" (page 71).

Effectiveness: "The company assesses the effectiveness of corrections by comparing implemented actions to the Code of Conduct principles and international obligations (e.g., UN Global Compact, ILO principles). Additionally, the results of employee surveys (Alma Voice) and the number and nature of reports received through the Whistleblowing channel are monitored" (page 71).

Taking action on material impacts on own workforce

Reference: page 71. Content index: "S1 - Own Workforce, p. 71" (page 78). The section is headed "Key actions to manage positive material impacts to own workforce", matching the single material S1 IRO, a positive impact from training and skills development (page 49).

"Impacts on the company's own workforce are managed primarily through training and skill development. These actions support skill growth, commitment, and retention, and prevent turnover and discrimination. Concrete actions include the Performance Management process covering the entire workforce, personal development plans, Future Leaders and Developer Trainee programs, AI and digital skills development, and DEI training. These actions are implemented as part of the HR policy and strategic skill development program, which allocates resources to supervisor training, employee training programs... language training, and diversity and inclusion training" (page 71).

Identification: "Necessary actions are identified in risk management and HR processes, which combine workforce data, survey results, and supervisor assessments."

Resources: "Resources are allocated annually to skill development (HR team work input, training programs). The adequacy of resources is assessed as part of the budgeting process." No monetary amount is given.

Targets related to own workforce

Reference: pages 71-72. Content index: "S1 - Own Workforce, pp. 71-72" (page 78).

"Alma Media has set time-bound and result-oriented targets for training, skill development, and supporting the commitment of its own workforce... to prevent negative impacts such as skill obsolescence" (page 71).

Targets and 2025 outcomes (page 72):

"In 2025, 90% of the workforce should have adopted the Performance Management process" (page 71), so the 86% outcome falls short.

Process: "Goal setting covers the entire company's workforce in 10 countries... The base year for the indicators is 2024, and the targets are reviewed at least every five years" (pages 71-72).

Characteristics of the undertaking's employees

Reference: pages 72-73. Content index entry: "S1 - Own Workforce, pp. 72-73" (page 78).

Headcount at 31 December 2025 (2024 comparative), page 72: total 1,711 (1,789); female 870 (919), male 841 (870), other 0, not disclosed 0.

By country, where at least 50 employees and at least 10% of the total (page 72): Finland 1,037 (1,039), Czech Republic 323 (355), Slovakia 120 (128), Croatia 95 (102).

By contract type (page 73): permanent 1,595 (1,656); temporary 116 (133); non-guaranteed hours 95 (89); full-time 1,528 (1,592); part-time 183 (197). Non-guaranteed hours employees "consist of employees on hourly contracts. This group is also included in the figure for part-time employees."

Turnover (page 73): employees who left 261 (235); "Rate of employee turnover" 15.1% (12.9%).

Basis (page 74): "Workforce size data is presented as the number of employees at the end of the financial year (31.12.2025). The workforce size also includes inactive employees, such as those on parental leave. Seasonal employees, such as summer workers, are included in the workforce size to the extent that they are employed at the end of the financial year." The key figures page separately reports 1,650 employees at 31 December 2025 "excluding telemarketers" (page 5).

Incidents, complaints and severe human rights impacts

Reference: page 73. Content index entry: "S1 - Own Workforce, p. 72" (page 78).

A complete nil return across all three limbs (page 73):

• Discrimination and harassment: "During the financial year, there were no cases or complaints related to discrimination or harassment against Alma Media's own workforce (0). This applies to all complaint mechanisms and feedback channels used by the company, including the ethical Whistleblowing channel, reports made through supervisors, HR, or other internal channels."
• National contact points: "During the financial year, there were also no complaints handled by national contact points (NCP) under the OECD Guidelines for Multinational Enterprises (0)."
• Severe human rights impacts and fines: "No serious human rights impacts or cases were identified in the company, and no fines, sanctions, or compensations related to such cases were imposed on the company (0)."

The EU-legislation table marks "ESRS S1-17 Discrimination Cases (103(a))" and "Non-Compliance with UNGP/OECD Principles (104(a))" as "Not relevant" (page 81), while the narrative above is given in full. Page 53 adds that "There have been no cases of corruption, bribery, or human rights violations in the company."

Business conduct policies and corporate culture

Reference: pages 75-77. Content index: "G1-1 | G1 - Business Conduct (Corporate Culture, Principles, Channels, Metrics), pp. 75-77" (page 78).

"Alma Media's operations are guided by principles of good governance, which include respect for human rights, equal and non-discriminatory treatment, prevention of corruption and bribery, prevention of anti-competitive practices, transparency in business, and responsibility in reporting" (page 75). Alongside the Code of Conduct sit tax policy, investment and financing policy, information security policy, board diversity policy and disclosure policy. "The principles are approved by the board and monitored by the audit committee."

Coverage and outcomes (pages 75-76): the two codes "apply to all employees, senior management, and key contractors". "In 2025, all employees completed Code of Conduct training, and 91.3% of the most significant suppliers completed Supplier Code of Conduct training", against 100% and 95.5% in 2024.

Whistleblowing (page 76): "an anonymous and multilingual Whistleblowing channel maintained by an external service provider, accessible via both the intranet and the company's website... Reports are received by Alma Media's legal counsel, CFO, and HR director." "The company does not tolerate any retaliation against individuals who make reports in good faith."

Targets related to business conduct

Back-filled from the business conduct chapter, where targets sit under the MDR-T minimum disclosure requirements rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS; this statement was prepared under the 2023 ESRS.

Reference: pages 75-76; group target table page 42.

"Alma Media has set clear quantitative targets for actions related to corporate culture and ethical business. The company's target is that annually 100% of employees and at least 90% of the most significant suppliers complete Code of Conduct or Supplier Code of Conduct training. Additionally, the target is that the employee engagement index remains above the average of the benchmark technology sector" (page 76).

2025 outcomes (page 75):

Both also appear in the group sustainability target table (page 42), among the measures tied to the 10% sustainability weighting in incentives (page 43). "Implementation is monitored through employee surveys, training metrics, the number of Whistleblowing reports, and management evaluations" (page 76), though "There are no separate metrics set for Whistleblowing reports" (page 77).