Alzchem Group AG

Governance roles

Reference: pages 96-101. The GOV-1 5(b) datapoint is incorporated by reference to the combined management report (page 96).

Two-tier board. The Management Board has five members at 31 December 2025: Andreas Niedermaier (CEO), Martina Spitzer (CSO, marketing, sales and sustainability/ESG, appointed 1 January 2025), Klaus Englmaier (COO, production, environment, safety, health and quality), Andreas Losler (CFO) and Dr. Georg Weichselbaumer (CSO, innovation, R&D, product safety).

The Supervisory Board has four members: Markus Zoellner (Chairman), Dr. Caspar Freiherr von Schnurbein (Vice Chairman), Prof. Dr. Martina Heigl-Murauer (Chair of the Audit Committee) and Steve Roeper. "All (100%) members of both the Management Board of Alzchem Group AG and the Supervisory Board are independent" (page 97).

"At Alzchem, the Management Board bears overall responsibility for sustainability and all climate-related issues", including the risk management system and the internal control system (page 97). The Supervisory Board monitors sustainability reporting and targets and "is informed about the sustainability statement once a year". A Sustainability Core Team set up in 2020 co-ordinates day to day (page 167).

Board gender diversity is given under S1-9: one of five Management Board members is female, 20% (page 217).

Information provided to and matters addressed by the boards

Reference: pages 101-104, with supporting detail on pages 97 and 240.

"The Management Board and Supervisory Board continuously address sustainability matters from various perspectives. The company's legal representatives are also responsible for the internal controls and processes necessary to ensure proper sustainability reporting. The Supervisory Board is responsible for monitoring these processes" (page 102).

Cadence. A risk manager appointed by the Management Board "submits a summary risk report at least once a year, which in future will also include the results of the IRO analysis" (page 102). "The topic of 'Sustainability@Alzchem' is a routine item on the agenda of every single Supervisory Board meeting; furthermore, the Compliance Officer reports to the Supervisory Board on the status of compliance once a year" (page 240). The Supervisory Board is informed about the sustainability statement once a year (page 97).

The first double materiality assessment was made in FY2023 and "a corresponding update of this analysis was carried out in fiscal year 2025" (page 102). Pages 103-104 tabulate the material ESG risks identified in 2025 with mitigating measures; these "were discussed by the responsible committees and reviewed by the Management Board and Supervisory Board".

Sustainability in incentive schemes

Reference: page 105.

"In fiscal year 2025, sustainability-related performance was once again included in the remuneration system for the Management Board. As part of the short-term variable remuneration (Short-Term Incentive, STI), 90% of the STI is determined by the business success achieved and 10% by the achievement of the company's sustainability targets." The Supervisory Board sets and weights those targets annually, preferring quantifiable measures "such as reducing occupational accidents, using resources more efficiently, reducing energy consumption, reducing waste, or reducing CO2 emissions".

2025 corporate goal: group-wide introduction of SAP Sustainability Footprint Management by end-2025, with the carbon footprint of all products above 1,000 tonnes a year reliably determined and the methodology externally audited and certified. It "was successfully implemented in the reporting year 2025, including certification of the calculation method used by TUEV Rheinland".

Climate link and its limit: "Climate-related considerations are taken into account in the STI, which accounts for approximately 30% of total remuneration." Then: "No specific climate-related targets have been set for 2025." Supervisory Board members receive fixed remuneration only.

Statement on due diligence

Reference: pages 105-106.

Page 106 maps the five core elements of due diligence to paragraphs of the statement: (a) integration into governance, strategy and business model to GOV-2, GOV-3 and SBM-3; (b) engaging affected stakeholders to GOV-2, SBM-2, IRO-1, MDR-P and the topical standards; (c) identifying and assessing negative impacts to IRO-1 and SBM-3; (d) actions against those impacts to MDR-A and the topical standards; (e) tracking effectiveness and communicating to MDR-M, MDR-T and the topical standards.

Reference frameworks named on page 105 are the UN Universal Declaration of Human Rights, the Ten Principles of the UN Global Compact, the ILO core labour standards, the UN Guiding Principles on Business and Human Rights, the OECD Due Diligence Guidance for Responsible Business Conduct, the German Supply Chain Due Diligence Act (LkSG), the Code of Conduct for Suppliers, the Responsible Care Global Charter and the German Corporate Governance Code.

"Alzchem has summarized the relevant obligations, processes, responsibilities, and measures in an internal manual created specifically for this purpose. The effectiveness of measures to address negative impacts is monitored through internal and external audits (e.g., TfS audit, EcoVadis assessment)" (page 105).

Risk management and internal controls over sustainability reporting

Reference: pages 106-107.

Sustainability reporting sits inside the internal control system: "the reliability of the process for preparing sustainability reporting is also implemented through specific controls for the accuracy and completeness of sustainability reporting in accordance with ESRS, including the dual control principle" (page 106). Environmental data is subject to "internal performance analyses, internal and external audits, and regulatory monitoring throughout the year". The process is monitored by the responsible departments, the Sustainability Core Team, the Management Board and the Supervisory Board.

A limitation is disclosed: "There is currently no formalized process for assessing risks and opportunities, including the method for prioritizing risks" (page 106).

Reporting risks named are incorrect, incomplete or delayed information; staff shortages from absences during the reporting period; and "insufficient or delayed availability of data on the upstream and downstream stages of the value chain". Mitigations are an early start to reporting and IT-supported data collection. Controls are designed by the departments that collect the data, with "critical discussions of the draft sustainability report at the Management Board level" (page 107).

Strategy, business model and value chain

Reference: pages 107-111, with segment data on pages 4-6 and site scope on page 173.

Alzchem is a Bavarian specialty chemicals group built on its "Verbund production" - a vertically integrated NCN chain from lime, coke and electricity through calcium carbide, calcium cyanamide, cyanamide and dicyandiamide to derivatives including DYHARD, Creapure, Creamino, Perlka, guanidine nitrate and nitroguanidine (pages 8, 199). Production runs at Trostberg, Schalchen, Hart and Waldkraiburg in the Bavarian Chemical Triangle plus Sundsvall, Sweden. Group sales in 2025 were EUR 562,115 thousand: Specialty Chemicals EUR 378,776 thousand, Basics & Intermediates EUR 155,091 thousand.

Strategy (page 107) includes "climate-neutral growth and achievement of climate neutrality in accordance with Scope 1 by 2033 at the latest; to this end, investments of over EUR 30 million are planned by 2030 ... which means an annual CO2 reduction of around 90,000 tons compared to the base year 2022".

Value chain (page 111): Alzchem sits at the start of the chain and depends on suppliers of lime, coke and electricity. "Alzchem does not engage in any activities in the coal, oil, or gas sectors" (page 173); the datapoint index marks chemical production as subject to a reporting obligation and the controversial weapons and tobacco rows as not (page 136).

Interests and views of stakeholders

Reference: pages 111-114.

Key stakeholders identified in the materiality process (page 111): shareholders, banks, authorities, local authorities, trade unions, customers, users and consumers, suppliers, employees, politicians and associations.

Channels (page 112): product presentations, trade fairs, trade association work, works meetings and investor roadshows. "In fiscal year 2025, our sales department once again conducted customer surveys that explicitly addressed sustainability aspects." Regular contact is maintained with municipal committees, local institutions and neighbours, and with political representatives at federal, state, district and local level. Employee surveys run at the German sites, most recently in Q3 2024, with a survey at the Atlanta site in 2025 (page 208).

How views reach the boards (pages 112-113): internal information sessions with the Supervisory Board including monthly meetings with its Chairman; regular meetings with neighbours, politicians and associations; inclusion of sustainability risks in company-wide risk management; and regular reporting by the Sustainability Core Team.

Alzchem cites its "EcoVadis CSR rating of Platinum" as evidence that stakeholder interests are integrated (page 112). Stakeholder views entered the assessment "by the respective topic managers" during the materiality workshops (page 128) rather than by direct stakeholder scoring.

Material impacts, risks and opportunities

Reference: pages 114-127; the IRO table runs from page 115 to page 126.

The table lists 116 individually typed rows across eight material standards, each labelled positive impact, negative impact, risk or opportunity, actual or potential, and mapped to upstream, own activities or downstream. The split is E1 15, E2 12, E3 5, E5 9, S1 40, S2 11, S4 9, G1 15.

Material sub-topics: climate adaptation, climate mitigation and energy (E1); air, water and soil pollution, substances of concern and SVHC, and microplastics (E2); water withdrawals and water discharges (E3, marine resources explicitly not material, page 191); resource inflows, resource outflows and waste (E5); working conditions, equal treatment and other work-related rights (S1); social dialogue, health and safety, training, and child and forced labour (S2); privacy, health and safety and responsible marketing (S4); corporate culture, whistleblower protection, political engagement, supplier relationships, and corruption and bribery (G1).

Financial effects are withheld: "Alzchem is refraining from disclosing the assessment of the expected financial effects during the transition period. In fiscal year 2025, no significant financial effects were identified in connection with the relevant risks and opportunities" (page 127).

Climate-specific risk identification and scenario analysis is also presented under E1-2 (2025 ESRS numbering).

Process to identify and assess material IROs

Reference: pages 128-135, with topic-specific IRO-1 sections for E1 (page 131), E2 (pages 131-132), E3 (page 132), E4 (pages 132-133), E5 (pages 133-134) and G1 (pages 134-135).

The first assessment was made in 2023 using the ESRS 1 AR 16 sub-topics as the long list and drawing on CSRD, SASB and TCFD frameworks. "In the reporting year 2025, Alzchem revised its materiality assessment to respond to changes in the company and its environment" (page 128).

Six phases (page 129): review of relevant topics; identification of IROs from a stakeholder perspective; consolidation into an ESRS-based long list; assessment by specialists; a short list; and review by senior management, the works council and the speakers' committee, with final approval by the Management Board.

Thresholds (page 129): a five-point scale on extent, scope and probability, with irreversibility added for negative impacts. Financial bands run from none, through very low below EUR 1.8 million, to high from EUR 22.5 million. "In the case of potential negative impacts on human rights, the severity of the impact takes precedence over its probability of occurrence."

Gaps disclosed: heavy rainfall, flooding and water shortages "are not yet fully included in the general risk management process" (page 130), and biodiversity risks "were therefore neither identified nor assessed in the IRO analysis" (page 133).

Disclosure requirements covered

Reference: pages 135-152.

Alzchem prints a real ESRS content index. "The appendix contains a list of disclosure requirements as an index that contain the relevant information in the sustainability statement (see ESRS index) ... an assignment was made based on the Datapoint List published in the EFRAG implementation guidance" (page 135).

Two tables. The EU-legislation datapoint table (pages 136-144) gives each SFDR, Pillar 3, Benchmark Regulation and EU Climate Law datapoint a yes/no reporting obligation. Rows marked as not subject to one include SBM-1 controversial weapons and tobacco (page 136), E1-7 GHG removals and carbon credits (page 138), all six E1-9 rows (pages 138-139), both E3-4 water rows (pages 139-140), the SBM-3 E4 and E4-2 rows (page 140) and the S3-1 and S3-4 rows (page 143).

The ESRS-INDEX (pages 145-152) covers ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2), E1 (E1-1 to E1-6), E2 (E2-1 to E2-6), E3 (E3-1, E3-2, E3-3, E3-5), E5 (E5-1 to E5-6), S1 (S1-1 to S1-17), S2 (S2-1 to S2-5), S4 (S4-1 to S4-5) and G1 (G1-1 to G1-6). E4 and S3 do not appear at all, and E1-7, E1-8, E1-9 and E3-4 are absent from their topic blocks. The classification on this site follows that index.

The statement is prepared "in partial compliance with the European Sustainability Reporting Standards" under Sections 315b and 315c HGB (page 95).

Transition plan for climate change mitigation

Reference: pages 166, 169-172.

Alzchem answers E1-1 with a negative: "Alzchem does not currently have a complete transition plan for climate change mitigation that meets the requirements of E1-1. The company does not plan to adopt a comprehensive transition plan that meets the relevant requirements in the future" (page 166).

What exists instead is a climate roadmap adopted in 2023 by the Supervisory Board and Management Board and presented to shareholders at the Annual General Meeting (Say on Climate) (page 172). It targets climate neutrality for Scope 1 by 2033 through four packages: CO2 liquefaction and use as a raw material, sustainable raw materials management, heat recovery, and efficiency improvements (page 169).

"Alzchem's climate roadmap has been integrated and aligned with the overall business strategy and financial planning. The measures required to implement the strategies have been included in the medium-term financial planning" (page 172).

No external validation: "Our climate roadmap has not been reviewed by an independent external organization such as the Science Based Targets Initiative (SBTI). Therefore, we do not currently have an independently verified transition plan" (page 172).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 (page 131) and the ESRS 2 SBM-3 content presented in the E1 chapter (pages 166-167), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risk classification (paragraph 15). Transition risks are named as regulatory (stricter limits on cooling water discharge into rivers, stricter emissions control, CO2 and energy cost burdens, tightening regulation or taxation of fossil fuels), geopolitical raw material risk, and technological risk from the high initial cost of sustainable technologies (page 166). Physical risks are described generically as acute (storms, floods, fires, heat waves) and chronic (temperature change, reduced water availability).

Methodology (paragraph 16). "Alzchem has conducted risk assessments that include an analysis of the vulnerability of the company's activities to climate-related hazards" (page 131). Time horizons follow ESRS 1 paragraph 77 (page 96).

No scenario analysis was performed, so paragraph 17 does not apply. "However, a comprehensive climate risk and vulnerability analysis that takes into account various climate scenarios and analyzes both physical and transition risks has not yet been carried out" (page 131, repeated page 166). No scenario, temperature projection or scenario assumption is named anywhere in the statement.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 as presented in the E1 chapter (pages 166-167) and from ESRS 2 IRO-1 (page 131) and SBM-3 (page 128), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

No ESRS-style resilience analysis has been performed, and Alzchem says so twice. "Alzchem has not yet conducted a detailed climate risk and vulnerability analysis taking into account various climate scenarios in order to accurately assess and improve the resilience of our strategy and business model to climate change" (page 166). IRO-1 repeats it and adds the purpose such an analysis would serve (page 131).

What is disclosed instead is generic: "In the course of developing business strategies, the resilience of business models is examined, taking into account economic, environmental, and social factors ... Where appropriate, resilience analyses, regulatory conditions, and stakeholder expectations are taken into account" (page 128).

Adaptation actions appear under E1-2 and E1-3: an action plan to minimise production restrictions when cooling water limits bite, and a water programme that by 2025 had cut groundwater use by 7.58 million cubic metres, 22% below 2022 (pages 168, 171). Capacity to adapt is not quantified and no areas of uncertainty are stated.

Policies related to climate change mitigation and adaptation

Reference: pages 166-168. Three material sub-topics carry policies: climate change adaptation, climate protection and energy efficiency.

Ownership: "In 2020, an overarching core team was set up to manage and monitor all aspects of sustainability at Alzchem. The CSO is responsible for sustainability on the Management Board ... The COO is responsible for implementing the policies and measures" (page 167).

Mitigation (page 167): avoid waste and emissions by closing production cycles, so that "CO2 that has been emitted to date is to be returned to the cycle as a raw material". Scope 3 is addressed through supplier audits that record raw material suppliers' Scope 3 emissions. Alzchem receives electricity price compensation and a Carbon Leakage Regulation discount, applied for annually.

Adaptation (pages 167-168): "Our policy includes the development of an action plan that will enable us to minimize potential production restrictions in the relevant seasons" on cooling water, plus a water reduction programme.

Energy efficiency (page 168): long-term energy price hedging, annual energy-saving measures, and waste heat use.

A gap: "Alzchem currently has no policy for large-scale in-house generation of renewable energies or for the use of power purchase agreements (PPA)" - rooftop photovoltaic is installed only to meet legal requirements, and green electricity certificates are bought instead.

Actions and resources in relation to climate change policies

Reference: pages 169-172. The climate roadmap "envisages achieving climate neutrality according to Scope 1 by 2033" through four packages.

Package 1, CO2 liquefaction. A new oxyfuel steam generator at Trostberg recovering concentrated CO2 for reuse: "The necessary investment costs (CapEx) amount to approximately EUR 14 million. The plan is to complete this measure by 2029 ... annual savings of around 21,000 tons of CO2 are forecast" (page 169). A parallel Schalchen process is calculated at "around 10,000 tons per year" with no final cost estimate. Hydrogen energy recovery delivered "approximately 1,000 tons".

Package 2, raw materials. A new lime kiln at Sundsvall fired by the site's own CO gas, eliminating coke as fuel: completion "scheduled for the end of 2027 ... approximately 13,000 to 15,000 tons per year" (page 170).

Package 3, heat recovery. Hart waste heat cut about 81% of building heating energy, "approximately 700 tons per year"; a 2025 Trostberg conversion saves "around 180 tons per year".

Package 4, efficiency. CO compressors at Hart, "around 3,300 tons per year"; the Trostberg PV park at about 1,400 MWh; LED conversion; and groundwater extraction down 22% (page 171).

Resources (page 172): 2025 measures cut about 180 tonnes a year for "EUR 264 thousand". Planned measures should save "approximately 65,000 tons" for "investments of approximately EUR 74 million".

Targets related to climate change mitigation and adaptation

Reference: page 172, with base year data on pages 178-183.

The targets:

• "The goal is to reduce gross GHG emissions in Scope 1 across the entire Group by 75% by 2030 compared to the base year 2022."
• "No gross target has been defined for Scope 2 to date. However, it is expected that the German electricity mix will consist of 80% renewable energies by 2030 in line with national targets. Alzchem is likely to benefit from this development due to its electricity-intensive business model."
• "No target has yet been set for Scope 3."

Base year 2022, chosen because it "falls within the range of fluctuations in emissions and energy consumption in previous years. There were no anomalies." Scope 1 was 105,000 tCO2e and all relevant site-based scopes 697,000 tCO2e. Adding Scope 3 categories 3.5 and 3.11 and switching the Swedish site-based electricity factor to ENTSO-E data means base and prior year figures have been restated.

Validation: the roadmap "has not been reviewed by an independent external organization such as the Science Based Targets Initiative (SBTI)".

Alzchem acknowledges the tension in its own numbers: "Despite a temporary increase in emissions due to significant investments in new production facilities, the target ... remains unchanged". Scope 1 in 2025 was 109,977 tCO2e, 4.2% above the base year (page 179).

Energy consumption and mix

Reference: pages 172-178. All five production sites belong to "climate-intensive sectors" (page 173), so intensity is disclosed. Total energy consumption 2025: 876,910 MWh, down 10.2% on the 2022 base of 976,167 MWh.

The fossil share fell from 77.5% to 46.0% and renewables rose from 9.9% to 47.4%; nuclear is 6.6%. "No fuels from renewable sources are used". Energy intensity improved from 2.00 to 1.56 MWh per EUR thousand of revenue (page 178). The renewable jump reflects a 2023 German EEG change plus certificates for about 30% of German consumption; 2025 uses prior year electricity labelling because the actual labelling arrives after the report is prepared (page 176).

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 178-183.

Intensity is 1.11 location-based and 1.06 market-based per EUR thousand of revenue (page 183).

Scope 1 covers CO2, nitrous oxide, SF6 and F-gases; "No other greenhouse gases are emitted." Only quicklime production at Sundsvall falls under EU ETS I, 32,576 tCO2e, "EU ETS-I share Alzchem 30%" (page 179).

Scope 3: only two of fifteen categories are significant - 3.1 purchased goods and services 319,417 tCO2e and 3.5 waste generated in operations 32,975 tCO2e, up 105.1% on the base year (page 182). Categories 3.10 and 3.11 "are not reported on", and 3.1 excludes purchased services and other goods, "approximately 10% of the raw material quantities" (pages 180-181). Avoided Eminex methane emissions "may not be credited, which is why they are reported separately" (page 181).

Policies related to pollution

Reference: pages 184-187. Five material sub-topics: air, water and soil pollution, substances of concern and SVHC, and microplastics.

Air and water. Alzchem "pursues the policy of continuous improvement of its environmental performance ... by applying an environmental management system in accordance with ISO 14001", supported by "a comprehensive program for self-monitoring" of emitted pollutants. Both apply at all production sites under the Production Management Board (page 184).

Soil. Narrower: "Alzchem owns land with old deposits or former landfills that are contaminated, the actual impact of which has not yet been clarified", so potentially contaminated sites are being examined. German sites only (page 185).

Substances of concern and SVHC (pages 185-187). Compliance rests on REACH full or intermediate registration, Chemical Safety Reports and exposure scenarios for all EU applications, safety data sheets automatically re-issued to every customer who bought the product in the last 12 months, PCN notifications and the ECHA PIC tool under Regulation (EU) 649/2012. Hazardous substance management is coordinated by Product Safety/Approval at Trostberg, with Tox-Asi discussions defining protective measures per work step and ECHA candidate list updates tracked automatically via REACH-IT.

Microplastics (page 187): all products are checked against REACH Regulation (EU) 2023/2055; the Chief Sales Officer is responsible.

Actions and resources related to pollution

Reference: pages 187-188.

Reduction of residues in production (Schalchen). "In order to minimize product discharge, the capacity of the NH3 stripping process was increased ... This increased the product yield and reduced the discharge into the residue from 1.0% to 0.5%. This corresponds to a reduction in product discharge of more than 1 ton per day ... Capital expenditure of approximately EUR 370 thousand was incurred for the measure."

Waste incineration plant (Trostberg). "An additional cleaning stage for the exhaust air from incineration in the form of a basic scrubber will be installed in 2026 ... Investment expenditure of EUR 1.925 million is planned."

Water. "In the reporting year 2025, no further measures were defined ... beyond the continued self-monitoring of water pollutants in Alzchem's discharges."

Suspected contaminated site (Schalchen). Investigation programmes run since 2020 with the licensing authorities and an expert licensed under Section 18 of the Federal Soil Protection Act "were completed in 2025. The suspicion of the occurrence and presence of harmful groundwater contamination could be ruled out" (page 188).

Microplastics. "No additional measures were necessary in the reporting year 2025."

SVHC (page 188): continuous training, safety data sheet updates, mandatory emergency plans for BImSchG-approved plants, and per-plant risk assessments tracked through Management of Change.

Targets related to pollution

Reference: pages 188-189. Two targets, both on air:

NOx. Delivered by installing a denitrification plant at Trostberg, so there are no interim targets. The value derives from the EU WI-BREF and "represents the state of the art in flue gas denitrification". "In 2025, an annual average of 37 mg/m3 was achieved. The target was thus exceeded by 63 mg/m3".

NH3. Delivered by increasing NH3 stripping capacity at the Schalchen DCD plant against a 2024 reference of 174 g/h. "During the measurement in 2025, a maximum emission value of 46 g/h was achieved, which is well below the target value of 100 g/h." No annual load was determined because no continuous measurement exists.

The gap is stated plainly: "No targets have yet been defined for the impacts, risks, and opportunities associated with pollution of soil, pollution of water, and the reduction or avoidance of substances of concern and substances of very high concern, as well as microplastics. The effectiveness of the policies and measures relating to these issues has not yet been systematically monitored".

Pollution of air, water and soil

Reference: page 189. This is the E-PRTR datapoint required by ESRS 2 Appendix B (paragraph 28), which the datapoint index marks as subject to a reporting obligation (page 139).

One pollutant exceeds the E-PRTR threshold:

"All other air, water and soil pollutants do not exceed the threshold values according to E-PRTR."

Method: "The annual load is determined using the analytically determined exhaust air concentrations and exhaust air volume flows, multiplied by the annual operating hours of the emission sources. The measurements to determine the pollutant concentrations were carried out by internal analytics or by approved measuring stations. These are accredited for these types of measurements by the German Accreditation Body (DAkkS)."

On the sixth E2 sub-topic a nil return is given: "Alzchem does not use or produce microplastics". This sits alongside the microplastics policy under E2-1, which is framed as monitoring compliance with REACH Regulation (EU) 2023/2055 rather than managing an existing flow (page 187).

Substances of concern and substances of very high concern

Reference: pages 189-191. Both limbs of paragraph 34 are answered - amounts generated, used or procured and amounts leaving the facilities - with SVHC presented separately per paragraph 35.

Substances of concern (SoC), 2025:

Substances of very high concern (SVHC), 2025:

"Almost half of the total SoC is generated by the CO gas produced during the manufacture of calcium carbide, which is, however, used as a raw material and energy source in later production steps within the company" (page 190). "Due to the confidentiality of the data ... no external validation of the data has been carried out".

Anticipated financial effects from pollution

Reference: page 191.

Alzchem gives a substantive, if brief, answer rather than invoking the transitional relief it uses for E1-9 and E3-5: "We currently do not anticipate any significant financial effects in relation to pollution. The retrofitting/upgrading of facilities that is continuously required due to changes in environmental law will be incorporated into the ongoing budgeting process in a timely manner".

The claim is consistent with the rest of the chapter. The pollution risks in the IRO table are all potential rather than actual - penalties and tightening limits for air and water, and "Soil contamination of an unassessed extent can lead to unquantifiable remediation requirements" (page 116) - and the one open soil exposure closed during the year, with the Schalchen investigation completed in 2025 and harmful groundwater contamination ruled out (page 188). The two quantified pollution actions are small against group scale: about EUR 370 thousand for the Schalchen NH3 stripping capacity increase and EUR 1.925 million planned for the Trostberg scrubber in 2026 (page 187).

No monetary amounts, time horizons or sensitivities are disclosed, and no attempt is made to quantify the regulatory exposure that dominates the E2 and G1-5 narrative - the REACH restriction procedure on calcium cyanamide as a fertiliser, which Alzchem opposes (pages 240-241).

Policies related to water and marine resources

Reference: pages 191-192. Scope is set at the outset: "Water resources were identified as material for Alzchem, but marine resources were not".

Water withdrawal. Impact: "High water withdrawal volumes can lead to water shortages at regional and/or supraregional level (negative impact). Alzchem withdraws groundwater at its German sites." Risk: a legal limit on permissible withdrawal could cut production capacity and revenue, and withdrawal fees would hit financially. Policy: continuous improvement of environmental performance in water withdrawal "by applying an environmental management system in accordance with ISO 14001", at all production sites under the Production Management Board.

Water discharge. Impact: discharging large volumes "could cause damage to aquatic life and plants in the event of unintentional contamination or excessive thermal stress". Policy: "A water ecology report was prepared for the discharge of cooling water at the German sites ... this serves as a basis for determining and specifying the permissible thermal load". Discharged water is monitored analytically under a self-monitoring programme. German production sites only (page 192).

Water stress: "None of Alzchem's sites are located in a water risk area or in an area with high water stress".

Actions and resources related to water and marine resources

Reference: page 192.

"A series of concrete measures has been defined at all German sites to reduce the amount of cooling water withdrawn and thus also discharged." The main measures are construction of cooling towers for a new plant at Schalchen, commissioning in 2026; optimisation of operating parameters for water consumers; and multiple use of cooling water.

"The measures taken are preventive in nature, as no actual damage is to be expected or has occurred due to the high availability of water at the Alzchem sites."

Resources: "The measures did not involve any significant operating expenditure (OpEx). Capital expenditure (CapEx) of approximately EUR 565 thousand is planned for the cooling towers at the Schalchen site."

Link to the target: the measures support the E3-3 target of total cooling water withdrawal below 30 million cubic metres at the German sites "despite capacity expansions in 2025 and 2026", and counteract the risk of authorities limiting withdrawal or levying fees.

Boundary: "The measures relate to the company's own activities and have no direct connection to the upstream or downstream value chain."

A related initiative is reported under E1-3: reducing groundwater extraction since 2023 through new tapping machines at Hart and other site measures, cutting groundwater use by 7.58 million cubic metres, or 22%, against the 2022 base year (page 171).

Targets related to water and marine resources

Reference: page 193. Two voluntary, self-set targets:

Withdrawal. Measured from a 2022 base of 33.9 million cubic metres. "This target is not formally defined, no stakeholders were involved, and no ecological thresholds were taken into account." Outcome: "At 26.5 million m3, the target value of less than 30 million m3 for 2025 was exceeded." The withdrawal volume parameter "is not validated externally".

Discharge temperature. "Alzchem does not have a formal definition of the target. However, the target was developed in accordance with the aquatic ecology report on the discharge of cooling water". Outcome: "With a maximum discharge temperature of 22.9 degrees C, the target value of 24 degrees C was met." It "will be externally validated for the first time in the annual water management report for 2025 by the responsible authorities ... in the course of 2026".

Gaps: "No targets relating to water resources have been defined for the Sundsvall site"; marine resources are "not material for Alzchem and is not reported here".

Policies related to resource use and circular economy

Reference: pages 194-195. "All policies aim to avoid waste within the framework of the waste hierarchy." Three material sub-topics are covered.

Resource inflows, including resource use. Impact: "High consumption and/or ineffective use of resources can lead to increased costs and limited availability of resources." Policy: "Alzchem pursues the policy of optimizing production processes in terms of yield and resource utilization. In particular, these aspects are already taken into account in product development."

Resource outflows. Impact: "Products not designed for recycling become waste at the end of their service life and thus pollute the environment." Policy: "We are optimizing our product portfolio with regard to recyclable products that can be manufactured with as little waste as possible".

Waste. Policy: in NCN integrated production, residual materials from carbide, calcium cyanamide, cyanamide and dicyandiamide manufacture are used to make other products, "e.g., CO gas from the carbide furnaces in Hart for the manufacture of DCD at the Schalchen site". "Alzchem has voluntarily obtained certification as a specialist waste management company (CWMC). An annual audit is carried out by an external approved assessor" (page 195).

The Production Management Board is responsible for implementation.

Actions and resources related to resource use and circular economy

Reference: pages 195-196.

Permanent measures. Waste management at the German sites is certified as a specialist waste management company (CWMC), with an organised separate-collection system so waste can be sorted by type for recycling or recovery; the annual external audit "was also successfully carried out in 2025". This is described honestly as "a support measure and not a remedy".

New measures in 2025:

• The IBC return system was extended to include additional materials.
• Recycling of solvents: "In 2025, a recycling option was identified for a solvent used in the production of an Alzchem product, which previously had to be disposed of. Since December 2025, the solvent used in the production process has been recycled externally. This will enable waste savings of up to 300 tons per year in the future."
• Recycled content in packaging: a new PE drum "with a recycling content of at least 30% has been in use since this year".

Resources: "These measures do not involve any significant operating expenditure (OpEx) or capital expenditure (CapEx). The measures relate to the company's own activities and the downstream value chain."

Gap: "No new measures were defined in 2025 with regard to resource inflows, including resource use and resource outflows in connection with products and services" (page 195).

Targets related to resource use and circular economy

Reference: page 196.

Hydrogen. By-product hydrogen replaces natural gas at the Trostberg waste incineration plant, against a 2023 reference consumption of 940,000 m3. "A total saving of 479,000 m3 of natural gas was achieved this year, exceeding the target of at least 400,000 m3 (120% target achievement). Investment expenditure of around EUR 1 million was required to make the hydrogen usable."

Solvents. External recycling started in December 2025; "The aim is to achieve a recycling rate of 100% in 2026. ... No investments were required for the changeover."

Limits disclosed: "For both targets, the measurements of the parameters for achieving the targets are not validated externally. The targets were not determined on a scientific basis. No stakeholders were involved in setting the targets." And: "No specific target has been set for 2025 in relation to resource outflows associated with products and services. The effectiveness of the policy and measures on this issue has not yet been systematically tracked."

Resource inflows

Reference: page 197.

"At Alzchem, all purchased raw materials constitute significant resource inflows. A total of 250,508 tons of raw materials were purchased in Germany and 111,250 tons in Sundsvall, Sweden, for the manufacture of products in 2025. These are sourced worldwide. Products from one site can also be used as raw materials for further production at the same or other sites."

Materials named: "The raw materials purchased are mainly organic and inorganic basic chemicals and intermediates, as well as coke, lime, and electrical energy. In addition, fine chemicals, auxiliary materials, and additives are purchased externally to a lesser extent." Alzchem states that "No biological materials are used in Alzchem's production."

Secondary materials: "Externally sourced secondary materials are not used in production. However, internally generated by-products and residues are reused on a large scale in our own production facilities. This avoids external inflows (integrated production). By-products and residual materials used internally are not included in the recycling or reuse rates."

Method and assurance: "The quantities of inflows are determined by inventory management in the SAP system. No significant assumptions were made when specifying the metrics. The resource inflows were not validated externally."

Resource outflows

Reference: pages 197-198.

"In total, Alzchem produced 500,011 tons of product at its production sites in Germany and 32,808 tons in Sundsvall, Sweden, in the reporting year 2025.

Durability, reparability and recyclability are all answered as not determinable, with reasons. "Some of our products are used in agriculture, human nutrition, or animal feed. These products are designed to be returned to the biological cycle ... These include, in particular, the products Perlka, Creapure and Creamino. As a result, no recycling rate can be specified for these products, or it is 0%."

"For chemical products, it is not possible to compare the shelf life of the products placed on the market with the industry average ... Repairability in the sense of repairing defective products cannot therefore be specified."

"The recyclable portion of products cannot be determined because the products are either returned to the biological cycle or first processed into end products by our customers. The recyclable portion of product packaging has not yet been determined due to the large number of different types of packaging."

"Data on resource outflows is recorded in Alzchem's SAP system and is not validated externally."

Waste outflows are reported separately below.

Anticipated financial effects from resource use and circular economy

Reference: page 199.

Alzchem uses the qualitative-only phase-in rather than omitting the requirement: "In accordance with ESRS E5-6, we are only reporting qualitative information on the anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities in the first three years, as it is not yet feasible to prepare quantitative information."

On the risk side: "Market prices for lime, coke, energy, and other chemical raw materials are subject to considerable fluctuations. In addition, disruptions in supply chains, unexpected production interruptions, and unreliable suppliers can be latent risks that management must always take into account. Despite the strict pursuit of a 'multiple sourcing strategy', certain supplier dependencies cannot be completely ruled out." And: "In the area of the circular economy, there is a latent financial risk not only for Alzchem due to rising disposal costs for the main waste streams of its main products."

On the opportunity side: "there is also a high potential for savings if waste streams can continue to be recycled internally or externally. This can reduce both disposal costs and raw material costs."

Waste

Reference: pages 197-199. Waste is reported separately for Germany and Sweden. "The total waste generated in both countries amounted to approximately 74,000 tons in 2025."

Germany 2025 (page 198), tonnes:

Hazardous waste for recycling 7,831 t (all "other utilisation"); non-hazardous for utilisation 16,314 t (recycling 1,585 t, other utilisation 14,729 t); hazardous for disposal 44,134 t (incineration 43,998 t, landfill 136 t); non-hazardous for disposal 2,674 t. Total hazardous waste 51,965 t; radioactive waste 0 t. Total non-recycled waste 69,369 t, 98% of waste generated.

Sundsvall, Sweden 2025 (page 198), tonnes: total waste 2,920 t (utilisation 1,612 t, disposal 1,308 t); hazardous for recycling 2 t; non-hazardous for utilisation 1,610 t; hazardous for disposal 1,006 t; non-hazardous for disposal 302 t. Total hazardous waste 1,008 t; radioactive 0 t. Total non-recycled waste 2,918 t, 100%. "The waste consists of residues from the production of calcium carbide" (page 199).

Method caveat: "For waste from Germany, the quantities from January to November are based on the actual amounts of waste generated according to waste disposal companies. For December, the waste quantities reported to waste disposal companies are taken into account."

Policies related to own workforce

Reference: pages 201-207.

"As part of an analysis based on the principle of double materiality (see ESRS 2 IRO-1), 14 important topics ... were analyzed in terms of material impacts, risks, and opportunities that are supported by the company, i.e., by the top management level (Management Board), and backed up by relevant policies, often in the form of relevant works council and speakers' committee agreements as well as collective bargaining agreements" (page 201).

Human rights policy (page 205). The "Alzchem Group AG Policy Statement on Human Rights" commits the group to the UN Universal Declaration of Human Rights and the ILO Declaration, "the prohibition of child and forced labor, the prohibition of all forms of human trafficking, slavery, and discrimination, and the strengthening of freedom of association", occupational health and safety, and "the ongoing payment of adequate, living wages". It applies to all Alzchem companies and is extended to suppliers.

Self-assessment: "the analysis identified many positive effects and only a few significant negative effects, as comprehensive policies and measures have been implemented over many decades" (page 201).

Processes for engaging with own workforce and workers' representatives

Reference: pages 207-208.

Representation (page 207). At German production sites employee interests are represented by elected works councils under the Works Constitution Act, covering working hours, holiday policy, accident prevention, wage structures and suggestion schemes, all subject to co-determination; senior executives are represented by the speakers' committee under the Executives' Committee Act. At Sundsvall, union representatives negotiate locally "in accordance with local custom and without legal requirements". "Due to the small number of employees, no employee representation bodies have been formed in the sales companies in the United Kingdom, China, and the United States."

Frequency. The works council informs employees twice a year at works meetings; the Management Board briefs employees at all German sites quarterly on the financial situation, with questions permitted anonymously in advance. "In addition to informal coordination meetings, an average of up to five rounds of negotiations on various topics are held each month."

Surveys. "The company has been conducting regular employee surveys again since 2023 (planned every 1 to 3 years), most recently in Germany in the third quarter of 2024 ... In Sundsvall, employee surveys are conducted every five years ... In 2025, an employee survey managed by the German headquarters was conducted at the Atlanta site" (page 208).

Processes to remediate negative impacts and channels to raise concerns

Reference: pages 208-209.

Channels (page 209). Employees at the German sites "can confidently contact the works council/speakers' committee, the representative for disabled employees, the Human Resources (HR) department, the compliance manager (including the external whistleblower hotline), the harassment officers, the company doctor, the data protection officer, the information security officer, trade unions, or directly to the Management Board". "The whistleblower hotline can also be contacted from sites outside Germany."

Awareness. Regular online "Acting Correctly/Company Guidelines" training with a mandatory exam is completed by new employees in their first days. "The management of the site in Sweden was last informed about the corporate guidelines at the end of 2025 during a quarterly meeting. Online training courses are planned at all international sites in 2026", which will align international practice with Germany.

Protection and outcome. "To date, no reports of retaliatory measures have been received by the compliance manager, the whistleblower hotline, or other channels." Employees are protected under the German Whistleblower Protection Act. Alzchem states that "in 2025, no significant negative effects on employees caused by Alzchem in its corporate role were identified" (page 208).

Taking action on material impacts on own workforce

Reference: pages 209-211, with the 2025 measures on page 210. "The focus of the reporting is on the German sites, as they employ around 96% of the workforce."

2025 actions (page 210):

• Social dialogue - a managers' kick-off event, and continuation of the MEET AND EAT programme of regular dinners where "employees can discuss important topics with representatives of top management in a relaxed atmosphere".
• Health and safety - preventive measures on workplace stress under the Company Health Management Programme with a regional health insurer; a new series of basic occupational safety seminars for managers with the BGRCI; skin cancer screening with an external dermatologist in autumn 2025; and a comprehensive health screening including a hearing test at the Swedish site.
• Training - completion of the "Management Learning Journey" for managers, a new management training programme for shift supervisors, and "an in-house training center was put into operation at the Trostberg site".
• Diversity - "personality management with regard to 'diversity in teams' was included in management training in 2025".

"Many measures are already in place for other core topics ... so we believe that no new or further activities were necessary in 2025" (page 210).

Targets related to own workforce

Reference: pages 211-213.

Health and safety (page 212), with outcomes disclosed against each:

• "A long-term target is to reduce sick leave at German sites to < 5%. Ultimately, the sickness absence rate in 2025 was 4.9% (excluding sickness absences during continued pay)."
• "Each year, there should be <= 39 external medical treatments (including non-employees) and <= 3 plant safety incidents at German sites. Alzchem fundamentally pursues a vision of zero accidents." Outcome: "In fact, 60 external medical treatments were necessary in 2025 (including non-employees) and two plant safety incidents were recorded" - the medical treatment target was missed.
• Sweden: zero lost-time accidents, at most 10 safety incidents, at least 15 hazard investigations. Outcome: no lost-time accidents, two safety incidents, 21 investigations.

Scope limit stated: "No further targets relating to material topics under ESRS 2 IRO-1 were set, as Alzchem has optimized the potential for impacts on the workforce ... to such an extent that these are now only of minor significance ... No overarching Group objectives regarding social issues beyond the policy statement on human rights ... have been agreed upon to date" (page 212).

Characteristics of the company's employees

Reference: pages 213-215. Figures are headcount at 31 December 2025 unless stated; "Around 96% of the Alzchem Group's employees are based in Germany", so no other country meets the 50-employee and 10% thresholds.

Headcount 1,794, of which 326 female (18.2%) and 1,468 male (81.8%); the average for 2025 was 1,765 (317 female, 1,448 male). Germany accounts for 1,719 employees (page 213).

By region (page 214): Europe 1,772, Asia 6, North America 16.

By contract type (page 214): permanent 1,585 (88.3%) and fixed-term 209 (11.7%); permanent employees comprise 273 female and 1,312 male, fixed-term 53 female and 156 male. On-call working models are not used: "On-call employment and other types of working models whose disadvantages clearly lie with the employees are not used at Alzchem" (page 202).

Turnover (page 214): 149 resignations from the Alzchem Group in 2025 against an average headcount of 1,765, an employee turnover rate of 8.4%.

Method (page 215): figures are headcount for active employment relationships only, excluding suspended relationships such as parental leave, passive partial retirement and long-term illness beyond 18 months. Data comes from the SAP HR system for German plants and an SAP Business Warehouse solution for other sites. "No checks were carried out by external bodies. However, internal audit routines and plausibility checks ensure a high level of data quality."

Characteristics of non-employee workers

Reference: page 215.

"The following table provides information on the number of non-employees. It is clear that the number of non-employees is very small and insignificant compared to the number of employees stated in S1-6. The reason for this is that Alzchem does not outsource any core competencies and only uses support services to maintain business operations in certain cases or, in rare cases, purchases special expertise that the organization does not have."

Non-employees in the company's own workforce at 31 December 2025:

Method: figures are headcount at the end of the reporting period. "Due to the very small number of persons involved, it is not necessary to comment on the fluctuation rate for this group." Temporary agency workers are drawn directly from the SAP personnel information system for the German plants, while contract workers and freelancers "are reported manually by the purchasing and legal departments"; international sites are reported manually for all three groups.

"No checks have been carried out by external bodies. However, internal audit routines and plausibility checks ensure a high level of data quality."

Non-employees are also covered by the health and safety management systems reported under S1-14 (page 219).

Collective bargaining coverage and social dialogue

Reference: page 216.

Group coverage: of 1,794 employees, 1,734 are covered by collective agreements, 96.7%.

Germany, the only country meeting the de minimis threshold of at least 50 employees and at least 10% of the workforce: "On December 31, 2025, collective bargaining coverage in Germany was 97.8% (all employees except senior executives and board members) and workplace representation (social dialogue) was 99.7% (all employees except board members)." Coverage is placed in the 80-100% band in the breakdown table.

Sweden: "Employees at the Sundsvall plant are subject to the collective agreements for the chemical industry in Sweden (IKEM)."

Outside the EEA: "Employees in non-EEA countries are not subject to collective bargaining agreements and are not represented by workers' representatives", and no non-EEA country reaches the de minimis threshold.

Employees not covered in Germany "are, without exception, in management positions with a high level of responsibility and correspondingly high pay, and comprise only 2.2%".

European works council: "There is no agreement on a European works council or similar European bodies, as the proportion of employees in companies in the European Economic Area outside Germany is only just under 3%." The works council chairman sits on the Bavarian and Federal IGBCE chemical industry bargaining commissions.

Diversity metrics

Reference: page 217.

Gender distribution at the top two management levels (31 December 2025):

Age distribution (31 December 2025):

Gender is recorded "as specified by the employees themselves". The age bands sum to 1,794 and each percentage is calculated on 1,794, so the printed total of 1,749 looks like a typographical error in the report.

Rationale. "Alzchem considers it important to include all genders in management positions, not only to comply with formal diversity principles, but also to leverage gender-specific perspectives for the benefit and well-being of the company while enriching the corporate culture." On age: "Alzchem attaches great importance to a balanced age distribution in order to be able to maintain business operations even in challenging times. In addition to fresh young talent, Alzchem also needs experienced middle-aged employees and benefits from the comprehensive expertise of older employees."

Adequate wages

Reference: page 217.

"Alzchem grants all employees in the EEA region appropriate remuneration in line with the applicable reference values. In Germany, collective agreements guarantee remuneration that is well above the statutory minimum wage. Although there is no statutory minimum wage in Sweden, the requirements of collective agreements are also met there. This also applies to simple auxiliary tasks."

"Outside the EEA, Alzchem operates sales offices in the United Kingdom, China, and the United States. Due to the technical requirements, sales employees in these countries are paid in line with industry standards. This not only enables employees to enjoy an adequate standard of living, but also guarantees remuneration that exceeds national reference values, thus ensuring a living wage."

No percentage of employees paid below an adequate wage benchmark is given; the disclosure is a qualitative statement that all employees are above the relevant reference values in every country of operation.

Social protection

Reference: page 217.

"The Alzchem Group provides all employees at all sites with comprehensive protection against loss of earnings due to significant life events in accordance with the following criteria, either based on legal requirements and/or against the background of company regulations in the respective countries:

• Sickness
• Unemployment starting from when the own worker is working for the company
• Employment injury and acquired disability
• Parental leave
• Retirement"

The five categories listed match the five major life events specified by the standard - sickness, unemployment, employment injury and acquired disability, parental leave and retirement - and Alzchem states coverage for all of them, at every site, without exception or country carve-out. Accidents at work and incapacity to work are named alongside them.

Supporting context sits in the health and safety disclosures: at the German production sites "workers ... are cared for around the clock by the company's own medical service", ranging "from the fastest possible treatment on site to the transport of those affected for further treatment in nearby hospitals", with plant fire departments for environmental and fire incidents; "The site in Sweden is also covered by external partnerships with a medical service and a fire department" (page 200).

No number or percentage of employees not covered by any of the five categories is reported, because Alzchem states that none are uncovered.

Persons with disabilities

Reference: pages 217-218.

Employees with disabilities at 31 December 2025:

Disabilities are counted "as defined and understood in the respective countries". In Germany this covers "people who are considered severely disabled or equivalent to severely disabled persons according to Section 2 SGB IX" (page 217).

Practice. "In close cooperation with the company's representative body for severely disabled persons, the inclusion office, the integration service, and the social psychiatric service, workplaces that are appropriate for the affected employees' conditions are sought or designed according to their needs" (pages 217-218). "Legislation in Sweden also attaches great importance to equal opportunities for employees with disabilities, which is actively practiced at the Sundsvall site under the watchful eye of management and union representatives."

Materiality basis. Employment and inclusion of persons with disabilities is one of the 14 core S1 topics, carried in the IRO table as a potential negative impact: "A lack of employment opportunities for people with disabilities would weaken the chances of this group finding jobs and earning an income" (page 121). S1-1 adds that "Alzchem stands by its employees and, where possible, provides jobs for employees with health restrictions" (page 204).

Training and skills development metrics

Reference: pages 218-219.

Performance and career assessments (31 December 2025):

Training hours (2025 averages):

Alzchem also reports a voluntary metric: 26,568 health and safety training courses, 15.1 per employee on average, "proactively presented beyond the reporting requirements in order to take into account our core topic of health and safety ... These are often short training courses in the form of company instructions or e-learning" (page 219).

Method caveat: "The evaluation includes all training hours recorded in our personnel information systems by January 12, 2026 ... Training hours reported later will not be included." Training hours for the UK and US sites are estimated (page 215).

Health and safety metrics

Reference: page 219.

Management systems. "Alzchem maintains a management system at its German production sites that covers health and safety and is certified according to OHRIS (Occupational Health and Risk Management System). The management system in Sundsvall (Sweden) also covers health and safety and is certified according to ISO 45001." Compliance is assured through internal audits; "OHRIS is certified by the authorities, ISO 45001 by external certifiers."

2025 metrics for the production sites in Germany and Sweden, on a headcount basis and determined under national law definitions:

• (a) "The management systems described cover 100% of the workforce at the production sites in Germany and Sweden."
• (b) "There were no fatalities as a result of work-related injuries or illnesses. Furthermore, there are no known fatalities among other workers employed at Alzchem's sites."
• (c) "A total of 30 reportable accidents at work were reported, corresponding to a rate of 12.2 (number of cases / hours worked x 1 million)."
• (d) "One reportable work-related illness occurred."
• (e) "There were 1,693 days of absence due to work-related accidents and illnesses."

The related 2025 targets and their outcomes are reported under S1-5, including 60 external medical treatments against a target of at most 39 (page 212).

Work-life balance metrics

Reference: pages 219-220.

"According to this definition, 100% of Alzchem Group employees are entitled to family leave", covering maternity leave, paternity leave, parental leave and leave for family caregivers (pages 219-220).

Standard metric (2025 averages):

Alzchem's own supplementary measure. "Since the standard evaluation in the above table is not very meaningful in terms of sustainability and does not adequately reflect the use of 'family leave', Alzchem additionally evaluates the total population of all employees who ... explicitly belonged to the group that had children in 2025 or cared for relatives in that year."

"The high implementation rate of 90% not only clearly shows that Alzchem offers an appreciative basis for work-life balance throughout the company, but also that eligible employees are happy to take advantage of the entitlement" (page 220).

Both measures are disclosed side by side, so a reader can see the difference between the ESRS denominator and the company's narrower one.

Compensation metrics (pay gap and total compensation)

Reference: pages 220-221. Both metrics cover the German sites only.

Gender pay gap (31 December 2025):

"The evaluation shows that the gender pay gap at Alzchem's German sites is low and that the pay equity described above is actually being practiced."

Total remuneration ratio (31 December 2025):

Method exclusions (page 221): only employees at German sites in active employment on 31 December 2025 who were employed for the whole year are counted. Joiners, trainees, interns and marginally employed staff are excluded "as they would have significantly distorted the results", as are employees with unpaid absences of three or more months. Employees outside Germany are excluded "for the sake of simplicity".

Incidents, complaints and severe human rights impacts

Reference: pages 221-222.

"In 2025, there were no known work-related incidents of harassment and discrimination or related complaints among the Alzchem Group's workforce, nor were there any serious incidents related to human rights, such as forced labor, human trafficking, or child labor. As a result, no remedial measures had to be taken and no fines or damages had to be paid" (page 221).

How the nil return was established (page 222). "At the German sites, the compliance manager and the company's anti-bullying officers were interviewed. At sites outside Germany, the respective site managers were asked to provide information using a standardized questionnaire. The compliance manager also provides information on incidents at national or international level that are reported via the whistleblower hotline."

The result is consistent with the rest of the chapter: no reports of retaliatory measures have reached any channel (page 209), and "in 2025, no significant negative effects on employees caused by Alzchem in its corporate role were identified" (page 208).

Forced and child labour exposure is assessed as absent from own operations: "Alzchem has not identified any activities that would be characterized by a significant risk of forced labor or child labor, as Alzchem only operates production sites in Germany and Sweden and is not active in regions susceptible to such practices" (page 201).

Policies related to value chain workers

Reference: pages 223-225. "The materiality assessment identified social dialogue, health and safety, training and skills development, and child and forced labor as key issues for workers in Alzchem's upstream value chain."

Instruments. "A fundamental prerequisite for working with our business partners is that they share our values. A key aspect for Alzchem is communication with employees along the upstream value chain at the beginning of the business relationship. During contract negotiations, the Purchasing department is responsible for checking whether business partners accept and comply with the specified requirements (see Supplier Self-Disclosure, Alzchem Code of Conduct)." (page 223).

Standards. "Alzchem's policies on the prohibition of child and forced labor, health and safety, social dialogue, and training and skills development in relation to the upstream value chain are in line with internationally recognized standards such as Responsible Care, the OECD Guidelines for Multinational Enterprises, the International Labor Organization (ILO), and other CSR guidelines, including the United Nations Guiding Principles on Human Rights" (page 225).

Outcome: "To date, no cases of non-compliance with the United Nations Guiding Principles on Business and Human Rights, the ILO Declaration ... or the OECD Guidelines have been reported to us" (page 225).

Processes for engaging with value chain workers

Reference: page 225.

Engagement is indirect, through suppliers rather than with workers or their representatives directly, and Alzchem describes the mechanism plainly: "Through our questions in the self-assessment, personal or online explanations of our values and requirements to our suppliers (see Partnership for Sustainability), or through audits with credible representatives on site, we gain direct insight into the situation of the local workforce and their satisfaction, for example, whether the necessary occupational health and safety measures are in place or whether working hours are being adhered to. Furthermore, the audit checks and evaluates information on the prohibition of child labor and forced labor, health and safety, and training and skills development."

Timing. "Our business partners and suppliers are involved before the start of a business relationship and begin by accepting our Code of Conduct and, for our suppliers, additionally by completing the supplier self-assessment."

Risk-based selection. "As part of an annual CSR risk assessment (criteria: CSR rating, compliance with the Alzchem Code of Conduct, potential damage to Alzchem), all direct suppliers from countries where we have identified an increased risk ... are reviewed and, if necessary, audited (online or on site)."

Processes to remediate negative impacts and channels for value chain workers

Reference: page 226.

"In the event of violations, workers along the value chain have the option of submitting anonymous complaints via our whistleblower system, which we have set up in collaboration with a third-party provider. To ensure compliance with human rights, Alzchem appointed a human rights compliance officer in 2023 and opened the existing anonymous whistleblower system to relevant reports. This system is available to all employees within the upstream value chain and has been presented both online and in face-to-face training sessions."

Handling. "All reports received are reviewed and forwarded by our legal department to the purchasing department for detailed investigation. Appropriate measures are then taken in justified cases." The compliance officer is responsible for technical effectiveness, "which is reviewed several times a year", working with Supply Chain Management, which owns "monitoring, implementing, and ensuring the effectiveness of these corrective measures".

Outcome and the inference drawn from it. "In 2025, no reports of problems or violations relating to human rights issues in our value chain were received", and "As no reports have been received via our whistleblower system to date, we assume that our measures to comply with human rights standards are effective".

Taking action on material impacts on value chain workers

Reference: pages 226-227.

Supplier training. Training launched in 2023 for direct suppliers from higher-risk countries covers "our Code of Conduct, including child and forced labor, health and safety, training and skills development, and explanations on how to conduct CSR audits. In the reporting year 2025, we conducted four training courses for our suppliers" (page 226).

Qualification and categorisation. Suppliers must provide self-disclosure and accept Alzchem's Code of Conduct or an equivalent of their own; they are then "categorized into classes A, B, and C. This determines whether a company is approved as a supplier or retains its approval. Suppliers that fall into category C are not approved and can only be considered if a CSR audit confirms that the necessary minimum requirements are met." Child labour and forced labour are knock-out criteria (page 239).

Audit findings. "In the reporting year 2025, we identified areas for improvement (both deviations and recommendations) in the areas of social affairs and corporate governance during CSR audits of our suppliers. The identified deviations have since been rectified and the recommendations implemented by our suppliers."

Resources: "In the reporting year 2025, no significant financial resources were allocated for the measures mentioned in connection with workers in the value chain."

Targets related to value chain workers

Reference: pages 227-228. "Our corporate target of responsible purchasing is to holistically and continuously improve the sustainability performance of our suppliers", covering social dialogue, occupational health and safety, training and skills development, child labour and forced labour.

Code of Conduct recognition. "We had set ourselves the goal for 2025 that at least 87% of all raw material suppliers would recognize our Code of Conduct (or a comparable code of conduct of their own, if available). Progress was continuously monitored and verified using the purchasing database. With a recognition rate of 91%, we have fully achieved our target. We intend to continue this positive trend in 2026" (page 228).

CSR audits. "Since 2022, Alzchem has been conducting CSR audits online and on site. The goal is to audit all raw material suppliers listed in the CSR risk analysis in the medium term. The audits serve to confirm the supplier assessment and identify high-risk suppliers. The order of the audits is based on the CSR risk analysis. A total of ten CSR audits were conducted in the reporting year 2025, thus fully achieving the set target."

Limitation disclosed: "The targets were not set with the direct involvement of employees in the value chain or their representatives" (page 228).

Policies related to consumers and end-users

Reference: pages 229-231. "The materiality assessment has shown that the issues of health and safety, privacy, and responsible marketing practices for consumers and end-users are of particular relevance to Alzchem."

Health and safety. "Although, as a B2B supplier of specialty chemicals, we rarely have direct contact with end-users or consumers, we are committed to providing our business partners with detailed and reliable information on the safe handling of our products. In this way, we support our business partners in providing their customers with competent and responsible information" (page 229).

Human rights (page 231). "The basis for our human rights due diligence can be found in the Human Rights Policy Statement, which has been in effect since April 2024, and in our corporate guidelines. The company also applies the principles and guidelines contained therein to business partners, consumers, and end-users." A compliance management system "serves to prevent and limit damage, detect and end violations of human rights, and ensure compliance with legal regulations", with the Management Board and Supervisory Board informed annually "and more frequently in the event of any violations. If any impact on human rights is identified, appropriate remedial measures are taken immediately, for example by terminating the business relationship with immediate effect."

Processes for engaging with consumers and end-users

Reference: pages 231-232.

"The customer relationship management (CRM) system supports the maintenance and management of customer and consumer relationships. Among other things, the system enables the sales department to communicate directly with relevant contacts. Regular surveys of customers and consumers on services, safe handling, and product quality are conducted by the sales department during customer visits. Based on the results, suggestions or measures are developed, the implementation and realization of which are then monitored" (page 231).

Frequency and form. "Our experts and our sales partners provide our direct customers and end consumers with advice or training on our products and their areas of application at least once a year, usually by telephone, e-mail, online, or at trade fairs. Potential new customers are informed at an early stage before the customer relationship is established in order to ensure the safe and proper use of our products and to rule out any potential health or environmental hazards. In addition, we maintain a continuous dialogue with our customers, including on topics related to the identified material IROs" (page 232).

Accountability. "Both the respective division manager responsible for operational business and the Management Board are responsible for ensuring that the results are incorporated into the corporate policy" (page 232).

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

Reference: pages 232-233.

Remediation sequence (page 232). "First, the negative impacts on consumers and end-users are identified through internal audits, customer feedback, or external reports. After a thorough assessment of the severity and scope of these impacts, the priorities and urgency of the corrective measures are determined. This is followed by detailed planning of specific measures to remedy the negative consequences, which may include product changes, recalls, compensation, or other corrective actions. The necessary resources (financial, human, technological) are made available ... Finally, feedback is obtained from affected consumers and end-users to assess their satisfaction with the measures."

Channels. Alongside a contact form and direct access to the compliance officer, "Alzchem has introduced a whistleblower system ('whistleblower hotline') at an external reporting office ... This system is available to internal and external stakeholders, including customers, consumers, and end-users, to submit concerns, needs, and reports of violations and incidents ... If necessary, reports can also be submitted anonymously ... Information about these reporting channels is publicly available."

Taking action on material impacts on consumers and end-users

Reference: pages 233-234.

Privacy. "To prevent this potential negative impact and to raise awareness of the protection of consumer and end-user data, targeted e-learning courses, training sessions, and phishing simulations were conducted for our employees in 2025. Mandatory training courses on information security, privacy, and compliance, which take place every two years, ensure a thorough understanding of the applicable guidelines and processes." Technical measures include backup strategies, virus protection and encryption, and compliance with the GDPR and the German Federal Data Protection Act. "No additional measures were implemented in the reporting year 2025."

Agricultural end use, described concretely (page 234). Distribution partners "conduct structured training courses and document them carefully. Users are personally instructed in the safe handling of the product. This direct transfer of knowledge ensures that even farmers who may not be able to read the safety and application instructions on the label are protected as well as possible. A bitter substance is added to certain products to prevent accidental ingestion. In addition, an intense dye ensures clear labeling so that these products can be clearly distinguished from food or drinking water." Where protective equipment is hard to obtain, "we offer chemical protective gloves free of charge".

Targets related to consumers and end-users

Reference: page 234.

Alzchem answers the requirement with an explicit negative: "There are no specific targets for privacy, health and safety, and responsible marketing practices in the reporting year 2025."

Consistent with MDR-T's second limb, it sets out how effectiveness is tracked in the absence of targets: "Nevertheless, it is essential for Alzchem to continuously monitor and evaluate the effectiveness of the measures and policies implemented in these key sustainability areas. This is achieved through customer feedback, for example through personal conversations at trade fairs or via our contact forms. Quantitative indicators such as the number of privacy violations or the frequency of inquiries due to insufficient user information can provide information about the perception and acceptance of policies and measures. Continuous data collection and analysis makes it possible to identify long-term trends and developments."

"These methods and approaches provide a basis for transparently monitoring and evaluating the effectiveness of sustainability policies and measures."

No baseline, target value, deadline or measured outcome is given for either of the indicators named, and no stakeholder involvement in target-setting is described - there being no targets to set. Complaint volumes are tracked internally through reports to the compliance officer and division managers (page 232), but no figure is published for 2025.

Business conduct policies and corporate culture

Reference: pages 235-238.

Corporate culture. "The values underlying the corporate culture are regularly reviewed and further developed by the company management together with the management team and workers' representatives, usually every two to three years or as required. At the end of 2024, for example, as a result of the latest employee survey, a 'Culture & Values' team was formed ... The work of the project group, which currently aims to develop a kind of internal 'Alzchem code', is not yet complete" (page 235).

Guidelines and training. "All employees are familiarized with the corporate guidelines, among other things, through the 'Acting Correctly' training course ... mandatory for all employees; successful participation is documented accordingly. In the reporting year 2025, a successful participation rate of 92.5% of employees was recorded."

Whistleblower protection (pages 236-237). A digitally supported whistleblower system run by a professional service provider is open to employees and third parties, anonymously. "The Compliance Officer reports directly to the Management Board. However, he is not bound by any instructions in his professional capacity." Protection is anchored in the German Whistleblower Protection Act (HinSchG) against termination, discrimination and bullying, transfer or demotion, and salary reductions or denial of promotions.

Management of relationships with suppliers

Reference: pages 238-239.

Payment terms. "Alzchem is interested in paying its suppliers not only fairly but also punctually for the services they provide. However, no distinction is made between small, medium-sized (SME) or large companies. Rather, Alzchem tries to agree on payment terms with its suppliers that are as uniform as possible, preferably based on its General Terms and Conditions of Purchase. Accordingly, invoices from Alzchem are paid within 65 days." "The highest level within the company that deals with the issue of late payments to suppliers is the Chief Financial Officer (CFO)."

Risk grid for supplier selection (page 239). Suppliers from non-OSCE countries are subject to a CSR review focused on human rights: completion of the CSR self-assessment questionnaire; acceptance of Alzchem's Supplier Code of Conduct or an equivalent; A/B/C categorisation by Purchasing; "the exclusion of suppliers if certain knockout criteria are met ... a. no exclusion of child labor; b. no exclusion of forced labor"; derivation of measures; and storage of evaluated questionnaires in the supplier database.

"We are not aware of any third-party standards or initiatives that the company has committed to comply with as part of the implementation of its strategy to prevent late payments" (page 238).

Prevention and detection of corruption and bribery

Reference: pages 239-240.

No dedicated programme, and Alzchem explains why. "Cases of corruption and bribery in which Alzchem or an Alzchem employee has been actively or passively involved have remained the absolute exception in corporate practice to date. Based on a risk-based approach, there are therefore no comprehensive, dedicated anti-corruption or anti-bribery procedures or guidelines. Instead, any cases of corruption and bribery are investigated, prosecuted, and, if necessary, punished within the framework of the general compliance organization and procedures." "For the reasons mentioned above, Alzchem does not plan to introduce general, comprehensive procedures to combat corruption and bribery in the foreseeable future. From the company's point of view, this would only fuel mistrust where there has previously been trusting cooperation" (page 239).

Training (page 240). "The topics of 'corruption' and 'bribery' are covered as part of the training on corporate guidelines ... As the corporate guidelines are taught company-wide on an annual basis, all risk-prone functions and members of the management bodies are covered. High-risk functions include senior executives, employees responsible for purchasing goods and services and sponsorship, sales staff, individuals entrusted with the management of finances and larger budgets, and employees in the areas of licensing and public affairs."

Targets related to business conduct

Back-filled from the business conduct chapter (pages 235-242), where targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS, and the report is prepared under the 2023 ESRS.

Alzchem discloses no outcome-oriented business conduct target, but does state a coverage target for training and reports against it. For the specialist compliance courses on gifts and benefits, purchasing processes and signature regulations, "The aim is to cover as many of the employees concerned as possible (> 95%)" (page 240).

Effectiveness tracking in the absence of targets, consistent with MDR-T:

• Participation in the mandatory group-wide "Acting Correctly" corporate guidelines training is documented, and "In the reporting year 2025, a successful participation rate of 92.5% of employees was recorded" (page 235).
• "The Compliance Officer reports to the Supervisory Board on the status of compliance once a year" (page 240).

The company's stated reason for having no wider anti-corruption programme is recorded verbatim under G1-3: dedicated procedures "would only fuel mistrust where there has previously been trusting cooperation internally and with our business partners" (page 239).

Incidents of corruption or bribery

Reference: page 240.

The 2025 return is nil, stated twice. "Neither the company nor its employees (with regard to their activities for the company) have been convicted of violations of applicable corruption and bribery regulations in 2025." And: "In the fiscal year 2025, the company was not aware of any violations of applicable corruption and bribery regulations, so there was no need to take any (sanctioning) measures."

How incidents would be assessed. "Cases of corruption and bribery are assessed by the company on the basis of the material damage incurred (either its own or that of third parties) and the associated reputational risk among stakeholders. In view of the extremely low number of cases of corruption and bribery in recent years, a further breakdown of this 'metric' or even its 'quality assurance' or 'validation' by an 'external body' does not appear to be expedient."

That last sentence is a disclosed limitation: the metric is not externally validated and is not broken down further, by the company's own choice. G1-1 records one non-corruption compliance investigation in an earlier year involving suspected theft of company property, where an external compliance consultant was engaged and the suspicion of a criminal network was "ultimately unprovable" (page 237).

Political influence and lobbying activities

Reference: pages 240-242.

Financial contributions: "In 2025, Alzchem did not make any financial or in-kind contributions exceeding the socially acceptable level to any office holder, political decision-maker, or political party inside or outside Germany" (page 240).

Registrations: "Alzchem Trostberg GmbH is registered in the EU Transparency Register (under No. 058565221863-63), in the Federal Lobby Register (under No. R001966) and in the Bavarian Lobby Register (under No. DEBYLT010E)" (page 242).

Topics, documented in the EU Transparency Register (page 241): the REACH restriction procedure "Calcium cyanamide as a fertilizer"; prohibiting production for export of chemicals banned in the EU; amendment of CLP Regulation 2008/1272; revision of the REACH Regulation; the Soil Monitoring Law; and the EU Parliament strategy to reduce methane emissions. On the REACH revision, "A position paper has been submitted to the REACH Committee to outline the socio-economic disadvantages of a ban". German and Bavarian lobbying covers the calcium cyanamide procedure, framework conditions for Eminex, and energy price and security of supply issues.

Revolving door: "Members of the Management Board, Board of Directors, and Supervisory Board of companies in the Alzchem Group did not hold any comparable positions in public administration (including regulatory authorities) prior to their respective appointments" (page 242).

Payment practices

Reference: page 242, with supporting detail on page 238.

"The payment terms for deliveries and services purchased by Alzchem are agreed individually with the contractual partners involved and do not follow any standard conditions. The average payment period is approximately 65 days. As no standard payment terms have been defined, it is not possible to specify the proportion of payments for which these terms were adhered to."

Legal proceedings: "Currently, and also in the past, no legal proceedings have been initiated against Alzchem due to late payment."

Supplier groups and the reporting gap: "The most important supplier groups are recorded according to the purchasing areas of raw materials, services and technical goods, transport, and packaging. However, there is currently no evaluation of the payment terms or their share of the total purchasing volume."

Process: "There are no standard payment terms due to individual agreements. Incoming invoices are immediately processed and checked in a workflow and posted with a due date to ensure timely payment."

So of the four G1-6 datapoints, Alzchem reports the average payment time and the nil return on late-payment proceedings, and states explicitly that the percentage of payments aligned with standard terms and the standard-terms description cannot be given because no standard terms exist.