AMG Critical Materials

Governance roles

Reference: page 78. Composition, roles, skills and diversity datapoints (GOV-1 paragraphs 20-23, 22(c)) are incorporated by reference to Corporate Governance (pages 127, 128, 130, 131) and the Report of the Supervisory Board (pages 44, 45, 46), as listed in Table BP-2 (page 72).

AMG's administrative bodies for the purpose of the sustainability statement are the Supervisory Board and the Management Board of AMG Critical Materials N.V., "as well as the administrative bodies mentioned in the next section" (page 78) - the Corporate ESG Functions set out under GOV-2.

Supervisory Board committees are the Audit & Risk Management Committee, the Remuneration Committee, the Selection & Appointment Committee and the Safety, Sustainability, and Science ("3S") Committee (Figure GOV-2, page 79; Shareholder Information, page 245). Sustainability oversight is anchored in the 3S Committee, chaired by Mr Warmolt Prins.

The Management Board has three members: Dr Heinz Schimmelbusch (Chairman and CEO), Mr Jackson Dunckel (CFO) and Mr Michael Connor (Chief Corporate Development Officer) (page 245). "Given our focus on sustainability, our CEO has overall ownership" (page 78).

Information provided to the boards

Reference: pages 78-79.

"The Management Board is responsible for incorporating sustainability matters into the company strategy and monitoring the performance of the business" (page 78). Reporting lines are stated with frequency:

• The 3S Committee "is informed on sustainability on a quarterly basis by the Senior Vice President of Environmental, Health, Safety, and Sustainability".
• The Supervisory Board "is informed of sustainability-related matters on a quarterly basis by the 3S Committee Chairperson as a function of its Supervisory Board meetings".
• Major transactions and risk management are considered "through the biweekly Management Board meetings and the quarterly 3S Committee function", including "the consideration of trade-offs associated with those impacts, risks, and opportunities".

Three Corporate ESG Functions prepare and maintain the statement: the Corporate EHSS team (environmental, health and safety), the Social Impact team (all social issues except health and safety), and the Chief Compliance Officer with the Corporate Secretary (governance) (page 78).

"During the 2025 reporting period, the Management and Supervisory Boards were apprised of the DMA IROs as shown in Table SBM-3" (page 78).

Sustainability in incentive schemes

Reference: page 79. Detail incorporated by reference to the Remuneration Report (pages 54, 56, 61) per Table BP-2 (page 72).

"Goals related to ESG aspects are included in the annual bonus targets for the Management Board. A detailed breakdown of the targets, including 2025 performance data, is found in the Remuneration Report section of the Annual Report" (page 79). The disclosure is cited against both ESRS 2 GOV-3 (paragraph 29, AR 7) and ESRS E1 GOV-3 (paragraph 13), so the climate-specific limb is answered by the same cross-reference rather than by a separate figure in the statement.

"There is no CSRD aligned sustainability-related performance incentive scheme in place for the Supervisory Board as these board members do not receive variable pay" (page 79).

One incentive target is quantified elsewhere in the statement: under S1-5, AMG "has set a compensation target, related to the lost time incident rate (LTIR) aspiring to be 10% better than our peers" (page 109). No percentage of Management Board variable pay linked to sustainability or climate is stated within the sustainability statement itself.

Statement on due diligence

Reference: page 79, Table GOV-4 "Mapping of due diligence information".

AMG maps the five core elements of due diligence to the paragraphs of the statement that carry them, and says the processes "are undergoing continuous development":

• Embedding due diligence in governance, strategy and business model - General information: GOV-2; GOV-3; SBM-3.
• Engaging with affected stakeholders - General information: GOV-2; SBM-2; IRO-1; Table MDR-P, plus "Topical chapters: Reflecting different stages and purposes of stakeholder engagement throughout the due diligence process".
• Identifying and assessing negative impacts on people and the environment - General information: IRO-1; SBM-3.
• Taking action to address negative impacts on people and the environment - "Topical paragraphs reflecting the actions through which impacts are addressed".
• Tracking the effectiveness of these efforts - "Topical paragraphs regarding metrics and targets".

The annex EU-legislation datapoint table records GOV-4 paragraph 30 as covered on page 79 (page 121). AMG's human rights due diligence is described further under S1-1: it "follows a risk-based approach, aligning with the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises" and is "reviewed at least annually for effectiveness" (page 106).

Risk management and internal control over sustainability reporting

Reference: pages 79-80. The overall framework is incorporated by reference to Risk Management & Internal Controls (page 34) per Table BP-2 (page 72).

"AMG's risk management and internal control system related to sustainability reporting largely mirrors that of the overall AMG risk management process" (page 79). The programme "applies the Precautionary Principle to determine when threats of serious or irreversible damage exist".

Controls are decentralised by design: "For the data collection in particular, decentralized processes are controlled locally across the various business units. Overall responsibility for the sustainability reporting processes lies with Corporate EHSS. AMG's process of data collection, local review, submission to Corporate, and reviews and plausibility checks at Corporate are part of the internal control system" (page 79). Scope "covers both the CSRD General Disclosure and the topical disclosures".

The risks are named rather than generic: "The main risks identified regarding CSRD reporting include data completeness, accuracy, and timing of information availability. Currently, AMG is working diligently to close the risk gap" (page 80). Findings go to the Audit & Risk Management Committee and the 3S Committee on selected topics, and "Once a year, the full Supervisory Board reviews AMG's risk management approach and system and internal control framework" (page 80).

Strategy, business model and value chain

Reference: pages 72-75. Business Review (pages 29, 31, 33) and Note 4 Segment Reporting (page 160) are incorporated by reference (Table BP-2, page 72).

AMG is headquartered in Amsterdam and listed on Euronext Amsterdam. It "operate[s] at 38 sites, of which 29 are production facilities" with 3,640 employees (2024: 3,651): 1,823 in Europe, 582 in Northern America, 774 in South America, 453 in Asia, 8 in Eastern Africa (page 72).

NACE codes, each above 10% of revenue: "C24.1 - Manufacture of basic metals, B07.29 - Mining of non-ferrous metal ores, and DK.29.21 Manufacture of Furnaces and Furnace Burners". Three segments: AMG Lithium, AMG Vanadium and AMG Technologies. Most significant 2025 markets are "the United States, China and Europe", with Brazil a further key area. "No products of AMG were banned in the past year in any jurisdiction where AMG is active" (page 73).

Figure SBM-1 (page 74) runs from upstream purchases through AMG operations (lithium, tantalum, niobium, aluminium master alloys, ferrovanadium, titanium alloys, chrome metal, vacuum furnaces, antimony oxide, natural graphite, silicon metal) to four end markets: energy, transportation, infrastructure, and specialty metals and chemicals. "AMG's position in the value chain is that of a metal mining and manufacturing company" operating "in the business-to-business marketplace" (pages 73-74).

Interests and views of stakeholders

Reference: pages 75-76.

AMG's Stakeholder Engagement Policy is "aligned ... with the Dutch Corporate Governance Code 2025" (page 75). Channels named include customer feedback sessions, "employee works council meetings", "meetings with shareholders, bondholders and industry analysts", communications with "regulatory bodies, government agencies and other organizations", and "surveys, roundtables with policymakers, academics and peers".

Stakeholders are split into affected stakeholders and users of sustainability statements, then ranked semi-quantitatively on how far each is affected by AMG and affects AMG. Eight key groups result: shareholders/investors, customers, employees, business partners, local communities, nature, financial credit institutions and insurance companies, and authorities and governments (page 75).

What changed in 2025. AMG "updated its double materiality assessment which included revisiting its stakeholder mapping and adding direct engagement with external stakeholders", "conducted by a third party utilizing both a survey and interview process". The findings are reported with their limits: "stakeholders consider water use and pollution to be non-material topics, while recognizing AMG's strong compliance in waste management and GHG emissions reduction ... these were limited in scope and thus did not affect our overall double materiality assessment results" (pages 75-76).

Material impacts, risks and opportunities

Reference: pages 76-77, Table SBM-3, which lists 21 individually typed IRO rows with impact type, value chain location and time horizon.

• Climate change - mitigation: actual negative impacts from Scope 1-2 emissions (own operations) and Scope 3 emissions (value chain), both long term.
• Climate change - energy: an actual positive impact "by reducing GHG emissions due to a shift to renewable energy", plus an opportunity of "higher demand for AMG's materials and technologies that improve energy efficiency".
• Biodiversity - land-use change: an actual negative impact "for specific locations within AMG's own operations", "determined as a new material topic" this year (page 76).
• Own workforce: health and safety (actual negative); collective bargaining and freedom of association (potential negative); adequate wage, diversity, and training and skills development (actual positive).
• Workers in the value chain: potential negative impacts on health and safety, forced labor, diversity, adequate wages and collective bargaining, all upstream, plus a forced-labor risk.
• Affected communities: local employment opportunities, a positive impact plus an opportunity - "one entity-specific sustainability matter" (page 77).
• Governance: corporate culture (positive), protection of whistleblowers (negative) and a corruption and bribery risk.

Process to identify and assess material IROs

Reference: pages 80-82, Table IRO-1.

"In 2025, AMG revisited its double materiality assessment. This process included two main updates: direct engagement with external stakeholders and re-evaluating the environment sustainability matters to decluster the water, pollution, and biodiversity topics to allow for a more granular analysis" (page 80).

The process is tabulated step by step with an objective for each (pages 80-81): defining the context; identifying and classifying stakeholders; a long list of sustainability matters; focus areas across the value chain; a short list mapped to the value chain; defining IROs and timelines; impact-materiality parameters ("scale, scope, irremediably (for negative impacts), and likelihood"); financial-materiality parameters ("magnitude and likelihood"); and ranking against thresholds.

A gap is disclosed candidly: the DMA "was carried out separately from our primary risk management framework. Currently, AMG is in the process of including the analysis of sustainability IROs into our risk management procedures as prescribed by the European Sustainability Reporting Standards (ESRS)" (page 81).

Non-material environmental screening has its own table (pages 81-82), covering E2 pollution (ENCORE, the Pollutant Release and Transfer database, IRMA and IFC standards), E3 water (WRI Aqueduct) and E5 circular economy (Circular Transition Indicators).

Disclosure requirements covered

Reference: page 69 (Content index) and page 82.

AMG prints a real ESRS content index, headed "Content index9 (ESRS 2 IRO2, 56)" on page 69, listing each disclosure requirement with a page reference under General information, Environmental Information, Social Information and Governance Information. Footnote 9: "Where appropriate disclosure names have been shortened to improve readability."

It covers BP-1, BP-2, SBM-1, SBM-2, SBM-3, GOV-1 to GOV-5, IRO-1 and IRO-2; the EU Taxonomy; E1 (SBM-3, IRO-1, E1-1 to E1-9); E4 (SBM-3, E4-2 to E4-6); S1 (SBM-3, S1-1 to S1-6, S1-8, S1-9, S1-10, S1-14); S2 (SBM-3, S2-1 to S2-5); S3 (SBM-3, S3-1 to S3-5); and G1 (G1-3 and G1-4, under the G1 Business Conduct heading beginning on page 117).

"The Content Index outlines AMG's reporting requirements in line with the ESRS framework and materiality. Table IRO-2 EU legislation datapoint reference table in the annex provides guidance on specific KPIs" (page 82). That annex table spans pages 121-124 with an "AMG materiality" column giving either a page number or "Not material" per datapoint.

Minimum Disclosure Requirements follow on pages 82-84. Table MDR-P lists each policy with scope, key contents, third-party standards and implementer. On targets: "The targets that have been disclosed are not externally validated against science-based initiatives such as SBTi" (page 83).

Transition plan for climate change mitigation

Reference: pages 93-94.

AMG states that it has no compliant transition plan. "AMG has not established a transition plan for climate change mitigation that is in full alignment with disclosure requirement E1-1. ... Over the next two years, we intend to further advance the analysis of climate-related transition risks and opportunities on our own operations and our upstream supply chain. ... The results of these analyses will inform the development and implementation of our transition plan" (page 93).

What is disclosed instead:

• Board-approved policy foundation. "In 2024, with approval and support by the AMG Management Board, AMG published our revised Environmental Policy which documents our decarbonization levers that form the foundation of our plans to achieve future GHG reduction targets" (page 93).
• Table E1-1 Decarbonization levers (page 94): optimising metallurgical processes "to reduce the combustion of carbon-containing materials, such as coal used in the production of silicon metal"; cutting electricity and gas use; expanding renewable sourcing; supplier engagement for Scope 3.
• Locked-in emissions. "We also expect an increase in locked-in GHG emissions based on current and future investment in new assets, such as our Lithium Refinery in Bitterfeld, Germany", and "AMG is not excluded from the EU Paris-aligned Benchmarks" (page 94).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and E1 IRO-1, where this content is disclosed in the FY2025 report (pages 92-93). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification. "AMG has conducted climate-related physical and transition risk analyses of its own operations and part of our upstream supply chain. Downstream value chain was excluded from the analysis because we prioritized the analysis where we identified the greatest potential risk which is the supply of raw materials" (page 92).

Scenarios. Physical: "RCP 8.5 (4°C scenario) and RCP 2.6 (below 2°C scenario)", covering "flooding, extreme wind, forest fire, soil movement, extreme heat, freeze-thaw" and "changes in risk profile from 2020 to 2100". Transition: "five emissions pathways, from a 'No Policy' scenario with over 4°C temperature increase to the 'Paris Aspiration' scenario targeting a 1.5°C increase", covering "four locations as these represent 87% of the netbook value of machinery and equipment assets" (pages 92-93).

Results. "riverine flooding has the potential to cause the greatest damage. Extreme wind and soil subsidence may impact all our sites by 2100". A stated limitation: "the analysis assumes uniform fossil fuel use across regions" (page 93).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and E1 IRO-1, where this content is disclosed in the FY2025 report (pages 76, 92-93). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Where it sits. "For the conducted resilience analysis in relation to climate change, reference is made to E1 IRO-1" (page 76).

Results. Both limbs conclude exposure is immaterial. Physical: "Based on this physical risk analysis and climate modeling scenarios, AMG does not have material exposure, from a value at risk perspective, to physical climate risk in the relative near, medium or long-terms". Transition: "The analysis determined no visible immediate risks", and "the financial impact of climate change transition is determined as not material, and so, it has not been identified as a material IRO in our DMA" (page 93).

Uncertainty. "Our transition risk analysis demonstrated that it is very difficult to estimate, with a high level of confidence, the economic impacts of future climate events over the extensive geography in which AMG's value chain operates" (page 93).

Capacity to adjust. Handled as preparedness rather than financial flexibility: "AMG has implemented critical planning processes such as emergency preparedness ..., crisis management, business continuity" (page 80).

Policies related to climate change mitigation and adaptation

Reference: page 94; policy overview Table MDR-P, page 83.

The single instrument is AMG's Environmental Policy, "designed to actively address the identified environmental material impacts, risks, and opportunities (IRO) linked to AMG operations, as set forth in our double materiality assessment" (page 94).

Standards: "Management programs in the areas of Energy Management (ISO 50001) and Environmental Management (ISO 14001) assist us in building and implementing programs based on the highest standards in our activities and at our sites" (page 94).

Table MDR-P records the policy's objective as "Promoting responsible environmental stewardship", its IROs as "Climate change mitigation, energy, biodiversity and ecosystem services land use change", its scope as "AMG Group and, Suppliers", and implementation by "Corporate and Local EHSS departments" (page 83).

Levers are cross-referenced rather than restated: "Found in our Environmental Policy, we have identified levers in our own operation and in the value chain for reducing GHG emissions. These include the use of electricity and natural gas, expanding renewable energy sourcing, and developing solutions that reduce carbon emissions" (page 94). The Management Board is accountable for all AMG policies "with no exclusions based on business activity or geography" (page 82).

Actions and resources in relation to climate change

Reference: page 95, Table E1-3.

"Starting in 2024, AMG began the process of developing a decarbonization plan. AMG's decarbonization plan is inclusive of all operationally controlled sites and considers potential projects focusing on energy efficiency and consumption reduction; material efficiency; fuel switching; electrification; use of renewable energy; phase out, substitution, or modification of products ... and of processes" (page 95).

Table E1-3 Climate-related actions names five projects with location and phase (Study / Planning / Implement): electrification - replacing diesel forklift trucks, U.K.; energy efficiency - replacing diesel generator, US; renewable energy - installation of solar power, DE and US; energy efficiency - hybrid energy storage system, DE; energy efficiency - electric vehicle charging stations, DE, US and U.K.

Resources are not quantified, and AMG says so. "The current financial resources for these examples are not significant and therefore cannot be directly related to amounts presented in the financial statements", and "Once further actions have been implemented, we will be able to disclose additional information about our decarbonization actions, their associated GHG emission reductions and significant monetary amounts of CapEx and OpEx required to implement them" (page 95).

Targets related to climate change mitigation and adaptation

Reference: page 95.

AMG set no GHG reduction target for 2025. "In 2024, AMG reported that it accomplished its Scope 1 and 2 emissions reduction target ahead of its expected deadline in 2030. We are currently in the process of evaluating revised Scope 1, 2, and 3 emission reduction targets which includes setting long-term (i.e., beyond 2030) GHG reduction targets compatible with limiting global warming to 1.5°C. AMG did not set targets in 2025 given that our emissions profile changed significantly this year, due to a decrease in production at AMG Silicon" (page 95).

"We continue to evaluate our operational capabilities, locked-in GHG emissions, changes in technologies and the availability of alternative energy sources to further reduce our CO2e emissions. We anticipate disclosing revised emission reduction targets ... in future Sustainability Statements" (page 95).

The change in profile is corroborated: "AMG Silicon is one of the largest contributors to AMG's GHG emissions. 76% of the reduction in AMG's overall Scope 1 and 2 GHG emissions between 2024 and 2025 is due to the site's reduced operational output" (page 99).

The general MDR-T position applies: "The targets that have been disclosed are not externally validated against science-based initiatives such as SBTi" (page 83). No base year, target year, milestones or carbon-credit reliance can therefore be reported for FY2025.

Energy consumption and mix

Reference: pages 95-96, Table E1-5.

"AMG operates in high climate impact sectors NACE (B) Mining and (C) Manufacturing" and "Our primary data source relies on metering and bills from third parties for energy consumption" (page 95).

Total energy consumption fell to 563,475 MWh from 732,805 MWh in 2024, a 23% reduction that the footnote attributes to "AMG's Silicon operations" (page 96).

Energy intensity is 0.0003 MWh per USD of net revenue (2024: 0.0005), on net revenue of USD 1,708,325 thousand (2024: USD 1,439,856 thousand) derived from the high climate impact NACE sectors (page 96). "In 2025, AMG generated 9,259 MWh of renewable energy" (page 95).

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 96-99, Tables E1-6b and E1-6c.

Scope 3: purchased goods and services 1,160,341; capital goods 9,846; fuel and energy-related activities 11,107; upstream and downstream transportation and distribution 100,502; waste generated in operations 2,285. Nine categories are "not applicable", each with a reason - business travel and employee commuting are "<1% of total emissions" (pages 98-99). Intensity is 0.0009 tCO2e per USD of net revenue (2024: 0.0010).

The direction of travel is disclosed with its cause. Scope 1 and 2 both fell about a third, but "76% of the reduction in AMG's overall Scope 1 and 2 GHG emissions between 2024 and 2025 is due to the site's reduced operational output" at AMG Silicon (page 99). Total emissions still rose, because Scope 3 grew 11%. "In 2025, renewable energy power purchase agreements and RECs in the amount of 30,017 MWh were utilized in calculating our Scope 2 market-based emissions" (page 97).

GHG removals and mitigation projects financed through carbon credits

Reference: page 99.

A nil return, stated in full: "AMG does not have GHG removal and GHG mitigation projects financed through carbon credits as prescribed in Disclosure Requirement E1-7" (page 99).

This is consistent with the rest of the climate chapter. AMG has no active GHG reduction target for 2025 at all (E1-4, page 95), so no question of reliance on removals or credits to meet one arises, and no net-zero claim is made that would need substantiating under paragraph 61. The decarbonisation levers in Table E1-1 are all abatement levers - process optimisation, energy reduction, renewable sourcing, supplier engagement and product substitution - with no offsetting lever among them (page 94).

E1-7 is listed in the ESRS content index against page 99 (page 69), so the nil return is the company's own claim of coverage rather than an inference from silence.

Internal carbon pricing

Reference: page 100.

A nil return, stated in full: "AMG does not apply internal carbon pricing schemes as prescribed in Disclosure Requirement E1-8" (page 100).

E1-8 is listed in the ESRS content index against page 100 (page 69).

AMG does apply a non-monetary carbon screen to investment decisions, disclosed under E1-1 rather than as a price: "AMG integrated a double materiality principle into our capital allocation program to screen activities and plans for potential future emission sources aligned with the decarbonization levers. Projects meeting the Corporate financial requirements for capital expenditure authorization are evaluated on two key elements: the incremental financial value and the impact on GHG reduction. Project champions are required to calculate the net CO2e contribution or removal for the project. The results are compared to the company and/or business unit carbon footprint and considered in the process for project authorization" (page 94). No shadow price, internal fee or carbon price level per tonne is disclosed. AMG does report that 15% of Scope 1 emissions fall under regulated trading schemes (page 99), which is an external price rather than an internal one.

Transition plan and consideration of biodiversity and ecosystems in strategy and business model

Reference: pages 100-101. The disclosure sits under a combined heading, "E4 SBM-3 ... & ESRS E4 IRO-1 ... & E4-1 - Transition plan and consideration of biodiversity and ecosystems in strategy and business model" (page 100). The shortened page-69 content index lists this section under "E4 SBM-3 ... 100" and prints no separate E4-1 line.

No biodiversity transition plan is presented. What AMG sets out is how biodiversity entered the strategy in 2025:

• A widened assessment. "In 2025, we expanded our study to consider specific impact drivers in our own operations and select upstream suppliers", partnering with Natcap and using the TNFD LEAP framework with ENCORE, IBAT and site-level data (page 100).
• The strategic hook. Land-use change is "primarily associated with the expansion of our current sites, construction of new facilities or future acquisitions", specifically "the new construction of the hydroxide plant in Bitterfeld and the expansion of our mining operations in Brazil" (pages 85, 100).
• Dependencies. Own and supplier activities "depend on similar ecosystem services such as provision of ground and surface water and natural resources; and regulating and maintenance services such as global climate regulation, flood mitigation, water flow regulation" (page 100).

Policies related to biodiversity and ecosystems

Reference: page 101; policy overview Table MDR-P, page 83.

The instrument is again AMG's Environmental Policy, which "actively addresses our identified environmental material impacts, risks, and opportunities (IRO) linked to AMG operations, as set forth in our DMA. ... Specifically, AMG aims to conserve water, energy, and ecosystems; reduce carbon emissions; minimize waste; and support environmental sustainability" (page 101). Table MDR-P names biodiversity and ecosystem services land use change among the policy's IROs and IFC standards among its third-party references (page 83).

The operative commitment is the mitigation hierarchy, stated in sequence: "Related to land-use change, when we operate in biodiversity sensitive areas, including legally protected areas, key biodiversity area, and areas of high conservation value, AMG applies stringent mitigation standards. ... First, we identify and avoid potential impacts on biodiversity and ecosystem services. Where avoidance is not possible, we minimize our impact. Where our operations have affected biodiversity, we seek to restore and/or mitigate impacted habitats" (page 101).

No traceability to sustainable land or agriculture practices, oceans and seas practices, or deforestation (paragraph 24(b)-(d)) is given in the E4-2 text itself.

Actions and resources related to biodiversity and ecosystems

Reference: pages 101-102.

A stated non-conformance opens the disclosure. "AMG has not established actions and resources that follow the mandatory content in ESRS 2 MDR-A or implemented biodiversity offsets. In addition, given that AMG sites are not located within land entitled to indigenous or tribal peoples or buffer zones, we have not incorporated local and indigenous knowledge and nature-based solutions into biodiversity and ecosystem-related actions" (page 101). "At present, biodiversity related impacts are primarily addressed through local environmental management systems."

Named examples:

• Pre-project assessment. "AMG conducts impact assessments for any new major project or large expansions ... and, when appropriate, develop biodiversity action plans before we start" (page 101).
• Brazil mining. A Mine Closure and Recovery Plan involving "continuous monitoring of soil, water, and biodiversity indicators, progressive rehabilitation of mined areas, and recontouring and revegetation of disturbed areas with native species" (page 101).
• Flora and fauna. "Since 2016, AMG Brazil has monitored wildlife on a semiannual basis ... Through this monitoring we can track any impact on endangered species" (page 102).

No expenditure figure is attached to any of these actions.

Targets related to biodiversity and ecosystems

Reference: page 102.

No biodiversity target has been set, and AMG says why. "As mentioned, given the diversity of our business activities, biodiversity-related actions and targets are primarily defined and implemented at the local level. In assessing biodiversity impact drivers, we currently track emissions, water consumption, waste generation, and pollution through our local environmental management systems. As we are at an early stage of our biodiversity journey, AMG has not yet established targets related to biodiversity. AMG will establish a baseline and report targets in future Sustainability Statements" (page 102).

This matches the blanket MDR-T position: "In case we do not have any targets set in relation to a material topic for which we disclose policies or actions, we do not have any explicitly defined level of ambition to be achieved. We track the effectiveness of our policies and actions through periodic analysis of our related metrics (if any), and by obtaining input from internal stakeholders" (page 83).

No ecological threshold and no measurable outcome-oriented level of ambition is disclosed. The Kunming-Montreal framework appears only as the basis for the metric baseline, not as a target: the E4-5 land-use-change figures use 2020 as base year "as specified by the Global Biodiversity Framework" (page 102).

Impact metrics related to biodiversity and ecosystems change

Reference: page 102.

Sites in or near biodiversity-sensitive areas (BSAs):

Total area of the two own-operation sites in BSAs is 6.7 hectares. AMG states that of four own sites originally identified inside a BSA, "one is an administrative office, and one is a warehouse and thus, were not included in the assessment and deemed not material", leaving AMG Alpoco (United Kingdom) and AMG Antimony (Chauny, France), where "the results show that the sites do not have a material biodiversity-related negative impacts on the surrounding areas. The activities at both sites use low volumes of water and data shows limited change in percentage of forests and connectivity of natural lands" (page 101). "No sites located in biodiversity-sensitive areas were determined to have a material negative impact on the surrounding environment" (page 102).

Land-use change 2020-2024, seven sites, with 2020 as base year "as specified by the Global Biodiversity Framework":

Total measured land-use change is 36.71 hectares across the seven sites.

Policies related to own workforce

Reference: pages 104-107; Table MDR-P (pages 83-84) and Table S (page 104).

"Seven AMG policies support the management of material impacts on AMG's workforce. The policies cover all of AMG's own workforce, not just specific groups": the Code of Conduct, Diversity and Inclusion Policy, Human Rights Policy, Stakeholder Engagement Policy, Supplier Code of Conduct, Speak Up & Reporting Policy and Health and Safety Policy (page 106). Table S maps each policy to each material issue (page 104).

Human Rights Policy. AMG "supports and respects the internationally recognized human rights in accordance with international standards and initiatives such as the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises; and the ILO Declaration ... In addition, AMG is a signatory of the United Nations Global Compact" (page 105).

Diversity and Inclusion Policy. "zero-tolerance for any kind of discrimination or harassment based on racial or ethnic origin, color, sex, sexual orientation, gender identity, disability, age, religion, political opinion, national extraction or social origin". A gap is disclosed: "AMG has not defined policy commitments related to inclusion or positive action for people from groups at particular risk of vulnerability in its own workforce" (page 106).

Processes for engaging with own workers and workers' representatives

Reference: page 107.

A stated gap opens the disclosure. "Due to its decentralized governance and company set-up, AMG has not established a general company-wide process to engage with its own workforce. Yet the group-wide employee engagement survey conducted in FY 2025 informs decisions or activities aimed at managing the actual and potential impacts on AMG's workforce" (page 107).

What does happen is local and continuous: "The AMG business units engage with people in its own workforce and workers' representatives continuously. In particular, local management and local HR teams are constantly in interaction with its own workforce. For pertinent topics, corporate HR and local HR communicate with each other and have also convened in person during the first global HR meeting. Where workers' representatives are active, AMG engages with them on various issues of relevance locally" (page 107).

The survey runs on a repeating cycle: a group-wide survey in 2024 informed the AMG Elevate mentoring programme, and "the second group-wide employee engagement survey rolled out in October 2025" (page 108).

No senior role is named as accountable for ensuring engagement happens, and no assessment of the engagement's own effectiveness is given.

Remediation processes and channels to raise concerns

Reference: page 107, with detail cross-referenced to G1-1 (pages 118-119).

"A key component of AMG's grievance mechanisms is AMG's Speak Up & Reporting Policy. Employees and third parties are encouraged to use the Speak Up Portal, a phone and web-based tool, to raise concerns, also on an anonymous basis. This may include, but is not limited to, all (social) issues of various levels of concern" (page 107).

Effectiveness is benchmarked rather than measured against a target: "The number of reported cases is regularly benchmarked against reputable and publicly accessible benchmark reports to assess effectiveness and AMG's Speak Up culture" (page 107).

Additional channels: "AMG encourages to address any potential suspected irregularities directly with the person involved or the relevant managers or supervisors at the relevant office or industrial site ... It is also possible to reach out to AMG's local Compliance Officer or representatives nominated at our sites" (page 107).

Awareness and protection are described under G1-1: the policy "is available on AMG's corporate website in six languages", a poster "is displayed at AMG sites worldwide and all employees have received an email on the Speak Up Policy" (pages 118-119). No number of reports received in 2025 is disclosed.

Taking action on material impacts on own workforce

Reference: pages 107-108.

AMG states plainly that it cannot yet meet MDR-A. "Activities are in an early stage and set a precedent in AMG. Therefore, we cannot report on comprehensive action plans including a list of key actions with expected outcomes and its contributions to AMG's policies nor necessary expenditures", and "the allocated resources are largely decentralized and part of the internal decision-making processes of individual business units" (page 108).

Named 2025 actions:

• First in-person Global HR meeting, "to review key talent priorities, sharing updates on workforce planning, organizational effectiveness, and employee engagement".
• AMG Elevate, a global mentoring programme "based on insights gained through the employee engagement survey results in 2024 ... to accelerate the development of future leaders".
• Corporate Diversity and Inclusion Council, established 2023, which "In 2025 it has 12 members from seven business units". Two Employee Resource Groups "held quarterly meetings in 2025, facilitated by an external consultant". Also the "From Ore to Us" initiative and AMG Connect, "started with a pilot project in Germany, which was successfully finalized in December 2025".
• Health and safety: ISO 45001-conforming systems, multilingual training, and "integrating health and safety performance evaluations into relevant staff appraisals and reward systems" (page 108).

Targets related to own workforce

Reference: page 109.

Three of the five material sub-topics carry no target, and AMG says so. "AMG has not set any targets on the identified positive or negative impacts regarding own workforce with regard to collective bargaining freedom of association, adequate wages, and training and skills development. We trust in the proficiency of our local HR staff and departments to track the effectiveness of local activities and actions ... A group-wide tracking of effectiveness of the actions regarding the particular sub-sub-topics has not been implemented" (page 109).

Diversity target. "In line with the SER framework, AMG has set a target to increase women in management-level leadership roles globally to 30% by 2030. No milestones were defined" (page 109). AMG adds: "We are not in the position yet to report an AMG target covering broader aspects of diversity and inclusion".

Health and safety target. "We aim to achieve an annual zero-incident status. ... AMG has set a compensation target, related to the lost time incident rate (LTIR) aspiring to be 10% better than our peers. AMG's 2025 LTI of 0.66 was significantly better than its peers and 34% below the peer group figure of 1.00" (page 109). "A consolidated monthly report, tracking the organization's progress towards the annual target, is prepared and disseminated to AMG management personnel".

Characteristics of the undertaking's employees

Reference: pages 109-110.

3,640 employees at 31 December 2025 (2024: 3,651). "574 employees (2024: 530) have left AMG in 2025 with an employee turnover rate of 16% (2024: 14.5%)" (page 109).

By gender (headcount): male 3,008 (83%), female 632 (17%), other 0, not reported 0 (2024: 3,021 / 622 / 0 / 8).

By country, for countries with at least 50 employees representing at least 10% of the total - "74% of AMG employees are based in three countries: Germany, Brazil and USA": Germany 1,436 (39%), Brazil 774 (21%), USA 511 (14%) (page 110).

By contract type: "The vast majority - 96.5% of all AMG employees - has permanent contracts". Permanent 3,513 (male 2,905, female 608), temporary 122 (male 98, female 24), non-guaranteed hours 5 (2024: 3,548 / 103 / 0).

By region (Table SBM-1, page 72): Europe 1,823, South America 774, Northern America 582, Asia 453, Eastern Africa 8.

Method: "Headcount refers to the number of employees at the end of the reporting period. Those on long-term leave or with temporary inactive status are excluded from this total", and "We do not apply estimations, but actual data provided by the Business Units" (page 108). The reconciliation is cross-referenced: "Footnote 1 Reporting Entity on page 143 states the number of employees" (page 109).

Collective bargaining coverage and social dialogue

Reference: pages 110-111.

"47% (2024: 49%) of AMG's total employees are covered by collective bargaining agreements" (page 110).

Agreements are named: "In the EEA there are three collective bargaining agreements in Germany (AMG Titanium, AMG Silicon and AMG Graphite Germany) and two in France (AMG Antimony and ALD France)" (page 110).

Social dialogue: "86% (2024: 92%) of employees are covered by workers' representatives in EEA countries with significant employment, respectively Germany", and "There is no existence of any agreement with its employees for representation by a European Works Council (EWC), a Societas Europaea (SE) Works Council, or a Societas Cooperativa Europaea (SCE) Works Council" (page 110).

Table S1-8 bands each qualifying country or region (page 111): Germany 40-59% for collective bargaining and 80-100% for workplace representation; Northern America 20-39%; South America 80-100%.

A prior-year correction is disclosed. "In the CSRD 2024, due to updated data Germany should have been classified in the 40-59% range rather than the 20-39% range. Previously reported coverage of AMG's total employees by collective bargaining agreements was corrected for 2024: from 46% to 49%" (page 111).

Method: "The S1-8 assessment is done on the basis of Q3 data", with data "collected via a cloud-based platform with primary inputs from Business Units" (page 109).

Diversity metrics

Reference: page 111.

Gender at top management. AMG defines top management as "one and two levels below AMG's Management Board": "the CEOs of the business units are level 1 top management, and level 2 are all reporting into these, incl. e.g. other board members and other direct reports" (page 111).

"The overall number of top management level increased due to newly established reporting lines to the Management Board and restructuring in one of the business units, while the percentage stayed stable" (page 111).

Age distribution (headcount, 2025): under 30 - 670 (18%); 30 to 50 - 1,986 (55%); over 50 - 984 (27%). 2024: 613 (17%), 2,029 (56%), 1,009 (28%).

A definitional restatement is disclosed. "During the current reporting cycle, the definition was clarified as stated above, and the data was fully recollected based on the updated criteria. The updated 2024 figures are presented in the table above, replacing the previously reported range of 25% to 75% with a total of 154 individuals identified as top managers" (page 111).

Adequate wages

Reference: page 112, with methodology on page 109.

The disclosure is a single sentence: "All AMG employees are paid an adequate wage in line with an adequate benchmark" (page 112), cited against ESRS S1-10 paragraphs 67 and 70. Because all employees are at or above the applicable benchmark, paragraph 69 - the countries and percentages of employees not paid an adequate wage - has no content to report.

The benchmarking method is described under Metrics and Targets: "For S1-8 and S1-10 metrics, data is collected via a cloud-based platform with primary inputs from Business Units, complemented by centrally performed calculations and ESRS-required benchmarking in the case of S1-10 metrics. The S1-10 analysis covers employees included in the normal headcount, excluding individuals on long-term leave, non-employees, apprentices, secondees, and interns. The lowest wage per country is determined based on basic pay plus fixed guaranteed payments and assessed against relevant benchmarks" (page 109).

Adequate wages is a material own-workforce IRO, an actual positive impact: "In specialized sectors like AMG, where highly skilled professionals such as engineers are essential, fair employment terms and adequate wages can have a profound positive impact" (page 105). No target is set for it (page 109), and the specific benchmarks used per country are not named.

Health and safety metrics

Reference: page 112, Table S1-14. Paragraph 88(e), days lost, is omitted under the Quick Fix phase-in (page 70).

A fatality is reported first, not buried. "In March 2025, a fatal accident involving an employee occurred at one of the Company's operating facilities in Rotherham, United Kingdom. ... The incident is the subject of a pending regulatory investigation" (page 112).

Both incident rates roughly doubled year on year. The coverage figure was restated: "In 2024, we disclosed that 47% of our employees were covered by ISO 45001 management system. In 2025, this disclosure was revised to reflect that 100% of AMG employees are covered by a management system in accordance with local legislation" (page 72).

Policies related to value chain workers

Reference: page 114, with the underlying policy text on pages 104-107 and Table MDR-P on pages 83-84.

"Several AMG policies support the management of material impacts on workers in AMG's value chain, in particular upstream workforce. ... Regarding the social IROs these are namely AMG's Code of Conduct, Diversity & Inclusion Policy, Human Rights Policy, Health & Safety Policy, Speak Up & Reporting Policy, Stakeholder Engagement Policy and Supplier Code of Conduct" (page 114). The S2-1 section itself is a routing disclosure, cross-referring to G1-1, Table MDR-P and S1-1.

The substantive commitments sit in the cross-referenced text:

• The Human Rights Policy "covers all value chain workers, with particular focus on supply chain workers" and "expresses the respect for human rights, including labor rights, of its own workforce and of value chain workers as well as communities, and indigenous peoples specifically" (page 105).
• "AMG's supplier code of conduct includes provisions that address worker safety, precarious work conditions, human trafficking, forced labor, and child labor, ensuring full compliance with applicable ILO standards" (page 105).
• Table MDR-P scopes the Supplier Code of Conduct to "Suppliers globally", referencing "UN Guiding Principles, ILO Declaration, OECD Guidelines on Multinational Enterprises and Supply chain Due Diligence" (page 84).

Processes for engaging with value chain workers

Reference: page 114.

The disclosure is a stated gap. "Due to the decentralized nature of its business, AMG has not adopted a general company-wide process to engage with workers in the value chain. It is up to the different business units to define the most adequate process for their respective situation regarding workers in their specific value chain. On the basis of the updated Supplier Code of Conduct and Human Rights policy we are preparing a common framework for further processes" (page 114).

No global engagement function, frequency, stage in the due diligence process, or engagement with credible worker proxies is described, and no senior role is identified as operationally responsible.

The context makes the limits explicit: "Due to the nature of its products and its position within the overall value chain, AMG's influence and leverage are likely to be limited"; "AMG has not yet developed an understanding of how workers with particular characteristics, those working in particular contexts, or those undertaking particular activities may be at greater risk of harm"; and "Workers who are particularly vulnerable to negative impacts, have not yet been identified" (page 113).

Remediation processes and channels for value chain workers

Reference: page 114, with detail cross-referenced to G1-1 (pages 118-119).

"A key component of AMG's grievance mechanisms is AMG's Speak Up & Reporting Policy. Employees and third parties, including value chain workers, are encouraged to use the Speak Up Portal, web-based tool, to raise concerns, also on an anonymous basis" (page 114). "The number of reported cases is regularly benchmarked against reputable and publicly accessible benchmark reports to assess effectiveness and promote a Speak Up culture".

The limitation is stated rather than glossed: "Awareness among value chain workers has not yet been assessed" (page 114), answering the paragraph 28 datapoint in the negative.

The channel's design is described under G1-1: "Since 2024, AMG operates a 'Speak Up Portal', alongside conventional reporting channels (email or phone). The online portal allows employees and external parties to report easily and anonymously by scanning a QR code or filing a report online" (page 118).

No supply-chain-specific grievance mechanism and no number of value chain grievances received in 2025 is disclosed. AMG does report that "No severe human rights issues and incidents connected to AMG's upstream and downstream value chain have been reported in 2025" (page 114).

Taking action on material impacts on value chain workers

Reference: pages 114-115.

AMG states that it has no actions to report. "Currently, we have not yet established or planned actions for this matter, we cannot report on comprehensive action plans regarding identified material potential negative impacts or risks regarding the workers in our value chain nor do we have a list of key actions with expected outcomes and its contributions to AMG's policies and necessary expenditures. While we have updated the AMG Supplier Code of Conduct, we cannot yet detail approaches for our own practices" (pages 114-115).

What is disclosed is a direction of travel: "We are considering ways to improve our methods for identifying suitable actions to address potential negative impacts on value chain workers. This involves assessing internal practices, evaluating the availability and effectiveness of remedy processes, and exploring a tighter integration with current risk management systems" (page 115).

The paragraph 36 datapoint is answered: "No severe human rights issues and incidents connected to AMG's upstream and downstream value chain have been reported in 2025" (page 114).

The Supplier Code of Conduct carries the substantive requirements: it "requires suppliers to establish internal programs to protect the health and safety of their staff, subcontractors and residents, through a documented safety management system" (page 113).

Targets related to value chain workers

Reference: page 115.

No target is set, and the reason is given. "Until now and due to the decentralized business structure of AMG in addition to its diverse global value chain(s) in the different businesses, AMG has not set any outcome-oriented targets regarding workers in the value chain. This does not imply that AMG does not take any potential negative impacts on workers in the value chain seriously" (page 115).

Effectiveness tracking, the other limb of MDR-T, is generic rather than topic-specific: "The effectiveness of AMG's policies in relation to workers in the value chain is currently tracked in the same manner as other AMG policies. AMG is developing a feasible system to allow the company and the business units to annually report on the effectiveness of AMG's policies" (page 115).

The group-level MDR-T position applies: "For material topics for which we do not have targets yet, this is because we have not yet completed our assessment of determining which specific targets to establish going forward" (page 83).

There is therefore no measurable level of ambition, base year or milestone for the five material value chain worker impacts - health and safety, forced labor, diversity, adequate wages, and collective bargaining and freedom of association - or for the forced labor risk to AMG (page 77). Value chain workers were not engaged in setting targets, consistent with S2-2 (page 114).

Policies related to affected communities

Reference: page 116, with the underlying policy text on pages 104-106 and Table MDR-P on pages 83-84.

"AMG's policies help manage addressing material impacts on affected communities include Diversity & Inclusion Policy, Human Rights Policy, Supplier Code of Conduct, Stakeholder Engagement Policy, and Speak Up & Reporting Policy. AMG considers not only local communities but also indigenous peoples in the regions where it operates" (page 116).

The commitments that reach communities sit in the shared social section. The Human Rights Policy "defines the framework for AMG's respect for human rights, both with regard to its own employees, workers in the value chain and affected communities". AMG "considers that the UN Guiding Principles on Business and Human Rights, reference the International Bill of Rights, the UN Declaration on the Rights of Indigenous Peoples, ILO Convention No. 169, and the core conventions that support these instruments" (page 105). "The Speak Up portal is the cornerstone of AMG's measures to provide and/or enable remedy for potential human rights impacts" (page 105).

Table MDR-P records the Environmental Policy's affected parties as "Nature, local communities", and scopes the Speak Up & Reporting Policy to "AMG Group and stakeholders globally", affecting "All stakeholders" (pages 83-84).

Processes for engaging with affected communities

Reference: page 116.

The disclosure is a stated gap with a stated rationale. "AMG has not yet adopted a general company-wide process to engage with affected communities due to its decentralized corporate set-up as well as the by definition specifically locally communities that need and are handled on the local level in a way seen as adequate and necessary by the local business in line with the AMG's expectations as expressed in AMG's Values and policies" (page 116).

Local engagement is evidenced elsewhere:

• Brazil mining. "the mining and closure and recovery plan includes engagement with local communities and environmental authorities during planning and implementation. The local team also conducts visits to surrounding and nearby communities every six months" (page 101).
• A structured programme. "AMG Brazil strengthened its relationship with surrounding communities through a structured community engagement program designed to foster transparency, dialogue, and local economic activity" (page 116).
• Indigenous and tribal peoples. "In 2024, AMG assessed whether its activities in operating production sites were causing conflict with indigenous and tribal peoples (ITP) ... none of the sites analyzed are located within land entitled to indigenous or tribal peoples or buffer zones" (page 101).

No senior role with operational responsibility is named, and no assessment of engagement effectiveness is reported.

Remediation processes and channels for affected communities

Reference: page 116.

The disclosure is short and conditional on materiality: "No negative material impacts were identified" (page 116), cited against ESRS S3-3, with a cross-reference: "More on Speak Up in the Governance section on page 117."

That is consistent with the S3 materiality position. AMG's only material affected-communities IRO is a positive one - local employment opportunities - plus a related opportunity for AMG, both in own operations (page 77). Under S3-4 the company confirms: "No human rights issues or incidents connected to affected communities have been reported" (page 116).

The channel that would carry a community grievance is the Speak Up Portal, described under G1-1 as open to "employees and external parties" who "report easily and anonymously by scanning a QR code or filing a report online", with reports handled "in accordance with the procedure outlined in the Speak Up Policy, which adheres to strict principles of confidentiality, objectivity, timely response, anonymity and non-retaliation. ... The outcome of any investigation is communicated back to the reporter" (pages 118-119). The Speak Up & Reporting Policy is scoped to "AMG Group and stakeholders globally", affecting "All stakeholders" (page 84).

AMG does not report whether affected communities are aware of, or trust, these channels, and no community-specific grievance mechanism is described.

Taking action on material impacts on affected communities

Reference: page 116.

No group-level action plan exists, and AMG explains why. "We also fully trust our local business units to make a positive impact on the communities around our manufacturing sites by providing local employment opportunities and thereby supporting livelihoods in a decentralized manner. As a result, we have not established AMG-wide action plans or allocated centralized resources to manage our material impacts or opportunities, nor do we track their effectiveness at the AMG Group level", and "At this time, we do not see the value in implementing an AMG-wide action plan on affected communities that aligns with the ESRS disclosure standards" (page 116). "No human rights issues or incidents connected to affected communities have been reported."

One worked example is given - Minas Gerais, Brazil (page 116):

• "Approximately 70% of our workforce is recruited locally from the areas surrounding the São João del-Rei plant and the Nazareno mine."
• "In 2025, the Company implemented an educational technology initiative in nearby public schools in collaboration with SESI a non-profit institution linked to the National Confederation of Industry."
• An "apprenticeship program that exceeds Brazilian legal requirements", plus technical training sessions for community members and educational visits for local students.

No expenditure figure is attached to any of these initiatives.

Targets related to affected communities

Reference: page 117.

No target is set, and neither limb of MDR-T is fully met. "AMG has not set targets regarding affected communities. Currently the effectiveness of policies and actions in relation to the material opportunity 'Local employment opportunities' regarding affected communities is not tracked. The reason is the decentralized structure of AMG and regarding the affected communities the localized specific nature of any interaction. AMG's defined level of ambition to evaluate the process, including the base period which progress is measured needs to be clarified yet" (page 117).

What is described is a generic mechanism plus a commitment to build one: "The effectiveness of AMG's policies in relation to affected communities is currently tracked in the same manner as other AMG policies. AMG is developing a feasible system, including metrics, to allow the company and business units to annually report on the effectiveness of AMG's policies" (page 117).

Communities were not engaged in setting targets, consistent with S3-2 (page 116). The one quantified community figure - "Approximately 70% of our workforce is recruited locally" around São João del-Rei and Nazareno (page 116) - is a fact about a single operation, not a target or a tracked KPI.

Business conduct policies and corporate culture

Reference: pages 117-119. The section is headed "G1-1 - Business conduct policies and corporate culture" on page 117, within the "G1 - Business Conduct" block the page-69 content index lists against page 117.

Policy framework: "the AMG's Code of Business Conduct ('the COBC') and AMG's Values, Speak Up & Reporting Policy, Anti-bribery, anti-corruption and conflicts of interest Policy ('ABC Policy'), and Supplier Code of Conduct". "Since 2009, AMG's Management Board has committed to" the UN Global Compact principles (page 117).

Tone from the top: "our Chairman of the Management Board asserts that honesty, integrity, and accountability are the foundations on which AMG is built", reinforced through "AMG Loop, a magazine that is distributed throughout the AMG organization every month" (page 118).

Whistleblower protection: retaliation "is treated as a violation of AMG's COBC and may result in disciplinary measures ... in line with the legal requirements ... following the EU Directive 2019/1937" (page 119).

Training: all employees complete an online COBC course at induction with refreshers "at least every three (3) years"; "functions at risk" get anti-trust and ABC training every three years; local Compliance Officers "receive refresher training annually" (page 119). No percentage trained is disclosed.

Prevention and detection of corruption and bribery

Reference: pages 119-120.

AMG structures the disclosure in three steps: "AMG (1) prevents misconduct by acting lawfully and enforcing the AMG Values, the AMG COBC, ABC Policy, and Supplier Code of Conduct; (2) detects misconduct through internal controls, the Speak Up Policy and Portal; and (3) investigates and responds to misconduct through the Compliance network and Speak Up procedure" (page 119).

Prevent. AMG will "comply with all applicable anti-bribery laws, including but not limited to the UK's Bribery Act 2010, the US Foreign Corrupt Practices Act, and all applicable laws where AMG transacts business" (page 119). The ABC Policy is "consistent with the United Nations Convention Against Corruption (UNCAC)" (page 117).

Detect. "it is AMG's policy to accurately reflect all transactions in AMG's books and records, which are checked by internal and external auditors", and fraud risks "are continuously monitored by the Management Board and the Internal Audit function ... with regular reporting to the Audit & Risk Management Committee" (page 120).

Independence (paragraph 18(b)). "The Chief Compliance Officer acts independently and separately from the chain of management, including the Management Board and Supervisory Board, in exercising his duties" (page 120).

Targets related to business conduct

Back-filled from the business conduct chapter and the Minimum Disclosure Requirements section, where targets are addressed under MDR-T rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

AMG discloses no measurable outcome-oriented business conduct target. The blanket MDR-T statement applies: "In case we do not have any targets set in relation to a material topic for which we disclose policies or actions, we do not have any explicitly defined level of ambition to be achieved. We track the effectiveness of our policies and actions through periodic analysis of our related metrics (if any), and by obtaining input from internal stakeholders as previously described" (page 83).

Consistent with MDR-T's other limb, effectiveness is tracked in the absence of a target:

• "AMG assesses awareness and trust in the AMG Values and COBC through its annual employee survey. The Management Board ... monitors the overall effectiveness of the AMG COBC" (page 119).
• The Chief Compliance Officer "regularly reports to the Supervisory Board about the performance against AMG's COBC, the number of reports filed and nature of the reports filed, employee awareness of the COBC" (page 118).
• "The number of reported cases is regularly benchmarked against reputable and publicly accessible benchmark reports" (page 107).

Incidents of corruption or bribery

Reference: page 120.

A nil return across all limbs of paragraphs 24 to 26: "There have been no incidents of convictions or fines for violation of anti-corruption and anti-bribery laws, and no breaches of procedures and standards relating to such laws. There have not been any incidents of corruption or bribery, also no reported incidents relating to contracts with business partners or public cases brought against the company or its workers in this area" (page 120).

G1-4 is listed in the ESRS content index against page 120 (page 69), so this is the company's own claim of coverage.

The statement corroborates the position elsewhere. The S1 chapter cross-refers to "Governance Information mentioning of no reports on page 117" (page 106); the S2 chapter points to "the governance section, which does not mention any reports" (page 113).

No number of reports received through the Speak Up Portal in 2025 is disclosed, so the reader cannot see the denominator behind the nil count. Corruption and bribery remains a material risk over the mid term: "The risk of financial loss or damage to AMG reputation caused by failure to comply with regulations regarding anti-corruption, anti-trust and anti-bribery due to the increasing complexity of regulations, significant business growth and presence into more countries" (page 117).