Anora Group Oyj

The role of the administrative, management and supervisory bodies

Reference: pages 44-45 (ESRS content index, page 56).

Duties of Anora's governing bodies are set by Finnish law, the Articles of Association and internal governance documents (Governance Principles, Charter of the Board of Directors, Charter of the Audit Committee), all approved by the Board (page 44).

Board of Directors (administrative body). In 2025 it comprised 6 (7) non-executive members elected by the General Meeting and 1 (1) member elected by personnel. It "holds primary oversight responsibility for sustainability-related impacts, risks, and opportunities", approves the sustainability strategy including targets and significant sustainability investments, and is supported by the Audit Committee (page 45).

CEO and Executive Management Team (management body). 7 (8) members in 2025, chaired by the CEO; responsible for implementing the sustainability strategy, approving and monitoring actions and targets, and preparing sustainability investment proposals. The report states plainly that "No separate management-level positions or committees have been appointed to oversee sustainability-related impacts, risks, and opportunities" (page 45).

Diversity and independence (page 45): 57% (63%) of board members independent of the company and significant shareholders; board gender diversity ratio 43% (38%); Executive Management Team gender ratio 29% (25%) including the CEO.

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

Reference: pages 45-46 (ESRS content index, page 56).

"Sustainability topics related to material impacts, risks, and opportunities are regularly discussed in both Executive Management Team and Audit Committee meetings. During the reporting period, the Audit Committee convened 5 (6) times" (page 45).

The Board is kept informed by the Chairperson of the Audit Committee, the CEO and the Executive Management Team "on the effectiveness of policies, actions, metrics, and targets related to sustainability", as part of the Board's oversight of governance and risk management (due diligence) (page 45).

The CEO and Executive Management Team "routinely evaluate potential trade-offs related to material sustainability matters to ensure alignment with Anora's long-term goals and commitments", with Board oversight and approval of any significant plans or changes (page 46).

Following completion of the 2025 double materiality assessment, "the Audit Committee reviewed the resulting list of material impacts, risks, and opportunities", which is presented in the SBM-3 table (page 46). No disclosure is made of the specific dates or frequency at which individual IROs were addressed during the year.

Integration of sustainability-related performance in incentive schemes

Reference: page 46 (ESRS content index, page 56).

"In line with the 'Pay for Performance' principle, both short- and long-term incentive programs are tied to the achievement of predefined sustainability targets" (page 46).

The disclosure is candid about the limits of that link: "Currently, the sustainability measure used in the plans does not directly include climate change or GHG emission reduction targets, with related aspects only reflected through the Sustainalytics ESG risk rating" (page 46).

Long-term incentive plans (page 46). Three overlapping share-based performance share plans, each with four performance measures, one of which is an ESG metric worth 10% of the total earnings opportunity:

• 2023-2025 plan (approved 21 December 2022) - ESG target: a 'low risk' Sustainalytics ESG risk rating by end of 2025.
• 2024-2026 plan (approved 13 February 2024) - 'low risk' rating by end of 2026.
• 2025-2027 plan (approved 12 February 2025) - 'low risk' rating by end of 2027.

Plans target management and selected key employees. The Group's remuneration policy sets the general principles for compensating the Board of Directors and the CEO, including sustainability-related performance (page 46).

Statement on due diligence

Reference: page 46 (ESRS content index, page 56).

Anora presents the required mapping table of where the core elements of due diligence are covered in the statement (page 46):

The table is a cross-reference map only; no narrative description of the due diligence process is given under GOV-4 itself.

Risk management and internal controls over sustainability reporting

Reference: page 47 (ESRS content index, page 56).

The disclosure is explicit that the control framework is not yet complete. Processes covering "the completeness, integrity, and quality of sustainability data - covering both its own operations and key value chain features - are being integrated into the company's general procedures and management systems" (page 47).

The Anora Risk Management Policy "aims to subject both internal and external sustainability reporting to the same control measures as financial and operational reporting". The Board has approved the Group Risk Management Policy, which sets objectives, principles, responsibilities and reporting procedures (page 47).

"All risks are assessed based on their estimated probability and impact. For sustainability reporting, key internal control risks relate to data completeness, accuracy of estimated metrics, and availability of upstream and downstream value chain data linked to material impacts, risks, and opportunities. Mitigation strategies and related controls for these risks are currently being developed" (page 47).

During 2025 the reporting process was coordinated by the sustainability team with functions across the Group. No description is given of how the findings of the risk assessment and internal controls are integrated into relevant internal functions and processes beyond this.

Strategy, business model and value chain

Reference: pages 47-48 (ESRS content index, page 56).

Anora offers alcoholic and non-alcoholic beverages, own brands and international partner wines, spirits and NoLo products, distributed through off-trade and on-trade channels including Nordic retail monopolies, Horeca, retail, travel retail and export. It also provides production, packaging and logistics services, and sells industrial products (barley starch, technical ethanol, feed components) derived as by-products of distillation (page 47).

Revenue by segment 2025 (page 47): Industrial EUR 141.7 (142.0) million, Spirits EUR 215.1 (227.0) million, Wine EUR 301.1 (323.0) million. "Anora has no activities or revenue related to fossil fuels sectors (coal, oil or gas)."

Employees: 1,190 (1,211) at end-2025 (page 47).

Inputs (page 48): approximately 180 million kilograms of Finnish barley annually, imported wines from over 35 countries, water, and dry goods.

Value chain (page 48): upstream - contract farmers (primarily barley producers), grain stores, partners (ProAgria, BSAG), wine exporters, dry goods suppliers, inbound logistics; own operations - distillation, maturation and blending, bottling and packaging, import of NoLo drinks, wines and spirits, logistics services; downstream - HoReCa, Nordic retail monopolies, grocery and online stores, agricultural industry, export and travel retail, end-users.

Long-term sustainability targets set in 2022 cover carbon-neutral production sites, regeneratively farmed barley and packaging (page 47). SBTi-validated climate targets are set out on page 48.

Interests and views of stakeholders

Reference: page 49 (ESRS content index, page 56).

Understanding of stakeholder views "was first established during a preparatory due diligence process in 2022, which informed the current sustainability roadmap". Institutional investors and creditors "emphasized transparency and long-term financial resilience"; key customers including Nordic alcohol monopolies and major retailers, and strategic suppliers, "highlighted the importance of Anora's financial stability to ensure reliable product delivery"; NGOs "provided perspectives on social and environmental impacts linked to Anora's business model" (page 49).

"To deepen insights on biodiversity, regenerative farming, and human rights in the value chain, Anora conducted additional stakeholder research in 2024 as part of its formal double materiality assessment" (page 49).

Engagement mechanisms by group (page 49): own workforce - employee surveys, collective bargaining, Board representation via the employee participation agreement; value chain workers - third-party audits, supplier self-assessments, cooperation with amfori BSCI; consumers and end-users - responsible marketing, awareness campaigns, website information, the NoLo offering; authorities, banks, analysts, investors, NGOs, media, owners and political decision-makers - press releases, briefings, interviews and social media; customer companies and suppliers - industry workgroup meetings and direct engagement; industry associations - joint initiatives and forums.

The Board, supported by the Audit Committee, oversees stakeholder engagement matters, which "are reviewed during Board meetings" (page 49).

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

Reference: pages 50-52 (ESRS content index, page 56).

The table on pages 50-51 lists 19 material IROs from the 2025 double materiality assessment, each with an IRO type, a location in the value chain and a time horizon. "While certain IROs have undergone minor adjustments in perspective, definitions, or scope to enhance clarity, no material changes have been made compared to the previous reporting year" (page 50).

By topic (pages 50-51): E1 climate change - 5 (Scope 1 and 2 emissions, Scope 3 emissions, acute physical risk to agricultural supply, chronic physical risk to raw material price/availability/quality, and a commercial opportunity from lower-impact products); E3 water - 1 (water consumption and wastewater discharges at production plants); E4 biodiversity - 1 (impacts from agricultural raw materials upstream); E5 - 4 (two positive impacts from waste management and the Koskenkorva circular model, two opportunities from packaging and side streams); S1 - 3 (occupational diseases and work accidents, provision of employment, the Anora Way culture); S2 - 1 (potential negative social impacts among seasonal workers in high-risk countries); S4 - 2 (adverse health effects of excessive alcohol consumption, and the NoLo opportunity); G1 - 2 (failure to uphold ethical business practices, and failure to detect corporate-culture differences in M&A).

Resilience. "During the reporting period, Anora did not conduct a formal qualitative or quantitative assessment of its business model and strategy's resilience in relation to all identified sustainability-related impacts, risks, and opportunities" (page 50). Climate-specific risk identification and scenario analysis is also presented under E1-2 (2025 ESRS numbering), and resilience under E1-3.

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

Reference: pages 52-55 (ESRS content index, page 56).

The 2025 update "was conducted by an appointed working group and built on the methodologies and findings from the 2022 sustainability roadmap process and DMA completed in 2024. The update did not significantly alter the set of material topics but refined the perspective on certain impacts, risks, and opportunities" (page 53).

Thresholds. Impacts were scored on severity and likelihood (negative) and scale, scope and likelihood (positive); "Impacts exceeding a quantitative materiality threshold (set at 70% of the theoretical maximum score) were deemed material". Risks and opportunities were scored on likelihood and the magnitude and nature of financial effects, with the same "70% of the theoretical maximum financial materiality score" threshold (page 53).

Approval. "The decision on which identified impacts, risks, and opportunities were considered material was made by Anora's CEO and Executive Team, and subsequently approved by the Board of Directors" (page 53). The process is "not yet fully integrated into Anora's overall risk management system" (page 54).

Topic-specific screening (pages 54-55). Climate - GHG Protocol categories plus TCFD principles and IPCC scenarios. Pollution - "none of the identified potential impacts were assessed as material based on their likelihood and severity". Water - production sites compared against WWF water risk maps and an online water risk tool in 2024; "none of Anora's operating sites are located in areas of water stress". Biodiversity - no own sites near Natura 2000, UNESCO World Heritage sites or Key Biodiversity Areas, so upstream agriculture was judged more material. Resource use and business conduct - high-level screenings, the latter covering corporate culture, anti-corruption, anti-bribery and whistleblower protection.

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

Reference: pages 56-64.

Anora prints a full ESRS content index at pages 56-59, organised by standard (ESRS 2, E1, E2, E3, E4, E5, S1, S2, S4, G1), giving each covered disclosure requirement with a page number, and marking phased-in items in a separate column rather than with a page.

Items flagged "Subject to phased-in provisions" rather than given a page: ESRS 2 SBM-3 paragraph 48(e) anticipated financial effects, E1-9, E3-5, E4-6, E5-6, S1-7 and S1-15 (pages 56-59).

Standards with no topical DRs listed. For ESRS E2 Pollution the index lists only "ESRS 2, IRO-1 - Description of the processes to identify and assess material pollution-related impacts, risks and opportunities" at page 52, and no E2-1 to E2-6. ESRS S3 Affected communities has no table at all.

Not listed within otherwise material topics: E1-7, E1-8, S1-10 to S1-13, S1-16, G1-2, G1-5 and G1-6.

Pages 59-64 carry the separate table of datapoints derived from other EU legislation (SFDR, Pillar 3, Benchmark Regulation, EU Climate Law), with a page number or "Not material" against each. E1-7 paragraph 56, E1-9 paragraphs 66-69, E2-4 paragraph 28, S1-16 paragraphs 97(a) and (b), S3-1 paragraphs 16-17, S3-4 paragraph 36 and G1-1 paragraphs 10(b) and 10(d) are all marked "Not material" (pages 60-64).

Basis of preparation: the statement follows Commission Delegated Regulation (EU) 2023/2772 and Chapter 7 of the Finnish Accounting Act, and applies the ESRS 1 section 10.2 value chain transitional provisions (page 44).

Transition plan for climate change mitigation

Reference: page 72.

Anora reports that it has no transition plan. "Anora does not yet have a formal transition plan to ensure its strategy and business model align with the goal of limiting global warming to 1.5 °C, as set out in the Paris Agreement and the EU objective of climate neutrality by 2050" (page 72).

What exists instead: "during the reporting period and prior reporting periods, Anora has laid the groundwork by calculating GHG emissions across its own operations and value chain, and by setting climate targets approved by the Science Based Targets initiative (SBTi). During 2025, Anora has been further developing its Scope 3 climate roadmap, focusing on building action plans for emissions from grain, wine, logistics, and packaging" (page 72).

Two required elements are explicitly deferred: "This work will eventually also involve an assessment over potential locked-in emissions and reviewing the alignment of its business strategy and financial planning with the 1.5 °C pathway" (page 72).

"A formal transition plan has not yet been adopted, and no timeline for adoption is currently available" (page 72).

The Appendix B datapoint table records E1-1 paragraph 16(g), undertakings excluded from Paris-aligned Benchmarks, against page 72 (page 60).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 SBM-3 and IRO-1, where this content is disclosed in the FY2025 report (pages 52, 54). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification (paragraph 15). "All material climate-related risks identified are physical in nature" (page 52). The SBM-3 table labels them explicitly: acute physical climate risks from "changing and unpredictable weather conditions including drought and forest fires" in the agricultural supply chain (short term), and chronic physical climate risks from "warming climate conditions" affecting the price, availability and quality of wine and barley (long term) (page 50).

Methodology (paragraph 16). Impact identification followed GHG Protocol emission categories, covering fuel and energy use, combustion engines and boilers in own manufacturing and logistics, FLAG emissions for upstream agriculture, and purchased goods and services data. Risk identification "utilizes the principles of the Task Force on Climate-related Financial Disclosures (TCFD)" (page 54).

Scenarios (paragraph 17). For physical risk, "Using the high-emissions scenario IPCC SSP5-8.5, Anora performed a high-level screening over the general features of its assets and key activities... to identify physical risks over the short-term (1 year), medium-term (2-5 years), and long-term (beyond 5 years)". For transition risk, "a scenario aligned with limiting global warming to 1.5°C, SSP1-1.9 by IPCC, was used" (page 54). Scenarios are sourced from the IPCC's Climate Change 2022: Impacts, Adaptation and Vulnerability report and are "considered credible, current, sufficiently covering Anora's plausible risks and uncertainties" (page 54).

Stated limits. "no formal scenario analysis has yet been conducted to assess exposure and sensitivity of key assets and activities, including geospatial hazard likelihood, magnitude, and duration", and "no formal sensitivity analysis of assets and business activities against this scenario has been performed" (page 54). No global average temperature projection per scenario is given.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and IRO-1, where this content is disclosed in the FY2025 report (pages 50, 52, 54). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Anora states that no resilience analysis was performed. "During the reporting period, Anora did not conduct a formal qualitative or quantitative assessment of its business model and strategy's resilience in relation to all identified sustainability-related impacts, risks, and opportunities" (page 50). On climate specifically: "Anora has not yet conducted a formal scenario analysis that includes a resilience assessment of its business model and strategy" (page 52).

What is disclosed instead (paragraph 19(a)). The company says it "maintains the resilience of its strategy and business model over the short-, medium-, and long-term" by addressing the material IROs through policies, actions and targets, and that existing due diligence processes "incur annual costs, such as membership fees and audits, which are primarily recorded under employee and other operating expenses" (page 50). Adaptation-relevant actions include regenerative farming collaboration with BSAG and ProAgria, updated barley farming contracts and near-market filling (pages 74, 87).

Uncertainty and next steps (paragraph 19(b)). "Anora is currently evaluating the potential financial effects of selected climate scenarios to inform future adaptation planning" (page 52), and "Anora intends to strengthen its scenario analysis capabilities and update its climate risk identification processes accordingly" (page 54).

Capacity to adjust (paragraph 19(c)). Not disclosed. No statement is made about the flexibility of financial resources, redeployment or repurposing of assets, or the effect of planned investments on resilience.

Policies related to climate change mitigation and adaptation

Reference: pages 72-73 (ESRS content index, page 56).

Three policies are tabulated against the material climate IROs (pages 72-73):

Anora Quality, Safety and Environment Policy - based on the Sustainability Roadmap; in relation to GHG emissions from own operations and the value chain "the policy includes a statement that Anora aims to minimise its climate impacts and strive for carbon-neutral production". Covers own operations. Accountable: Executive Management Team. Third-party reference: UN Sustainable Development Goals. Publicly available online. Associated IRO: global warming potential from Scope 1 and 2 GHG emissions.

Anora Code of Conduct for Suppliers and Subcontractors - minimum requirements for the upstream value chain; "the policy requires suppliers and subcontractors to aim to reduce energy use, shift from fossil energy to renewable energy sources and actively monitor and strive to reduce greenhouse gas emissions in their own operations and respective supply chain". Applies to suppliers, subcontractors and their own suppliers. Accountable: Executive Management Team. References the UN Universal Declaration of Human Rights, UN Global Compact and the amfori BSCI Code of Conduct. Publicly available online. Associated IROs: Scope 3 emissions, and the acute and chronic physical climate risks.

Anora Risk Management Policy - "Climate-related risks and opportunities are considered part of overall risk management". Covers the whole Group; business partners expected to follow similar principles. Accountable: Board of Directors. Based on the COSO ERM framework, SFS-ISO 31000 and the Finnish corporate governance code. Available internally on the intranet.

No separate climate change adaptation policy is disclosed.

Actions and resources in relation to climate change policies

Reference: pages 73-75 (ESRS content index, page 56).

Actions are grouped by decarbonisation lever (pages 73-75).

Fuel switching and renewable energy. "In 2025, Anora invested in a new biomass boiler to enable its Koskenkorva Distillery to fully transition to fossil-emission-free fuels by the end of 2026. Scheduled for commissioning in 2026, the biomass-boiler will operate on 100% renewable fuels and replace the remaining fossil-fuel boiler." "Approximately EUR 8.4 million in capital expenditure has been allocated to implement these actions, of which EUR 6.8 million relates to future financial resources", reflected as additions to property, plant and equipment and increases in liabilities (pages 73-74). Koskenkorva continued on 100% renewable wind electricity and accounted for "approximately 79% (79%) of Anora's Scope 1 and 2 emissions"; Rajamäki and the Ruoholahti head office also run on 100% renewable electricity (page 74).

Supply-chain decarbonisation. Near-market filling of bulk wine; regenerative farming collaboration with BSAG, with the commitment renewed for 2026-2030; updated barley farming contracts including "an option for a monetary incentive when farmers provide farm-level CO₂e calculations" and a decision not to purchase grain cultivated in peat soil; requesting estimated CO₂e values per inbound transport lane, with "almost 93% of deliveries in Swedish distribution... now fossil-emission-free" (page 74).

Products change. Promotion of rPET, tetra and Bag-in-Box; "BiBs have an over 80% lower CO₂ footprint compared to traditional glass bottles" and a PET bottle "has an over 60% lower carbon footprint than a similar glass bottle" (page 74).

Energy efficiency and R&D. The Koskenkorva cooling-water heat pump, once fully in use, "is expected to reduce primary steam production by approximately 10%"; the joint A-Rehu feed dryer progressed toward operation; CO₂ recovery from fermentation continued (pages 74-75).

Gap: "Anora has not yet fully calculated the disaggregated achieved or expected GHG emission reductions from the actions listed above" (page 75).

Targets related to climate change mitigation and adaptation

Reference: pages 75-77 (ESRS content index, page 56). SBTi targets summarised at page 48.

Targets were "validated by the Science-Based Targets initiative (SBTi) in 2024" and use a 2021 base year (pages 48, 75).

Anora "also commits to maintaining no deforestation across its primary deforestation-linked commodities" (pages 48, 76).

Boundary caveats (pages 76-77). The Scope 1 and 2 target boundary includes biogenic fermentation emissions and so "diverge[s] from the Scope 1 emissions reported under Disclosure Requirement E1-6"; the FLAG target covers 77% of reported FLAG emissions. "Science-based targets presented above are not fully consistent with Anora's material GHG inventory boundaries disclosed in section E1-6." "Quantitative contributions of these actions to Scope 1, 2, and 3 reductions have not yet been calculated" (page 77). The FLAG 2024 comparative was restated to the SBTi target boundary (page 44).

Energy consumption and mix

Reference: pages 77-78 (ESRS content index, page 56).

Anora's activities are "primarily classified under NACE Rev. 2 code C11 (Manufacture of beverages), with additional activities under H49.41 (Freight transport by road) and H52", and its operations "are classified within high climate impact sectors" under Commission Delegated Regulation (EU) 2022/1288 (page 77).

Anora "produced 116,441 (122,103) MWh of renewable energy from distillation byproduct barley husks at the Koskenkorva Distillery". Energy intensity relative to net revenue was "0.03% (0.02%)", and net revenue from high climate impact sectors "includes all of Anora's activities" (page 77). Metrics "have not been validated by an external body other than the assurance provider" (page 77).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 79-81 (ESRS content index, page 56).

Scope 3 is dominated by category 1 purchased goods and services at 426,863 tCO2eq (2024: 443,447), then upstream transport 22,689, downstream transport 19,203 and fuel and energy-related activities 6,396 (page 79).

FLAG (page 80): "Within the above Scope 3, Category 1 figure, 255,279 (217,992) tCO₂eq comes from FLAG emissions, mainly from purchased grain and wine", plus Scope 1 FLAG of 7,196 (7,196) tCO₂eq from Anora's owned forest area.

Biogenic CO₂ excluded from the table (page 80): 12,416 (13,203) tCO₂eq mainly from fermentation in Scope 1, 31,486 (31,164) from biomass combustion in Scope 2, and 8,507 (8,599) from use of sold products in Scope 3 category 11.

Method (page 80): "98% (99%) of Scope 2 electricity originated from fossil free sources". Scope 3 is "primarily calculated using the average-data method", with "approximately 17% (7%) of total Scope 3 GHG emissions... based on primary data". Categories 8, 13, 14 and 15 are excluded as not applicable or insignificant.

Intensity (page 81): total GHG per net revenue 0.07% location-based and 0.08% market-based, on net revenue of EUR 658 million.

Policies related to water and marine resources

Reference: page 82 (ESRS content index, page 57).

Two documents are tabulated (page 82):

Anora Quality, Safety and Environment Policy - "includes a commitment to minimising negative environmental impacts, including water consumption and wastewater generation. It also highlights Anora's efforts to protect water and marine resources, such as implementing a forest management plan to safeguard groundwater areas and supporting regenerative farming practices." Covers own operations. Accountable: Executive Management Team. Reference: UN Sustainable Development Goals. Publicly available online.

"How we manage and protect water at Anora" - covers Anora's production sites individually as well as the groundwater area it owns. "Anora sources water mainly from groundwater and municipal supplies... Production sites set own water use and wastewater reduction targets and actions aligned with Anora's sustainability roadmap, including identifying wastewater sources, reducing liquid waste, and reusing process water. Wastewater quality is regularly analysed at Rajamäki, Koskenkorva, and Gjelleråsen using indicators such as COD (Chemical Oxygen Demand) and pH." Accountable: Executive Management Team. Publicly available online.

Both are associated with the single material IRO, "water consumption and wastewater discharges".

Two stated limits: "Anora does not operate in water-scarce areas, and while its products do not directly address water or marine issues, water use is carefully managed throughout production"; and "Although Anora partners with the Baltic Sea Action Group to promote regenerative farming, it has not formally adopted policies or practices related to sustainable oceans and seas" (page 82). Water-related impacts are identified through environmental management aligned with ISO 14001 principles at the certified Finnish sites.

Actions and resources related to water and marine resources

Reference: page 83 (ESRS content index, page 57).

"During the reporting period, Anora undertook actions aimed at managing negative water-related impacts. Anora does not currently operate in areas of water scarcity" (page 83). Four actions are described:

• Koskenkorva Distillery process water recycling. "wastewater reduction efforts in 2025 focused on further increasing the recycling of process water and making further small investments to improve efficiency. Measures included recycling process water and optimising wash cycles, which reduced wastewater volumes and improved quality (COD). The plant also investigated enhancements to its wastewater pre-treatment facility." Ongoing over the short to medium term.
• Rajamäki plant water monitoring and liquid waste reduction. Part of "Anora's multi-year circular economy project", lowering wastewater volumes "by redirecting clean cooling water to the stormwater sewer as that water is clean and can be returned to the environment", plus optimised washing programs, shortened wash cycles, and repair of factory sewer systems "to prevent excess water, such as rainwater, from entering the wastewater".
• Gjelleråsen wastewater quality monitoring. "regular monitoring of COD levels in wastewater has been established in 2025. Measures to prevent products from entering the wastewater stream have been implemented, which has led to reduction in COD levels."
• Groundwater area protection in Rajamäki. "Anora owns 984 hectares of groundwater area in Rajamäki, Finland, where water for its products is extracted from pure groundwater springs without filtration", protected through management plans for forest and swampland areas.

No monetary amounts, current or planned operating or capital expenditure, are disclosed for these actions.

Targets related to water and marine resources

Reference: page 83 (ESRS content index, page 57).

One target is set, "to reduce wastewater. The target also indirectly supports lower water consumption through improved water circulation and reduced usage" (page 83).

The 2030 target has therefore already been passed. Methodology: "Calculated from the generated wastewater in Anora's own production plants during the reporting period, based on the water meter data. The target is not based on formal conclusive scientific evidence." It "is monitored continuously and reported annually" (page 83).

Two limits are stated by the company: the target "applies to Anora's own production, which does not operate in areas of water risk, and therefore does not currently address risks in such regions", and "The wastewater target is voluntary and not mandated by legislation" (page 83). No target is set for water consumption itself, for water intensity, or for the upstream agricultural value chain where freshwater use is linked to the E4 impact.

Water consumption

Reference: page 84 (ESRS content index, page 57).

"The water intensity (total water consumption in Anora's own operations (m3) per million EUR net revenue) during the reporting period was 1,123 (1,115)" (page 84).

Method and coverage (page 84). Reported consumption is "primarily based on sites and office water meter readings. The main sources are communal water and groundwater." For 2025 only the Copenhagen office was estimated (by headcount, office size and average use in comparable offices); estimates "account for less than 0.5% of total water use". All metrics are "derived from direct measurement, sampling, extrapolation, or best estimates, with 100% coverage".

Recycling "is material only at Koskenkorva Distillery. The reported figure includes recycled water in product flows and cooling circuits... Without recycling these waters, clean water consumption would increase by an equivalent amount. Recycled water is not applicable to any other Anora sites."

The most water-consuming sites are Koskenkorva Distillery and Rajamäki bottling plant in Finland, Globus Wine in Denmark and Gjelleråsen in Norway; "All other industrial sites and offices account for approximately 1% of total water use". Anora "complies with water intake limits set by authorities and regularly monitors groundwater surface levels" (page 84).

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

Reference: page 85 (ESRS content index, page 57).

The disclosure is a two-sentence negative statement. "Anora has not yet conducted a formal resiliency analysis of its business model's and strategy's ability to adapt to future biodiversity and ecosystem-related physical, transition and systemic risks. Anora has identified that its primary biodiversity and ecosystems-related risks are closely linked with the material climate related chronic and physical risks outlined in section E1 Climate Change" (page 85).

No biodiversity transition plan is disclosed, and no date is given for adopting one. The IRO-1 section adds context that is not repeated here: Anora's "business model depends on various agricultural inputs - such as barley, wine, sugar, and spices - making it indirectly reliant on biodiversity and ecosystem services. These dependencies may be affected by future biodiversity-related physical, transition and systemic risks, particularly those linked to chronic and acute weather changes described under E1 Climate change. However, no detailed assessments of these risks have yet been conducted, and no consultations with affected communities regarding shared biological resources and ecosystems have taken place" (pages 54-55).

Policies related to biodiversity and ecosystems

Reference: pages 85-86 (ESRS content index, page 57).

Two policies are tabulated against the single material IRO, "actual negative environmental impacts from agricultural raw materials production in some geographical areas" (page 86).

Anora Code of Conduct for Suppliers and Subcontractors. "Suppliers and subcontractors are expected to understand their potential impacts on biodiversity and, where relevant, take action to safeguard it, for example, by adopting regenerative farming methods." It requires suppliers "to implement water management plans and actively reduce water consumption, particularly in areas facing water scarcity". On deforestation: "Suppliers must also comply with the EU Deforestation Regulation... To support zero deforestation, Anora's suppliers must ensure that raw materials are not sourced from primary forests or other pristine ecosystems, and that sourcing does not result in deforestation, including conversion of tropical peatlands, natural forests, high conservation value (HCV) areas, or high carbon stock (HCS) forests." Accountable: Executive Management Team. Publicly available online.

Anora procurement policy. Sustainability requirements for agricultural products such as barley and wine, addressing land-use and freshwater-use change. It "requires all raw material suppliers to comply with ISO 9001 quality standards. However, it does not define specific criteria for traceability of products, components, or raw materials linked to material impacts, or sourced from ecosystems that are managed to maintain or enhance conditions for biodiversity" (page 86).

The report adds that "None of Anora's own operational owned, leased or managed sites are located near biodiversity sensitive areas", and that although sea-use change "ha[s] not been formally identified as being associated with material impacts or risks", Anora cooperates with BSAG on regenerative farming (page 86). The policies "do not explicitly cover the social consequences of biodiversity and ecosystem impacts" (page 85).

Actions and resources related to biodiversity and ecosystems

Reference: page 87 (ESRS content index, page 57).

Two actions are described (page 87):

• Regenerative farming partnership. "Anora promotes regenerative farming practices in its upstream agricultural value chain, focusing on barley growing in Finland. These practices aim to restore soil health, improve water retention, enhance carbon sequestration, and support biodiversity by minimizing soil disturbance, maintaining soil coverage and living roots, and reducing the use of pesticides and synthetic fertilizer. Since 2018, Anora has partnered with the Baltic Sea Action Group (BSAG) to reduce nutrient runoff to the Baltic Sea. Anora renewed its BSAG commitment for the years 2026-2030." With BSAG and ProAgria, "a government-funded agricultural advisory service", Anora provides training, education and farm-level support to contract farmers, and "ProAgria also conducts seasonal audits to monitor implementation." Planned to continue at least over the medium term.
• Forest area in Rajamäki. "Anora manages approximately 950 hectares of natural land, including 150 hectares of protected swampland and 800 hectares of forest. These areas are estimated to act as a carbon storage for around 830,000 tons of CO₂, reducing negative impact drivers on biodiversity."

Stated gap: "Formal, standardised biodiversity offsets - including KPIs, targets, and financial planning - have not yet been applied in the actions described above. However, Anora is evaluating how biodiversity considerations, including offset mechanisms, can be effectively integrated into its forest management plans" (page 87). No monetary amounts are given for either action. Note the report gives the Rajamäki natural land area as approximately 950 hectares here and the groundwater area as 984 hectares under E3-2 (page 83).

Targets related to biodiversity and ecosystems

Reference: pages 87-88 (ESRS content index, page 57).

One target, the Regenerative share (page 88):

"Anora purchases approximately 165 million kilograms of Finnish barley annually, making regenerative farming a key strategy for mitigating biodiversity-related impact drivers such as soil degradation, habitat loss, and nutrient runoff" (page 87). The metric "is calculated by dividing the volume of ethanol derived from regenerative barley by the total ethanol used in the production of Anora's own products at the Rajamäki plant" (page 88).

Stated limits (page 88). "The target contributes to multiple layers of the biodiversity and ecosystems impact mitigation hierarchy, including avoidance, minimisation, restoration, and rehabilitation. However, no formal ecological thresholds - defined as scientifically established tipping points - or biodiversity offsets have been considered in setting the target. While the target is informed by the EU Biodiversity Strategy for 2030, formal alignment with either this strategy or the Kunming-Montreal Global Biodiversity Framework cannot currently be demonstrated."

Note the annual barley purchase figure is given as approximately 165 million kilograms here and approximately 180 million kilograms under SBM-1 (page 48).

Impact metrics related to biodiversity and ecosystems change

Reference: page 88 (ESRS content index, page 57).

"For the reporting period, Anora currently considers regenerative farming, measured as the Regenerative share, to be the most suitable biodiversity and ecosystems impacts metric for its business model and value chain. The Regenerative share is calculated by dividing the used ethanol made from regenerative barley by the total ethanol used in Anora's own product manufacturing at the Rajamäki plant, and reported under section E-4-4" (page 88).

"Since 2021, Anora has grown the absolute amount of purchased regeneratively farmed barley from 0.05 million kg to 1.83 (3.46) million kg during the reporting period, and since 2023, it has calculated and reported the regenerative share described above" (page 88). The absolute volume therefore fell year on year while the reported Regenerative share rose from 1.61% to 3.58%; the report does not explain that divergence.

"This metric is considered reliable, provided that the underlying assumptions regarding the definition and environmental benefits of regenerative farming remain valid. The metric is not validated by an external body other than the assurance provider" (page 88).

This is an entity-specific metric. No land-use change, ecosystem extent or condition, or species-level metrics are reported; the SBM-3 footnote confirms the Regenerative share is the metric used for "avoidance of natural environment loss and habitat fragmentation" (page 51).

Policies related to resource use and circular economy

Reference: page 89 (ESRS content index, page 57).

Two policies are tabulated (page 89):

Anora Quality, Safety and Environment Policy - "It emphasizes investment in sustainable packaging materials and solutions to improve waste handling within operations and the downstream value chain. To mitigate negative impacts from resource use, the policy includes a commitment to efficient use and recycling of energy, natural resources, and materials, exemplified by circular economy practices at Koskenkorva Distillery." Covers own operations. Accountable: Executive Management Team. Reference: UN Sustainable Development Goals. Publicly available online. Associated IROs: the positive impacts from Koskenkorva's circular economy model and from general waste management and recycling practices.

Anora Risk Management Policy - "Resource use and circular economy-related risks and opportunities are considered part of overall risk management." Covers the whole Group. Accountable: Board of Directors. Based on the COSO ERM framework, SFS-ISO 31000 and the Finnish corporate governance code. Available internally on the intranet. Associated IROs: the commercial opportunities from lower-impact products and from side-stream innovations.

"The policy principles aim to reduce reliance on virgin resources and minimise environmental impacts by promoting efficient use and recycling of energy, natural resources and materials. The policies also support reduced scrapping and the development of packaging materials and solutions with smaller environmental impact... The policies do not currently explicitly account for sustainable sourcing and the use of renewable resources" (page 89).

Actions and resources related to resource use and circular economy

Reference: page 90 (ESRS content index, page 57).

Three actions are described (page 90):

• Regulatory preparedness for packaging waste compliance. "Anora continued to implement and prepare for recent and upcoming legislative changes in Finland and across the EU, including the EU Packaging and Packaging Waste Regulation (PPWR). These developments may require future investments in packaging waste management systems and technologies."
• rPET and recycled glass bottle development. "Anora made a decision to increase the PCR glass in its Koskenkorva glass bottles from 10% to 60% during 2026, which will increase the usage of recycled glass, and it is expected to lead to decreased GHG emissions in the upstream value chain over the medium term. In 2025, Anora adjusted rPET dosing in its PET bottle portfolio to improve recyclability and secure high-quality material streams, reinforcing circularity and resource efficiency."
• Continuous waste reduction and recycling improvements across production plants, "expected to decrease waste volumes and increase recycling rates in the short to medium term".

Anora also "continued optimising resource inflows at its Koskenkorva Distillery", with the principles described under E5-4 (page 90).

Resources: "No significant current or future operational or capital expenditures have been identified for the implementation of these actions" (page 90).

Targets related to resource use and circular economy

Reference: pages 90-91 (ESRS content index, page 57).

Three targets are set (page 91):

The recycled-content target for glass bottles moved backwards year on year, from 49% to 44%; the report does not explain the fall. The recycling-rate target has already been exceeded.

Methodology notes: the recycled-content KPIs are measured "based on weight"; the recycling rate is "calculated as the proportion of total waste diverted to recycling, excluding incineration, divided by total waste generated". Two targets are said to support Sustainable Development Goal 12 (page 91).

Stated limits (page 91): "Anora's current targets do not formally address sustainable sourcing or the use of renewable resources in line with the cascading principle. The targets are voluntary." No target addresses resource inflows in absolute terms or waste generation volumes.

Resource inflows

Reference: page 92 (ESRS content index, page 57).

"The main resource inflows to Anora's production processes include biological raw materials such as barley and spices, other inputs like water, wine, sugar, and ethanol, and technical materials used in packaging, including glass, carton, plastic, and other components" (page 92).

"Of this, 100% (100%) of biological materials - grain and spices - were sustainably sourced following Anora's requirements for grain and relevant certificates for spices. The absolute weight of recycled materials used to manufacture the products, including packaging, was 9,984 (13,952) tons, representing 42% (46%) of the total material input by weight" (page 92).

The 42% figure is stated against total material input of 371,383 tonnes, which the arithmetic does not support; the report gives no reconciling denominator, and it explains that "Recycled material calculations apply only to packaging, as other raw materials (e.g. wine, grain) cannot be reused or classified as secondary" (page 92).

Basis (page 92): "no general certification scheme exists for grain in Finland", so Anora sources all grain "under contracts that comply with Finnish Cereal Committee (VYR) standards, which Anora considers a relevant certification framework. Organic and regeneratively farmed barley are also recognised as valid sustainability schemes." For spices, "93% (94%) in 2025 were sourced from certified suppliers". The Koskenkorva Distillery "fully utilises the side-products of barley grain used in the distilling process", and biogenic CO₂ "is partially captured and repurposed, for example, in greenhouse cultivation".

Resource outflows

Reference: page 93 (ESRS content index, page 57).

"Key outputs from Anora's production processes include packaged and bottled wine and spirits, and associated packaging materials, technical ethanol products, feed components and barley starch. A circular model is applied at production sites, where side streams are utilised to improve resource efficiency, reduce waste disposal costs, and generate revenue through by-product sales" (page 93).

Recyclability of products. "Circular design principles are especially applied to packaging, with recyclability as a key factor. During the reporting period, 92% (91%) of Anora's own products were packed in recyclable packaging" (page 93).

"Recyclable and non-recyclable packaging volumes are separated based on material definitions for each product - e.g. glass and PET bottles are recyclable, while multi-material pouches are not, as end-user cannot separate the materials" (page 93). Outflow data is "sourced from Anora's internal systems and calculated based on stock movements and weights of sold products".

No disclosure is made of the expected durability of products, their reparability, or the rates of recyclable content in products and packaging expressed separately from the 92% figure. Waste outflows are reported in the same section and are set out under Waste below.

The measurement of these metrics "has not been validated by an external body other than the assurance provider" (page 93).

Waste

Reference: page 93 (part of the E5-5 Resource outflows section; ESRS content index, page 57).

"Total waste generated during the reporting period was 13,716 (10,080) tons. The total amount of non-recycled waste was 427.7 (486.1) tons, representing 3% (5%) of the total waste generated. The total amount of hazardous waste was 14.8 (11.5) tons" (page 93). "No radioactive waste was generated during the reporting period."

Waste diverted from disposal (tonnes):

Waste directed to disposal (tonnes):

Waste streams named are ashes, liquid waste, wastewater, packaging waste (carton, glass, plastic, wood) and other waste including metal, construction waste, hazardous waste and biowaste. "Incinerated waste is not classified as recycled waste." Data comes from external waste companies' reports; estimates for Atlungstad and the Riga, Vilnius and Copenhagen offices "represent less than 0.5% of Anora's total waste" (page 93).

Policies related to own workforce

Reference: pages 94-96 (ESRS content index, page 58).

Seven policies are tabulated (pages 94-95), mapped to the three material own-workforce IROs (potential occupational diseases and work accidents; positive impacts from provision of employment; positive impacts among a resilient and engaged workforce):

• Code of Conduct (Anora Way) - ethical behaviour, respectful treatment, legal compliance; covers occupational health and safety, human rights, diversity, equity and inclusion, anti-discrimination and harassment, competences and development, and labour relations. Applies to all individuals employed by every Anora Group company. Accountable: Board of Directors. "aligned with OECD Guidelines for Multinational Enterprises and the UN Business and Human Rights principles". Publicly available online.
• HR plan including the equality and non-discrimination plan, for Anora's own employees in Finland for 2024-2025. Accountable: Executive Management Team. Internal.
• Non-Harassment Policy - "zero-tolerance towards harassment". Internal.
• Quality, Safety and Environment policy - covers good working conditions; concerns all sites and every employee.
• Human Rights Commitment - aligned with the International Bill of Human Rights and the ILO Declaration; publicly available online.
• Policy of Alcohol Consumption for employees.
• Anora Group's Policy on Diversity, Equity and Inclusion, published in 2025 (pages 95-96).

Anora "unequivocally condemns all forms of child labour and forced labour". In Finland, Rajamäki, Koskenkorva and the Ruoholahti HQ "are certified under ISO 45001"; elsewhere operations follow the HSEQ policy, and "all Anora employees have access to occupational health services, at minimum in line with local legal requirements" (page 96). Harassment is defined to include "discriminatory behaviour, personal harassment, sexual harassment, bullying, and abuse of authority" (page 96).

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

Reference: pages 96-97 (ESRS content index, page 58).

"Operational responsibility for employee engagement lies with Anora's CEO" (page 97).

Board-level representation. "Employees are represented on Anora's Board of Directors by an elected employee representative, who contributes their experience and perspective to enhance dialogue between employees and management" (page 97).

Anora Summit. "Anora continues a practice to organize an employee forum, now called Anora Summit, comprising around 50 participants from across the organisation. The forum meets regularly and workshops focus on setting company mid-term priorities" (page 97).

Health and safety consultation. Employee representatives participate in occupational health and safety consultation "through health and safety committees", contributing to "surveys, observation and near-miss reporting systems, and participating in regular OHS meetings". Committees "operate in accordance with local legal requirements at the plant level in each country. In Finland, all units hold bi-annual meetings, with additional quarterly meetings at the plant level" (page 97).

Survey. "The annual Anora Tasting employee survey provides insights into diversity, equity, and inclusion (DEI), as well as employee engagement, leadership, team performance, and overall wellbeing. The survey also assesses experiences of discrimination and harassment. Conducted anonymously, it ensures that all employees can share their views freely and be heard" (page 97).

The disclosure does not state how the effectiveness of engagement with own workers is itself assessed.

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

Reference: page 97 (ESRS content index, page 58).

"Anora provides multiple channels for employees to raise concerns and contributes actively to remediating negative impacts on its workforce. These include structured feedback mechanisms, health and safety committees, and the whistleblowing channel" (page 97).

"Anora maintains a whistleblowing channel operated by an independent third party, open to all employees and external stakeholders. Concerns can be submitted anonymously, and the process is actively communicated to ensure awareness. The annual Anora Tasting employee survey also evaluates whether employees feel safe reporting misconduct or unethical behavior" (page 97).

Health and safety concerns "are addressed through regular consultation with employee representatives, near-miss and accident reporting systems, and surveys. Health and Safety Committees operate at the plant level in accordance with local legislation, meeting bi-annually or quarterly depending on location. These committees assess risks, propose corrective actions, and ensure that employees are equipped with appropriate protective equipment and training" (page 97).

Stated gap. "Even if information on the whistleblower channel and its associated processes is included in official onboarding materials for each employee, Anora does not currently formally assess the awareness of, and trust in, structures and processes to raise and address concerns of people in its own workforce, besides the employee survey" (page 97). The Appendix B table maps the ESRS S1-3 paragraph 32(c) grievance/complaints handling datapoint to page 97 (page 62).

Taking action on material impacts on own workforce

Reference: pages 97-98 (ESRS content index, page 58).

Actions are grouped by theme (pages 97-98):

Health and safety. "Anora continued to provide safety equipment e-training for employees and supervisors, aiming to strengthen the safety culture and reduce workplace accidents in the short and medium term." "In 2025, Anora organized Safety Week activities across its sites and offices, including management-led safety walks, safety equipment demonstrations, emergency preparedness, and active encouragement of safety observations."

Diversity. "In 2025, Anora launched a dedicated DEI policy to endorse diversity, equity, and equal opportunity, including principles for recruitment practices. Anora's recruitment process and platform, renewed in 2024, now enable a systematic, inclusive, and unified approach with clearly defined qualifications and competencies."

Secure employment, work-life balance and social dialogue. Annual performance and development dialogues, separate Future Development Planning discussions, and a "value-based leadership program... to provide common tools for leaders to create common leadership culture and improve internal networks".

Effectiveness. "Anora applies the ISO 45001 health and safety management standard across its operations", requiring all departments "to identify, assess, and manage work-related risks". Effectiveness is assessed "using indicators such as workplace accidents, near-miss incidents, and employee well-being surveys", with the Anora Tasting survey covering seven metrics: "engagement, leadership, team efficiency, OSI (Organisational and Social Well-being Index), perception of top management, psychological safety, and eNPS". Results are "reviewed and followed by training and action planning, which are consistently followed throughout the organisation hierarchy up to Board level" (page 98).

Resources. "The associated financial resources are recognized as personnel-related operating expenses in Anora's income statement" (page 98). No separate amount is given.

Targets related to own workforce

Reference: pages 98-99 (ESRS content index, page 58).

Anora sets two health and safety targets and states plainly that "Anora has currently not set formal targets related to other material Own workforce related sustainability matters" (page 98), so the positive-impact IROs on employment and workforce culture carry no target.

The safety-observations target has already been passed. LTIF improved from 5.8 to 5.1 but remains at roughly the 2021 Altia level, and the 2030 target of zero implies a step change not yet evidenced.

"The targets were defined through Anora's Sustainability Roadmap process, based on a materiality analysis that included input from over 200 stakeholders via an open survey, including employees. Employees and their representatives are engaged during target setting and follow-up... LTIF and safety observations are monitored monthly and reviewed locally. After each performance cycle, Anora conducts joint evaluations with employees and their representatives to assess outcomes and identify improvements" (page 99). Both targets are said to address Sustainable Development Goal 3.

Characteristics of the undertaking's employees

Reference: pages 99-100 (ESRS content index, page 58).

Total employees at the end of 2025: 1,190 (1,211) head count (page 99).

Of the 1,190, 1,148 are permanent and 42 temporary; non-guaranteed hours employees are 0 (page 100). By gender in 2025: permanent 425 female and 723 male; temporary 16 female and 26 male.

By country in 2025 the table on page 100 reports Finland 405, Norway 342, Sweden 182, Denmark 155, and Estonia, Germany, Latvia and Lithuania 106 combined. Note the SBM-1 narrative gives the same two figures the other way round: "182 (163) in Denmark, 155 (185) in Sweden" (page 47). One of the two presentations is inconsistent; the report does not reconcile them.

"Employee numbers are reported as headcount at the end of the reporting period from Anora's unified HR system" (page 101). Full-time and part-time head counts are shown as dashes rather than figures in the 2025 and 2024 country tables (page 100). No employee turnover figure is disclosed under this DR, and the report presents no reconciliation of head count to the number reported in the financial statements.

Collective bargaining coverage and social dialogue

Reference: page 101 (ESRS content index, page 58).

"In total, 80% (79%) of Anora's employees are covered by collective bargaining agreements" (page 101). By country: "100% (100%) of Anora's own employees in Finland, 100% (100%) in Norway, 44% (47%) in Denmark, and 77% (72%) in Sweden, are covered by workers' representatives."

"A significant share of Anora employees are covered by collective bargaining agreements, except in Latvia, Lithuania, Estonia and Germany, where such agreements are not in place. In these countries, working conditions are governed by local laws and employment contracts" (page 101).

Anora defines significant employment as "at least 50 employees representing at least 10% of the total workforce", which applies in Finland, Norway, Denmark, Sweden and Estonia (page 101).

Coverage bands (EEA, countries above the significance threshold): 0-19% Estonia; 40-59% Denmark; 60-79% Sweden; 80-100% Finland and Norway. Workplace representation covers Finland, Norway, Sweden, Denmark and Estonia. "Anora does not have employees in non-EEA regions" (page 101).

"Anora is currently reviewing an agreement regarding the European Works Council (EWC) with employee representatives" (page 101).

The coverage rate is calculated per country as employees covered divided by total employees. Metrics "ha[ve] not been validated by an external body other than the assurance provider" (page 101).

Diversity metrics

Reference: page 101 (ESRS content index, page 58).

Gender distribution at top management, defined as "the Executive Management Team of the Anora Group" (page 101):

Age distribution (number of employees):

The share of women in top management rose from 25% to 29%, but through a reduction in the number of men (6 to 5) rather than any increase in the number of women, which stayed at 2.

"Employee data is sourced from Anora's unified HR system, local payroll, and reporting systems, without assumptions. All employee numbers are reported as headcount at the end of the reporting period. The measurement of the metrics has not been validated by an external body other than the assurance provider" (page 101). Group-wide gender split is reported separately under S1-6 (page 99).

Health and safety metrics

Reference: page 102 (ESRS content index, page 58).

The last two rows carry a 2025 figure only in the source table. The days-lost figure of 0 sits oddly beside 12 lost time injuries, since Anora defines a recordable accident as a lost time incident; the report offers no explanation.

"Anora's Quality, Safety and Environment Policy applies to 100% of its own workforce. Data on accidents, fatalities, and work-related ill health is collected from internal health and safety records. Recordable work-related accidents are defined as lost time incidents (LTI). The accident rate is calculated as lost time incident rate (LTIF), based on one million hours worked" (page 102).

Metrics "ha[ve] not been validated by an external body other than the assurance provider" (page 102). The Appendix B table maps the S1-14 paragraph 88(b), (c) and (e) datapoints to page 102 (page 62). No figures are given for non-employee workers in the own workforce.

Incidents, complaints and severe human rights impacts

Reference: page 102 (ESRS content index, page 58).

"No fines, penalties, or compensation for work-related discrimination or harassment were incurred during the reporting year. Similarly, no sanctions or compensation related to severe human rights violations involving Anora's own workforce were reported" (page 102).

The four complaints filed are reported as a number only; no breakdown by subject, outcome or remediation is given, and the report does not reconcile four complaints with zero discrimination incidents.

"The data is based on reports received through Anora's whistleblowing channel and other internal reporting mechanisms, including those specifically related to discrimination. The measurement of the metrics has not been validated by an external body other than the assurance provider" (page 102).

Policies related to value chain workers

Reference: pages 103-104 (ESRS content index, page 58).

Six policies are tabulated, all mapped to the single material IRO, "potential negative social impacts in certain high-risk countries" (pages 103-104):

• Code of Conduct for Suppliers and Subcontractors - "addresses significant impacts on value chain workers' working conditions, human rights, and equal treatment, along with essential measures for monitoring supplier compliance". Applies to all upstream suppliers and subcontractors. Reference: amfori BSCI principles. Publicly available online.
• amfori BSCI Code of Conduct - referencing the Universal Declaration of Human Rights, the Children's Rights and Business Principles, the UN Guiding Principles, OECD Guidelines, the UN Global Compact and ILO Conventions.
• Human Rights Commitment - "addresses all identified actual or potential salient human rights risks and covers all material impacts related to working conditions and other working related rights", aligned with amfori BSCI principles and the International Bill of Human Rights.
• Quality, Safety and Environment policy - covers value chain workers' working conditions.
• Safety Policy - "expectations for suppliers to educate and train personnel and subcontractors in appropriate, and safe ways of working"; monitoring "involves meetings between Anora and its service providers, as well as two-way feedback".
• Procurement Policy and Principles of responsible sourcing.

All are accountable to the Executive Management Team and apply to Anora's upstream suppliers.

"During the reporting period, no cases involving value chain workers were reported that indicated formal non-compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines for Multinational Enterprises" (page 105). The Appendix B table maps the S2-1 human rights policy commitment and value chain worker policy datapoints to page 103 (page 63).

Processes for engaging with value chain workers about impacts

Reference: page 105 (ESRS content index, page 58).

"Anora's engagement with value chain workers includes frequent supplier visits and amfori BSCI audits conducted by qualified third-party auditors. The amfori BSCI monitoring process promotes responsible social practices through a structured approach: suppliers commit to a Code of Conduct covering fair wages, zero child labour, and safe working conditions. Risk assessments identify high-risk suppliers based on factors such as country of operation, certifications, and working conditions, prioritising them for monitoring, audits, or preventive measures" (page 105).

"Audits include on-site inspections and direct worker interviews to assess compliance with standards related to labour rights, health and safety, and also environmental protection" (page 105).

Stated gap. "While these audits provide valuable insights, Anora currently does not have additional formal processes for collecting feedback from workers who may be particularly vulnerable to human rights impacts" (page 105).

Monopoly collaboration. "Anora also collaborates with the Nordic alcohol monopolies to strengthen engagement with value chain workers. In this context, suppliers undergo an additional risk assessment covering traceability, risk identification, and minimum requirements related to working conditions and human rights. Identified risks or deviations trigger targeted follow-ups and, where necessary, audits - carried out in close cooperation between Anora, the monopolies, and the suppliers" (page 105).

"The overall responsibility for supplier engagement at Anora lies with the sourcing teams, under the leadership of the SVP Wine and the SVP Industrial" (page 105).

Processes to remediate negative impacts and channels for value chain workers to raise concerns

Reference: pages 105-106 (ESRS content index, page 58).

"Anora's human rights management processes are constantly developing, and Anora recognises that this is an area which requires active attention" (page 105). The processes used are listed as: the Code of Conduct for Suppliers and Sub-contractors; third-party audits (amfori BSCI) and certificates such as Fair for Life and Fairtrade; internal audits and supplier visits; "risk country profiles to give a holistic understanding of the human rights situation in Anora's supply chain countries"; a Supplier Self-Assessment tool; and "human rights training for all employees to strengthen internal competence" (page 105).

"Concerns and non-compliance can be reported through the Anora Whistleblowing Channel. The same reporting system is open for both Anora employees as well as external parties. Through the whistleblowing channel, value chain workers can raise their potential concerns, without fear of retaliation in any form" (page 105).

Anora "requires that all suppliers implement a system enabling employees to anonymously and reliably report any observed defects and issues related to the company's responsibilities. Anora also expects its suppliers to inform value chain workers about these channels" (page 105).

Two stated gaps (pages 105-106). "Currently, Anora does not formally evaluate the value chain workers' awareness or trust in the whistleblowing channel or the process for raising concerns." And: "Anora does not have a formal pre-established process for providing or tracking the effectiveness of remedy, but is committed to taking measures, based on due diligence processes, to avoid causing or contributing to adverse human rights impacts through its own activities, including its operations and supply chain."

Taking action on material impacts on value chain workers

Reference: pages 106-107 (ESRS content index, page 58).

Actions during 2025 (page 106): "Ensuring compliance through certifications and audits: Anora continued to utilise third-party certifications and initiated planning for external audits"; "Strengthening oversight through internal audits and supplier engagement"; "Enhancing risk awareness through country profile assessments"; "Supplier insight through self-assessments"; and an updated "field guide to support brand managers, sourcing and procurement teams in assessing and discussing human rights during partner visits".

"During 2025, Anora supported additional initiatives aimed at generating positive impacts for value chain workers. One of Anora's producers participated in Human Rights Impact Assessment, organized by Nordic monopolies... Another activity includes anonymous worker surveys at a producer site, enabling direct feedback on workplace conditions and wellbeing activity at one of our Chilean producers via a third party company" (page 106).

Affected groups. "Stakeholders affected include a wide range of groups, with particular attention to vulnerable populations such as seasonal workers from Eastern Europe and non-EU countries, women workers, migrant workers, and undocumented migrant workers" (page 106).

Salient risks. Based on the 2023 human rights risk assessment, salient risks "relate to health and safety, freedom from discrimination in employment, decent work, freedom of association and collective bargaining and forced labour. No severe human rights issues and incidents connected to upstream and downstream value chain were reported in 2025. Reviews and updates of the assessment will be conducted as needed" (page 106).

Escalation. "If the supplier fails to take corrective action or commits a serious breach, Anora may terminate the contract and end the cooperation" (page 107).

Resources. "Anora allocates standard operational resources... primarily reflected in personnel expenses, including wages and employee benefits and membership and auditing fees" (page 107). No amount is given.

Targets related to managing material negative impacts on value chain workers

Reference: page 107 (ESRS content index, page 58).

One target (page 107):

Methodology change. "The target is currently measured based on the percentage of suppliers in Anora's own-brand wine segment that are located in risk countries and covered by a valid social audit or recognized certification, such as amfori BSCI or equivalent schemes... In 2025, Anora has updated the target measuring methodology, forming a new baseline from the year 2025. Previously the target has been measured with a number of amfori BSCI audits conducted during the year. Anora continues to develop the tracking of target measurement to its other relevant categories as well. Most salient human rights risks are located in the wine value chain" (page 107).

The 86.0% figure is therefore not comparable with any prior year, and the target as currently measured covers the own-brand wine segment rather than the full sourcing landscape it is stated to apply to.

The target "was established through the Sustainability Roadmap process and informed by a materiality analysis, including input from over 200 stakeholders via an open survey - such as industry associations and NGOs" (page 107).

Policies related to consumers and end-users

Reference: pages 108-109 (ESRS content index, page 58).

Policies are tabulated against the material IROs of negative health impacts from excessive alcohol consumption and the NoLo opportunity (page 108):

• Code of Conduct (Anora Way) - "describes Anora's commitment to support a responsible drinking culture in accordance with Anora's purpose, Let's drink better. The policy addresses material impacts on consumers' and end-users' health and safety, while also supporting financial opportunities through the expansion of NoLo products and the encouragement of responsible drinking habits." Applies to all individuals employed by every Anora Group company, including the Board and Executive Management Team, "and to all people working for or representing Anora". Accountable: Executive Management Team.
• Responsible Marketing Policy - "demonstrates Anora's commitment to ethical and responsible marketing practices" (page 108).

"Anora recognises that excessive alcohol consumption can have adverse social and health impacts on individuals and society. The company is committed to fostering a modern and responsible drinking culture" (page 109).

Business model limit on remedy. "As a business-to-business (B2B) company, Anora does not engage directly with consumers or end-users of its products, as all sales are conducted through intermediaries. Consequently, Anora does not provide remedies to consumers or end-users directly. However, mechanisms are in place for individuals to raise concerns related to Anora's products or marketing, including the Anora Whistleblowing Channel, customer service channels, and online platforms" (page 109).

"During the reporting period, no cases involving consumers were reported in relation to non-compliance with the UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work or OECD Guidelines for Multinational Enterprises" (page 109).

Processes for engaging with consumers and end-users about impacts

Reference: page 109 (ESRS content index, page 58).

"As Anora's products are sold through an intermediary, formal processes for direct engagement with consumers and end-users have not been established" (page 109). What exists instead:

• "consumer perspectives are considered through tools such as consumer insights, which inform packaging design and marketing campaigns";
• "To promote responsible alcohol consumption, the majority of product packaging includes a 'Drink responsibly' message or a link to informational resources, such as responsibledrinking.eu";
• "Anora's website also provides relevant information on the effects of alcohol use";
• "spirits packaging includes details on the alcohol content per serving or unit".

"Anora's primary objective in engaging with consumers is to promote responsible alcohol consumption and raise awareness of the social and health risks associated with excessive use" (page 109).

"The SVP Wines and SVP Spirits have the overall responsibility for overseeing these forms of consumer engagement at Anora in their respective business areas" (page 109).

The disclosure does not describe how the perspectives of consumers most vulnerable to harm - the groups the DMA identifies as at increased risk, namely minors, pregnant individuals, those on specific medications and those with medical conditions (page 52) - are obtained, nor how the effectiveness of engagement is assessed.

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

Reference: pages 109-110 (ESRS content index, page 58).

"To help mitigate the potential negative impacts of excessive alcohol consumption, Anora is continually expanding its NoLo (no- and low-alcohol) product offering by introducing alternatives with lower alcohol by volume (ABV). Effectiveness is monitored through the development of net sales and the breadth of the NoLo portfolio" (page 109).

Channels. "Consumers can report concerns or potential non-compliance through Anora's primary channels: the Whistleblowing Channel, customer service, and online platforms. The Whistleblowing Channel, operated by an independent third party, is accessible to both Anora employees and external stakeholders. All reports are handled confidentially and investigated appropriately... It allows consumers and other stakeholders to raise concerns confidentially and without fear of retaliation" (page 109).

Three stated limits. "While Anora has not formally assessed consumer awareness of this channel, it remains a key mechanism for reporting potential issues" (page 109). "Anora does not currently have a formal process in place for remediating actual negative impacts. In 2025, no instances requiring corrective actions were reported to Anora" (page 110). And: "As Anora primarily operates in a B2B context and does not engage directly with consumers or end-users, it cannot formally ensure the effectiveness of any available remedy processes in terms of implementation or outcomes" (page 110).

In Anora's Nordic core markets "the marketing of alcoholic beverages is subject to strict regulation", and Anora "adheres to high standards of responsible marketing" (page 109).

Taking action on material impacts on consumers and end-users

Reference: pages 109-111 (ESRS content index, page 58).

Actions (pages 109-110). "Advancing responsible consumption through NoLo product innovation: Anora expanded its NoLo offering in the ready-to-drink (RTD) and wine categories to support both commercial growth and the promotion of responsible drinking. Following changes to Finland's Alcohol Act in 2024, a wide range of wines with up to 8% ABV were introduced in grocery stores, continuing in 2025. New RTD launches included for example Koskenkorva long drinks." Second, "Enhancing market insight through trends research", building on 2024 research on responsible drinking and the NoLo category.

Responsible marketing (pages 110-111). "Anora's marketing is strictly directed at individuals of legal drinking age. To prevent exposure to underage audiences, Anora avoids campaigns in media and contexts popular among youth, including certain social media platforms. Age verification mechanisms are applied across online channels and events. Marketing content must not include minors, nor use elements that appeal to children or youth culture, such as cartoons, fairy tale characters, or youth idols." Marketing also "does not target other vulnerable individuals, such as those affected by alcohol misuse or people for whom alcohol should not be sold, including pregnant individuals", and "does not glamorize alcohol use, depict excessive consumption, or link alcohol to personal success, social status, or physical appeal". In Norway, "where alcohol marketing is prohibited, Anora refrains from all promotional activities."

Memberships. VBF (Norway), SVL (Sweden), ETL (Finland) and SAJK (Finland); SVL and SAJK are affiliated with spiritsEUROPE, supporting campaigns such as "Talk about Alcohol" for primary schools in the Nordics (page 110).

Resources. "Producing NoLo products may require targeted investments in equipment (e.g. de-alcoholisation, canning lines), production facilities, hygiene measures, and innovation capabilities" (page 110). No amount is given. "No significant human rights issues or incidents involving consumers were reported in 2025" (page 111).

Targets related to managing material impacts on consumers and end-users

Reference: page 111 (ESRS content index, page 58).

One target (page 111):

"The 2030 target of 5% was achieved in 2025. Progress remains on track as initially planned" (page 111). The target is therefore met five years early and is not restated upward.

Prior-period error. "The comparative figure for 2024 has been corrected due to a calculation error. The share of NoLo products in Anora's net sales for 2024 was 4.2% instead of the previously reported 5.9% in the 2024 sustainability report. The difference from the 2024 figure is -1.7 p.p." (page 111, also disclosed under BP-2 at page 44).

The target was set with input from "affected stakeholders (with an open survey)", and "Anora takes into account general consumer views, to adjust targets if needed" (page 111). No target addresses the negative health impact IRO directly other than through the NoLo sales share.

Business conduct policies and corporate culture

Reference: pages 112-114 (ESRS content index, page 59).

Five policies are tabulated against the two material G1 risks - failure to uphold ethical business practices, and failure to detect corporate culture differences in an acquisition target (page 113): the Code of Conduct (Anora Way), accountable to the Board of Directors and publicly available; the Anora Code of Conduct for Suppliers and Subcontractors; the Anti-Bribery and anti-Corruption Policy (internal) and the separate Anti-Bribery and anti-Corruption Policy for Business Partners (public); the Procurement policy and Principles of responsible sourcing; and the Anora Risk Management Policy, accountable to the Board.

Corporate culture. "Anora's Code of Conduct and values - Courage to explore, Energy to inspire, and Empowering to win - guide daily decision-making and behaviour across the company... The company's corporate culture is actively developed through performance reviews, recruitment processes, internal communications, and leadership training. Progress is monitored annually through the Anora Tasting employee survey" (page 114).

Whistleblower protection. "Anora maintains a whistleblowing channel operated by an independent third party, accessible to all employees and external stakeholders. All reported concerns... are investigated following a defined process that ensures accuracy, anonymity, objectivity, and fairness. The Audit Committee, which plans and oversees the work of the internal auditor, may assign targeted audits to support the identification of inappropriate conduct." "Anora does not tolerate retaliation against individuals who report concerns in good faith... Retaliation is strictly prohibited and considered a serious breach". Protection is "aligned with national legislation implementing the EU Whistleblowing Directive (EU) 2019/1937" (page 114).

Training. "New employees complete a Code of Conduct e-training upon joining the company, with mandatory annual renewal of the training for all employees" (page 114). No completion rate is given for Code of Conduct training itself.

The Appendix B table marks the G1-1 paragraph 10(b) UN Convention against corruption and paragraph 10(d) protection of whistleblowers datapoints as "Not material" (page 64), which sits awkwardly with the narrative above.

Prevention and detection of corruption and bribery

Reference: pages 114-115 (ESRS content index, page 59).

Voluntary disclosure. "Although the ESRS sustainability matter 'corruption and bribery' was not assessed as material in Anora's materiality process, the company considers its prevention essential to maintaining an ethical corporate culture and mitigating related risks. Anora has a zero-tolerance policy towards bribery and corruption, as outlined in its Anti-Bribery and Corruption Policy for Business Partners" (page 114).

Risk exposure. "Anora's main markets in the Nordic countries and Northern Europe rank low on the corruption index. However, due to the highly regulated nature of the alcohol industry, obtaining and maintaining licenses and permits may pose corruption and bribery risks in countries with higher corruption levels. Employees and business partners operating in these regions are considered most exposed to such risks" (page 114).

Investigation procedures. "Allegations of corruption or bribery are addressed through internal control and risk management systems. Depending on the case, investigations may be conducted as (i) internal investigations - guided by the principles of the Whistleblower Policy and Conflict of Interest Policy - and/or (ii) special assignments to the internal auditor. Authorities are involved when appropriate. Investigations are carried out independently from the management chain involved in the matter. All incidents and allegations are reported to the Audit Committee and the Board of Directors" (page 114).

Training coverage. "Employees in functions-at-risk are required to complete the training. All salaried employees and management, not members of the Board of Directors, are in scope... 63% (24%) of employees for whom the training is relevant, consisting of salaried workers, have currently completed the course in 2025" (page 115).

Anti-bribery training coverage therefore more than doubled year on year but still leaves over a third of the in-scope population untrained, and the Board is outside the scope entirely.

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

Anora sets no business conduct targets and says so twice. "Although Anora has not set formal, measurable targets with base lines for business conduct and corporate culture, the company monitors policy effectiveness by tracking annual participation in Code of Conduct training" (page 114). And: "Although Anora has not set formal, measurable targets with base lines for the prevention and detection of corruption and bribery (as referenced in sections G1-3 and G1-4 of this Sustainability Statement), the company monitors the effectiveness of its policies by tracking the number of employees trained in anti-bribery and corruption matters and the number of cases reported annually through the whistleblowing channel" (page 115).

This is the MDR-T alternative limb: effectiveness tracked in the absence of a target. The tracking measures actually disclosed are:

• anti-bribery and corruption training completion, "63% (24%) of employees for whom the training is relevant" in 2025 (page 115);
• convictions for violation of anti-corruption and anti-bribery laws, 0 (0), and fines, EUR 0 (0) (page 115);
• corporate culture progress "monitored annually through the Anora Tasting employee survey" (page 114);
• complaints filed through own-workforce channels, 4 (5) (page 102).

No completion rate is disclosed for the Code of Conduct training that page 114 names as the effectiveness measure for corporate culture, and no baseline or time-bound outcome is attached to any of these measures.

Incidents of corruption or bribery

Reference: page 115 (ESRS content index, page 59).

"The number of convictions for violation of anti-corruption and anti-bribery laws was 0 (0) during the reporting period. The amount of fines for violation of anti-corruption and anti-bribery laws was EUR 0 (0). These metrics have been obtained through direct measurement and are not subject to validation by an external body other than the assurance provider" (page 115).

"During the reporting period, Anora continued with actions related to the annual evaluation of the need to review and update anti-corruption and bribery principles and procedures" (page 115).

The Appendix B datapoint table maps the G1-4 paragraph 24(a) fines datapoint and the paragraph 24(b) standards of anti-corruption and anti-bribery datapoint to page 115 (page 64).

Only the two SFDR-linked datapoints are given. The report does not disclose the total number of confirmed incidents of corruption or bribery, the number of confirmed incidents in which own workers were dismissed or disciplined, or the number of confirmed incidents relating to contracts with business partners that were terminated or not renewed. Related context is disclosed elsewhere: "Anora had no court convictions or serious infringements related to the minimum safeguards during the reporting period" (page 70), and 4 (5) complaints were filed through own-workforce channels in 2025 (page 102).