Antares Vision S.p.A.

Italy|Electrical & Electronic Equipment|FY2025|Auditor: EY S.p.A.|View original report →

Sustainability statement, in full

The complete text of Antares Vision S.p.A.’s FY2025 sustainability statement is held here – 147 pages, captured from the published report. Every disclosure below also links to its own passage.

ESRS 2 – General Disclosures

GOV-1The role of the administrative, management and supervisory bodies
Reported

Governance roles

Reference: pages 8-19 (index entry, page 45).

Antares Vision S.p.A. uses the "traditional model of administration and control": Shareholders' Meeting, Board of Directors, Board of Statutory Auditors, Board Committees (Appointments and Remuneration; Control, Risk and Sustainability; Related-Party Transactions), Supervisory Board and Independent Auditors (page 8).

The Board, appointed 10 July 2024 with eleven members, changed twice in 2025: on 14 October Fabio Forestelli replaced Gianluca Mazzantini as CEO and was named director in charge of the internal control and risk management system; in mid-December, after Crane NXT acquired a first tranche of shares, three directors resigned and Hans Lidforss, Christina Cristiano and Kimberly Di Maurizio joined as non-executive, non-independent directors (pages 8-9).

At 31 December 2025 the Board had 11 members, 3 executive and 5 non-executive and independent (pages 9-10). "There are no workers or workers' representatives on the board" (page 10).

The Board, supported by the Control, Risk and Sustainability Committee and the CEO, "determines the availability of adequate knowledge and skills to oversee sustainability issues"; deputy chair Crostarosa Guicciardi and directors Ambriola and Beretta are named as having "long-standing experience in ESG issues" (page 19). The Board's role is restated for G1 at pages 131-132.

GOV-2Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies
Reported

Information provided to the governance bodies

Reference: pages 19-20 (ESRS 2 index entry, page 45).

"The governance bodies described above meet periodically throughout the year to be updated on the impacts generated by the Company, on risk management and ESG opportunities, as well as to take decisions in relation to such matters. In case of need, these bodies are informed immediately and are ready to meet on an extraordinary basis" (page 19).

The Group's Global ESG team "has met monthly for a total of 6 times in 2025" (page 19).

Management periodically informs the governance bodies about the risk analysis "drawn up at the end of 2024 and approved by the BoD of the Parent Company and which was monitored and updated during the reporting period"; that document "is consistent with the Double Materiality Assessment (DMA) as the ESG risks shown in it are also represented in greater detail in the DMA" (page 20).

During the reporting period the governance bodies, with the ESG Team, "developed and approved an action strategy that considers the impacts generated, the scope and main characteristics of the risks identified, the internal control systems that have been implemented and the objectives to be achieved" (page 20). No list of the specific matters addressed at each meeting is given.

GOV-2(was GOV-3)Integration of sustainability-related performance in incentive schemes
Reported

Sustainability in incentive schemes

Reference: pages 20-24, restated for climate at pages 76-77 (index entries, pages 45 and 145).

At least one ESG target must sit among the individual targets of the CEO, key management personnel and other senior executives, "the achievement of which has a 10% weighting in the variable component of remuneration" (page 21). A unit head's individual ESG targets become "Unit targets" shared by all employees of that unit (page 21).

All ESG objectives in the 2024 remuneration policy were achieved (page 21): raising the female share of the Global Management Team to 20; the LIGHT and Robin AI projects; strengthening ERM with ESG risks and opportunities; raising FT Italia's renewable electricity use to 80; and achieving at least 85% of the ESG 2024 LTI scorecard targets.

A new LTI plan was approved on 7 May 2025, running 2025-2029 in three three-year cycles, with "90% linked to financial performance objectives and 10% to non-financial and ESG performance objectives" (pages 21, 76). Claw-back clauses entered the MBO policy from 2025.

The 2025 ESG-LTI scorecard is set out by ESRS topic (pages 22-23), covering E1, E5, S1, S2, S3, S4 and G1. The target is at least 85% of scorecard sub-objectives, with 72% treated as "above threshold" (page 22).

GOV-3(was GOV-4)Statement on due diligence
Reported

Statement on due diligence

Reference: pages 24-25 (index entry, page 45).

The process "clearly defines the phases of ESG data collection, validation, and consolidation, ensuring traceability and methodological consistency throughout the information flow". Operational functions are named data owners for each indicator; coordination sits with the Sustainability Specialist; top management oversees and approves final outputs (page 24).

Controls include management software, RCM matrices and formal attestations. Board and Control, Risk and Sustainability Committee oversight "ensures alignment with corporate strategies and the management of relevant ESG risks", and the process is integrated with Risk Management through a dedicated ESG RCM matrix (page 24).

Certifications cited as evidence: ISO 9001:2015, ISO 45001:2023, ISO 14001:2015 and ISO/IEC 27001:2024, each held by named sites and companies rather than Group-wide (page 24).

A TÜV gap assessment in 2025 of the foreign manufacturing companies (Antares Vision North America, Applied Vision, Antares Vision do Brasil, AVI Excellence, AV Electronics) "revealed a number of shortcomings in terms of documentary evidence, compliance alignments and updates, and the integration of security and emergency plans"; a corrective action plan is to be implemented in 2026 (pages 24-25).

GOV-4(was GOV-5)Risk management and internal controls over sustainability reporting
Reported

Risk management and internal controls over sustainability reporting

Reference: pages 25-26 (index entry, page 45).

In the six-monthly risk analysis "no specific risks were identified relating to the reporting of data and information disclosed in the sustainability report as the Group had already had a structured data reporting process in place since 2021", used previously for the NFRD statement (page 25).

To strengthen the system the parent company prepared on 16 December 2025 and sent to all Group companies the procedure "AV Group Sustainability Reporting Instructions 2025", setting out data owner responsibilities, reporting rules, local control and representation letters (page 25). The "Talentia" reporting software was updated in 2025 to allow ESG and financial data on one platform, automatic data squaring control, collaborative workflows and audit-trail traceability.

"Lastly, in December 2025, Antares Vision developed a Risk Control Matrix for its ESG reporting processes" (page 25). "Each local CEO signed a representation letter confirming the reliability, completeness and accuracy of the data" (page 25). Periodic supervision by the Control, Risk and Sustainability Committee and the Board of Statutory Auditors was carried out "without raising objections" (pages 25-26).

SBM-1Strategy, business model and value chain
Reported

Strategy, business model and value chain

Reference: pages 26-31 (index entry, page 45).

Antares Vision Group "leads the digitalization of products and supply chains through traceability, quality control inspection and integrated data management", enabling what it trademarks as Trustparency® (page 26). Outlet sectors are Life Sciences, Beverage, Food, Cosmetics, Chemicals and Packaging (page 30). In pharmaceuticals it describes itself as "the world leader in drug traceability, with solutions used both by the world's leading manufacturers (50% of the top 20 pharmaceutical multinationals) and by government authorities" (page 26).

The portfolio has five blocks: quality control inspection, traceability, authentication and brand protection, NATIV.AI, and data management (pages 26-28). Two internal programmes are named: the Ford Project and the DYNAMO project (page 27).

At 31 December 2025 the Group had 1,146 employees, with a country breakdown by gender (page 28). "There are no prohibited products or services in the markets served by Antares Vision" (page 29).

Upstream, the Group "uses a large number of suppliers, where the most representative and important are the Partners involved in the implementation phase and in the installation of the solutions"; a table maps supplier types to each production stage (page 31). The 2026-2030 ESG strategy sets targets with KPIs across the three pillars (page 29).

SBM-2Interests and views of stakeholders
Reported

Interests and views of stakeholders

Reference: pages 32-33 (index entry, page 45); restated for S2 (pages 115-116) and S3 (pages 120-121).

Ten stakeholder categories are tabulated with the engagement tools used for each (page 32): shareholders; banks, lenders and investors; employees; industrial partners, goods suppliers and service and installation partners; competitors; customers, including direct plant and production-site customers; final customers; national and local public administration, authorities, institutions and regulatory bodies; local communities and trade associations; and media.

For the double materiality assessment specifically, "the members of the ESG team were directly involved through a digital round table" (page 33). They were presented with the methodology and results and "invited to express their opinions on the material topics", and asked whether topics were missing, whether ratings were inaccurate, or whether they agreed with the work done (page 33).

"Stakeholder engagement activities did not reveal any additional or different sustainability issues or concerns with respect to the aspects already managed in the Antares Vision strategy" (page 33). Outcomes are shared with the ESG Team and the Board of Statutory Auditors through specific meetings.

The engagement is internal: the round table involved ESG team members as internal stakeholders (page 40). No external stakeholder consultation is described for the DMA itself.

SBM-3Material impacts, risks and opportunities and their interaction with strategy and business model
Reported

Material impacts, risks and opportunities

Reference: pages 33-38 (index entry, page 45).

The DMA "is aligned with the 2023 European Sustainability Reporting Standards (ESRS) and, in particular, with the Implementation of Guidance IG1 Materiality issued by EFRAG in 2024" (page 33). Eight topical standards are material: E1, E2, E5, S1, S2, S3, S4 and G1; E3 and E4 are not (pages 33-34).

"The areas affected by the greatest number of impacts on stakeholders are Own workforce (26%), Consumers and end-users (19%) and Workers in the value chain (17%), while the areas affected by the greatest number of risks and opportunities are Own workforce (26%), Consumers and end-users (20%)" (page 34).

A full IRO table follows (pages 35-37), each row carrying ESRS topic, sub-topic, description, type, actual or potential, negative or positive, a 1-5 score and direct or indirect. Examples: Scope 1 and 2 GHG emissions (actual negative, 3.5, direct); GHG from the aluminium, steel and iron supply chain (actual negative, 4, indirect).

Two statements govern scope (page 38). "In accordance with applicable exemptions, Antares Vision has not analysed the expected financial impacts", and "Although Antares Vision has not yet formalised a specific resilience plan... the integration of ESG targets and actions into the short and long-term strategy is the concrete response". The update "did not lead to significant changes in the IRO assessments".

IRO-1Description of the processes to identify and assess material impacts, risks and opportunities
Reported

Processes to identify and assess material IROs

Reference: pages 39-43 (index entry, page 45); topic restatements for E1 (pages 77-78), E2 (pages 86-87), E5 (page 88) and G1 (page 132).

Mapping applied "the application guides issued by EFRAG and, in particular, the IG 1 Materiality Assessment, as well as through analyses and interviews with Group personnel", on "a top-down approach" (page 39).

Thresholds are disclosed. Impact severity is scored 1-5 on extent, scope and, for negative impacts, irremediable nature; "to be assessed as material, such impacts must show a severity prudentially set at a threshold of > 2.5 on the 1-5 assessment scale" (page 41). Potential IROs are material if severity and likelihood place them "in the red area of the following heatmap (5 x 5)".

For risks and opportunities, magnitude is scored 1-5 and probability 1 (rare) to 5 (almost certain) (page 42). Financial materiality magnitude was "calculated on the basis of the impact on consolidated operating cash flow", banded up to EUR 500 thousand; 500 thousand to 2 million; 2 to 5 million; 5 to 25 million; over 25 million. "The same thresholds were used for the Group Risk Assessment and Risk Management process" (page 42).

Inputs were the prior year's reporting, four business areas, the geographies Europe, North America, APAC and Brazil, and the value chain (page 40). "The next review of the materiality assessment is expected by the end of 2026" (page 43).

IRO-2Disclosure requirements in ESRS covered by the undertaking's sustainability statement
Reported

Disclosure requirements covered

Reference: pages 44-48.

The Group prints a full ESRS content index headed "IRO-2 - ESRS disclosure requirements covered by the corporate sustainability statement", tabulating ESRS / DR / description / page (pages 45-48). The page column refers to the pagination of the full Annual Financial Report, not to this statement's own page numbers.

Listed disclosure requirements, by standard:

  • ESRS 2: BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2, MDR-P, MDR-A, MDR-M, MDR-T
  • E1: GOV-3, E1-1, SBM-3, IRO-1, E1-2 to E1-7
  • E2: IRO-1, E2-1, E2-2, E2-3
  • E5: IRO-1, E5-1 to E5-5
  • S1: SBM-3, S1-1 to S1-9, S1-13 to S1-17
  • S2: SBM-2, SBM-3, S2-1 to S2-5
  • S3: SBM-2, SBM-3, S3-1, S3-2, S3-4, S3-5
  • S4: SBM-3, S4-1 to S4-5
  • G1: GOV-1, IRO-1, G1-1, G1-2, G1-3, G1-4, G1-6

E3 and E4 do not appear at all. Within material standards the index omits E1-8, E1-9, E2-4, E2-5, E2-6, E5-6, S1-10, S1-11, S1-12, S3-3 and G1-5.

The stated basis: thresholds were set "in application of the methodology suggested by the Implementation Guidance IG1 Materiality issued by EFRAG", and "Specific disclosures relating to topics, sub-topics or sub-sub-topics below the materiality threshold have not been included" (page 48). No table of datapoints derived from other EU legislation and no phase-in list is printed.

E1 – Climate Change

E1-1Transition plan for climate change mitigation
Reported

Transition plan for climate change mitigation

Reference: page 77 (index entry, page 45).

"As at 31 December 2025, the Antares Vision Group has not adopted a transition plan for climate change mitigation" (page 77).

The Group cross-refers instead to the ESRS E1 objectives "defined by the Group within the Industrial Plan and the Sustainability Plan", disclosed under ESRS 2 MDR-T (page 58) and E1-4 (page 79). It states that "The Group plans to develop and implement a medium-term Transition Plan" (page 77), without naming a date.

Adjacent quantification is limited. Capital expenditure for energy efficiency initiatives under the sustainability strategy "ranges from EUR 350 thousand in 2027 to EUR 500 thousand in 2030, and relates to the AVIT and FT System production sites" (page 77). For 2025 actions, "a specific reporting process has not yet been developed to quantify greenhouse gas emission savings related to the aforementioned climate change mitigation actions, nor to measure the related CapEx and OpEx", and "A detailed quantitative assessment will be conducted during the development of the Transition Plan" (page 79).

No GHG reduction target expressed against a base year, no decarbonisation lever quantification, no locked-in emissions assessment and no statement on Paris alignment or exclusion from EU Paris-aligned benchmarks appears in the E1 chapter.

E1-2(was covered under ESRS 2 IRO-1)Identification of climate-related risks and scenario analysis
Reported

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 as restated in the E1 chapter (pages 77-78). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Outcome first. "Antares Vision performed a qualitative assessment for each material climate-related risk or transition risk identified in the 'Application Requirements' section of ESRS E1: based on this assessment, the Group did not identify material physical or transition climate-related risks. As a result, no climate resilience analysis, including the use of climate scenario analysis, was conducted" (page 77).

Physical risk methodology (page 78). Using the ESRS 2 time horizons, the Group "assessed the extent to which the Group's assets and business activities could be exposed and sensitive to the identified climate hazards, taking into account their probability, magnitude and duration, as well as specific geospatial coordinates (such as the NUTS classification for EU territories) of its operating locations".

Transition risk methodology (page 78). It "identified transition events in the short, medium and long term, using examples based on the classification developed by the Task Force on Climate-related Financial Disclosures (TCFD)".

Scope: own emissions and energy use, plus upstream suppliers of "materials used in the manufacture of the Group's machinery" (page 77).

E1-3(was covered under ESRS 2 SBM-3)Resilience in relation to climate change
Reported

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 (page 38) and the E1 strategy section (page 77), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The company states plainly that no climate resilience analysis was carried out. "Based on this assessment, the Group did not identify material physical or transition climate-related risks. As a result, no climate resilience analysis, including the use of climate scenario analysis, was conducted" (page 77).

The same position is taken at Group level across all sustainability matters: "Although Antares Vision has not yet formalised a specific resilience plan on the Group's ability to address sustainability issues, the integration of ESG targets and actions into the short and long-term strategy is the concrete response to the risks and opportunities that have emerged from the double materiality analysis" (page 38).

In its place is strategy integration: ESG targets embedded in the industrial plan and monitored by the ESG Team (page 19), the 2026-2030 ESG strategy (page 29), and the Sustainability Plan approved 17 March 2026 (page 58). Capacity to adapt is quantified only as energy efficiency capital expenditure of EUR 350 thousand in 2027 rising to EUR 500 thousand in 2030 (page 77). No areas of uncertainty are described, because no assessment was performed.

E1-4(was E1-2)Policies related to climate change mitigation and adaptation
Reported

Policies related to climate change mitigation and adaptation

Reference: page 78 (index entry, page 45).

"Although, as of today, the Group has not yet adopted a specific policy dedicated exclusively to climate change management, starting from 2024 the Parent Company has defined and made available a Global QHSE Policy, which provides the adoption of innovative technologies aimed at improving the energy efficiency of the Antares Vision Group companies" (page 78).

The Quality, Health, Safety and Environment policy is described in more detail in the E5 chapter, where its climate-relevant commitments are listed as reduction of energy consumption and "reduction of atmospheric pollutant emissions, with particular attention to the organisation of business travel and logistics", alongside a commitment to apply and promote ISO 14001:2015 standards (pages 88-89).

No policy scope, no named accountable body for a climate policy specifically, and no third-party standard for climate is disclosed beyond ISO 14001. Antares Vision Italia holds ISO 14001:2015 certification for the Sorbolo and Travagliato locations only (page 24).

E1-5(was E1-3)Actions and resources in relation to climate change policies
Reported

Actions and resources in relation to climate change policies

Reference: pages 78-79 (index entry, page 45).

Eight actions implemented in 2025 (pages 78-79):

  • mandatory and voluntary training on energy-saving actions
  • measurement systems integrated into machinery to monitor energy consumption
  • a list of actions and rules to limit the volume of stored data
  • more hybrid and electric vehicles in the corporate fleet
  • KPIs to measure business travel (AVIT)
  • review of the Group Travel and Business Trips Policy "with a view to reducing atmospheric emissions"
  • measurement of logistics and shipments "in order to implement a plan for reducing emissions"
  • virtualisation of Rfxcel products to reduce indirect CO2 emissions

A planned action: "In 2025, FT System initiated a project involving the installation of photovoltaic panels and new electric vehicle charging stations... These installations will be carried out during 2026" (page 79).

Resources are not quantified. "At present, a specific reporting process has not yet been developed to quantify greenhouse gas emission savings related to the aforementioned climate change mitigation actions, nor to measure the related CapEx and OpEx", and the FT System project's effects "have not yet been measured in quantitative terms" (page 79). Readers are referred to the EU Taxonomy Article 8 disclosure (pages 60-76), where no Taxonomy-aligned CapEx is reported (page 71).

E1-6(was E1-4)Targets related to climate change mitigation and adaptation
Reported

Targets related to climate change mitigation and adaptation

Reference: page 79, with incentive-linked objectives at pages 76-77 (index entry, page 45).

Antares Vision "has defined, within its Sustainability Plan, further targets related to climate change mitigation, some of which include quantitative targets", then qualifies them: "the targets set have not been selected on the basis of external scientific evidence, but rather through internal, reasoned assessments, and that they are not explicitly linked to Group policies" (page 79). Responsible functions were identified for each area.

The climate objectives stated in words appear under the incentive schemes and sustainability strategy (pages 76-77): increasing the share of renewable energy sources; promoting a culture of energy efficiency and saving; reducing the carbon footprint of the organisation and of products; developing new energy efficiency solutions. The 2025 objectives entering variable remuneration were reduction of indirect CO2 emissions from business travel, logistics and products, energy efficiency improvement, and transition to renewable energy (page 76).

No base year, no target year, no percentage reduction and no absolute tCO2e target is disclosed for Scopes 1, 2 or 3. The MDR-T caveat applies: the strategic objectives are "not based on reliable scientific data and not measurable or results-oriented", and not all objectives yet have measurable metrics (page 58).

E1-7(was E1-5)Energy consumption and mix
Reported

Energy consumption and mix

Reference: pages 80-81 (index entry, page 45).

Total energy consumption 2025: 5,400.03 MWh (2024: 5,939.71 MWh), a fall of about 9%.

Source2025 (MWh)2024 (MWh)
Fossil sources3,970.304,539.74
Nuclear sources159.05246.19
Renewable fuels incl. biomass0.010.01
Purchased renewable electricity, heat, steam, cooling1,269.531,139.80
Self-generated renewable energy without fuels1.1513.97
Total renewable1,270.691,153.78
Total5,400.035,939.71

Shares: fossil 73.52% (2024: 76.44%), nuclear 2.95% (4.14%), renewable 23.53% (19.42%) (pages 80-81).

"Compared to 2024, the procurement of electricity from renewable sources increased by approximately 4% in 2025. Starting from October 2024, FT System and AV Electronics began purchasing electricity exclusively from suppliers providing Guarantees of Origin, thereby aligning their commitment with that of Antares Vision S.p.A., which already sources 100% of its electricity through Guarantees of Origin contracts" (page 81).

The Group is not a high climate impact sector filer and no sectoral energy intensity ratio is disclosed. Consumption covers equipment, production facilities and commercial offices (page 80).

E1-8(was E1-6)Gross Scopes 1, 2, 3 and Total GHG emissions
Reported

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 82-86 (index entry, page 45).

"The Group does not fall within the scope of application of the EU Emissions Trading Scheme (EU ETS)" (page 82).

tCO2e20252024
Scope 1 (direct)729.2859
Scope 2 market-based489568
Scope 2 location-based752893
Scope 317,27420,757
Total (market-based)18,49222,183
Total (location-based)18,75522,509

Scope 1 comprises diesel 344.4, fuel 311.7 and natural gas 73.1 tCO2e; it "decreased by 15%" on fleet reorganisation and lower gas use (page 82). Emissions "do not include losses related to fluorinated gases (F-gases)" (page 83). Scope 2 applies a zero factor to electricity covered by Guarantees of Origin (page 82).

Scope 3 by category, tCO2e (page 85): purchased goods and services 1,124; fuel and energy-related activities 241; upstream transport 1,288; waste 0.6; business travel 1,491; employee commuting 1,212; downstream transport 617 (new in 2025); use of sold products 11,301 (2024: 14,922).

Emissions intensity: 90.6 tCO2e per EUR million of net revenue market-based (2024: 107.1), 91.9 location-based (2024: 108.7), on net revenue of EUR 204 million (page 86). The Group states "100% of Scope 3 emissions were calculated using internal primary data" (page 84).

E1-9(was E1-7)GHG removals and GHG mitigation projects financed through carbon credits
Reported

GHG removals and mitigation projects financed through carbon credits

Reference: page 86 (index entry, page 45).

The Group discloses two offsetting-type initiatives and then rules them out of its accounts:

  • "Tree-planting activities carried out by Tradeticity... involving the planting of approximately 1,000 trees in Croatia and India. To date, the quantities of GHG emissions expected to be avoided or removed as a result of this project have not yet been quantified" (page 86).
  • "Participation by FT System, through its logistics partner GLS, in a climate protection project" (page 86).

"At present, the aforementioned projects are not accounted for within the Group's GHG compensation metrics, nor are they included in the calculation of reported GHG emissions" (page 86).

No carbon credits are purchased or cancelled, no removals are claimed in the value chain, and no net-zero or neutrality claim is made anywhere in the E1 chapter.

E1-10(was E1-8)Internal carbon pricing
Not Material
E1-11(was E1-9)Anticipated financial effects from material physical and transition risks and potential climate-related opportunities
Omitted

E2 – Pollution

E2-1Policies related to pollution
Reported

Policies related to pollution

Reference: page 87 (index entry, page 46).

"At present, the Antares Vision Group has not adopted a specific policy dedicated to pollution, as this topic does not arise directly from the Group's core activities" (page 87).

The context for that position is set out immediately above it under IRO-1: "Given the nature of the business, as the Group designs and manufactures its machinery primarily through assembly activities rather than transformation-intensive production processes, no direct impacts, risks or opportunities specifically related to pollution were identified. However, indirect IROs were identified upstream along the value chain", relating to GHG and other atmospheric pollutants "such as NOx, SOx, particulate matter, etc." from the extractive and manufacturing processes of steel and aluminium (pages 86-87).

The Group's QHSE Policy, described in the E5 chapter, does carry two pollution-relevant commitments: "reduction of atmospheric pollutant emissions, with particular attention to the organisation of business travel and logistics" and "reduction or substitution of hazardous chemicals used in production processes with safer and lower-impact alternatives" (page 89). The E2 section does not present that policy as a pollution policy.

E2-2Actions and resources related to pollution
Reported

Actions and resources related to pollution

Reference: page 87 (index entry, page 46).

"Although pollution does not directly result from the Antares Vision Group's activities, a specific action aimed at reducing air pollution has been defined within the Sustainability Plan. This initiative involves the monitoring of logistics and shipping activities, both upstream and downstream along the value chain, with the objective of identifying and implementing emission-reduction strategies, including, for example, prioritising transport modes with a lower environmental impact" (page 87).

"The Group expects to complete this action by 2027" (page 87).

"Through this initiative, the Group aims to maintain a very high proportion of certified transport providers (above 90%) and to prioritise lower-impact transportation solutions" (page 87).

No CapEx or OpEx figure is attached to the action, no baseline for the certified-provider share is given, and no other pollution action is described. The action targets the same upstream and downstream air-pollution IRO identified in the DMA (page 35).

E2-3Targets related to pollution
Reported

Targets related to pollution

Reference: pages 87-88 (index entry, page 46).

"Within the Sustainability Plan, Antares Vision has defined an objective aimed at safeguarding air quality, as outlined below" (page 87). The table that follows the sentence carries no extractable text in the source document, so the target's metric, baseline and deadline cannot be quoted; the accompanying narrative action is the logistics and shipping monitoring due for completion by 2027, with a target of keeping certified transport providers above 90% (page 87).

"For the definition of the above-mentioned objective, the Parent Company involved and identified the functions responsible for each relevant area. These functions will also be responsible for the monitoring and achievement of the objective" (page 87).

"This objective is not linked to the Antares Vision Group's environmental sustainability policies and is not mandated by, nor derived from, compliance with any applicable regulatory requirements" (page 88).

The Group-level MDR-T caveat applies: the strategic objectives are described as "not based on reliable scientific data and not measurable or results-oriented", and not all objectives yet have associated measurable metrics (page 58).

E2-4Pollution of air, water and soil
Not Material
E2-5Substances of concern and substances of very high concern
Not Material
E2-6Anticipated financial effects from pollution-related impacts, risks and opportunities
Omitted

E5 – Resource Use and Circular Economy

E5-1Policies related to resource use and circular economy
Reported

Policies related to resource use and circular economy

Reference: pages 88-89 (index entry, page 46).

"At present, the Antares Vision Group does not have a specific policy dedicated to the material impacts, risks and opportunities (IROs) related to circular economy aspects" (page 88).

In its place the Group points to the Quality, Health, Safety and Environment (QHSE) Policy, which "includes principles and provisions related to resource use and the circular economy, as well as specific guidance on waste management. In particular, the policy promotes responsible waste management practices and the use of recyclable materials" (page 88).

Through it the Group commits to ISO 14001:2015 and to (page 89): responsible, efficient use of raw materials; progressive reduction of waste through process optimisation; product and packaging design on a full life-cycle perspective; reduced energy consumption; reduced atmospheric pollutant emissions, with attention to business travel and logistics; reduction or substitution of hazardous chemicals with lower-impact alternatives; substitution of high-impact materials with eco-compatible ones; responsible waste management and circular economy principles; and continuous monitoring of direct and indirect environmental aspects.

ISO 14001:2015 certification covers Antares Vision Italia's Sorbolo and Travagliato sites only (page 24). No policy owner or scope of application is stated in this section.

E5-2Actions and resources related to resource use and circular economy
Reported

Actions and resources related to resource use and circular economy

Reference: pages 89-90 (index entry, page 46).

Waste at the main European sites "is sorted for recycling, and is subsequently sent for recycling, reuse or waste-to-energy conversion, in accordance with the policies adopted by the final operator" (page 89). A separate waste collection project at the Travagliato headquarters has run since 2024, and during 2025 the Group "reinforced existing programmes aimed at waste reduction, reuse and recycling", including minimal and biodegradable packaging and reduced paper use through digitalisation.

Since 2019 the Group has adhered to the #PlasticFree campaign and the #IoSonoAmbiente initiative of the Italian Ministry for the Environment, "anticipating the European ban on single-use plastic products": water dispensers replacing single-use bottles, coffee machines using paper cups and accepting reusable containers, customised reusable bottles for employees, and eco-sustainable takeaway containers (page 89).

Paper reduction: machine manuals redesigned for digital consultation via QR codes, and "Follow Me" badge-authenticated printing introduced in 2021 "resulted in a reduction of over 32,000 printed pages at AVIT in 2025, compared to 2024" (page 90).

"At present, the Group has not yet implemented a specific system for reporting costs and investments related to the initiatives and actions described above" (page 90).

E5-3Targets related to resource use and circular economy
Reported

Targets related to resource use and circular economy

Reference: page 90 (index entry, page 46).

An achieved target is reported: "The Antares Vision Group achieved the target set for the 2024-2025 period concerning the launch of a separate waste collection project at the headquarters in Travagliato, as well as the subsequent extension of the project's scope to all Group sites, supported by the activities of the ESG Champions. An exception applies to the Group's sites in the United States, where the implementation of separate waste collection is limited due to local waste management systems that are not compatible with this practice" (page 90).

Forward targets: "Within its Sustainability Plan, Antares Vision has set targets relating to incoming and outgoing resource flows, with particular focus on the management of product end-of-life, the efficiency and traceability of raw materials, and the procurement and use of sustainable resources. The targets defined are set over a medium-term time horizon" (page 90). Responsible functions were identified for each area. The detail table that follows carries no extractable text in the source document, so the individual metrics, baselines and deadlines cannot be quoted.

"These targets are not linked to the Antares Vision Group's environmental sustainability policies and are not mandated by, nor derived from, compliance with any applicable regulatory framework" (page 90).

E5-4Resource inflows
Reported

Resource inflows

Reference: pages 90-91 (index entry, page 46).

Scope is limited: inflows "are reported exclusively for the Group's manufacturing and assembly companies" and cover metals, used for machinery and spare parts, and wood, used as packaging material. Other companies are excluded as procuring non-significant quantities, and cables, electronic components and other assembly parts are excluded as "immaterial quantities... considered ancillary components"; the DMA "did not identify any material impacts, risks or opportunities (IROs) related to the excluded categories" (pages 90-91).

The table splits technological from biological material. It carries no unit label in the source document, so figures are given as printed (page 91):

Category20252024
Case Machine (technological)253,140.46261,382.00
Spare Parts (technological)13,961.0016,170.67
Wood packaging (biological)380,564.83234,261.00
Total647,666.29511,813.67

Method: the Case Machine count "is derived from the number of machines sold, each identified by a unique serial number, thereby preventing any double counting", weight from machine families and bills of materials, spare parts from unique transport documents, and wooden packaging from purchase orders (page 91).

No share of recycled, secondary or biological materials is disclosed, though raising the recycled share is an ESG-LTI scorecard sub-objective (page 22).

E5-5Resource outflows
Reported

Resource outflows

Reference: pages 91-95 (index entry, page 46).

The Group's outflow disclosure is expressed entirely as waste: "The total amount of waste generated in 2025 amounted to 107,267 kg" (page 91). Recovery and disposal tables follow (pages 92-93), waste types are itemised (pages 94-95), and non-recycled waste is 38,366.55 kg, 36% of total waste generated, down from 46% the previous year (page 94). "This variation indicates that the recycling rate of waste increased in 2025". Hazardous waste totalled 3,479 kg and "No radioactive waste was generated" (page 95).

Classification "is based on the technical documentation prepared at the time of collection (such as, for example, waste transfer documentation in Italy) and takes into account the information and estimates provided by environmental service operators" (page 95). Collection and disposal are outsourced to private and municipality-linked operators (page 88). Waste figures for Applied Vision, AV Brazil, AV India, AV Electronics and AV North America "include uncertainties in the estimate", derived from purchasing data (page 8).

Products and materials leaving the Group are not otherwise characterised. No expected durability, reparability, recyclability or recycled content of the machines and software sold is disclosed. Product end-of-life is named as a Sustainability Plan target area rather than a reported metric (page 90).

E5-6Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities
Omitted
E5-5(was E5-5-Waste)Waste
Reported

Waste

Reference: pages 91-95 (index entry for E5-5, page 46).

Total waste generated in 2025: 107,267 kg (page 91). Hazardous waste totalled 3,479 kg, and "No radioactive waste was generated" (page 95).

Waste sent for recovery, kg (pages 92-93):

20252024
Hazardous - preparation for re-use1,069.001,073.80
Hazardous - recycling1,034.00501.00
Hazardous - other recovery252.00-
Total hazardous2,103.001,826.80
Non-hazardous - preparation for re-use4,596.3015,080.20
Non-hazardous - recycling67,866.4559,869.40
Non-hazardous - other recovery4,878.001,953.20
Total non-hazardous77,340.7576,902.80
Total sent for recovery79,433.7578,729.60

Sent for disposal, kg (page 93): hazardous incineration 416.00, landfill 960.00, other 62.00, total 1,376.00; non-hazardous incineration 3,882.80, landfill 22,344.45, other 220.00, total 26,447.25. Total sent for disposal 27,823.25 (2024: 33,484.40).

Non-recycled waste: 38,366.55 kg, 36% of total waste, against 46% the previous year (page 94).

Waste types are itemised in full (pages 94-95). Estimation uncertainty is disclosed for Applied Vision, AV Brazil, AV India, AV Electronics and AV North America, whose figures came from purchasing data using a percentage taken from similar Group companies (page 8).

S1 – Own Workforce

S1-1Policies related to own workforce
Reported

Policies related to own workforce

Reference: pages 98-101, with policy descriptions at pages 48-57 (index entry, page 46).

Seven policies apply to the own workforce: Human Rights, Whistleblowing, Diversity Equity and Inclusion, Gender Equity, Parental Care, Working Hours, and Information Security Management System (page 98). All apply Group-wide "with the exception of the 'Information Security Management System' and 'Working Hours' policies, which apply only to the Italian perimeter". Associated companies outside the consolidation perimeter must sign a declaration committing to comply (page 99).

Several were adopted in 2025: the Gender Equity Policy, approved 12 June 2025 (page 49), the Performance Evaluation, Individual Variable Compensation, Parental Care and Working Hours Policies (pages 51-52), and the Information Security Management System Policy (pages 53-54).

The Human Rights Policy, adopted 31 January 2023, is aligned to the International Bill of Human Rights, the ILO fundamental conventions, the UN Convention on the Rights of the Child and the ECHR, and "is consistent with the United Nations Guiding Principles on Business and Human Rights" although not explicitly referenced within it (pages 99-100). It "explicitly addresses and rejects practices of forced or compulsory labor, child labor, and any form of discrimination".

Health and safety is managed under Legislative Decree 81/08, with ISO 45001 at the Parent Company's sites (page 100).

S1-2Processes for engaging with own workforce and workers' representatives about impacts
Reported

Engaging own workforce and workers' representatives

Reference: pages 101-103 (index entry, page 46).

"In Italy, the workforce is involved in dialogue with the company through trade union representatives and Employee Meetings. At a global level, involvement takes place through communication with the HR department and/or - in some cases - with management" (page 101). Engagement at Travagliato runs through internal and external Unitary Trade Union Representations (RSU) and through external RSUs elsewhere; Workers' Safety Representatives "are always involved in the annual safety meetings".

Frequency: "Meetings with employees are scheduled on a quarterly basis: at Group level, in fact, three such meetings were held during 2025. Meetings with RSUs, on the other hand, do not have a defined frequency"; ad hoc meetings on request take place "within 7 to 10 days" (page 102).

"The function with the highest level of responsibility for engaging workers' representatives is the Chief HR Officer" (page 102).

Two limits are stated: "At present, no specific global agreements have been signed with workers' representatives concerning the respect of workers' human rights", and "As of today, there are no tools in place to measure the effectiveness of engagement" (page 102).

For vulnerable workers the Group lists ergonomic workstations, meal vouchers and welfare plans, translation of key documents and visual safety symbols, and equitable parental leave (pages 102-103).

S1-2(was S1-3)Processes to remediate negative impacts and channels for own workforce to raise concerns
Reported

Remediation and channels to raise concerns

Reference: pages 103-104 (index entry, page 46).

The Group operates a Whistleblowing system through a dedicated portal, with reports directed to "the external lawyer acting as Chair of the Supervisory Body (OdV)", who manages them "including the launch of an internal investigation and, if necessary, the collection of evidence and the involvement of internal functions (e.g. the Chief HR Officer or the Legal Manager)" (page 103). Reports are handled by a qualified and independent third party (page 135).

Alongside it, local HR teams organise ad hoc meetings on team issues; "in any case, the average response time is approximately 7 to 10 days" (page 103). Reports may also be submitted through internal RSUs, and for Antares Vision Italia the RLS receive reports "through various channels (e-mail, meetings, analyses such as work-related stress assessments)" which "are duly archived" (pages 103-104).

Availability is communicated through the intranet, the website and internal e-mail (page 104).

"As of today, there are no specific processes and/or tools in place to assess workers' awareness of, and confidence in, the existence and use of structures or systems for raising concerns or needs" (page 104).

The Whistleblowing Policy "addresses the confidentiality of the reporting party and expressly establishes the prohibition of retaliation or discrimination against the same".

S1-3(was S1-4)Taking action on material impacts on own workforce
Reported

Taking action on material impacts on own workforce

Reference: pages 104-106 (index entry, page 46).

Against material impacts on skills retention, collective bargaining and data security, the Parent Company "ensures the implementation of training plans to promote the development of upskilling tools, career paths and knowledge sharing" and adopted policies for IT infrastructure management (page 104).

On work-life balance: vacation planning reorganisation, work-related stress analyses, and a salary review completed in 2025 across the Group perimeter (page 105).

UNI/PdR 125 certification was obtained in 2025 by the Parent Company and FT System Italia, "aimed at mitigating certain workforce-related risks such as the gender gap (roles, pay, contractual conditions, growth opportunities, etc.), strengthening practices and processes supporting work-life balance" (page 105).

New 2025 policies cover workforce confidentiality and personal data, internal data breaches and unauthorised server access, smoking prevention at AVIT, and site access in Italy (page 105).

Other actions (page 106): Global Surveys on work-life balance "which yielded more than satisfactory results (8.1 out of 10)"; dissemination of the Global Gender Equity Policy; and the Workplace Health Promotion project at Travagliato, which "achieved the third level of certification". Effectiveness is monitored through training records and the Docebo, eLearning and Udemy platforms (page 105).

S1-4(was S1-5)Targets related to own workforce
Reported

Targets related to own workforce

Reference: pages 106-108 (index entry, page 46).

"In 2025, the Parent Company and FT System Italia achieved an initial predefined objective, namely obtaining the UNI/PdR 125 certification (with a focus on gender equality, reduction of gender or role gaps, and strengthening work-life balance policies)", framed as both a short-term objective (certification by 2025) and a long-term one (pages 106-107).

Globally the Group "intends to strengthen pay equity (including the reduction of any gender pay gaps) through a salary review and a common variable incentive policy" (page 107).

The Sustainability Plan, approved March 2026, adds numbered objectives each with a responsible function, action type and KPI target (page 108): PPE availability where not legally required; improved near-miss detection aligned to Crane NXT policy; a Safety Leader for each site; four work-life balance initiatives; tracking of overtime through the attendance system; "Gradual extension to the entire Group, starting from Italy in 2026, of the analysis on the Gender Pay Gap"; and cyber security strategy implementation.

"It is specified that these targets are not related to the Group's policies" (page 108).

S1-5(was S1-6)Characteristics of the undertaking's employees
Reported

Characteristics of employees

Reference: pages 108-110, with the country table also at page 28 (index entry, page 46).

Total employees at 31 December 2025: 1,146 (275 women, 871 men), unchanged in total from 2024 (269 women, 877 men) (page 108). Headcount is measured at the end of the reporting period (page 110).

Countries where the Group holds at least 10% of the workforce (page 109): Italy 609 (157 women, 452 men), USA 206 (41 / 165), India 185 (38 / 147). The full country table (page 110) also covers Hong Kong, Korea, Thailand, China, Ireland, Brazil, Serbia, Croatia, UK, Germany and France.

Contract type2025 total2024 total
Permanent1,1321,139
Fixed-term135
Full-time1,1191,120
Part-time2726

Turnover (page 109): 153 hires in 2025 (35 women, 118 men) against 142 in 2024, and 153 leavers (28 women, 125 men) against 306 in 2024. Turnover rates are given as positive 13% and negative 13%, net 0% (2024: 11% / 23%, net -12%).

Context is disclosed: "during 2025 the Irish site was closed and... some employees recorded in turnover between hires and terminations experienced redeployments among different Group Companies" (page 110). Data "were compiled by each Group Company with the support of the Parent Company's HR department" (page 109).

S1-6(was S1-7)Characteristics of non-employee workers
Reported

Characteristics of non-employee workers

Reference: page 110 (index entry, page 46).

A headcount table of non-employee workers in the own workforce is disclosed by category and gender (page 110). Total non-employee workers 2025: 257 (68 women, 189 men), against 218 in 2024 (41 women, 177 men).

By category, 2025 (2024 in brackets):

  • Agency workers 13 (9)
  • Interns 19 (9)
  • Coordinated and continuous collaborations (Co.co.co) 2 (2)
  • Self-employed workers and external consultants 27 (27)
  • FSE and Partner 109 (173)
  • Workers for activities related to personnel research, selection and supply 29 (-)
  • Other 64 (-)

The categories "seasonal workers" carries no figure. As with employees, "The number of employees and non-employees is based on a headcount and is reported as of the end of the reporting period" (page 110).

The SBM-3 narrative identifies who these workers are: alongside permanent full-time employees "there are also self-employed workers, mainly involved in scouting activities and supplier selection, external consultants, agency workers and interns" (page 96). No methodology note, no FTE conversion and no commentary on the year-on-year movement in the FSE and Partner category is provided.

S1-7(was S1-8)Collective bargaining coverage and social dialogue
Reported

Collective bargaining coverage and social dialogue

Reference: page 111 (index entry, page 46).

20252024
Total employees1,1461,146
Employees covered by collective bargaining agreements626690
% covered54.62%60.21%

The Group states that within the EEA these are "the collective bargaining agreements for the geographical areas that are significant for the Group", and that "No collective bargaining agreements are in place for geographical areas that are significant for the Group outside the EEA" (page 111).

Coverage fell by about 5.6 percentage points year on year; the report offers no explanation for the movement.

The topic is material: non-application or non-compliance with collective bargaining agreements is a potential negative impact in the DMA, scored 2.83, direct (page 35), and the S1 narrative describes the material negative impact as "limitations to collective bargaining and situations where the individual employment contract between employer and employee is less favourable than the collective agreement" (page 97). No social dialogue coverage percentage for the European Works Council or equivalent body is disclosed.

S1-8(was S1-9)Diversity metrics
Reported

Diversity metrics

Reference: pages 111-112 (index entry, page 46).

Top management is defined as "the first and second levels below the Board of Directors... composed of the CEO, the Global Management Team and the directors of the subsidiaries" (page 111).

Top management20252024
Women5 (21.7%)4 (18.2%)
Men18 (78.3%)18 (81.8%)
Total2322

By age, top management is 34.8% aged 30-50 and 65.2% over 50, with no one under 30 (page 111).

Employees by category and gender (page 111): managers 85 (15 women, 70 men), employees and middle management 923 (244 / 679), workers 138 (16 / 122). As percentages of total workforce: managers 7.4%, employees and middle management 80.5%, workers 12.0%; women are 24% of the workforce and men 76% (page 112).

By age (page 112): under 30 204 (17.8%), 30-50 757 (66.1%), over 50 185 (16.1%), against 232 / 725 / 189 in 2024.

The Board of Directors at 31 December 2025 comprised 11 members with 5 non-executive and independent directors (pages 9-10); board gender composition is not restated as a metric in this section.

The gender split of top management improved from 18.2% to 21.7% women, against the 2024 remuneration policy objective to "Increase the female manager component of the Group Management Committee... to 20", recorded as achieved (page 21).

S1-9(was S1-10)Adequate wages
Not Material
S1-10(was S1-11)Social protection
Not Material
S1-11(was S1-12)Persons with disabilities
Not Material
S1-12(was S1-13)Training and skills development metrics
Reported

Training and skills development metrics

Reference: pages 112-113 (index entry, page 46).

Performance reviews. Employees who received periodic performance reviews with a view to career development: 695 in 2025, 60.6% of the workforce (175 women / 63.6%, 520 men / 59.7%), against 704 and 61.4% in 2024 (180 women / 66.9%, 524 men / 59.7%) (pages 112-113).

Average training hours per employee (page 113): 2025 women 11, men 11, total 11; 2024 women 9, men 10, total 10. Category-level averages are printed with partly Italian column headings that do not extract cleanly, so they should be read from the source document rather than relied on here.

Training and skills development is material on three counts in the DMA (page 35): a potential negative impact from "Loss of workforce knowledge and reduced employability" (2.5); an actual positive impact from "training and skills-strengthening programmes, including through collaboration with universities, laboratories and external organisations" (3.5); and a productivity risk "arising from insufficient technical and professional competencies among employees in key positions, especially within newly acquired subsidiaries" (2.83).

S1-13(was S1-14)Health and safety metrics
Reported

Health and safety metrics

Reference: pages 113-114 (index entry, page 46).

Employees20252024
Total recorded injuries22
Commuting accidents13
Total hours worked2,039,5432,236,421
Days of absence due to injuries2328
Injury rate (per 1,000,000 hours worked)0.9810.894

The table's "fatal injuries" and "serious injuries" lines carry no figures in the source document; only the total recorded injuries line is populated (page 113).

"% of employees covered by the occupational health and safety management system: 100%" (page 114).

The rate rose year on year because hours worked fell by about 8.8% while the injury count was unchanged.

Health and safety is material on both sides of the DMA: for the own workforce as a risk "associated with the outbreak of new pandemics, potentially leading to lockdowns at the Company's sites" (2.17, page 35), and for value chain workers as a potential negative impact on "workers in the value chain (e.g. accidents, injuries, etc.) involved in the production and manufacturing of hardware components outsourced by the Group" (2.67, indirect, page 36). Two worker categories are named as higher risk: "operators working in assembly plants and employees who undertake a high number of business trips" (page 98). The Parent Company's sites hold ISO 45001 certification (page 100).

S1-14(was S1-15)Work-life balance metrics
Reported

Work-life balance metrics

Reference: page 114 (index entry, page 46).

Family leave20252024
Employees eligible for family leave1,135 (275 W / 860 M)1,134 (269 W / 865 M)
Employees who took family leave49 (21 W / 28 M)67 (31 W / 36 M)
Days taken2,241 (2,060 W / 181 M)3,514 (3,155 W / 359 M)
Share of eligible employees taking leave4.3% (7.6% W / 3.3% M)5.9% (11.5% W / 4.1% M)
Percentage of employees eligible for parental leave99% (100% W / 99% M)98.9% (100% W / 98.6% M)

Take-up fell year on year for both women and men, and the days taken fell by more than a third; no explanation is offered.

Work-life balance is a material S1 sub-topic, recorded in the DMA as an actual negative impact - "Negative impacts on the own workforce generated by an imbalance between work and private life", score 3, direct (page 35). Actions against it are described under S1-4: vacation planning reorganisation, work-related stress analyses run by the RLS and HR, and Global Surveys on work-life balance policies which "yielded more than satisfactory results (8.1 out of 10)" (pages 105-106). Four work-life balance initiatives are set as Sustainability Plan targets - smartworking regulation, flexible working hours and the parental care policy among them (page 108).

S1-15(was S1-16)Compensation metrics (pay gap and total compensation)
Reported

Compensation metrics (pay gap and total compensation)

Reference: page 114 (index entry, page 46).

Gender pay gap. Average gross hourly wage 2025: women EUR 23.96, men EUR 29.58, a gap of 19% (2024: EUR 21.97 and EUR 25.70, a gap of 15%). Hours worked were 464,739 for women and 1,578,280 for men; total base remuneration was EUR 11,134,420 for women and EUR 46,680,114 for men (page 114).

The gap widened by four percentage points year on year. No explanation is given.

Total remuneration ratio (page 114):

20252024
Highest-paid individualEUR 385,000EUR 374,169
Median employee (excluding the highest-paid)EUR 39,307EUR 42,711
Annual remuneration ratio979.5%876.1%

The ratio rose because the highest-paid individual's remuneration increased about 2.9% while the median fell about 8.0%.

Under S1-5 the Group states an intent to "strengthen pay equity (including the reduction of any gender pay gaps) through a salary review and a common variable incentive policy" (page 107), and where reports of gender pay disparities arise "an independent pay equity analysis is initiated, with any resulting salary adjustments" (page 103).

S1-16(was S1-17)Incidents, complaints and severe human rights impacts
Reported

Incidents, complaints and severe human rights impacts

Reference: page 115 (index entry, page 46).

"In 2025, no incidents or complaints related to the respect of human rights occurred within the own workforce" (page 115).

The Group discloses that the position follows a prior-year event: "following an event that occurred in March 2024, Antares Vision decided to accelerate and strengthen" three things (page 115):

  • "the review, update and dissemination of the Human Rights, Diversity, Equity and Inclusion Policies and the Code of Ethics, in order to reinforce the principles, rules and values in force within the Company on these matters"
  • "the use of the (new) internal corporate communication platform (OneVision), both to ensure visibility and accessibility of the aforementioned documents and to more effectively promote a culture of inclusion"
  • "the acceleration of the process to obtain the UNI/PdR 125 Gender Equality Certification, identified as a tool to foster continuous improvement in inclusion within the working environment"

The nature of the March 2024 event is not described, and no fines, penalties or compensation amounts are disclosed. No number of severe human rights incidents connected to the own workforce is given for the comparative year.

S2 – Workers in the Value Chain

S2-1Policies related to value chain workers
Reported

Policies related to value chain workers

Reference: pages 118-119, with SBM-2 context at pages 115-116 (index entry, page 46).

The Group applies its Code of Ethics, Human Rights Policy and Diversity, Equity and Inclusion Policy, managed by the Parent Company's HR department with support from Legal, which "internally also address matters relating to suppliers' activities, without exclusions" (page 118).

New in the reporting year: "in December 2025 the Group developed a Supplier Code of Conduct, which establishes the principles underpinning relationships with its suppliers. Through this Code, the Group intends to ensure that its suppliers adhere to and respect the same values with regard to workers' health and safety, environmental protection, respect for human rights, gender equality, as well as transparency and fairness in business management" (page 118).

The Human Rights Policy binds "Each Stakeholder - employees, collaborators, suppliers of goods and services, and anyone who has a business relationship with Antares Vision Group... especially in high-risk and conflict-affected contexts", and is aligned to the International Bill of Human Rights, ILO conventions 29, 87, 98, 100, 105, 111, 138 and 182, the UN Convention on the Rights of the Child, ILO Conventions 107 and 169, and the ECHR (page 119).

A gap is disclosed: "There are no specific policies for suppliers that explicitly address human trafficking, forced, compulsory or child labor" (page 119).

S2-2Processes for engaging with value chain workers about impacts
Reported

Engaging value chain workers about impacts

Reference: page 119 (index entry, page 47).

"Value chain workers have not, as of today, been involved with regard to the impacts that concern them" (page 119).

That is the whole of the disclosure. No engagement process, no responsible function, no frequency and no stage in the process at which engagement occurs is described, and the Group does not state whether it intends to introduce one.

The context is set out under SBM-3: the workers who could be subject to material impacts are identified as workers of social cooperatives performing cleaning and simple manual tasks at the Company's premises; workers employed by third parties producing components for equipment and machinery; and downstream logistics workers, distributors, affiliates and retail resellers (pages 116-117). Areas of Asia and the Pacific (India and China) and Latin America (Brazil) "may be more sensitive to risks of forced labor and child labor" according to UNICEF data cited by the Group (page 117).

What is described instead is supplier-level information gathering rather than worker engagement: two ESG questionnaires introduced in 2024, differentiated between Goods and Services, collected information from hundreds of suppliers "covering more than 80% of Antares Vision Group's total revenue" (page 116).

S2-2(was S2-3)Processes to remediate negative impacts and channels for value chain workers to raise concerns
Reported

Remediation and channels for value chain workers

Reference: page 119 (index entry, page 47).

"In addition to the Whistleblowing channel, which is available to all and easily accessible from the homepage of the Antares Vision Group website... there is currently no specific mechanism in place for collecting communications from value chain workers" (page 119).

"The control and monitoring of issues raised and addressed by value chain workers through the Whistleblowing channel are carried out in accordance with the applicable procedure" (page 119).

The Whistleblowing channel itself is described under S1-3 and G1-1: reports go to an external lawyer acting as Chair of the Supervisory Body, are handled "by a qualified and independent third party, in compliance with current legislation", and the Group guarantees confidentiality of the reporter's identity, prohibits retaliation and provides sanctions for those who breach the whistleblower protection measures (pages 103, 135). The Human Rights Policy applies to suppliers of goods and services and "anyone who has a business relationship with Antares Vision Group, regardless of the legal nature of the relationship" (page 99).

No count of reports received from value chain workers is disclosed, and no assessment of whether those workers are aware of or trust the channel is provided.

S2-3(was S2-4)Taking action on material impacts on value chain workers
Reported

Taking action on material impacts on value chain workers

Reference: page 120 (index entry, page 47).

"In 2025, Antares Vision Group analyzed the two questionnaires introduced in 2024, differentiated between Goods and Services, with a specific focus on ESG criteria aimed at monitoring suppliers' actions. The data collected were archived and integrated into supply chain management processes, thereby further strengthening the Group's commitment to the responsible management of its supply chain" (page 120).

G1-2 adds the detail: the questionnaires collected "information, qualifications and certifications from hundreds of suppliers, with a coverage of more than 80% of the total spend", and "In 2025, the responses received were analysed and the ESG ratings were evaluated and put into categories according to the size of the company (Small <50 employees - Medium 51-250 employees - Large >250 employees)" (page 138).

"In the coming years, the Group plans to enhance the quality of its procedures in order to improve monitoring of compliance with applicable laws and regulations relating to the supply chain workforce" (page 120).

No supplier audits, corrective action plans, remediation of identified harms or resources are disclosed, and no measure of effectiveness is given. The impact addressed is the potential negative impact on health and safety of value chain workers producing outsourced hardware components (2.67, indirect, page 36).

S2-4(was S2-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Reported

Targets related to value chain workers

Reference: page 120 (index entry, page 47).

"During 2025, Antares Vision Group prepared a Sustainability Plan, approved in March 2026, which includes targets related to workers in the value chain. For the definition of these targets, the Parent Company involved and identified the responsible functions for each area addressed, which will also be responsible for monitoring and achieving the targets themselves" (page 120).

Two target areas are named: "The objectives pursued are aimed at safeguarding confidentiality and the protection of data of value chain workers and at launching a program for their assessment based on ESG criteria, thereby implementing the sustainability of the supply chain, both from an environmental and a social perspective" (page 120).

"It is specified that the targets set are not related to the Group's policies" (page 120).

No metric, baseline, target value or deadline is disclosed for either objective, and value chain workers were not involved in setting them. The Group-level MDR-T caveat applies: the strategic objectives are "not based on reliable scientific data and not measurable or results-oriented", and "not all objectives have associated measurable metrics to date, as feasibility studies and evaluations are still underway" (page 58).

S3 – Affected Communities

S3-1Policies related to affected communities
Reported

Policies related to affected communities

Reference: page 122, with strategy context at pages 120-122 (index entry, page 47).

"As no material negative impacts or risks have been identified, the Group does not currently have specific policies in place with regard to affected communities. However, the policies adopted by the Group in the areas of Human Rights, together with the Code of Ethics, also refer to affected communities that may be potentially impacted by the Group's activities, without distinction" (page 122).

The scoping is disclosed: affected communities "are not represented by groups of people located in specific geographical areas (e.g., no reference is made to indigenous peoples or local communities adjacent to the Group's plants and offices), but rather by groups of consumers who can benefit from the informational assets made available by Antares Vision's customers through the machines and software provided by the Group during their product labeling activities" (page 121).

Negative impacts were assessed and excluded: because the properties are mainly offices and assembly centres, "from the perspective of atmospheric pollutant emissions, noise, improper water use or discharges, there are no material negative impacts on the communities surrounding these sites" (page 121).

The material S3 impacts are therefore positive only, running through the Food and Beverage and Supply Chain Transparency business areas (pages 121-122).

S3-2Processes for engaging with affected communities about impacts
Reported

Engaging affected communities about impacts

Reference: page 123 (index entry, page 47).

"As of today, no direct process has been carried out to engage affected communities with respect to the impacts affecting them" (page 123).

The Group then lists the indirect channels that exist: "the Group organizes meetings and exchanges of communications for specific requirements or requests, also through ordinary communication channels, audits and verifications, and maintains correspondence with Public Authorities and institutions. Initiatives aimed at support and dialogue, relationships and corporate social responsibility (CSR), social commitments and the enhancement of cultural heritage, as well as Community Events with local communities, the local area and associations, are also encouraged" (page 123).

"The Group commits to evaluating potential engagement of affected communities over the medium to long term" (page 123).

Neither the function with operational responsibility nor a frequency is stated. The same position is recorded elsewhere: "Affected communities were not directly involved in the analysis of impacts, risks and opportunities related to resource use and the circular economy" (page 88), and they were not consulted on air pollution either (page 87).

S3-2(was S3-3)Processes to remediate negative impacts and channels for affected communities to raise concerns
Not Material
S3-3(was S3-4)Taking action on material impacts on affected communities
Reported

Taking action on material impacts on affected communities

Reference: page 123 (index entry, page 47).

"The impacts identified on affected communities are positive, both actual and potential, with a variable time horizon. It was therefore not necessary to develop an action plan for the management of negative impacts and risks. The prevention of potential negative impacts is integrated into ordinary processes, Group policies and ESG governance safeguards, supported by existing organizational resources" (page 123).

Three positive-impact activities are described (page 123): Food and Beverage projects that "contribute to the development of sustainable food systems and to the generation of positive impacts and new opportunities for operators in the food value chain"; "the promotion of innovation and digitalization through an open network involving Universities, Research Centers and start-ups"; and donations and sponsorships that "benefit affected communities and the organizations involved".

Beneficiaries are named at page 122, including Università Cattolica di Brescia, Università di Brescia, Fondazione Brescia Musei, AISM, Telethon and Fondazione Cesar onlus; these were assessed and found not material in the DMA.

"As of today, no practices are in place for monitoring activities and initiatives relating to affected communities", and "No serious human rights issues or incidents have emerged in relation to affected communities" (page 124).

S3-4(was S3-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Reported

Targets related to affected communities

Reference: page 124 (index entry, page 47).

"During 2025, the Parent Company prepared a Sustainability Plan, approved in March 2026, which includes actions and targets aimed at enhancing the Group's positive impacts on affected communities. For the definition of these targets, the Parent Company involved and identified the responsible functions for each area addressed, which will also be responsible for monitoring and achieving the targets themselves" (page 124).

"It is specified that the targets set are not related to the Group's policies" (page 124).

No metric, baseline, target value or deadline is disclosed, and affected communities were not involved in setting the targets - consistent with the statement under S3-2 that no direct engagement process has been carried out (page 123).

One community-facing objective does appear in the 2025 ESG-LTI scorecard, under S3 "Economic, social and cultural rights of communities": sub-objective S3.A2, "Access to quality information" (page 23). The Group-level MDR-T caveat applies: the strategic objectives are described as "not based on reliable scientific data and not measurable or results-oriented", and "not all objectives have associated measurable metrics to date, as feasibility studies and evaluations are still underway" (page 58).

S4 – Consumers and End-users

S4-1Policies related to consumers and end-users
Reported

Policies related to consumers and end-users

Reference: page 126 (index entry, page 47).

"Since 2023, Antares Vision Group has adopted a Human Rights Policy... The application of this Policy also benefits Antares Vision Group's clients and end users, ensuring that the principles of respect and protection of human rights are applied throughout the entire value chain. As of today, the Group does not have a specific policy dedicated to consumers and end users" (page 126).

The Group frames its obligations through legislation rather than its own policy: "Consumers' right to receive clear and complete information on products is established in Italy by the Consumer Code (Legislative Decree of September 6, 2005, No. 206) and in other countries by similar local regulations... Antares Vision supports manufacturers in fulfilling the obligation to place safe products on the market and to provide all useful information to assess and prevent risks associated with the normal or reasonably foreseeable use of the product" (page 126).

Related commitments sit elsewhere: the Information Security Management System Policy, drafted in accordance with the GDPR, the Privacy Code, Legislative Decree 138/2024 implementing NIS2, the AI Act Regulation (EU) 2024/1689 and Law 132 of 23 September 2025 (pages 53-54), and monitoring of marketing communications "in accordance with principles of ethics and integrity" (page 128).

S4-2Processes for engaging with consumers and end-users about impacts
Reported

Engaging consumers and end-users about impacts

Reference: page 126 (index entry, page 47).

"As of today, no specific actions have been carried out with regard to engagement with consumers and/or end users, nor have measures been adopted to provide and/or remedy impacts on human rights. The company acknowledges the importance of such actions and plans to develop appropriate processes in the future to address these issues in a more structured manner. Accordingly, no direct involvement of consumers and end users or their legitimate representatives or trusted delegates has been envisaged" (page 126).

That is the whole of the disclosure. No process, responsible function, frequency or stage of engagement is described.

The scope of who would be engaged is set out under SBM-3: consumers and end users of products "that are intrinsically harmful to people and/or increase the risks of chronic diseases", of services affecting rights to privacy, data protection, freedom of expression and non-discrimination, and those "who require accurate and accessible information on products or services, such as product manuals and labels" (page 125). Vulnerability is acknowledged: "certain categories of consumers and end users may be more exposed to risks... particularly in the pharmaceutical, food and cosmetic sectors" (page 125).

Under S4-5 the Group confirms the Sustainability Plan objectives were set "without the direct involvement of consumers and end users" (page 129).

S4-2(was S4-3)Processes to remediate negative impacts and channels for consumers and end-users to raise concerns
Reported

Remediation and channels for consumers and end-users

Reference: pages 126-127 (index entry, page 47).

Two channels are described. A dedicated mailbox is available on the Antares Vision Group website contacts page (pages 126-127). For direct customers, "a complaint collection system is also in place: a ticketing system managed by the Service department. This system is supported through the execution of contracts with customers that specify response times and procedures for tickets. The Group ensures the availability of contact and support channels through its commercial relationships with customers, providing for specific technical support and assistance mechanisms in supply and service contracts" (page 127).

"In addition, the ticketing system enables traceability of reports, management of corrective actions, and monitoring of response and resolution times. Through this system, analyses and trends can be extracted in order to monitor received reports and the time elapsed between receipt and implementation of corrective actions" (page 127).

Under S4-4 the Group adds a "Group-level data collection system relating to the number of complaints involving compensation claims and the related amounts" (page 128).

The channels reach the Group's customers rather than end consumers directly; no complaint volumes are reported, and no assessment of end-user awareness or trust is provided.

S4-3(was S4-4)Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions
Reported

Taking action on material impacts on consumers and end-users

Reference: pages 127-128 (index entry, page 47).

"The Group has not adopted a specific action and resource plan to manage its material impacts on consumers and end users." It lists instead "highly selective internal validation and quality control processes and the execution of specific insurance policies" (page 127).

Described activities: quality controls and validation of solutions, information security safeguards, and "a structured technical assistance and customer care service designed to intervene promptly in the event of malfunctions or critical issues" (page 127). Remote assistance is measured on "an objective service with measurable milestones, such as First Response Time, Resolution Time, SLA KPIs... monitored through dedicated dashboards", and on quality perceived by the customer (page 128).

Three 2024 actions continued in 2025 (page 128): the Group-level complaints and compensation data collection system; "the creation of a system for identifying and measuring the social and environmental impacts of products offered by Antares Vision (Pharma)"; and "the definition of a Policy and ongoing monitoring of marketing communications in accordance with principles of ethics and integrity".

Planned: products "capable of detecting micro-holes in packaging" and "contaminant control systems in the agri-food sector through the use of microwave technologies" (page 128). No resources are quantified.

S4-4(was S4-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Reported

Targets related to consumers and end-users

Reference: pages 128-130 (index entry, page 47).

The Board and top management "identified a development plan based on three strategic pillars: selectively leveraging market opportunities also through internal reorganization; increasing margins and cost discipline; and unlocking cash generation" (page 128). Supply Chain Transparency goals coincide with the industrial plan (pages 128-129).

"The metrics necessary for monitoring the goals largely coincide with the economic and financial KPIs envisaged by the industrial plan... over the 2024-2026 period, Antares Vision Group expects consolidated revenues on a like-for-like perimeter basis... to grow at an average rate (CAGR) of +4% to +6%" (page 129).

"With reference to consumers and/or end users, as of today there are no specific goals in place; rather, there are goals related to product development which, when implemented in production lines for pharmaceuticals, beverages and food, may have a positive impact on this category of stakeholders" (page 129).

The Sustainability Plan approved in March 2026 sets goals "to strengthen data security and confidentiality for customers and to improve the quality and safety of the products offered", defined "without the direct involvement of consumers and end users" (page 129). "It is specified that the targets set are not related to the Group's policies" (page 130).

G1 – Business Conduct

G1-1Business conduct policies and corporate culture
Reported

Business conduct policies and corporate culture

Reference: pages 132-143 (index entry, page 47).

The Code of Ethics and Conduct "applies to the Parent Company and all Group Companies" and "strengthens and integrates the policies already in place at Group level", which are then listed as the Human Rights Policy, the Diversity, Equity and Inclusion Policy, the Gender Equity Policy and the Anti-Corruption Policy (pages 132-133). It sanctions conduct departing from the Code "even in the event that such behaviour was carried out... in the belief that it would bring an advantage to the Company" (pages 142-143).

The Anti-Corruption Policy was approved by the Board on 31 January 2023 and binds corporate bodies, employees, suppliers and consultants (page 134).

Whistleblowing follows Legislative Decree 24/2023 implementing EU Directive 2019/1937; reports "are handled by a qualified and independent third party", with confidentiality and a prohibition on retaliation (page 135).

Model 231 under Legislative Decree 231/2001 maps sensitive processes and controls in a General Part and carries the sanctioning system in a Special Part, overseen by a Supervisory Body (pages 141-142).

Training: videoconference updates with external legal advisers and a final test for top managers, and DOCEBO LMS courses with tests for all employees. In 2025 the Group "developed courses on the Code of Ethics and Whistleblowing" (pages 136-137).

G1-2Management of relationships with suppliers
Reported

Management of relationships with suppliers

Reference: pages 137-138 (index entry, page 47).

Payment management: "management analyses the supplier schedule weekly together with the payment manager, subsequently involving the CEO, to determine the order of suppliers to be paid". Payments are concentrated on the 10th and 20th of the month, which "means that there may be 'physiological' delays in payments but, also on notification from the purchasing office, it tries to give priority to artisans or small companies that are known to be the most vulnerable" (page 138).

Scale: during 2025 the Group "worked with more than 1,500 suppliers", and "To reduce the risk of dependence on a single supplier... adopts the policy of using at least two suppliers for each type of product" (page 138).

ESG screening: two questionnaires introduced in 2024, one for Materials and one for Services, "allowed us to collect information, qualifications and certifications from hundreds of suppliers, with a coverage of more than 80% of the total spend". In 2025 "the responses received were analysed and the ESG ratings were evaluated and put into categories according to the size of the company (Small <50 employees - Medium 51-250 employees - Large >250 employees)". "The work was completed, but this is only the start of the process" (page 138).

A Supplier Code of Conduct was developed in December 2025 (page 118). No supplier audit programme is disclosed.

G1-2(was G1-3)Prevention and detection of corruption and bribery
Reported

Prevention and detection of corruption and bribery

Reference: pages 138-143, with the policy at pages 134-135 (index entry, page 47).

"The management of the various companies of the Group, supported by the legal office and the quality function of the parent company, have the task of implementing actions to prevent and mitigate corruption risks... Any investigative activities, both preventive and related to the need to verify reported events, are carried out by independent functions, such as the Internal Audit function" (page 138).

Both Antares Vision S.p.A. and FT System S.r.l. have their own Supervisory Body; the Parent Company's is chaired by Francesco Menini (page 139). Internal Audit's anti-corruption mandate covers control effectiveness, corruption risk management and compliance support, and "The legal entities belonging to the Group are included in the plan according to a rotating coverage criterion" (page 139).

Reporting route: where corruption is suspected or confirmed, the Supervisory Body or Internal Audit reports to the Board on the event, evidence, impact and suggested measures, then monitors implementation (page 140).

Risk areas: relations with public authorities; third parties; gifts and hospitality; contributions to political parties and trade unions; human resources; and accounting, with exposed functions listed (page 137).

Training was built by Audirevi's lawyers from 2023 and delivered Group-wide through Docebo (page 140).

G1-3(part of MDR-T/GDR-T disclosures)Targets related to business conduct
Reported

Targets related to business conduct

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

Antares Vision does set business conduct targets, through the ESG-LTI scorecard. Under the GOVERNANCE area of the 2025 scorecard, ESRS G1 Business conduct carries two groups (page 23):

  • G1.A Active and passive corruption - sub-objective G1.A1 "Prevention and repression of corruption"
  • G1.B Business conduct - sub-objectives G1.B1 "Certifications, Standards of Sustainability (policy)", G1.B.2 "Supplier relationship management", G1.B.3 "Economic performance"

The LTI Plan approved on 7 May 2025 weights performance 90% financial and 10% ESG, and "The ESG objective is to achieve at least 85% of the objectives of the ESG - LTI scorecard" (page 22). The 2024 equivalent target is reported as achieved (page 21).

MDR-T adds the caveats (page 58): the Sustainability Plan was "formally approved by the Board of Directors on 17 March 2026", but the strategic objectives are "not based on reliable scientific data and not measurable or results-oriented".

Effectiveness is also tracked through annually updated anti-corruption training with tests, the rotating Internal Audit plan, and Supervisory Body monitoring of corrective actions (pages 139-140).

G1-4Incidents of corruption or bribery
Reported

Incidents of corruption or bribery

Reference: page 143 (index entry, page 48).

"During 2025, no cases of active and/or passive corruption occurred in any of the Group Companies" (page 143).

The Group sets out the preventive framework in the same paragraph: "To prevent cases of corruption or bribery... Antares Visions Group has in place the Anti-corruption Policy and the Donations and Sponsorships Policy, as well as the Organizational, Management and Control model pursuant to Legislative Decree 231/01 and underlines these values in its code of ethics" (page 143).

No convictions, no fines, no confirmed incidents involving business partners, and no dismissals or disciplinary actions arising from corruption are reported, consistent with a nil return. No comparative figure for the prior year is given in this section.

The report separately records that in 2025 "no incidents or complaints related to the respect of human rights occurred within the own workforce" (page 115), and that "There were no cases of legal proceedings due to payment delays in 2025" (page 144).

G1-5Political influence and lobbying activities
Not Material
G1-6Payment practices
Reported

Payment practices

Reference: page 144 (index entry, page 48).

"Based on current practice, all invoices from non-group suppliers are paid within 30 days of the due date, while for single-member companies, small businesses or artisans, the deadlines are usually met within 10-20 days of the due date, paying greater attention to the needs of small businesses. Payments are made 'spontaneously' without waiting for a reminder from the supplier" (page 144).

"The Group's average payment days indicator is 90 days in 2025. There were no cases of legal proceedings due to payment delays in 2025" (page 144).

No comparative figure for 2024 is given for the average payment days indicator, and the report does not reconcile the 90-day average with the stated practice of settling non-group invoices within 30 days of the due date. No percentage of payments aligned with standard payment terms and no breakdown by supplier size is disclosed.

The related G1-2 disclosure explains the operational mechanism: the supplier schedule is reviewed weekly with the payment manager and the CEO, payments are concentrated on the 10th and 20th of the month, which "means that there may be 'physiological' delays in payments", and priority is given "to artisans or small companies that are known to be the most vulnerable" (page 138).