Antibiotice

Governance roles

Reference: pages 42-49 (Annex 2 index, page 284).

Two bodies: a Board of Directors of 7 members (1 executive, 6 non-executive, of whom 4 independent, 57.14%) and a Management Team of 10 (the General Manager plus 9 executive directors). All are Romanian nationals aged 33 to 66 (page 42).

Gender diversity (page 45): Board 4 men (57.1%) / 3 women (42.9%), ratio 0.75; Management Team 4 men (40%) / 6 women (60%), ratio 1.5.

Employee representation: "Antibiotice does not have direct representation of employees or other workers on the Board of Directors or in other supervisory bodies", governance being set by GEO no. 109/2011 on public enterprises; involvement runs instead through the Antibiotice Free Trade Union and the Collective Labour Agreement (page 45).

Responsibility (page 46): the Board approves strategic sustainability objectives and oversees progress, supported by a Risk Management Committee at Board level. The Quality Director coordinates the Sustainability Working Team (established 2022, reorganised in 2025 from the "G4 Sustainability Working Group"); the Environment Director oversees environmental compliance, the Legal Director regulatory risk and the Finance Director the financial impact of ESG initiatives.

Expertise is described at pages 48-49; in 2025 a 24-participant ESRS workshop was run, plus 155 participations on the Sustainability School platform (231 hours).

Information provided to the administrative, management and supervisory bodies

Reference: pages 49-50 (Annex 2 index, page 284).

Reporting flows upward from named functions: the Environmental Protection Department reports emissions, waste and environmental compliance; Human Resources reports diversity, inclusion and occupational health and safety; the Risk Management Department reports significant non-financial and emerging risks; Finance monitors the financial impact of sustainability initiatives. The Sustainability Working Group consolidates the data before it reaches the governing bodies (page 49).

Frequency (page 49): "each department reports quarterly to the Sustainability Working Team on the results and effectiveness of its own policies, while in the event of major risks, significant deficiencies or important regulatory changes, ad hoc briefings are issued". Sustainability topics are addressed monthly in Board and Executive Committee meetings "whenever necessary".

At strategic level the Board and executive management review how impacts on public health, the environment and employees, and operational, compliance and financial risks, may influence the company's direction; these analyses feed approval of the medium- and long-term strategy (page 50). For major transactions the governing bodies weigh "tradeoffs between short term investment costs and long-term benefits" (page 50).

Sustainability performance in incentive schemes

Reference: pages 47-48, 50-51, 129 (Annex 2 index lists GOV-3 and E1.GOV-3 at page 50).

Remuneration is governed by GEO no. 109/2011, GD no. 639/2023 and Order no. 651/2024, which require non-financial indicators in administrators' mandate contracts (page 50). Indicators for the 2025-2029 mandate were approved by the General Meeting of Shareholders in December 2025 and by AMEPIP (page 47).

Non-executive administrators (page 47): sustainability KPIs carry 40% - direct GHG emissions down 2.49% per year (10%), supplier adherence to the Partner Code of Conduct (5%), employee safety system (5%), four safety trainings per year (10%), customer retention (10%). They are paid a fixed allowance only: "There is no variable component of remuneration directly linked to the achievement of sustainability indicators."

General Manager (page 48): sustainability KPIs carry 50% - energy consumption reduction (5%), water consumption intensity down 1% per year (5%), risk management policies (10%), training hours per employee (5%), customer satisfaction at least 80% (10%), sales from new products (10%), Board attendance (5%). The variable component is paid only if overall KPI achievement reaches 85%.

Statement on due diligence

Reference: page 52 (Annex 2 index, page 284).

The statement is given as a mapping table of the five core due diligence elements to page ranges in the sustainability statement (page 52):

Annex 3 marks the GOV-4 statement-on-due-diligence datapoint (paragraph 30; SFDR indicator number 10, Table #3 of Annex 1) as Material, page 52 (page 288).

Risk management and internal controls over sustainability reporting

Reference: pages 52-53 (Annex 2 index, page 284).

The internal control framework rests on an internal procedure established in 2024 defining responsibilities for collecting, verifying and validating ESG data and the documentation needed for traceability by material topic. In 2025 the procedure "was updated to reflect organizational changes resulting from the reorganization of the G4 Sustainability Working Group into the Sustainability Working Team... No other internal controls were defined or modified during the year" (page 52).

Risk assessment follows the system procedure Risk Management, prioritising by likelihood correlated with potential impact, applied consistently "regardless of their nature, financial, operational or sustainability related". Oversight sits with the Risk Management Committee at Board level (pages 52-53).

Main reporting risks (page 53): the complexity of consolidating data from multiple sources; consistency and availability within the reporting timeline; and "the limited availability of data from the upstream value chain. Suppliers, particularly those outside the European Union, may have underdeveloped reporting processes, which limits the accuracy of estimates".

Strategy, business model and value chain

Reference: pages 53-60 (Annex 2 index, page 284).

Antibiotice is an integrated manufacturer of generic medicines headquartered in Iasi, Romania. The portfolio has three directions: anti-infective medicines (the historical core), topical products (dermatological, ophthalmic, vascular) and treatments for chronic diseases (cardiovascular) (page 54). It is "the leading manufacturer of first line anti tuberculosis medicines in Romania" and is WHO-prequalified (page 54).

Headcount and revenue (pages 55-56): 1,356 employees at 31 December 2025 (2024: 1,357). Total revenues RON 685,826,946, operating revenues RON 669,274,430, net turnover RON 645,275,929 (2024: RON 675,010,971).

Products reach over 360 Romanian public hospitals and over 30 international territories, with offices in Moldova and Vietnam (pages 54-55).

Value chain (pages 57-60): upstream covers API, excipient, packaging and solvent suppliers inside and outside the EU including Asia, equipment mainly from the EU, plus in-licensing, with a supplier-category table giving the verification process for each. Downstream runs through 6 joint distribution partnerships plus 4 dedicated veterinary partnerships nationally, and importer/distributor models internationally including WHO-subsidised territories (Iraq, Yemen, Kosovo, Ukraine).

Interests and views of stakeholders

Reference: pages 61-68 (Annex 2 index lists SBM-2, S1.SBM-2, S3.SBM-2 and S4.SBM-2 all at page 61).

Stakeholders are split into affected stakeholders and users of sustainability reports. The affected group is enumerated as patients and consumers, employees and employee representatives, internal suppliers, external suppliers, distributors, doctors and hospitals, each with the interest connecting them to the company (page 61).

Engagement in 2025 widened in three directions (page 108):

• Employees - a questionnaire on ESRS S1 topics distributed through internal channels; the organizational climate survey ran 5-20 March 2025.
• Distributors - new for 2025, "a dedicated questionnaire addressed to commercial partners. The feedback received was analyzed by the commercial team and integrated into the reassessment of IROs relevant to customer and market relationships."
• Local communities - feedback from the "Open Doors Day" event in June 2025, "attended by approximately 250 participants", plus a questionnaire for the broader local community.

Other categories "were continuously engaged through permanently available communication channels, with the feedback received being analyzed during the context understanding phase" (page 108).

Material impacts, risks and opportunities

Reference: pages 69-105 (Annex 2 index, page 284).

Material IROs are set out in three sequential tables covering impacts (pages 71-89), risks (pages 90-95) and opportunities (pages 95-105), each row giving topic and sub-topic, description, nature of impact (negative/positive, actual/potential) or magnitude of financial effects, location in the value chain, time horizon and the link to strategy.

Financial effects (page 70): the main risks are "increasing costs of compliance with environmental regulations, fluctuations in the prices of raw materials and essential resources, and supply chain vulnerabilities". The company states that "The assessment did not include a precise quantification of the financial impact on financial position, performance and cash flows, and therefore no significant adjustments to the carrying values of assets and liabilities are expected during the reporting period."

Strategic responses (pages 69-71): the first formal ESG supplier assessment (September 2025, top 80% of procurement); the Code of Conduct for Partners; a EUR 75 million financing agreement signed November 2025 for the "INOVA a+ research and development center and production of critical medicines" (2025-2029); and a 2025 SBTi commitment.

Ratings disclosed: Sustainalytics 17.7 (Low Risk) and EcoVadis 72 (pages 69-70).

Process to identify and assess material IROs

Reference: pages 105-118 (Annex 2 index lists IRO-1 and each topical X.IRO-1 at page 105).

This is the second year of ESRS reporting. "The core methodology, including the assessment scales and materiality thresholds, remained unchanged from the previous year, ensuring comparability of results. The reassessment was carried out by the Sustainability Working Team, with the involvement of relevant specialists from each department" (page 105).

Steps (pages 107-108): (a) mapping of value chain hotspots, informed for the first time by an ESG supplier assessment covering the top 80% of procurement - "over 42% of suppliers are classified as low risk, while approximately one third present areas for improvement... The average total ESG score was 3.06 out of 5"; (b) mapping of business model dependencies, environmental and social; (c) identification of IROs from the established list, testing triggers such as Law no. 124/2025 (NIS2) and Regulation EU 2025/2083 (CBAM); (d) affected stakeholder consultation.

Thresholds (page 118): "impacts are considered material if they achieve a score higher than 8, while risks and opportunities are considered material if they achieve a score of 9 or higher. If at least one impact, risk or opportunity associated with a topic exceeded the materiality threshold, the entire topic was classified as material."

Disclosure requirements covered

Reference: page 118 and Annex 2, pages 284-287; Annex 3 (datapoints from other EU legislation), pages 288-294.

The report prints a genuine ESRS content index. Annex 2 "presents the disclosure requirements under ESRS 2 and the nine topic standards relevant to Antibiotice, indicating where information related to each specific requirement can be found" (page 284), listing each DR code, its title and a page number.

Covered: BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2; E1-1 to E1-8; E2-1 to E2-6; E3-1 to E3-4; E5-1 to E5-5; S1-1 to S1-6, S1-9, S1-10, S1-12 to S1-17; S3-1 to S3-5; S4-1 to S4-5; G1-1 to G1-4; plus a "SPECIFIC TOPICS" block for clinical studies (211), research and development (217), access to medicines (224), counterfeit medicines and parallel trade (229), preventing drug abuse (234) and cybersecurity (249).

Not listed: E1-9, E3-5, E5-6, S1-7, S1-8, S1-11, G1-5, G1-6, and the whole of E4 and S2. Annex 3 marks the four E1-9 datapoints as "Phase-in" (page 290) and the E4 and S2 datapoints as "Not material" (pages 291-293).

Materiality changed versus FY2024: "Value chain workers and Biodiversity and ecosystems were excluded following reassessment based on updated data obtained from the supplier ESG evaluation process. At the same time, Cybersecurity was identified as a new material topic" (page 118).

Transition plan for climate change mitigation

Reference: pages 129-130 (Annex 2 index, page 284); Annex 3 marks the E1-1 paragraph 14 datapoint Material at page 129.

Antibiotice has no transition plan. "As of the reporting date, Antibiotice S.A. does not have a formalized and approved climate transition plan. The company is currently evaluating options for developing such a plan, in alignment with the evolving European regulatory framework and its strategic priorities" (page 129).

What exists instead:

• A 2025 SBTi commitment: "the submission, in 2025, of a formal commitment to set short-term emission reduction targets under the Science Based Targets initiative (SBTi), with Committed status. As of the reporting date, these targets have not yet been defined or submitted for validation to SBTi" (page 129).
• Continued energy efficiency and emission reduction measures, annual GHG inventory monitoring and integration of climate into operational and investment decisions "with a focus on Scope 1 and Scope 2 emissions" (pages 129-130).
• An explicit negative: "Antibiotice has not established a formal Net Zero commitment" (page 130).

Annex 3 records the E1-1 paragraph 16(g) datapoint on exclusion from Paris-aligned Benchmarks as Not material (page 289). "Decisions regarding the development of a climate transition plan will be periodically assessed in line with the evolution of the regulatory framework" (page 130).

Identification of climate-related risks and scenario analysis

Back-filled from the E1 climate DMA section (pages 130-132). This DR did not exist under the 2023 ESRS the report was prepared against.

Risk classification (page 130): risks are split into physical and transition. Physical - "extreme weather events such as droughts, floods or heatwaves may affect the availability and cost of raw materials sourced from climate-sensitive regions". Transition - tightening EU and national regulation on emissions, energy efficiency and resource use; vehicle-emission requirements; energy and fuel price volatility; and reputational risk from "the absence of a clear and credible plan to reduce climate impact".

Methodology and scenarios (pages 131-132): the process covers the GHG inventory plus physical and transition risk analysis. Scenario analysis was done in 2022 using TCFD over short (to 2030), medium and long (to 2050) horizons, with four scenarios. "For transition risks, at least one scenario aligned with the objective of limiting global warming to 1.5°C was used, namely Net Zero 2050, equivalent to SSP1-1.9. Scenarios 2 and 3 are aligned with a 42% emission reduction target by 2030."

Physical hazards were identified using "a high-emission scenario... without detailed site-specific geospatial modelling" (page 131). No per-scenario temperature projection is given, and the analysis was not refreshed in 2025.

Resilience in relation to climate change

Back-filled from the "Resilience analysis" section of the E1 chapter, where this content is disclosed in the FY2025 report (pages 131-132). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Results (page 131): "At the time of the assessment, the analysis did not indicate climate-related risks that would significantly affect the company's operational continuity in the short and medium term. No assets or activities were identified as inherently incompatible with the climate transition. However, certain operational processes will require progressive investment efforts to remain aligned with a Net Zero 2050 scenario, primarily due to partial dependence on conventional energy sources."

How the analysis informs the response (page 132): "In direct response to the identified transition risks, the company has oriented its investment decisions towards energy efficiency and renewable energy. In 2024, a 2.5 MW photovoltaic plant was completed, and in 2025 the company initiated the modernization of the 110/6 kV transformer station, commissioned two 6/0.4 kV electrical transformers and entered the final testing phase of a 1.2 MW rooftop photovoltaic system."

Policies related to climate change mitigation and adaptation

Reference: pages 132-133 (Annex 2 index, page 284).

The policy instrument is the Climate Resilience Policy, "adopted at company level and integrated into the overall governance and risk management framework" (page 132), covering both mitigation and adaptation.

Mitigation commitments (page 132):

• Reduction of GHG emissions from own operations through energy efficiency and low-carbon energy sources.
• Improvement of energy efficiency of infrastructure and equipment, "including the modernization of internal electrical networks and the progressive integration of renewable energy".
• Integration of sustainability criteria into relationships with relevant suppliers.

Adaptation commitments (page 133):

• Periodic assessment of physical climate risks and operational vulnerabilities "with the objective of ensuring business continuity".
• Measures to protect assets and infrastructure against extreme weather.
• Continuous monitoring of climate risks and updating of response measures.

The policy also "serves as the reference framework for potential future initiatives regarding the development of a climate transition plan. In the context of the near-term SBTi commitment undertaken in 2025, the policy may be subject to periodic review" (page 133).

Actions and resources in relation to climate change policies

Reference: pages 133-134 (Annex 2 index, page 284).

Actions implemented in 2025 (page 133), all directed at Scope 1 and Scope 2:

• Initiation of the modernisation of the 110/6 kV transformer station, replacing a 16 MVA transformer with a high energy-efficiency unit - "By reducing network losses, this decreases the amount of energy required to achieve the same level of consumption".
• Commissioning of two 6/0.4 kV electrical transformers of 1,000 kVA each.
• Entry into the final testing phase of a 1.2 MW rooftop photovoltaic plant.

These "are part of a multi-year program for the modernization of energy infrastructure, with progress monitored annually" (page 133).

Decarbonisation levers, three (pages 133-134): energy efficiency (infrastructure modernisation, process optimisation, reduction of energy losses); renewable energy (on-site photovoltaic generation and, from August 2024, a supplier certifying through guarantees of origin that 100% of purchased electricity is renewable); and asset modernisation ("gradual electrification where technically and operationally feasible").

Targets related to climate change mitigation and adaptation

Reference: pages 134-135 (Annex 2 index, page 284).

The target: "reducing Scope 1 and Scope 2 emissions by 46% by 2030 compared to the 2019 baseline. This target is absolute, measurable and time-bound, based on audited reference data for 2019" (page 134), equating to "approximately 7,563 to 7,694 tCO2e" (page 135). It "has not been validated by SBTi and is currently treated as an internal commitment"; no Scope 3 target exists (page 134).

Progress (page 134), tCO2e:

"For Scope 2 - location-based, the 46% reduction target has already been achieved and exceeded in 2025" (page 135), but overall "additional measures are required to accelerate the pace of decarbonization, particularly with regard to emissions from stationary combustion" (page 135). No interim milestones to 2030 are set.

Energy consumption and mix

Reference: pages 135-137 (Annex 2 index, page 284).

Total energy consumption: 66,714.98 MWh in 2025 (2024: 62,979.24 MWh). "The increase is mainly driven by higher natural gas consumption as a result of expanded operational activities" (page 135).

Electricity is 99.47% renewable: guarantees of origin 15,537.83 MWh (83.60%) and on-site photovoltaic 2,949.78 MWh (15.87%), with 98.23 MWh (0.53%) from the national mix. "The company does not use power purchase agreements (PPAs) and has not purchased or sold unbundled certificates of origin separate from electricity" (page 136).

Energy intensity (page 137): the whole business is high climate impact, so intensity is 0.10 MWh per thousand RON of net revenue (2024: 0.09).

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 137-140 (Annex 2 index, page 284).

2025 (tCO2e): Scope 1 10,115.65; Scope 2 location-based 2,810.11, market-based 17.65; Scope 3 33,949.51. Total location-based 46,875.27, market-based 44,082.81 (pages 137-138). Scope 1 emissions covered by emissions trading systems: 0%.

Scope 3 by category, 2025 (tCO2e): 1 purchased goods and services 24,951.93; 2 capital goods 4,679.66; 3 fuel- and energy-related 2,321.02; 4 upstream transport 300.71; 5 waste 46.31; 6 business travel 30.83; 7 employee commuting 369.02; 9 downstream transport 355.33; 12 end-of-life treatment 894.70.

Six categories excluded (page 139) with reasons: 3.8, 3.10, 3.11 ("Emissions from the use of medicines by patients cannot be reliably estimated with currently available data"), 3.13, 3.14 and 3.15.

Method (page 138): GHG Protocol; DEFRA factors; the supplier's energy mix label for Scope 2 market-based. "The share of Scope 3 emissions calculated based on primary data is 5.72%". In 2025 EXIOBASE was replaced by CEDA 2025 for categories 3.1, 3.2 and 3.4 and 2024 was recalculated (73,014.38 restated to 41,642.26 tCO2e), so the prior year's published Scope 3 "are therefore no longer directly comparable" (pages 41, 138-139).

Intensity (pages 139-140): 0.07264 location-based and 0.06832 market-based tCO2e per thousand RON net revenue. No biogenic CO2 was recorded.

GHG removals and mitigation projects financed through carbon credits

Reference: page 140 (Annex 2 index lists E1-7 at page 140; Annex 3 marks the paragraph 56 datapoint Material at page 140, page 290).

A complete nil return: "In 2025, Antibiotice did not develop any greenhouse gas removal or storage projects within its own operations or across the value chain and did not finance emission reduction projects through the purchase of carbon credits on the voluntary market" (page 140).

"The company does not use carbon credits to offset reported emissions and has not made any public claims regarding climate neutrality. Its decarbonization strategy is based exclusively on real emission reductions at source" (page 140).

This is consistent with the E1-1 statement that "Antibiotice has not established a formal Net Zero commitment" (page 130) and with the absence of any removals or credits component in the 46% by 2030 Scope 1 and 2 target (page 134).

Internal carbon pricing

Reference: page 140 (Annex 2 index lists E1-8 at page 140).

A nil return: "As of the reporting date, Antibiotice has not implemented an internal carbon pricing system. Emissions under Scope 1, Scope 2 and Scope 3 are not subject to any internal pricing mechanism, and carbon pricing is not incorporated into the assumptions used in the preparation of financial statements or in investment appraisal" (page 140).

The scope of the statement is explicit on both limbs the DR asks about - whether a scheme exists, and whether carbon prices feed financial statement assumptions or investment decisions. No shadow price, internal fee or implicit price is disclosed anywhere in the E1 chapter.

Policies related to pollution

Reference: pages 142-144 (Annex 2 index, page 285).

The framework is an Environmental Policy establishing "the general framework for the prevention, control and reduction of material environmental impacts, including those related to air, water and soil pollution, as well as the management of chemicals and waste", published on the website and communicated through the environmental management systems (page 142).

It is supported by named complementary policies: the Climate Resilience Policy, the Water Management Policy, the Air Quality Management Policy, the Policy on the management of hazardous substances and chemicals, the Position on the Environmental Impact of Pharmaceutical Products, the Code of Ethics and the Business Partner Code of Conduct (page 142).

Scope and responsibility (pages 142-143): the policy covers all own operations under direct control; suppliers are reached through the Code of Conduct for Partners setting "minimum requirements regarding environmental protection, pollution prevention and responsible waste management". The Board approves the policy; the Environmental Protection function reviews it.

Incident prevention (pages 143-144): an integrated system aligned with ISO 14001, documented in an Accidental Pollution Prevention and Response Plan. In 2025 two internal simulation exercises were run, on a fire at the solvent storage facility and at the reagents and fuels storage area.

Actions and resources related to pollution

Reference: pages 144-145 (Annex 2 index, page 285).

Actions are monitoring-led rather than project-based: "Pollution management actions are ongoing, supported by continuous monitoring and annual reporting, while equipment modernization and efficiency measures are planned over the medium and long term" (page 144).

Water quality (page 144): wastewater, rainwater and groundwater are monitored by accredited laboratories and self-monitoring. Wastewater parameters (pH, BOD5, COD-Cr, suspended solids, phosphorus, ammonium) are measured monthly, groundwater semi-annually. "In 2025, no non-compliances were recorded regarding the quality of discharged water."

Value chain (page 145): in 2025 the Code of Conduct went to contractual partners for signature, and the first ESG supplier assessment ran with an environmental component covering policies, ISO 14001 certification, pollution prevention and carbon footprint monitoring; "over 42% of suppliers within the Top 80% category were classified as low risk". The company "intends to expand and deepen supplier assessments in 2026".

Outcome: "In 2025, no environmental incidents were recorded that resulted in remediation costs, compensation, fines or penalties" (page 145).

Targets related to pollution

Reference: pages 145-146 (Annex 2 index, page 285).

The company sets no reduction target beyond the law: "Antibiotice has not established quantitative targets for pollution reduction beyond legal requirements. The company's primary objective is to ensure continuous 100% compliance with the maximum permissible limit values set by applicable environmental legislation for air emissions, wastewater and soil quality. This objective is absolute in nature" (page 145).

No milestones: "The objective applies on a continuous basis, without intermediate milestones, as the requirement is the permanent compliance with emission limit values set by environmental permits" (page 146).

Performance (page 146):

"Stakeholder involvement in defining the objective takes place indirectly, through the legislative and regulatory framework established by the competent authorities" (page 146).

Pollution of air, water and soil

Reference: pages 146-147 (Annex 2 index lists E2-4 at page 146; Annex 3 marks the E-PRTR paragraph 28 datapoint Material at page 147).

The company reports under Regulation (EC) No. 166/2006 (E-PRTR): data "are centralized at site level and structured by source type... and are submitted to the competent authorities" (page 146). The 2025 values "are subject to official E-PRTR reporting. Following the completion of the reporting process, the data will be available in the European Pollutant Release and Transfer Register."

The one quantified pollutant disclosed (page 147):

The increase "is correlated with the structure of the business plan during the reporting period".

Microplastics - an explicit gap: "the company does not currently monitor their generation or use within its own operations and has not carried out specific assessments during the reporting period" (page 147), although microplastics is one of the company's own material E2 sub-topics (page 74).

Overall: "no exceedances of limit values or compliance parameters set in environmental permits were recorded" (page 147).

Substances of concern and substances of very high concern

Reference: pages 147-149 (Annex 2 index lists E2-5 at page 147).

Both limbs of ESRS E2 paragraph 34 are addressed - amounts procured and used, and outflows - split by CLP hazard class.

2025 (tonnes, page 148):

Reporting threshold: 0.5 tonnes, "internal threshold established by the company". 2024 comparatives are given (procured 674.49 t, used 893.94 t, emissions 401.25 t); "In 2024, SoC reporting was carried out at the level of individual substances. In 2025, reporting was restructured based on CLP hazard classes" (page 148).

Anticipated financial effects from pollution-related risks and opportunities

Reference: page 149 (Annex 2 index lists E2-6 at page 149).

The disclosure is a nil return supported by an explanation of the ongoing cost base rather than a quantified forward projection:

"During the 2025 reporting period, the company did not record any environmental incidents that required operational or capital expenditures for the remediation of air, water or soil pollution. In the absence of such events, no costs were incurred for remediation measures, compensation, fines or penalties, a situation consistent with that reported for the 2024 financial year" (page 149).

"Ongoing pollution-related expenditures are preventive and compliance-driven in nature, covering emissions monitoring, laboratory analyses, as well as the maintenance and modernization of treatment and filtration installations. These are reflected in the company's operating and capital expenditures, under the sections dedicated to environmental costs and infrastructure investments, and are fully financed from internal resources" (page 149).

No monetary amounts, ranges or time horizons are attached. The qualitative magnitude of each pollution risk and opportunity is rated High or Very high in the SBM-3 tables (pages 90-92, 96-98), which is the only forward-looking financial signal given.

Policies related to water and marine resources

Reference: page 153 (Annex 2 index lists E3-1 at page 153).

Water management is integrated into the Environmental Policy rather than a standalone document: "The policy adopted in previous years remained unchanged in 2025, with no modifications to its scope, responsibilities, reference standards or communication mechanisms" (page 153).

Objectives (page 153): prevent further deterioration of water bodies and protect surface and groundwater quality; ensure sustainable use "by increasing efficiency and reducing water abstraction and discharge"; ensure appropriate wastewater treatment; and maintain good ecological and chemical status of water bodies.

Product design - an explicit exclusion (page 153): "the policy does not include the redesign of pharmaceutical formulations from a water management perspective, as product composition and characteristics are strictly regulated by pharmaceutical legislation."

Water-stressed areas (pages 153-154): all operations sit on a single site "located in an area characterized by medium to high water stress", addressed through process optimisation, water recycling, own wells and monitoring. "The integrated approach of the overall policy covers the risks associated with operating in a water-stressed area, without the need to adopt a separate dedicated policy."

Actions and resources related to water and marine resources

Reference: pages 154-155 (Annex 2 index, page 285).

Diversification of supply (page 154): the headline 2025 action is "the commissioning of the company's own network of 15 groundwater wells, developed based on a preliminary hydrogeological study and the necessary regulatory approvals". The water irrigates green spaces, reducing potable water drawn from the public network. "The contribution of the wells to total water consumption remained limited in 2025, due to their commissioning in the second half of the year and the seasonal nature of irrigation demand."

Water efficiency (page 154): the main measure is "recovering steam condensate and reintroducing it into the boiler feed system". Recycled and reused water was 11,925 m3 in 2025 against 9,902 m3 in 2024, the increase coming from expanding condensate recovery from two production units in 2024 to five units in 2025.

Monitoring and treatment (pages 154-155): discharged wastewater, rainwater and groundwater are monitored under the Integrated Environmental Permit and the Water Management Permit across ten named parameters. Wastewater goes to the company's own plant for "successive mechanical and biological treatment stages". "Monitoring results confirmed that all parameters remained within legal limits, with no exceedances of permitted values."

Targets related to water and marine resources

Reference: pages 155-157 (Annex 2 index lists E3-3 at page 155).

"The effectiveness of water-related policies and actions is monitored through quantitative objectives integrated into the company's environmental strategy" (page 155), tracked through total consumption volume, "consumption intensity relative to economic activity, the quality parameters of discharged water against legal limits, and the number of reported non-compliances or environmental incidents" (page 156).

The water target appears in the executive incentive scheme, where the General Manager carries a KPI of "Reduction of water consumption intensity (m3/net turnover) by 1% per year" at 5% weight (page 48). The E3 actions are "ongoing in nature and aligned with achieving the company's 2030 objective" (page 154).

Performance (page 156): total consumption fell from 149,664 m3 in 2024 to 147,164 m3 in 2025, against a 2019 reference of 187,475 m3. Recycled and reused water rose from 9,902 to 11,925 m3 and storage capacity from approximately 5,000 to 5,500 m3.

Against the intensity measure the direction is adverse: intensity per thousand RON of net operational income rose from 0.222 to 0.228, and specific consumption per thousand RON of merchandise production from 0.448 to 0.449 (page 157), because net operational income fell faster than consumption.

Water consumption

Reference: pages 156-157 (Annex 2 index lists E3-4 at page 156).

Total water consumption 2025: 147,164 m3 (2024: 149,664; 2019 reference: 187,475). The entire volume sits in an area of medium to high water stress (page 156).

By source (page 156): the regional operator from the Timisesti source in Neamt County supplies 142,549 m3 (96.9%); the company's 15 own groundwater wells supply 4,615 m3 (3.1%), "used exclusively for irrigating green spaces".

Method (pages 156-157): "primarily obtained through direct measurements, using calibrated meters installed on production lines, in water use areas and at own water sources. For smaller or auxiliary flows, where direct measurement is not feasible, sampling and extrapolation are used."

Site water risk was reassessed in 2025 using the WRI Aqueduct Water Risk Atlas 4.0 at river basin level across 2030, 2050 and 2080 horizons; the Iasi site sits "in an area with a medium-to-high overall water risk, trending toward high" (pages 150-151). No water discharge volume is reported.

Policies related to resource use and circular economy

Reference: page 159 (Annex 2 index, page 285).

"The policies applicable in 2025 are identical to those reported for the 2024 financial year, with no new policies adopted and no changes to scope, responsibilities, reference standards or communication mechanisms" (page 159).

Two instruments sit inside the Environmental Policy: a Circular Economy Policy aiming "to optimize resource use, reduce waste generation and support the transition to a production model that prioritizes waste prevention and the efficient use of raw materials, auxiliary materials and packaging", and a Waste Management Policy covering "the responsible management of all categories of waste generated, with a focus on source reduction, increasing recycling rates and applying the 3R principles".

A sector constraint stated up front (pages 157, 159): "regulations regarding product safety, quality and efficacy prohibit the use of recycled materials in the manufacturing of medicines and in primary packaging that comes into direct contact with them, structurally limiting the adoption of circular models at product level." Consequently "the company does not use recycled materials in its manufacturing processes and has not established specific targets in this regard".

Scope (page 159): all operations, extended to the value chain through the Code of Conduct for Partners; aligned with ISO 14001 and ISO 9001.

Actions and resources related to resource use and circular economy

Reference: page 160 (Annex 2 index, page 285).

Actions "are ongoing in nature, without a predefined end date, and cover the company's own operations and, to some extent, the upstream value chain" (page 160). The main ones:

• Separate collection by stream of hazardous and non-hazardous waste - distillation and solvent recovery residues, industrial sludge and mycelium, filter cakes, contaminated absorbents, used oils, medical and pharmaceutical waste, laboratory reagents, and non-hazardous paper, plastic, wood, metal, glass, WEEE and used tyres - each "managed through distinct streams depending on its nature and hazard level... and transfer exclusively to authorized operators".
• Separation and recycling of packaging and industrial waste (cardboard, plastic, metal) under contracts with authorised operators.
• Supplier assessment in 2025 covering environmental compliance, waste management and responsible resource use.
• An internal campaign for the collection of expired medicines from employees, handed to authorised operators.

Resources: "Actions related to resource use and the circular economy did not require significant dedicated capital or operational expenditures. In 2025, certain contracts with authorized waste management operators were updated and/or renewed... without significant additional financial allocations" (page 160).

Targets related to resource use and circular economy

Reference: pages 160-162 (Annex 2 index, page 285).

The landfill target, already met: "Antibiotice has set a voluntary target to reduce the quantity of waste disposed of in landfill by 80% by 2030, compared to the 2019 baseline. This target was achieved and exceeded in 2024, ahead of the established deadline, reaching a reduction of 88.14% compared to 2019" (page 161).

"No new quantitative targets have been established at this stage" (page 161), and the target "was set internally, without being based on specific scientific sources".

Packaging recycling targets (page 161), an EPR obligation under Law No. 249/2015 applicable from 2025: paper/cardboard 75%, plastic 50%, glass 65%, metal 70%, aluminium 70%, wood 50%, with a global recycling target of 65% and a global recovery target of 70%, monitored monthly.

Targets explicitly not set (pages 161-162): "The company has not established targets related to increasing circular product design, the use of circular materials, minimizing the use of primary raw materials or reversing the depletion of renewable resource stocks", reflecting regulatory constraints requiring virgin raw materials.

Resource inflows

Reference: page 162 (Annex 2 index, page 285).

Materials in scope are "active pharmaceutical ingredients (APIs), excipients, solvents, chemical reagents, substances used in technological processes, auxiliary substances for manufacturing and packaging materials" (page 162).

The series is not comparable. "In 2025, the reporting scope was expanded... in addition to APIs and excipients, reagents, chemicals used in technological processes and auxiliary manufacturing substances were also included... Therefore, the 2025 data are not directly comparable with those from 2024, and any quantitative variations primarily reflect this expansion of the reporting scope rather than an increase in material consumption" (page 162).

Two stated gaps (page 162): no secondary components or materials are used "due to strict regulatory requirements"; and "Antibiotice does not collect data on the share of biological materials sourced from certified sustainable origins".

Method (page 162): internal procurement records and accounting documents, with volume-to-mass conversion using product-specific densities and each category counted once.

Resource outflows

Reference: pages 162-163 (Annex 2 index lists E5-5 at page 162).

Products. Antibiotice places on the market "pharmaceutical products for human and veterinary use, active pharmaceutical ingredients (APIs), cosmetic products, food supplements and medical devices, all manufactured in compliance with Good Manufacturing Practice" (page 162).

Durability, reusability, repairability, recyclability - a stated nil (pages 162-163): "The design of finished products does not allow reuse, repair, remanufacturing or recycling, due to strict regulatory constraints. Circular principles are therefore applied primarily at the level of secondary and tertiary packaging and in the management of waste streams."

Recycled content (page 163): "The recyclable content in products and their packaging is 0%, reflecting the prohibition on the use of recycled materials in pharmaceutical products and in primary packaging. Secondary and tertiary packaging are designed to enable separate collection and recycling at the end of their life cycle, this aspect being addressed within the framework of extended producer responsibility obligations."

The waste limb of E5-5 is reported at pages 163-165 and set out separately under the Waste entry: 517.56 tonnes generated in 2025 against 540.24 in 2024, with 183.01 tonnes (35.36%) not recycled and 17.56 tonnes hazardous.

No expected durability figures relative to industry average are given.

Waste

Reference: pages 163-165 (reported within the E5-5 resource outflows section listed at page 162 of Annex 2).

Total waste generated 2025: 517.56 tonnes (2024: 540.24), a fall of approximately 4.2%.

The rise in hazardous waste "is due to the nature of pharmaceutical manufacturing and biosynthesis activities during those periods"; it is stored in leak-proof containers and "handed over exclusively to authorized operators" (page 163).

Method (page 165): "determined primarily based on direct measurements, by weighing the waste at the time of delivery to authorized operators"; where weighing is not possible, standard conversion factors are used. "The reported data is based on verifiable documents: loading and unloading forms, transport documents, accounting records, and contracts with authorized operators."

Policies related to own workforce

Reference: pages 168-171 (Annex 2 index, page 285).

The policy set covers "all employees, regardless of contract type, role or location", with specific provisions for vulnerable groups such as young people under 18, mothers and people with disabilities (page 168).

Human Rights Policy (page 168) aligned with the Universal Declaration of Human Rights, the OECD Guidelines, the ILO Tripartite Declaration, the Helsinki Declaration and ISO 45001:2018. It "prohibits the use of child labour and forced labour in any aspect of its operations" and applies zero tolerance to suppliers and partners.

Other instruments (pages 168-170): the Code of Conduct for Partners, the Collective Labour Agreement, the Internal Regulation, the Code of Ethics, the Human Resources Policy (monitored indicator: retention of at least 95%), the Compensation and Motivation Policy (indicator: minimum salary above the national minimum wage), the Diversity, Equality and Inclusion Policy, and the Occupational Health and Safety Policy.

Grievance channels (pages 168-169) run under the Law No. 361/2022 whistleblower procedure: internal e-mail, a line to the Chair of the Ethics and Integrity Council, paper submission, the national avertizori.integritate.eu platform and in-person reporting at ANI.

Association (page 169): "The percentage of employees covered by collective labour agreements is 100% (all 1,370 employees)."

Processes for engaging with own workforce and workers' representatives

Reference: pages 171-172 (Annex 2 index, page 285).

Engagement runs through the Antibiotice Free Trade Union, part of the Federation of Free Trade Unions in the Chemical and Petrochemical Industry, affiliated to "Cartel ALFA"; "the Collective Labour Agreement applies to all employees, regardless of contract type or trade union membership" (page 171). Consultations "have an advisory, information and negotiation role" and are carried out under the Collective Labour Agreement and Law No. 367/2022 on social dialogue.

2025 activity (page 171): "collaboration with employee representatives was structured and documented through the organization of at least one quarterly consultation, with a total of five consultations", covering the organizational climate survey launch, the annual performance evaluation process, REGES ONLINE changes, implementation of Collective Labour Agreement measures from 1 June 2025, and the Family Day event.

Surveys (page 171): the organizational climate survey, run every two years, was carried out 5-20 March 2025; results "are analyzed together with management and trade union representatives".

A stated gap (page 172): "Currently, there is no separate consultation process for vulnerable groups; however, all employees are included in the general consultation processes, either directly or through trade union representatives."

Processes to remediate negative impacts and channels to raise concerns

Reference: page 172 (Annex 2 index, page 285); Annex 3 marks the S1-3 grievance and complaints handling mechanisms datapoint (paragraph 32(c)) Material at page 172.

"The company has not identified any situations where it has caused or contributed to a significant negative impact on individuals in its workforce. However, to ensure a transparent and fair working environment, several channels are provided for employees to express their concerns, and needs or report issues" (page 172).

Internal channels (page 172): directly, in person at the Human Resources Department; and by e-mail to resurse.umane@antibiotice.ro. These sit alongside the whistleblowing channels at pages 168-169 - the Ethics and Integrity Council, the national avertizori.integritate.eu platform and ANI - which employees, contractors, suppliers and business partners may all use.

"The procedure for addressing individual requests and complaints is detailed in the Internal Regulations (Chapter VI), which is available on the company's website. The internal channels follow fundamental principles such as legitimacy, accessibility, clarity and transparency, and are aligned with international human rights standards" (page 172).

Outcome for the year: no incidents or complaints were reported through the official channels (page 184).

Taking action on material impacts on own workforce

Reference: pages 173-174 (Annex 2 index, page 285).

The integrated policy set applied is named: "the Human Resources Policy, the Compensation and Motivation Policy, the Human Rights Policy, the Diversity, Equality and Inclusion Policy, and the Occupational Health and Safety Policy" (page 173).

Measures (page 173): performance evaluation systems based on indicators, training and development programmes, medical screening, performance recognition, leadership programmes, and talent attraction and retention. Health and safety risk is managed through the Occupational Health and Safety Committee, covering the Prevention and Protection Plan, equipment assessment and accident cause analysis, reporting at least annually via the General Manager.

2025 initiatives (pages 166-167): more than 12,000 training hours and over 1,400 programme participations; the a+ Academy; a mentoring programme with 44 certified trainers and 30 mentors; a digital platform delivering over 8,500 learning hours to 617 users with 1,025 certifications; 64 onboarding plans; the Green Park area; the INOVA a+ Research Centre; and fleet renewal.

Effectiveness (page 174): monitored through satisfaction surveys and "the employee retention rate, employees' income levels, professional training hours per employee, occupational health and safety indicators". Retention reached 97.57% in 2025 (page 167).

Targets related to own workforce

Reference: page 175 (Annex 2 index, page 285).

The company works from operational indicators rather than dated outcome targets: "Antibiotice uses performance indicators to stimulate and measure progress... The effectiveness of actions is monitored through employee satisfaction surveys and specific indicators such as the employee retention rate, employees' income levels, professional training hours per employee, occupational health and safety indicators, and periodic assessments of the organizational climate" (page 175).

The three stated aims (page 175): "The company aims to maintain the internal minimum salary above the national minimum wage, achieve zero serious occupational accidents, and continuously improve organizational performance and employee well-being."

Quantified targets disclosed elsewhere in the chapter:

• Employee retention of at least 95%, the Human Resources Policy indicator (page 169), achieved at 97.57% (page 167).
• Training hours per employee: "in 2024, 50.19 hours were recorded compared to a target of 44 hours, while in 2025, 49.42 hours were recorded compared to the target of 46 hours. For the period 2026 to 2029, progressive targets have been established, namely 47 hours in 2026 and 48 hours annually during the period 2027 to 2029" (page 170).

Characteristics of the undertaking's employees

Reference: pages 175-177 (Annex 2 index, page 285).

Headcount at 31 December (page 175): 2025 - 778 women, 578 men, 1,356 total; 2024 - 778 women, 579 men, 1,357. Average number of employees: 1,370 in 2025, 1,350 in 2024 (page 176).

By contract type (page 176): permanent 1,345 (772 women, 573 men) against 1,331 in 2024; temporary 11 (6 women, 5 men) against 26; non-guaranteed hours 0 in both years; full-time 1,354; part-time 2.

By age (page 177): under 30 - 95 (2024: 100); 30 to 50 - 698 (658); over 50 - 563 (599).

Turnover (page 176): "In 2025, 87 employees left the company, of which 33 did so on their own initiative". The total turnover rate was 6.35% against 7.78% in 2024, a fall of 1.43 points; the voluntary rate was 2.41% against 3.41%.

Method (page 176): headcount, not FTE - "The company does not use the full-time equivalent (FTE) metric. The number of employees is reported at the end of the reporting period (December 31)." The average uses calendar days of employment including suspended contracts, with part-time weighted proportionally. "no estimates were used; the reported indicators are based exclusively on information recorded in internal systems", managed through Charisma software with manual extraction.

All employees are in Romania (page 55), so no country breakdown is given.

Diversity metrics

Reference: page 177 (Annex 2 index, page 285).

Gender distribution at top management (page 177):

"The management team (Top Management) consists of the executive directors and executive managers." Executive directors "develop the company's strategies, adjust their course during implementation and make decisions that have an impact on the entire organization"; executive managers "report to the executive directors, collaborate with them in the development of the strategic plan, oversee its implementation and plan and monitor the indicators related to their respective areas of responsibility" (page 177).

Age distribution of the whole workforce (page 177):

Related figures elsewhere: at governance level the Board is 4 men (57.1%) and 3 women (42.9%), and the 10-member Management Team is 4 men (40%) and 6 women (60%), a gender diversity ratio of 1.5 (page 45). The S1 narrative adds that "diversity is supported through balanced representation at management level, where women account for more than 50 percent" (page 166) - a statement that refers to the 10-member Management Team rather than the 22-person Top Management group tabled here.

Adequate wages

Reference: pages 177-178 (Annex 2 index, page 286).

"Within Antibiotice S.A., there is a Compensation and Motivation Policy for employees that includes a reference value, salary coefficients and salary grades. The company's approach is to keep the reference value continuously updated in line with the evolution of the national minimum wage" (page 177).

Benchmark used (page 178): "the company uses as an indicative benchmark the provisions of national legislation regarding the mechanism for setting the national gross minimum wage guaranteed in payment, as well as the benchmarks set out in Directive (EU) 2022/2041 on adequate minimum wages in the European Union."

The result: "Under these conditions, all employees of the company are remunerated above the national minimum wage" (page 178). All 1,356 employees are in Romania (page 55), so no country breakdown is required.

Adequate wages is the one negative impact in the company's own S1 IRO table - "Inadequate or unfair wages can generate dissatisfaction among employees and affect the company's ability to attract and retain talent" (potential negative impact, page 76) - and the narrative concedes the pressure: "The internal analysis identified adequate wages as an area with potential adverse effects... developments in this area also depend on the broader socio economic and fiscal context, including the accelerated increase in inflation recorded in 2025" (page 166).

Persons with disabilities

Reference: page 178 (Annex 2 index, page 286).

"The percentage of employees with disabilities within the company's own workforce was 0.37% in 2025, of which 0.07% were women and 0.29% were men (reported relative to the total number of employees). Reported by gender distribution, the percentage of women with disabilities out of the total number of female employees was 0.13%, while the percentage of men with disabilities out of the total number of male employees was 0.69%" (page 178).

2024 comparative: "the percentage of employees with disabilities within the total workforce was 0.66%, of which 0.37% were women and 0.29% were men. Reported relative to the total number of employees in each gender category, 0.64% of women and 0.69% of men were persons with disabilities" (page 178). The share roughly halved year on year, driven by the female cohort.

Method (page 178): "calculated by dividing the number of persons with disabilities as of 31 December 2025 by the number of employees at the same date (total, men and women, as applicable)."

HR and health and safety policies "include specific provisions in line with applicable legislation for vulnerable groups such as young people under the age of 18, mothers and people with disabilities" (page 168). No absolute headcount is given, and no statement is made about legal restrictions on collecting disability data.

Training and skills development metrics

Reference: pages 178-179 (Annex 2 index, page 286).

Performance reviews (page 178):

2024: women 677 (49.67%), men 551 (40.43%), total 1,228 (90.10%).

An important caveat is printed with the table: "Considering that the performance evaluation process for 2025 has not yet been completed, information related to the 2024 performance evaluations was used. Annual performance evaluations were not carried out for employees who, at the time of the evaluation, had less than six months of service within the company or had more than six months of interruption of activity during the same year" (page 178).

Training hours (page 179):

2024: women 41,148 hours (52.88 average), men 26,973 (46.59), total 68,121 (50.20).

Against the internal target the result is a near miss on a raised bar: "in 2024, 50.19 hours were recorded compared to a target of 44 hours, while in 2025, 49.42 hours were recorded compared to the target of 46 hours" (page 170), with progressive targets of 47 hours in 2026 and 48 hours annually for 2027-2029.

Health and safety metrics

Reference: pages 179-183 (Annex 2 index, page 286).

Coverage and system (pages 179-180): the OHS management system has run since 2007, is aligned with ISO 45001 and certified by TUV Rheinland Romania, with the most recent recertification audit in October 2025. An internal Prevention and Protection Service of six members operates. "During the last reported year, 100% of the company's active workforce was trained in occupational health and safety, out of an annual average of 1,364 employees. The total number of occupational health and safety training hours delivered was 21,413 hours."

Fatalities (page 182): "No deaths were recorded among employees as a result of occupational accidents or occupational diseases. Likewise, no deaths were reported among other workers performing activities on the company's sites."

Accidents (pages 182-183): five cases were reported to the Iasi Labour Inspectorate in 2025; "four cases were classified as occupational accidents; one case was classified as a minor accident". The work accident rate was 1.87 per million hours - "4 / 2,141,073 x 1,000,000 = 1.87" - against 1.78 in 2024. Days lost were 137 against 132 in 2024.

Prevention (pages 180-182): risks were reassessed for 64 job positions; three OHS Committee meetings and four emergency simulation exercises were held; 1,977 pieces of equipment received 2,350 inspections with no equipment-safety incidents.

Work-life balance metrics

Reference: pages 183-184 (Annex 2 index, page 286).

Entitlement (page 184): "In accordance with the Collective Labour Agreement in force at Antibiotice, 100% of employees benefit from the right to leave for family related reasons, under the conditions provided by applicable legislation and internal regulations." The entitlement covers medical leave, parental leave, paid leave for family events (marriage, bereavement), blood donation, relocation, medical check-ups during pregnancy and leave related to childbirth including paternity leave.

Take-up in 2025 (pages 183-184), in three cuts:

Overall take-up (page 184): 284 women (36.5%) and 169 men (29.2%), total 453 employees, 33.4% in 2025; in 2024, 273 women (35%) and 186 men (32%), total 459 (34%).

The underlying material impact is a positive one in the company's own IRO table: "By adopting policies that support work-life balance (flexible schedules, remote work, paid leave), Antibiotice improves the quality of life for its employees" (page 76).

Remuneration metrics (pay gap and total remuneration)

Reference: page 184 (Annex 2 index lists S1-16 "Remuneration metrics (pay gap and total remuneration)" at page 184; Annex 3 marks the paragraph 97 (a) and 97 (b) datapoints Material at page 184).

Gender pay gap: "The pay gap between women and men within the company is 1.29% (vs. 0.81% in 2024), calculated based on the total income earned by employees" (page 184). The gap widened by 0.48 percentage points from a very low base.

Total remuneration ratio: "The annual total remuneration ratio was calculated at 8.27, by comparing the annual total remuneration of the highest paid employee with the median annual total remuneration of all employees (excluding the highest paid employee). The calculation included base salary, allowances, premiums, bonuses, profit sharing and other forms of variable cash payments. In 2024, the ratio was 7.87" (page 184).

Both metrics are stated with their calculation basis and a 2024 comparative, so the direction is visible: the pay gap and the CEO-to-median ratio each moved slightly against the workforce.

Context: the Compensation and Motivation Policy's main indicator is "maintaining the minimum salary within the company above the national minimum wage" (page 169), and all employees are paid above it (page 178). No adjusted pay gap and no explanation of the drivers behind the widening are given.

Incidents, complaints and severe human rights impacts

Reference: pages 184-185 (Annex 2 index, page 286).

A complete nil return across every limb of the DR. "In 2025, no incidents or complaints were reported through the official channels made available to the company's own workforce, including through the grievance mechanisms provided under the Internal Regulation" (page 184).

"At the same time, the company did not record (page 185):

• incidents of discrimination or cases of harassment;
• complaints submitted through internal channels through which employees can raise concerns;
• complaints submitted to the OECD National Contact Points for Multinational Enterprises;
• fines, penalties or compensation for damages resulting from incidents of discrimination or complaints related to discrimination and harassment;
• serious issues or incidents related to human rights involving the company's own employees;
• cases of non-compliance with the UN Guiding Principles on Business and Human Rights or the OECD Guidelines for Multinational Enterprises;
• fines, penalties or compensation for damages related to serious human rights issues."

The governance-side figures agree: "During 2025, no reports regarding ethical incidents were recorded" (page 38).

Policies related to affected communities

Reference: pages 189-190 (Annex 2 index, page 286).

"The company has not adopted a separate policy specifically dedicated to affected communities; however, the principles for preventing and managing social and environmental impacts on these communities are integrated into the company's existing policies and codes, including the Human Rights Policy, the Environmental Policy, the Access to Medicines Policy and the Business Partner Code of Conduct" (page 189).

A formal stakeholder consultation procedure supports implementation, with four steps (page 190): identification of stakeholders (local communities, public authorities, educational institutions, relevant NGOs); planning of consultations, including quarterly consultations and the "Open Doors Day" event; collection of feedback through questionnaires, direct discussions and digital platforms; and integration of feedback into strategic decisions.

The Human Rights Policy "applies to all company activities, including its relationship with local communities potentially affected by its operations", based on the UN Guiding Principles, the ILO Tripartite Declaration and the OECD Guidelines (page 190).

The company joined the UN Global Compact in June 2025 and "has not recorded any incidents of human rights violations in relation to communities affected by its activities" (page 190).

Processes for engaging with affected communities

Reference: pages 190-192 (Annex 2 index, page 286).

The channels are named and dated (pages 190-191):

• "Open Doors Day", organised once every three years, held 25-28 June 2025 over four days for institutional representatives, the general public and the educational community, with guided tours of the industrial platform and information sessions on environmental impact. "Dialogue with the community was supported through interactive sessions and the systematic collection of feedback, using public consultation questionnaires accessible to participants through digital tools." Attendance was approximately 250 (page 108).
• Online questionnaires for residents of Iasi and the metropolitan-area communes.
• Meetings with local authorities at the company's headquarters.

Stage and type (page 191): engagement occurs "primarily during the stage of identifying and assessing impacts associated with operations, as well as during the stage of monitoring the effectiveness of the prevention and mitigation measures implemented", and is "predominantly consultative and informative".

Responsibility (pages 191-192): operational responsibility sits with the Director of Quality Assurance; at strategic level "the General Manager is responsible for ensuring that the outcomes of dialogue with communities are integrated into decision making processes".

Processes to remediate negative impacts and channels for communities

Reference: pages 192-193 (Annex 2 index, page 286).

"To date, no major material negative impacts on communities located in proximity of the production platform have been identified; however, the company has structured processes in place to ensure rapid and effective intervention should such impacts arise" (page 192).

Remediation (page 192): where the company determines it has caused or contributed to a significant negative impact, "an internal investigation is initiated to identify the causes and assess the scope of the situation, followed by the implementation of appropriate corrective measures... Such measures may include, where relevant, actions to decontaminate affected areas, proper waste management, additional staff training or the implementation of alternative solutions aimed at reducing inconvenience for communities."

Channels (page 192): internal mechanisms managed by the Ethics and Integrity Council - the company registry in a sealed envelope, e-mail to etica.integritate@antibiotice.ro, a dedicated telephone number, or face-to-face meetings on request - plus "independent external reporting mechanisms, including the national whistleblowing platform".

Protection against retaliation runs through the whistleblowing policy under Law no. 361/2022, which "strictly prohibits any form of retaliation" (page 193).

Taking action on material impacts on affected communities

Reference: pages 187-188, 193-194 (Annex 2 index lists S3-4 at page 193).

Positive-impact projects delivered in 2025 (pages 187-188), with values and reach stated:

• "Education in Action" - practical training placements for students in vocational and technical education in the North East Region. Total project value RON 2,452,958.07; "Training provided for 124 students who completed their practical training placements by the end of 2025."
• "AntibioticeSkills" - funded through the European Social Fund Plus, total value RON 4,857,830.53, over 24 months from 1 March 2025; "102 students completed their practical training placements within the company; 99 continued their educational path in the following academic year."
• Blood donation - "More than 160 participants... donated blood, helping save approximately 440 lives."

Effectiveness (page 193): "At present, the company does not have a single formalized process for monitoring the effectiveness of all actions dedicated to affected communities. However, the evaluation of outcomes is carried out using specific indicators adapted to the type of activity" - visitor numbers and feedback for Open Doors Day, respondent numbers for questionnaires.

No significant negative impacts on residents' health or access to essential resources were identified (page 187).

Targets related to affected communities

Reference: pages 194-195 (Annex 2 index lists S3-5 at page 194).

An explicit negative with a stated reason: "Antibiotice has not currently established measurable outcome-oriented targets for managing material impacts, risks and opportunities related to affected communities, as no significant negative impacts on these communities have been identified. However, the company continuously monitors potential risks and opportunities associated with its relationship with communities and analyses available data and feedback received in order to assess the need to define measurable objectives in the future" (page 194).

Community involvement in target setting (page 194): "In the absence of formal targets, affected communities have not been directly involved in the process of setting targets or monitoring the company's performance against them. Nevertheless, Antibiotice maintains mechanisms for collecting feedback from communities through existing channels such as dedicated events, electronic correspondence and online interactions, including through social media platforms."

Consistent with MDR-T's alternative limb, effectiveness is tracked through operational indicators: participation levels, direct feedback, the nature of concerns identified, and for social responsibility projects "indicators such as the level of participation and the interest demonstrated by the community" (page 193).

Policies related to consumers and end-users

Reference: pages 196-198 (Annex 2 index, page 286).

Responsible Marketing Policy (pages 196-197): it "aims to ensure the ethical promotion of medicines and the accurate and balanced presentation of the benefits of the products included in the company's portfolio". It applies to marketing, promotional and sales activities for prescription and non-prescription medicines addressed to healthcare professionals; "Food supplements are not directly covered by this policy, but they remain subject to the applicable legal requirements". Implementation is owned by six named executive directors, and the framework incorporates the Code of Ethics and the APMGR, RASCI and EFPIA codes.

Coverage of the S4 sub-topics (page 197): access to quality information through the summary of product characteristics, leaflet and labelling; health and safety across manufacturing, quality control, pharmacovigilance and distribution; child protection; non-discrimination; and access to products through production planning and traceability.

Human rights framing (pages 197-198): affordable generics are recognised "as a direct contribution to the fulfilment of the right to health", aligning with SDG 3, Article 25 of the Universal Declaration of Human Rights and the WHO Global Strategy; the company has been a UN Global Compact member since June 2025.

Processes for engaging with consumers and end-users

Reference: pages 199-203 (Annex 2 index lists S4-2 at page 199).

National market (pages 199-200): the annual "Customer Satisfaction Assessment" study runs under ISO 9001:2015 across pharmacists, physicians, distributor managers, national chain managers and mini chain managers, with action thresholds - above 85% no intervention, 80-85% preventive actions, below 80% corrective actions.

2025 results (pages 199-200): retail pharmacists 95.50% (down 0.59pp), physicians 95.45% (up 0.63pp), distributor managers 91.39% (down 0.65pp), national chain managers 84.60% (up 0.79pp), mini chain managers 93.70% (up 1.48pp). "The average level of satisfaction across all categories in 2025 is 92.17%, representing an increase of 0.37 points compared to 2024 (91.80%)."

International market (page 200): a first-half study covers customers accounting for over 80% of sales with a minimum transaction value of USD 50,000. "In 2024, the satisfaction level was 97.65%. For 2025, the satisfaction level will be measured by 31 March 2026."

Vulnerable consumers (pages 202-203): perspectives are collected "through collaboration with general practitioners, pharmacists and patient associations, particularly to identify barriers to treatment administration among patients with chronic conditions, those living in rural areas".

Processes to remediate negative impacts and channels for consumers

Reference: pages 200-205 (Annex 2 index lists S4-3 at page 203).

Detection and handling (page 203): issues are identified through "the pharmacovigilance system, dedicated channels for receiving complaints, interaction with healthcare professionals, as well as internal audits and inspections". Quality complaints follow a defined procedure - "The nonconformity is classified according to a defect category, and the investigation is conducted by a multidisciplinary team... the complainant receives a summary of the conclusions, including the classification of the complaint as justified or unjustified".

Channels (page 203): the website complaint form and adverse reaction reporting form; the consumer representative; a dedicated adverse-reaction telephone line and e-mail; and general company contacts. "All these channels are developed and administered directly by the company."

Volumes in 2025 (page 204): medical inquiries - 13 from consumers/patients, 19 from health professionals, 4 from partners; pharmacovigilance - 5, 7 and 11 cases respectively; quality - "In 2025, 66 complaints regarding product quality were received. Of these, 29 were confirmed as justified and were handled in accordance with internal procedures. The reported defects included damage to primary or secondary packaging, labelling issues and incomplete commercial units" (2024: 62 complaints, 26 justified).

Taking action on material impacts on consumers and end-users

Reference: pages 205-210 (Annex 2 index lists S4-4 at page 205).

Antimicrobial resistance (page 205): the "Antibiotics of the Third Millennium" programme ran clinical workshops in Iasi and Cluj-Napoca hospitals covering the WHO AWaRe classification and priority pathogens. A digital campaign ran 18-24 November 2025 aligned with WHO and ECDC recommendations, supported by a newsletter to approximately 1,850 subscribers and articles reaching more than 4,800 subscribers and physicians. "In parallel, to strengthen information safety, 30 variations were submitted to update safety information in the SmPC and the Package Leaflet."

Accessibility (page 205): packaging was redesigned for elderly and disabled users, including "implementing Braille codes on packaging, both for medicines and for supplements, even in the absence of a legal obligation".

Online store (pages 207-208): launched March 2025; by year end 70,349 visits, 539 orders, 461 unique customers, deliveries in 41 counties, 8 complaints. "2025 is considered a pilot year."

"During the reporting period, no serious human rights issues or major incidents affecting consumers or end users were recorded" (page 206).

Campaigns in 2025 (pages 205-206): a counterfeit medicines warning, World TB Day, World Patient Safety Day, and the 27-31 October campaign collecting 115.5 kg of expired medicines.

Targets related to consumers and end-users

Reference: pages 208-209 (Annex 2 index lists S4-5 at page 208).

The target: "the company has established a measurable operational objective in responsible commercial practices, based on the results of the annual 'Customer Satisfaction Assessment' study. The target consists of achieving an average score of at least 80% for each audience category included in the research" (page 208).

Action mechanism (page 208): "If the score remains above 85%, the strategies applied for each audience type and product category are maintained. For scores between 80% and 85%, preventive actions are established, while for scores below 80% corrective actions are initiated in order to address the identified deficiencies and reduce associated risks."

Involvement of end-users (page 208): through the annual study, whose audience "includes pharmacists, physicians, distributor managers, managers of national pharmacy chains and managers of pharmacy mini chains, who provide feedback directly or through relevant intermediaries". Questions are "predominantly closed ended, but each section also includes an open component".

2025 performance: all five categories scored above 80% - 95.50%, 95.45%, 91.39%, 84.60% and 93.70%, averaging 92.17% (pages 199-200). The national chain managers category at 84.60% sits in the 80-85% preventive-action band.

This is the sole S4 target; none is set for access to medicines or product safety.

Business conduct policies and corporate culture

Reference: pages 237-239, 242-246 (Annex 2 index lists G1-1 at page 237).

Instruments (pages 238, 242-243): the Code of Ethics, adopted by the Board within 90 days of appointment under GEO No. 109/2011, establishing "integrity, professionalism, responsibility, transparency, impartiality and confidentiality"; the Corporate Governance Code, which "regulates the structure and responsibilities of the governing bodies, the risk management and internal control system, the principles regarding the remuneration of administrators"; the Internal Regulation; the Sustainable Corporate Governance Policy; and the Cybersecurity Policy. The Code of Ethics and Corporate Governance Code were "significantly revised in 2025".

Oversight (page 237): the Ethics and Integrity Council, composed of executive directors plus internal audit representatives. "Any deviation from the provisions of the Code is considered an ethics incident and may lead to the application of disciplinary sanctions."

Whistleblower protection (pages 245-246): a procedure under Law No. 361/2022 allowing confidential and anonymous reporting, with confirmation within seven days; retaliation is prohibited, with eleven listed prohibited actions.

Training (pages 237-238, 246): in 2025 an internal session attended by 69 directors and managers, plus Code of Ethics and Integrity Plan training for 584 employees each.

Management of relationships with suppliers

Reference: pages 247-248 (Annex 2 index lists G1-2 at page 247).

Policy (page 247): the Sustainable Procurement Policy "reflects a commitment to minimizing environmental impact, promoting high ethical standards and contributing to the development of the communities in which it operates", with objectives focused on "prioritizing suppliers that provide products and services with a lower carbon footprint, recyclable materials and sustainable packaging". Ethical practices are promoted "by selecting partners who comply with international and national legislation regarding human rights, fair labor practices and the prohibition of forced labor or child exploitation, with periodic verification through audits".

Supplier assessment (page 248): "in 2025 the company carried out an evaluation targeting suppliers representing approximately 80% of its total procurement expenditure", through a recognised platform and dedicated questionnaires. Over 42% of the cohort was classified low risk, average ESG score 3.06 out of 5 (page 107); coverage is to rise to approximately 90% of spend over two years (page 69).

A stated gap (page 248): "social and environmental criteria have not been integrated into the supplier approval process".

Late payment (page 247): liquidity risk management plus synchronisation of import and export flows so supplier payments track export collections.

Prevention and detection of corruption and bribery

Reference: pages 239-242 (Annex 2 index lists G1-3 at page 239).

Framework (page 239): the Code of Ethics and the Code of Conduct for Business Partners "establish the principle of zero tolerance for corruption, bribery or fraud, prohibit the abuse of position and require strict compliance with the applicable legal framework". The company states that it "does not have a distinct anti-corruption policy explicitly formulated with direct reference to the United Nations Convention against Corruption", relying instead on the Declaration of adherence to the National Anti-Corruption Strategy 2021-2025 (GD No. 1269/2021), which "transposes at national level some of the principles of the United Nations Convention against Corruption".

Training (pages 240-242): 22 internal sessions of at least one hour attended by 584 employees (10 at-risk-function managers, 51 operational managers, 523 other workers), plus 91 e-learning "Compliance" participants. "In 2025, 100% of the functions exposed to risk were covered by training programs." New employees are enrolled within three months and must pass a final test.

At-risk functions (page 239): "sales, procurement, finance and accounting, investments and human resources", where third-party interactions and resource allocation decisions concentrate.

Targets related to business conduct

Back-filled from the business conduct chapter (MDR-T). G1-3 Targets became a standalone DR only in the 2025/2026 ESRS; this report was prepared under the 2023 ESRS (page 40).

Antibiotice discloses no dated, measurable outcome target for business conduct. Consistent with MDR-T's alternative limb, effectiveness is tracked through coverage and outcome indicators.

Coverage achieved in 2025 (pages 241, 246): "In 2025, 100% of the functions exposed to risk were covered by training programs, including both members of the Executive Board and company managers"; 22 anti-corruption sessions attended by 584 employees; Code of Ethics and Integrity Plan training for 584 employees each.

Culture measurement, new in 2025 (page 244): the climate survey "for the first time, included items specifically designed to measure the extent to which employees are aware of, adhere to and apply the organization's values. The results showed that more than 68% of respondents had integrated these values, a score classified as 'good'."

Outcome for the year: no corruption incidents, convictions, fines or sanctions (pages 38, 240).

Effectiveness is "evaluated annually through feedback surveys" (page 241).

Supplier adhesion (page 244): "By the end of December 2025, more than 76% of the targeted suppliers had signed adhesion agreements or confirmed compliance."

Incidents of corruption or bribery

Reference: page 38 (Annex 2 index lists G1-4 at page 38) and page 240.

A complete nil return, given in the corporate governance chapter (page 38):

• "Corruption incidents recorded: none"
• "Employees dismissed or sanctioned for corruption related acts: none"
• "Contractual relationships terminated due to corruption related reasons: none"
• "Legal actions initiated in court regarding suspected corruption: none"

The same position is stated in the G1 chapter: "During the reporting period, no convictions were recorded at Antibiotice for violations of legislation regarding the prevention and fight against corruption and bribery. Likewise, the company was not subject to fines or other administrative or criminal sanctions related to such acts, which reflects the functioning of the internal prevention and control mechanisms" (page 240).

Supporting nil returns on page 38: "During 2025, no reports regarding ethical incidents were recorded"; "no public interest whistleblowing reports were recorded and no notifications regarding breaches of ethical principles, internal procedures or applicable legislation were received"; and "no reports regarding conflicts of interest were recorded".

Antibiotice is a public enterprise majority-owned by the Ministry of Health (53.02%, page 4) and has adopted the Declaration of Adherence to the National Anti-Corruption Strategy 2021-2025 (page 38).