Artego S.A.

The role of the administrative, management and supervisory bodies

Reference: printed pages 7-8 and 74-75.

Artego prints a short GOV-1 section. "The company is led by the General Meeting of Shareholders and managed by a Board of Directors consisting of 3 members" (page 7): one executive member, David Viorel, "graduate of the Iasi Polytechnic Institute, Faculty of Chemistry and Chemical Engineering, specialization in physical chemistry of polymers", and two non-executive members, Anglitoiu Florian (Bucharest Polytechnic Institute, chemical engineering) and Buse Diana Loredana (Bucharest Academy of Economic Studies, management) (pages 7-8).

The same three-member composition is repeated in the G1 chapter under the heading "The role of administrative, management and supervisory bodies / ESRS 2 GOV-A", where the Board is described as having "a management and supervisory role, being permanently trained in matters related to professional conduct" (page 74).

What is missing. There is no board committee structure, no allocation of sustainability responsibility to a named role or committee, no statement of the bodies' sustainability expertise, and none of the ESRS 2 paragraph 21 composition and diversity datapoints (gender split, ratio of executive to non-executive members, independence). The gender composition can only be inferred from the three names, which the report does not do itself.

Statement on due diligence

Reference: printed page 22.

Artego prints a section headed "DUE DILIGENCE PROCESS STATEMENT / GOV-4". It anchors due diligence in the company's Integrated Management System, which "addresses the issues of Quality, Environment and Operational Health and Safety, which applies throughout the company", monitored "through internal and external audits, as well as ensuring the achievement of environmental objectives and targets" (page 22).

The section then lists "the main elements of the due diligence process":

• "Incorporating the due diligence process into governance, strategy and business model"
• "Collaborate with affected stakeholders at all key stages of the due diligence process"
• "Identification and assessment of negative impacts"
• "Taking steps to address these negative impacts"
• "Tracking the effectiveness of these efforts and communicating"

Those five bullets restate the ESRS 2 GOV-4 core elements. What the section does not give is the mapping ESRS 2 asks for: it does not say where in the statement each of the five elements is disclosed, and it gives no page or paragraph cross-references.

Risk management and internal controls over sustainability reporting

Reference: printed pages 22 and 79-80.

Two passages address this. The first, headed "Risk management and internal controls related to sustainability reporting / IRO 1" (page 22), is a plain admission: "At the Company level, a risk register has not yet been developed according to ESRS standards, the main risk categories are presented within the Sustainability Report in order to minimize the impact of high-severity risks for the year 2025, relating to risks of compliance with legal provisions and operational risks." The company adds that "An ESG risk register will be developed as the basis of the Company's strategy in 2026" and that the process has begun, "which was presented in a narrative form above" (page 22).

The second carries the GOV-5 code (page 79) and runs into the digital security chapter: "The company aims to improve the analysis of IT risks by assessing risks in the context of an analysis of the external and internal environment, from the point of view of the impact but also of the financial significance of risks and opportunities. The risks associated with digital security are identified internally and will determine appropriate actions to minimize inherent risks in 2025. These actions are implemented at the level of departments, responsible persons and implementation deadlines" (page 80).

Gap. Neither passage describes the scope, main features or components of the internal control and risk management processes over sustainability reporting itself, the risk assessment approach applied to the reporting process, or how findings are reported to the Board.

Strategy, business model and value chain

Reference: printed pages 8-16.

Four consecutive sections carry the SBM-1 code: Company location (page 8), Description of the company's activity (pages 9-11), Description of technological processes (pages 12-14), Business model (pages 14-15) and Strategy (pages 15-16).

Artego is a technical rubber goods manufacturer on the northern industrial platform of Targu Jiu, Gorj County, on a site of "approximately 20,000 m2" (page 8). "In Romania, the Society is the leader on conveyor belt market" (page 9). Products are conveyor belts with textile or metal inserts (general purpose, underground and fire-resistant, temperature-resistant for cement and steel, food-industry, oil-resistant, aramid), technical plates, mats, pressed and injected gaskets, plastics and jointing solutions, plus rubber waste collection and regeneration, used-oil treatment, dairy, bakery and tailoring lines (pages 9-10, 14).

Value chain. Named upstream suppliers include "Gotera 2012 SA Tg. Jiu - natural rubber, zinc oxide, sulfur; Premier Energy Furnizare SA - natural gas; Nova Power GAS SRL - electric energy; Sunchemy International China - antioxidants, accelerators; EP Belt Doo Serbia - fabrics; LG Chem Europe Poland - nitrile rubber; Caucho LTD Bulgaria - carbon black; Stera Chemicals SRL - SBR rubber" (pages 14-15). Named customers include "Complexul Energetic Oltenia, Masanes Servindustria SA Spain, FMD Germany, Lutze International Europe Germany, Primogum Aktiebolag Sweden, Muller Beltex BV Netherlands, Steadfast Resource Development Ltd England, Metroseal Rochford England, Ites Gummi-und Dichtubgstechnik Germany, Siban Peosa SA Spain" (page 15).

Turnover for 2025 is "131,357,355 lei, of which the sale of dairy products 3,208,791 lei (2.44%), bakery 104,255 lei (0.08%) and tailoring 1,143,245 lei (0.87%)"; the statement scopes itself to rubber, since the other lines "will not be analyzed from the point of view of sustainability aspects" (page 15).

Gap. No breakdown of turnover by ESRS sector, no employee headcount by geography under SBM-1, and no value chain map or diagram.

Interests and views of stakeholders

Reference: printed pages 15-16, 65, 68 and 71.

There is no single stakeholder chapter. The SBM-2 code appears at the head of three topical chapters.

• Value chain workers (page 65): "The Company's activities do not affect employees in the value chain. The Company collaborates with local and international suppliers for the purchase of raw materials and equipment. As a result of signing the contract with the Company, each supplier undertakes to respect human rights, as well as other obligations established at national and international level (the Universal Declaration of Human Rights and the United Nations Convention on the Rights of the Child, as well as the International Labor Organization Conventions)."
• Affected communities (page 68): "The Company respects the views of the communities that could be affected by its activities... The communities that could be affected by the Company's activities are individuals, legal entities, industry, public institutions and public authorities. The Company's strategy and business model are built around respecting these views and interests."
• Consumers and end-users (page 71): consumers "are represented by individuals, legal entities, authorities and public institutions located in the Municipality of Tg. Jiu and the surrounding areas", and their interests "are integrated into the Company's business model, but a specific strategy has not been established, according to the requirements of the ESRS standards".

The strategy section adds a general commitment to "a partnership system to consistently guide the Company towards satisfying the needs of relevant stakeholders" (pages 15-16).

Gap. No stakeholder identification or prioritisation method, no description of how engagement is organised or how often it happens, no account of how the results changed the strategy, and no statement of how the administrative bodies are informed of stakeholder views.

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

Reference: printed pages 28-29, 60-61, 65-66, 68, 72-73 and 80.

Artego does not present a consolidated material IRO list. Instead an SBM-3 block opens each topical chapter and is followed by a per-topic impacts, risks and opportunities table (Figures 2 to 13).

For climate (pages 28-29) the SBM-3 text names the impacts as "Greenhouse gas emissions (Scope 1 and 2) from: Rubber-specific technological processes, Large energy-consuming machinery (presses, extruders, autoclaves); Indirect emissions from Scope 3: Procurement of natural rubber, synthetic polymers, carbon black, Transport of raw materials and finished products"; the risks as carbon costs from rising energy prices and "Future carbon taxation or ETS expansion", physical risk of "Disruptions in natural rubber supplies due to climate-related events", and transition risk of "Customer pressure (especially automotive OEMs) for low-carbon components"; and the opportunities as energy efficiency, renewable electricity, low-carbon compounds and "Competitive advantage over customers subject to Scope 3 reduction targets".

The same structure runs through S1 (page 60), S2 (pages 65-66), S3 (page 68), S4 (pages 72-73) and the entity-specific digital security topic (page 80), where the risks are "Penetration of physical and cyber protection system... Unauthorized access to confidential data".

The sector-level IRO register on pages 20-21 sets out the same material for all ten topical standards in narrative form.

Gap. The tables give no time horizons, no distinction between actual and potential impacts, and no explanation of how each IRO originates in or connects to specific parts of the business model. Financial effects are given only as an adjective per topic ("medium to large negative", "medium", "low").

Processes to identify and assess material impacts, risks and opportunities

Reference: printed pages 22-24, 36, 45-46, 49-50, 54 and 76.

The method is set out under "DOUBLE MEANING - BASIS FOR REPORTING INFORMATION / IRO-1" (page 23). Artego reports "based on the dual meaning principle, as defined and explained in the ESRS 1 standard", covering impact materiality and financial materiality, and states that impacts "include those related to the enterprise's own operations and its value chain, including through its products and services, as well as its business relationships".

Scoring is disclosed. Impact materiality: "Severity = Scale x Scope x Irremediability (rated on a scale of 1-5); Probability = Likelihood of occurrence (rated on a scale of 1-5)" (page 23). Financial materiality: "Magnitude = EBITDA / cash flow impact (rated on a scale of 1-5); Probability = Likelihood (rated on a scale of 1-5)" (page 24).

Results are tabulated. Two DMA summary tables on page 24 score every topical standard on impact, risk, financial magnitude and financial probability and give a Material? verdict: E1 material, E2 material, E3 "Probably NOT", E4 material, E5 material, S1 material, S2 "On the edge", S3 "NOT", S4 material, G1 material.

Per-topic IRO-1 blocks describe the process by which each topic's table was built - for pollution, "Risks are identified and assessed within the internal management process, and then control measures and actions are established to reduce their impact. Internal control and monitoring tools are assigned to each identified risk, which are recorded within a Register of the Company's environmental aspects" (page 36), with a list of the eleven environmental factors screened. Water, biodiversity and circular economy each describe "an internal analysis process organized together with management employees, as well as by consulting other sources of literature, operating authorizations and the internal risk register" (pages 45-46, 49-50, 54).

Gap. No thresholds are stated for the 1-5 scales, no time horizons, no stakeholder or expert input to the scoring, and no description of how the process is integrated into the company's ongoing risk management - the company states plainly that no ESRS risk register exists yet (page 22).

Transition plan for climate change mitigation

Reference: printed pages 31-32; context pages 28, 30.

The company's E1-1 disclosure is a nil return. Under the heading "Transition plan for climate change mitigation / ESRS E1-1": "As of the 2025 reporting year, there was no transition/emissions reduction plan within the Company, in accordance with the requirements of the ESRS standard. The Company's climate strategy is under preparation and will include policies, targets and a transition/emissions reduction plan, and their adoption is planned for 2026" (page 31).

The remainder of the section (pages 31-32) paraphrases what ESRS E1-1 asks for - a high-level explanation of how the undertaking will adjust its strategy and business model to be compatible with limiting warming to 1.5 degrees C under the Paris Agreement and climate neutrality by 2050 under Regulation (EU) 2021/1119 - without answering any of it.

Two other statements bear on the same point. In the E1 strategy section: "For 2025, the Company does not have a strategy adapted to the ESRS requirements, as well as a business model that addresses climate change. A new strategy will be prepared in the coming period" (page 28). And on targets: "The Company's climate strategy will include policies, objectives/targets and a transition/emission reduction plan, including adaptation, and their adoption is planned for 2025. For 2025, the Company has not set GHG emission reduction targets, these will be set according to the ESRS standards" (page 30).

The two adoption dates conflict: page 30 says adoption is "planned for 2025", page 31 says 2026.

Gap. None of the ten E1-1 content items is present: no decarbonisation levers with quantified effects, no locked-in emissions assessment, no investment or funding plan, no board approval statement, and no statement on exposure to coal, oil and gas activities. The only exclusion statement offered is unrelated: "Our company does not meet the requirements of Directive 2009/29/EC because the combustion plant has a nominal installed thermal power below 20MW" (page 29).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 SBM-3 and IRO-1, where this content is disclosed in the FY2025 report (printed pages 20, 28-29, 30-31). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risk identification and classification (paragraph 15). Artego separates its climate risks into the two required categories without using the ESRS labels for the split. Transition risks: "Exposure to carbon costs from: Rising energy prices; Future carbon taxation or ETS expansion" and "Customer pressure (especially automotive OEMs) for low-carbon components", plus an energy-specific row, "Transition risk: Increase in energy purchase tariffs if no investment is made in green technologies" (pages 29, 31). Physical risks: "Disruptions in natural rubber supplies due to climate-related events and supplier shortages" upstream, and for the site itself, "Physical risk: Climate change may have a potential negative impact on water supply and sanitation infrastructure (severe weather conditions, reduced water quality, flooding, increased costs to ensure the required water quality)" (page 31).

Methodology (paragraph 16). Only the generic DMA process is described: the climate IROs "were identified... These were subsequently assessed as part of the dual materiality analysis process in an internal workshop and by consulting other relevant sources, such as environmental authorization. Depending on the probability of occurrence and the potential magnitude of the financial effects generated in the short, medium and long term, the Company determines the significant aspects" (page 30). No screening of assets or activities for exposure and sensitivity, no asset-level or location-level analysis, and no separate treatment of upstream and downstream exposure beyond the natural rubber supply reference.

Scenario analysis (paragraph 17). None was performed. The statement names no climate scenario, no high-emission physical scenario, no 1.5 degrees C transition scenario, no temperature projection and no date of analysis. Because paragraph 17 applies only where scenario analysis was used, its absence is not itself a failing - but the paragraph 16 methodology it would otherwise support is also missing.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the E1 climate chapter, where this content is disclosed in the FY2025 report (printed pages 28-31). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

No resilience analysis as defined by ESRS E1 has been performed. The statement contains no results of a climate resilience assessment, no areas of uncertainty and no analysis of the capacity to adjust or adapt over short, medium and long horizons.

What the report does say bears directly on paragraph 19(a)(i), the implications for strategy and business model, and it is negative: "For 2025, the Company does not have a strategy adapted to the ESRS requirements, as well as a business model that addresses climate change. A new strategy will be prepared in the coming period and will be aligned with the new requirements of the ESRS standards" (page 28).

Adaptive capacity is touched on once, in the E1 IRO table under the "Adaptation to climate change" row: "Potential negative impact on the Company's activity as a result of climate change. The degree of adaptation to extreme conditions may generate a negative impact, but it is not major" (page 31). The same row carries the only physical-risk pathway the company identifies for its own site, on water supply and sanitation infrastructure.

Elsewhere the company asserts resilience without evidence: "The activity carried out within the Company does not lead to an increase in the negative effect of the current and future climate on the environment, people or buildings. The interventions and modernizations carried out demonstrate that there are no major negative influences regarding this environmental objective on the company's activity or on people, nature or assets" (pages 29-30). No modernisation is named, dated or costed in support of that claim.

Gap. Everything paragraph 19 asks for beyond the strategy statement above: scenario-informed effects, uncertainty, financial flexibility, and the ability to redeploy, repurpose, upgrade or decommission assets.

Policies related to climate change mitigation and adaptation

Reference: printed page 34; also page 29.

Artego prints a section under this exact title and states plainly that no climate policy exists: "No specific policies have been formulated for the Climate Change area, these will be formulated as part of the development of the Company's climate strategy and transition/emission reduction plan in 2026. In 2025, a responsible person was not designated to be responsible for the implementation of a climate change policy" (page 34). The same admission appears in the E1 strategy section on page 29.

What exists instead is a general Environmental Policy, described as the company's commitment "to minimize the impact on the environment through measures such as: establishing environmental objectives and targets, supervising compliance with sanitary protection zones, conserving natural resources, reducing the risks of degradation for the Artego SA site and neighboring ones, reducing the risks of pollution of environmental factors, and ensuring that contractors comply with legal environmental requirements" (page 34). None of those measures is climate-specific.

The section also records that "The Company reported based on the requirements of the new ESRS standards for the first time in 2024" (page 34).

Gap. With no climate policy there is nothing to disclose against the MDR-P content: no scope, no accountability at the highest level, no reference to third-party standards, no stakeholder consideration, and nothing on how the policy is made available. The company's only stated coverage of the E1 sub-topics - mitigation, adaptation, energy - is the DNSH commitment: "In carrying out its activity, the Company adheres to the principle of 'Do No Significantly Harm' (DNSH) and environmental objectives are established" (page 29).

Actions and resources in relation to climate change policies

Reference: printed page 34; also pages 29 and 32.

The section headed "Actions and resources related to climate change policies" contains two actions, neither resourced:

• Awareness raising. "As a result of the activities carried out, a significant amount of electrical energy is used. In 2025, the aim was to raise the awareness of the personnel who carry out their activities within the framework of the Company's objectives regarding the importance of reducing energy consumption through the responsible use of electrical energy" (page 34).
• Renewable generation. "Recently, electricity prices have increased significantly, which is accelerating the Society's efforts to ensure energy independence, with an increasing emphasis on the production of green energy from renewable sources" (page 34).

The only dated, quantified actions sit in the E1-4 section and are historic: "In 2023, a photovoltaic park of 399.15 KWh was put into operation on 28.02.2023, and in 2024, a photovoltaic park of 0.9999 MWh was put into operation on 19.08.2024. In 2025, no investments were made in this direction" (page 32).

Page 29 adds a forward statement without a plan behind it: "The company has initiated actions to improve energy efficiency and evaluate renewable energy supply to reduce emissions and mitigate transition risks... GHG emissions can be reduced as a result of the use of photovoltaic panels."

Gap. No current or planned CapEx or OpEx attached to any action, no expected GHG reduction per action, no time horizon, no link to the EU Taxonomy CapEx or OpEx key performance indicators, and no distinction between mitigation and adaptation actions.

Targets related to climate change mitigation and adaptation

Reference: printed pages 32-33; also page 30.

The E1-4 section is a nil return with a small indicator table. "There are no targets set according to ESRS for the next period. An Environmental Management Program has been implemented at the Company level, which defines a series of objectives, targets, measurable indicators and persons responsible for implementing measures, applicable to the different environmental aspects on which the company has an impact, the stage of achievement being monitored periodically" (page 33). Page 30 repeats: "For 2025, the Company has not set GHG emission reduction targets, these will be set according to the ESRS standards."

The E1-4 table (page 32) reports four key indicators for 2024 and 2025:

The GHG row is blank for both years. The renewable row gives a percentage for 2024 only; the 2025 figure is a bare number with no unit stated in the table, though the surrounding text treats these values as kWh.

Gap. No base year, no absolute or intensity reduction target, no 2030 or 2050 target, no gross target statement, no sectoral decarbonisation pathway, and no statement of whether the targets are science-based. Adaptation targets are likewise absent.

Energy consumption and mix

Reference: printed pages 33-34; also page 32.

The E1-5 section prints a month-by-month electricity consumption table for 2024 and 2025 in kWh and in lei excluding VAT (pages 33-34). The totals are 8,664,725 kWh costing 6,509,873.57 lei in 2024, against 7,319,794 kWh costing 6,727,478.09 lei in 2025 - a 15.5% fall in volume with a 3.3% rise in cost, consistent with the company's statement that "electricity prices have increased significantly" (page 34). Monthly 2025 values run from a low of 370,362 kWh in April to a high of 799,840 kWh in March.

The E1-4 indicator table adds the aggregate: total energy consumed 104,252.35 GJ in 2024 and 71,840.20 GJ in 2025, and solar electricity consumption of 773,109 in 2024, described as "8.92%" of total, rising to 1,334,887 in 2025 (page 32). Self-generation capacity is a 399.15 kWh photovoltaic park commissioned 28.02.2023 and a 0.9999 MWh park commissioned 19.08.2024 (page 32).

The E1 chapter also states that the company's combustion plant "has a nominal installed thermal power below 20MW" and so falls outside Directive 2009/29/EC (page 29). Natural gas is purchased from Premier Energy Furnizare SA and Premier Energy SA, and electricity from Nova Power GAS SRL (pages 14-15).

Gap. No split of total energy consumption between fossil, nuclear and renewable sources; no separate fuel consumption figures despite natural gas and diesel both being purchased (42,955 kg of diesel is reported in the hazardous substances table, page 42); no energy intensity per net revenue; and no statement of whether the company operates in a high climate impact sector.

Policies related to pollution

Reference: printed page 38; context pages 35-36.

The section headed "Pollution-related policies / ESRS E2-1" is candid about its own status: "The company has not yet developed a Policy in accordance with the provisions of the ESRS standards, but it has an Environmental Management Program in which a series of objectives are defined, with targets, measurable indicators and persons responsible for implementing the measures. The year 2024 was the first reporting year in accordance with the requirements of the ESRS standards. In 2025, the SMI policy is updated according to the requirements of the standard regarding environmental pollution factors" (page 38).

The policy framework that does exist is the certified Integrated Management System, "unitary from a technical, organizational and functional point of view", built "on risk management, in accordance with the requirements of the reference standards: SR EN ISO 9001:2015, SR EN ISO 14001:2015 and SR EN ISO 45001:2023, with applicable legal regulations in force" (page 38). The company "holds a certificate for the Environmental Management System and maintains its certification according to the ISO 14001:2015 standard" (page 27). Alongside it sits a major accident prevention policy, which "aims to prevent major impact accidents caused by hazardous substances, as well as to limit their consequences on the health of the population and the environment", with stated objectives covering plant safety, "optimal management starting with the supply, storage, handling and use of hazardous substances and materials", compliance with major-accident legislation, contracted waste recovery and staff training (pages 35-36).

Gap. No policy scope or exclusions, no accountability at the most senior level, no reference to substances of concern or substances of very high concern in the policy itself, and nothing on how the policy is made available to those who must implement it.

Actions and resources related to pollution

Reference: printed pages 38-39; context pages 26-27.

The E2-2 section describes control through the Environmental Management Program rather than through named projects: "The Company has developed an environmental management system that is applied to ensure the protection and control of the environment during the performance of activities with potential direct or indirect impact on the environment. For each identified environmental aspect, the Company has established clear measures and established responsible persons so that environmental risks are eliminated. Thus, all requirements imposed by the authorities through regulatory acts or results of controls are 100% monitored through the Environmental Management Program" (pages 38-39).

The environmental section that precedes E2 sets out the concrete measures taken in 2025 (pages 26-27): in hazardous substances management, "displaying the hazards mentioned in the Safety Data Sheets where these substances are used"; in pollution prevention, "training of personnel with the Intervention Plans in case of accidental pollution"; in waste management, "proper labeling of containers, preparation of documents related to legislation, proper storage of all waste". Monitoring under the environmental permit covers nitrogen oxide emissions from the medium combustion plant, dust emissions at the dosing and mixing section, and physical and chemical determinations of technological water (page 27).

External verification. "In 2025, the Company was the subject of external inspections, carried out by the control structures within the National Environmental Guard, Jiu Water Administration, Rina Simtex Bucharest, APM, ISU... Following the controls and inspections, no sanctions were applied, only improvement measures were established, as evidenced by the inspection reports of the control authorities" (page 27).

Gap. Resources are described only as "various types of environmental services were purchased: physico-chemical analysis services for technological waters; services for domestic water treatment; dust analysis services, as well as services regarding waste recovery" (page 27), with no amounts. No action is dated, costed or linked to an expected pollution reduction.

Targets related to pollution

Reference: printed pages 39-43.

Artego states that its pollution targets are its permit limits and nothing more: "For the specific activity of the Company, the targets are represented by the limits imposed by the Environmental Authorizations issued according to the legislation in force. No other targets have been established in relation to the regulated limits, as regards the subject of Pollution." Measured values "are permanently monitored according to the frequencies imposed by the regulatory acts", by the company's own RENAR-accredited laboratories and by other RENAR-accredited laboratories (page 39).

The section then prints the 2025 results against those limits (pages 39-40):

Sedimentable dust is measured monthly at three sampling points against a limit of 17 g/m2/month; the twelve 2025 readings run from 1.0 to 6.69, all inside the limit (pages 40-41).

For water: "Water discharges: The quality indicators analyzed are in accordance with the Water Management Authorization (test reports attached)" and "Targets established for waste water: The indicators analyzed for waste water are in accordance with the Water Management Authorization, authorization obtained annually" (pages 39, 43). For soil: "Targets set for the environmental factor soil: Not applicable" (page 43).

Gap. No target is expressed as a reduction against a baseline, none has a target year, and none is stated to be more ambitious than the legal minimum. No wastewater quality values are printed even though the report says test reports are attached.

Pollution of air, water and soil

Reference: printed pages 39-43; context pages 26-27 and 36-38.

The pollutant data Artego publishes sits inside the E2-3 targets section rather than under an E2-4 heading, and it is a concentration-against-limit table rather than a mass-emitted inventory.

Air. Nitrogen oxides from the thermal power plant measured 178 mg/Ncm against a 200 mg/Ncm limit under Law no. 188/2018, monitored once every three years; powders at the dosing section measured 1.1 mg/Ncm against a 50 mg/Ncm limit, monitored annually (pages 39-40). Sedimentable dust is measured monthly at three sampling points against a 17 g/m2/month limit, with 2025 readings between 1.0 and 6.69 (pages 40-41). The 2025 monitoring programme under the environmental permit covers exactly these: nitrogen oxides from medium combustion installations and dust at the dosing and mixing raw materials section (page 27).

Water. No values are published. The company states only that "The quality indicators analyzed are in accordance with the Water Management Authorization (test reports attached)" (page 39) and that physical and chemical determinations of technological water are carried out (page 27). Industrial wastewater requiring treatment is discharged "into the Jiu River through the Hodinau stream"; domestic and dairy wastewater goes to the Targu Jiu sewerage system (page 45).

Soil. "Targets set for the environmental factor soil: Not applicable" (page 43).

The E2 IRO table treats air, water and soil pollution as three separate material sub-topics, each a potential negative impact arising in accidental or major-event conditions (pages 36-38), and the company states that "Environmental pollution can only occur under accidental conditions, and in such conditions it was of a local nature" (page 36).

Gap. No amounts of any pollutant emitted in tonnes, no reference to Annex II of the E-PRTR Regulation, no microplastics, no emissions to soil, and no breakdown between own operations and value chain. The company also pays "monthly fees for emissions of pollutants into the atmosphere, hazardous substances and oil introduced on the domestic market" to the Environmental Fund (page 27) but does not publish the underlying quantities.

Substances of concern and substances of very high concern

Reference: printed pages 41-42; IRO table pages 37-38.

ESRS E2 paragraph 34 requires two limbs joined by "and": "the total amounts of substances of concern that are generated or used during the production or that are procured, and the total amounts of substances of concern that leave its facilities as emissions, as products, or as part of products or services split into main hazard classes". Paragraph 35 adds that information on substances of very high concern must be presented separately.

Artego answers the first limb and not the second. Under the heading "3. MANAGEMENT METHOD FOR DANGEROUS SUBSTANCES AND PREPARATIONS" the statement prints a table of 26 named chemical substances with the quantity used in 2025 in kilograms (pages 41-42). The largest entries are used oil 307,333 kg, oil for the rubber industry (base oil) 221,240 kg, chloroparaffin K70 99,230 kg, zinc oxide 82,248 kg, diesel 42,955 kg, CBS accelerator 25,495 kg, antioxidant IPPD 19,098 kg, toluene (TBA solvent) 18,251 kg, antimony trioxide 10,862 kg, cobalt octoate 5,959 kg, DM accelerator (MBTS) 5,473 kg, ethyl acetate 5,007 kg, DPG accelerator 4,497 kg, hydrochloric acid 2,410 kg and ammonia water 2,400 kg, plus gases (oxygen 1,518 m3, Corgon 283.2 m3, acetylene 320) and several substances recorded at zero (resorcinol 80 SBR, M-accelerator, chloroparaffin K52, tar, hydrazine).

The E2 IRO table treats substances of concern as a material sub-topic - "Potentially negative impact in the situation where hazardous substances are not managed or stored properly", with the risk of "improper storage and disposal of chemical substances used in the production process" and "significant remediation costs" (pages 37-38). The substances of very high concern and microplastics rows of that table are left blank.

Gap. No outflow figures at all: nothing on substances of concern leaving the facilities as emissions, as products or as part of products. No split into main hazard classes. No separate presentation for substances of very high concern under paragraph 35, and no statement that none are used. The table is also headed as a management method and sits inside the E2-3 targets section, not under an E2-5 label.

Anticipated financial effects from pollution-related impacts, risks and opportunities

Reference: printed pages 43-44.

The section is labelled "Anticipated financial effects of pollution-related impacts, risks and opportunities / ESRS E2-6" and is a declared non-quantification: "The anticipated financial effects of significant physical and transition risks and potential opportunities related to soil, water and air pollution are not assessed or quantified in detail. Their relevance and significance have been noted in the dual materiality analysis" (page 44).

The company gives its reason and its plan: "The Company's environmental aspects register includes a series of risks that will be re-analyzed and aligned with the ESRS reporting requirements in the next period, with 2024 being the first year of reporting based on the new ESRS standards" (page 44).

The qualitative assessment that stands in its place is on page 38: "The financial effects on the Company in the short, medium and long term of the significant risks and opportunities arising from the impacts associated with pollution have been assessed as material within the dual materiality process." The DMA summary table scores E2 on 1-5 scales with financial magnitude 3 and financial probability 3 (page 24). The risks the company expects to carry a financial consequence are named in the E2 IRO table: costs for pollutant emissions discharged, more restrictive discharge conditions, reputational risk from odorous discomfort, "significant litigation and/or remediation costs", fines for soil pollution, and damage to the water supply and sewage system (pages 36-38).

Gap. No monetary amounts, no ranges, no time horizons, no assets or activities at material risk identified, and no quantified operating or investment cost associated with pollution prevention and control.

Policies related to water and marine resources

Reference: printed page 47. Disclosed voluntarily: Artego's own double materiality assessment records E3 as "Probably NOT" material (page 24).

The section headed "Marine resources policies" points to the Integrated Management System rather than a dedicated water policy: the company "has implemented an Integrated Management System in accordance with the requirements of the reference standards: SR EN ISO 9001:2015, SR EN ISO 14001:2015 and SR EN ISO 45001:2023, with applicable legal regulations in force, taking into account the requirements of customers and stakeholders" (page 47).

Four water-related topics are stated to be addressed by that policy:

• "supervision of compliance with sanitary protection zones"
• "reducing the risk of pollution"
• "achieving the conditions for the organization's compliance with legal environmental requirements and those of interested parties"
• "Continuous identification of environmental aspects generated by the organization's activities and initiation of actions with a view to reducing their impact on the environment"

The section closes: "Through integrated management systems and environmental and water management authorizations, the Company assumes responsibility for managing water resources in a sustainable manner, with a view to respecting water quality indicators and protecting ecosystems and human health" (page 47).

Gap. No policy on water use, water recycling, wastewater treatment beyond permit compliance, product design for water efficiency, or sustainable oceans and seas. No statement on whether the policy addresses areas at water risk, and no accountability or availability statement.

Actions and resources related to water and marine resources

Reference: printed pages 45 and 47. Disclosed voluntarily: E3 is recorded as "Probably NOT" material in the DMA summary table (page 24).

The actions section states that "The actions related to water resources that the Company intends to take are correlated with the measures provided for in the existing Company Policy. Thus, regarding sanitary protection zones, the Company is obliged by the legislation and regulatory acts held to establish the respective zones for all its objectives that are directly related to water. Through the actions it permanently takes, the Company ensures that the risk of water pollution is reduced to a minimum. The Company carries out monitoring of the managed waters. All environmental aspects identified within the Company are periodically evaluated with a view to reducing their impact on the environment" (page 47).

The one operational measure with a figure attached is described earlier in the chapter: the internal recirculation rate of technological water is 58%, covering "the regenerated rubber sections and workshops, dosing-mixing, pressed gaskets, oxygen" (page 45). The chapter also describes the water infrastructure: drinking water from the municipal network under a contract with Aparegio Gorj SA; process water from three groundwater wells and from a Jiu River surface abstraction with treatment, conveyance and storage; firefighting water from tanks of 1,500 cubic metres supplying 58 external hydrants; separate collection of domestic and industrial wastewater; and pre-treatment stations used "in special cases that require these treatments" (page 45).

Gap. No action is dated, resourced or attributed to a responsible function; no CapEx or OpEx figure; and no expected effect on withdrawal, consumption or discharge. The section is written in the future and conditional tense throughout.

Targets related to water and marine resources

Reference: printed page 48. Disclosed voluntarily: E3 is recorded as "Probably NOT" material in the DMA summary table (page 24).

The section is headed "ESRS E-3, ESRS MDR-T" and opens with a nil return: "No targets have been set for water resources, in accordance with the provisions of the ESRS E3 - Water and Marine Resources standard. For the specific activity of the Company, the targets are represented by the maximum permitted values that must be met according to the environmental and water authorizations held" (page 48).

One indicator is tabulated:

The company frames this as part of "a series of targets and measures for water management for 2025, to strengthen the implementation of an Integrated Management System" (page 48).

Gap. No target relates to water withdrawal, consumption, discharge or recycling; none has a base year, a target year or a level of ambition; and none is stated to be more demanding than the permit limits. The single indicator measures compliance monitoring, not water performance.

Anticipated financial effects from water and marine resources-related impacts, risks and opportunities

Reference: printed page 48. Disclosed voluntarily: E3 is recorded as "Probably NOT" material in the DMA summary table (page 24).

The section carries the E3-5 code and is a declared non-quantification with a materiality qualifier attached: "The anticipated financial effects of the risks and opportunities related to water resources have not been assessed or quantified in detail, with 2024 being the first reporting year under the new ESRS standards. Their relevance and significance was however noted in the dual materiality analysis as being at a low materiality level. The Company's environmental register includes a number of risks that will be re-analysed and aligned with the ESRS reporting requirements" (page 48).

The qualitative position is set out on page 47: the financial effects of water risks "are assessed as low, for the risks identified for the sub-themes of Water Extraction, Water Consumption and Discharges into Surface Waters", and "The Company's activity does not involve the use of waters from the seas and oceans and does not discharge wastewater into the seas and oceans, the Company having no impact on marine resources."

The risks that would carry a financial consequence, had they been quantified, are named in the E3 IRO table (page 46): a falling water table for groundwater sources and reduced easement flows downstream on the Jiu River; the risk of polluting the river if the wastewater treatment plant is operated improperly, "which may lead to criminal sanctions and reputational risks"; and higher raw water treatment costs where upstream pollution degrades the intake.

Transition plan on biodiversity and ecosystems

Reference: printed pages 50-51; context page 49.

The section headed "Transition plan and consideration of biodiversity and ecosystems within the strategy and business model / ESRS E4-1" answers with a legal compliance statement rather than a plan. It cites the framework the company operates under - "OM no. 1964/2007 on the establishment of the protected natural area regime for sites of community importance, as an integral part of the European ecological network Natura 2000 in Romania - amended and supplemented by OM no. 2387/2011" and "GEO no. 57/2007 regarding protected natural areas, conservation of natural habitats, wild flora and fauna approved by Law no. 49/2011" - and concludes: "The Company's facilities are not located in protected areas, sites or zones" (pages 50-51).

The chapter's opening section supports that with a site assessment: "The Company's location does not overlap with natural areas protected by community interest. Under normal operating conditions, the Company's activity has no impact on the characteristics of species on the land and the capacity to expand ecosystems, respectively impact and dependence on ecosystem services. Also, the Company's activity does not involve the direct exploitation of fauna and flora, nor does it lead to the emergence of exotic species. At the same time, the Company's activity does not lead to changes in land use, groundwater levels, salinization or habitat destruction." The nearest protected areas are named: "the Izbucu Jalesului Nature Reserve, the Izvernei Springs, the Jiu Gorge or the forested areas located near the locality" (page 49), with the site itself "in the Municipality of Targu Jiu, an anthropized area".

Gap. There is no transition plan. Nothing addresses alignment with the Kunming-Montreal Global Biodiversity Framework or the EU Biodiversity Strategy for 2030, and no target date, milestone or business model change is given. The upstream deforestation exposure the company itself identified - "Indirect impacts on biodiversity through: Supply of natural rubber (risk of deforestation in the supplying regions)" (page 20) - is not carried into this section.

Policies related to biodiversity and ecosystems

Reference: printed page 51.

The E4-2 section is a nil return: "Specific policies for biodiversity and ecosystems have not been formulated in accordance with the ESRS requirements, elements regarding these being included within the framework of integrated management systems or in specific work processes" (page 51).

The commitment that stands in place of a policy is a single sentence: "The company is committed to taking the necessary measures to monitor, evaluate and continuously improve environmental performance, prevent pollution, sustainably use resources and conserve biodiversity in its location" (page 51). Biodiversity also appears among the eleven environmental factors screened when environmental aspects are identified - "affecting biodiversity (fauna, flora)" (page 36) - and the ISO 14001:2015 certified Environmental Management System is the mechanism named for handling it.

Gap. With no biodiversity policy there is nothing to disclose on traceability of products, components and raw materials, on sustainable land and agriculture practices, on sustainable oceans and seas practices, or on deforestation - the four sub-topics ESRS E4 asks a policy to address. The natural rubber deforestation exposure named in the sector IRO register (page 20) has no policy response, and no third-party standard or certification scheme is referenced.

Targets related to biodiversity and ecosystems

Reference: printed page 51.

Two separate passages on the same page both state that no target exists. Under "Targets related to managing significant negative impacts, promoting positive impacts and managing significant risks and opportunities / ESRS E4-4": "The company did not set targets related to impact management during 2024 and 2025 because it was not necessary." The indicator table that follows has a single row with a dash for both 2024 and 2025. Under the second heading, "Biodiversity and ecosystem targets / ESRS E4-4": "No targets related to biodiversity and ecosystems have been set" (page 51).

The reason offered - "because it was not necessary" - is not developed, and sits awkwardly against the DMA summary table, which scores E4 at 4 on all four dimensions and records the Material? verdict as YES (page 24). The E4-5 section resolves the tension in the company's favour by asserting that "no significant impacts have been identified that would require the establishment of impact indicators related to biodiversity and ecosystems" (page 52), and the E4 IRO table qualifies each of its five estimated negative impacts as "Low probability" (page 50).

Gap. No ecological threshold, no reference to the Kunming-Montreal Global Biodiversity Framework, the EU Biodiversity Strategy for 2030 or any other authoritative instrument, no base year, and no stakeholder involvement in target setting. Because the company states no target exists rather than leaving the requirement unaddressed, this is recorded as a nil return.

Impact metrics related to biodiversity and ecosystems change

Reference: printed pages 51-52.

The E4-5 section is a single sentence: "This is not the case, as no significant impacts have been identified that would require the establishment of impact indicators related to biodiversity and ecosystems" (page 52).

That conclusion follows from the E4 IRO table on page 50, which qualifies every impact it records as low probability. The table screens the ESRS E4 drivers one by one: climate change, land use / freshwater use / sea use change, direct exploitation, invasive alien species, pollution and "Other" under "Determinants of direct impact on biodiversity decline"; then "The impacts of species extinction" (species population size, risk of global species extinction); "Impacts on the extent and condition of ecosystems" (soil degradation, desertification, soil waterproofing); and "Impacts and dependencies on ecosystem services". Five rows record that a "negative impact was estimated" with "Low probability"; four record "That is not the case".

The site basis is given on page 49: the location "does not overlap with natural areas protected by community interest", the activity "does not involve the direct exploitation of fauna and flora, nor does it lead to the emergence of exotic species", and it "does not lead to changes in land use, groundwater levels, salinization or habitat destruction". Page 26 adds that on the industrial platform and its vicinity "there is no vegetation and fauna with rare or endangered species, protected by national legislation".

Gap. No metric of any kind is given - no land use area, no number of sites in or near biodiversity-sensitive areas, and no metric for the upstream natural rubber deforestation exposure identified on page 20, which is the E4 impact the DMA actually scored.

Anticipated financial effects from biodiversity and ecosystem-related impacts, risks and opportunities

Reference: printed page 52.

The section carries the E4-6 code and states: "The anticipated financial effects of risks and opportunities related to biodiversity and ecosystems have not been assessed or quantified in detail, and 2024 was the first reporting year under the new ESRS standards. Their relevance and significance was noted in the dual materiality analysis" (page 52).

The qualitative position is on page 50: "The financial effects on the Company in the short, medium and long term of the significant risks and opportunities arising from the impacts associated with biodiversity were assessed within the framework of the dual materiality process and were assessed as having negative financial effects (risks) at a medium level." The DMA summary table scores E4 at financial magnitude 4 and financial probability 4 on 1-5 scales (page 24).

The financial risks the company identified but did not price are in the sector IRO register: "Increased control of supply chains for deforestation-free materials; Loss of customers who require traceable and sustainable raw materials", against opportunities in "Sustainable sourcing policies; Supplier engagement and certification (e.g. responsible rubber initiatives); Differentiation as a responsible supplier" (page 20).

Gap. No monetary amount, range or time horizon, and no identification of assets or business activities at material biodiversity risk. The stated reason - that 2024 was the first ESRS reporting year - is also used verbatim for E2-6, E3-5 and E5-6, and the E5-6 version of the same sentence describes 2025 as the second reporting year (page 55).

Policies related to resource use and circular economy

Reference: printed page 53; context page 52.

The E5-1 section sets out a waste hierarchy and then states that no ESRS-compliant policy backs it: "Efficient waste management is an important aspect of the Company's activity, and its approach is based on a hierarchy of waste management options, the first option being the reduction of waste generation, by choosing, from the design phase, the best technologies. When avoiding waste production is not possible, the aim is to minimize the amount generated, by identifying options for reuse, recycling and energy recovery of these, without affecting operational processes." Then: "The company does not have a policy on waste management in accordance with the provisions of the ESRS, but it proposes to plan and implement the processes of the Integrated Environmental Management System, based on Risk Management, in accordance with the requirements of the reference standards: ISO 9001:2015, ISO14001:2015 and SREN ISO 45001:2023, as well as with applicable legal regulations in force" (page 53).

Waste classification is governed by law: "The company keeps records of the waste management generated, classifies each type of waste generated from its own activity in accordance with the provisions of Government Decision no. 856/2002 and in accordance with the provisions of EU Decision no. 955/2014" (page 53).

The chapter opens with a recovery commitment: "In general, it is ensured that at least 90% (by weight) of non-hazardous waste from the Company's activities and generated by the supply of raw materials and materials will be prepared for reuse, recycling and other material recovery operations, in accordance with the waste hierarchy and the waste management legislation in force. The company aims to continuously reduce the exploitation and use of exhaustible natural resources, which is reflected in the investment program, as well as in their decreasing consumption" (page 52).

Gap. Nothing on the transition away from virgin resources, on sustainable sourcing of renewable resources, or on circular design of products - which matters because the company itself lists "Circular Product Design" and "Dependence on virgin raw materials" among its E5 IROs (pages 21, 25).

Actions and resources related to resource use and circular economy

Reference: printed pages 53-54; context pages 14 and 26-27.

The E5-2 section restates the waste hierarchy as the operating rule - prevention first "by selecting the best technologies from the design phase", then minimisation "by identifying options for its reuse, recycling and energy recovery", with disposal "applied only as a last resort" - and adds that "All waste quantities resulting from the processes carried out are identified, monitored and weighed periodically, on an annual basis" and that recovery or disposal is contracted to authorised operators by waste type (page 53).

Four named separate-collection initiatives are listed (page 53):

• "Implementing standards for the efficient management of paper and cardboard"
• "Measures regarding the efficient management of packaging made of plastic/metal/wood"
• "Measures to reduce the quantities of contaminated packaging"
• "Efficient management of waste electrical and electronic equipment (WEEE), fluorescent tubes, batteries and accumulators"

Employee training "on waste prevention, mandatory use of certain products/materials, where possible, and selective waste collection are carried out periodically" (page 54).

The substantive circular activity is in the business model rather than in this section: waste collection and recovery "consists of purchasing waste, sorting, temporary storage, cutting, dismantling, metal insert recovery, grinding, wire baling, and finally its marketing"; rubber waste "is transported to the powdered regenerated rubber section for recycling, while metal waste is recycled through authorized companies"; and used oil is decanted, centrifuged, filtered and dewatered so that "the recovered oil is used as a plasticizer for rubber" (page 14). For large domestic customers the company "ensures the return and ecological recycling of used delivered products" (page 12).

Gap. No CapEx or OpEx attached to any action, no expected quantitative effect, and no time horizon.

Targets related to resource use and circular economy

Reference: printed pages 54-55.

The section is headed "ESRS E5-3, ESRS 2 MDR-T" and prints the fullest indicator table in the statement (pages 54-55):

The company adds that "The training of employees in various fields of activity was carried out through participation in courses organized by competent organizations in this regard (quality, ISO audit, ISCIR, etc.)" and reports employee training meetings at 100% in both years against a plan of semester training (page 55).

Read against the waste table, the fall in waste recovered from 1,675 to 953 tonnes tracks a fall in waste generated rather than a fall in recovery performance: rubber waste generated fell from 578,218 to 580,446 tonnes recovered in the corresponding row and iron waste from 1,368 to 1,266 tonnes (pages 42-43).

Gap. None of the four indicators is expressed as a target with a base year, a target year or a stated ambition. No target addresses resource inflows, the share of recycled or biological materials, or the durability, reusability, repairability or recyclability of products, and none relates to the 90% recovery commitment stated on page 52.

Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities

Reference: printed page 55.

The section carries the E5-6 code: "The anticipated financial effects of risks and opportunities related to resource use and the circular economy have not been assessed or quantified in detail, as 2025 is the second reporting year under the new ESRS standards. Their relevance and significance have been noted in the dual materiality analysis. The Company's environmental register includes a number of risks that will be re-analysed and aligned with the ESRS reporting requirements in the coming period" (page 55).

This is the only place in the statement that describes 2025 as the second ESRS reporting year; the equivalent sentences under E2-6, E3-5 and E4-6 all say 2024 was the first (pages 44, 48, 52), which is consistent, and the E1-2 policies section confirms that "The Company reported based on the requirements of the new ESRS standards for the first time in 2024" (page 34).

The qualitative assessment is on page 54: "The financial effects on the Company in the short, medium and long term of the significant risks and opportunities arising from the impacts associated with waste were assessed within the framework of the dual materiality process and were assessed as having medium-level financial effects." The unpriced risks and opportunities are named in the sector IRO register: "Rising raw material and waste disposal costs; Regulatory pressure on waste reduction and recycling; Dependence on virgin raw materials" against "Recycling and utilization of rubber scrap; Design for durability and recyclability; Cost savings through material efficiency; Participation in circular supply chains (especially in the automotive industry)" (pages 20-21).

Gap. No monetary amounts, ranges, assumptions or time horizons.

Waste

Reference: printed pages 42-43; context pages 26-27, 52-55.

The waste table is printed inside the E2 chapter under "4. HOW TO MANAGE WASTE IN 2025" and gives, per European Waste Catalogue code, the opening stock at 31.12.2024, the amount generated, the amount recovered and the closing stock at 31.12.2025 (pages 42-43). The rows as printed are:

The table is headed in tonnes, but several rows (rubber, ferrous, aluminium, iron) are internally inconsistent - the recovered figure exceeds the generated figure by orders of magnitude, and the closing stock exceeds both - so the decimal convention differs between rows and the tonnages cannot be reconciled as printed. The E5-3 indicator table gives a waste recovery rate of 1,675 in 2024 and 953 in 2025, expressed in tonnes (pages 54-55).

Routes are described qualitatively: rubber waste and used oil are recovered inside the company, everything else goes to contracted authorised operators (pages 27, 53). No split is given between waste diverted from disposal and waste directed to disposal, no treatment-method breakdown (preparation for reuse, recycling, other recovery, incineration, landfill), and no total hazardous or radioactive waste figure.

Policies related to own workforce

Reference: printed page 63; context pages 56-57 and 60.

The section headed "Own workforce policies" rests on the certified management system: "The company has implemented an Integrated Management System (Quality, Environment and Occupational Health and Safety). The Occupational Health and Safety Management System ISO 45001:2018 has the objectives of protecting the health and safety of employees, preventing occupational accidents and diseases, complying with applicable regulations and legal norms, improving productivity and quality of work, as well as reducing the costs associated with occupational accidents and diseases... Internal and external (surveillance) audits of this system are carried out annually in order to evaluate its performance and identify opportunities for improvement" (page 63). Note that the ISO 45001 edition cited here is 2018, while the E2 and S1 chapters elsewhere cite SR EN ISO 45001:2023 (pages 35, 38).

Human rights commitments are set out earlier in the chapter: employee rights and responsibilities in the Collective Labor Agreement and the Internal Regulations "are formulated in accordance with the respect for human rights and the right to work, in accordance with the principles contained in the International Charter of Human Rights and the International Labor Organization Declaration on Fundamental Principles and Rights at Work", and "The company adopts a zero-tolerance policy regarding the undermining or violation of human rights, regardless of the manner in which they are violated" (pages 56-57).

The Internal Regulations carry "Rules on compliance with the principle of non-discrimination and the elimination of any form of violation of dignity by applying the principle of equal treatment to all employees", equal opportunity and treatment between women and men, "Rules on maternity protection at workplaces", an Anti-harassment Policy, and "a Procedure for complaining/notifying and resolving issues related to sexual harassment, informally and formally through the Commission for receiving and resolving harassment cases at the Company level" (page 60).

Gap. No explicit policy commitment on human trafficking, forced labour or child labour, and no statement on whether the policies align with the UN Guiding Principles, the ILO declaration and the OECD Guidelines - a statement the company does make for value chain workers and communities (pages 67, 69) but not for its own workforce.

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

Reference: printed page 62; context pages 58-59.

The section headed "Processes for engaging with own workers and worker representatives on impacts" identifies the Collective Labor Agreement as the vehicle: "The Company strictly complies with the laws and international treaties that regulate human rights, both within this framework and in its relations with its partners and collaborators. The general rights and obligations of the Company's employees are stipulated in the Collective Labor Agreement (CCM), this document being the result of social dialogue and collective bargaining between Management and employees" (page 62).

Access is described: "Each employee has access to the content of the Collective Labor Agreement, through the representatives with responsibilities in the field of human resources within the organizational structures in which they carry out their activity" (page 62), and the Internal Regulation "applicable to all employees" sets the rules on work organisation and discipline.

The formal structure for health and safety engagement is a joint committee: under the Collective Labor Contract "a Health and Safety at Work Committee is established, consisting of: the head of the company, the head of the labor protection department, a representative of the medical service and representatives of the employees. It fulfills the duties established by its Regulations, approved by order of the Ministry of Labor, Social Solidarity and Family" (page 59). Prevention and protection measures are analysed in that committee's meetings (page 57). The company also commits to "maintain a constructive collaborative relationship with employee organizations and other interested parties" through the CCM and "permanent communication on all major aspects of the Company's evolution with employees" (page 58).

Gap. No frequency of engagement is given, no named function or role with operational responsibility for it, no description of how the results are used, and no separate arrangement for engaging workers who may be particularly vulnerable.

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

Reference: printed pages 62-63; context page 60.

The section headed "Processes for remediating negative impacts and channels through which employees can express their concerns" points to the Internal Regulations: they "set out the procedure for resolving individual employee requests and/or complaints. They also cover the rights and responsibilities of both employees and the employer, including rules on non-discrimination and respect for human dignity, rules on conflicts of interest, disciplinary procedures and methods for resolving employee requests or complaints. The Internal Regulations are communicated and signed by employees at the time of employment" (page 63).

Remediation obligations come from the Collective Labor Agreement, which "provides for the Company's obligation to take all necessary measures to protect the life and health of employees, and if the expected measures, which aim to improve working conditions and provide appropriate protection according to the legal provisions in force, are not possible, monetary or other compensation is provided, under the conditions of the law". For workplaces where conditions require it, the company provides at no cost "individual protective equipment, medical services for the recovery of work capacity, private insurance for work accidents and occupational diseases" (page 63).

A specific channel exists for harassment: "a Procedure for complaining/notifying and resolving issues related to sexual harassment, informally and formally through the Commission for receiving and resolving harassment cases at the Company level" (page 60).

The G1 chapter adds two general channels open to employees and third parties under the Anti-Corruption Policy - the email address artedir@artego.ro and the postal address in Targu Jiu - together with a commitment "to maintaining the confidentiality of all requests" for whistleblowers, protected through "an Intranet-type Ethics Platform" (pages 77-79).

Gap. No assessment of whether workers know about and trust these channels, no policy on retaliation protection specific to the workforce, and no number of grievances received or resolved.

Taking action on material impacts on own workforce

Reference: printed page 62; context pages 59-60.

The occupational health and safety actions taken in 2025 are listed under the S1-5 targets section (page 62):

• "Workplace inspections were carried out according to the annual OHS control program; when deficiencies were found, remedial measures were taken. During the inspections, the existence and functioning of protective devices and guards, the cleanliness of workplaces, the maintenance of social groups, the wearing of PPE, the use of collective protective equipment and the training of personnel were monitored. Weekly activity reports were drawn up in which shortcomings were reported."
• "the staff was equipped with PPE and hygienic and sanitary materials, according to the approved internal lists"
• "training and authorization of the professions provided by law (electricians, abrasive stone installers, internal transport) was carried out"
• "Workers were provided with protective food, according to the collective labor agreement"

Standing entitlements are described on page 59: at all workplaces other than administrative ones, "reduced working hours at the Dosage Section, free food to strengthen the body's resistance, free protective equipment and free sanitary materials", a medical examination by the occupational medicine doctor "once every 12 months", and protective and work equipment whose cost "is fully borne by the employer". Workplace measures cover "ergonomic design of workplaces; ensuring environmental conditions (lighting, noise, vibrations, temperature, ventilation, humidity); design of social annexes of workplaces (bathrooms, changing rooms, sanitary groups, canteen); reduction, up to gradual elimination, of polluting emissions" (page 59).

On retention, "In 2025, considering the economic context, labor migration, and lack of qualified labor, the Company focused its attention on the retention of qualified personnel, but also on the training of newly hired personnel" (page 16), with measures including "financial incentives... involving employees in the board of directors, maintaining the budget for resolving special social situations, and developing an integration plan for new employees" (page 59).

Gap. No section carries the S1-4 code; no resources are quantified; and no action is tracked for effectiveness against a stated outcome.

Targets related to own workforce

Reference: printed page 61.

The S1-5 section states that no ESRS targets have been adopted: "The adoption of specific targets related to its own employees has not yet been carried out within an internal process, based on materiality. The company has started a process of analysis and implementation of such targets" (page 61).

One indicator is tabulated:

The rate more than doubled year on year. The company does not comment on the movement, though it records on the following page that "During the period 01.01.2025 - 31.12.2025, two work accidents were recorded within the Company" (page 62).

Gap. No target value, base year or target year for TRIR or for any other workforce measure; no target on diversity, training, pay equity or collective bargaining coverage; and no statement of whether workers or their representatives were involved in setting targets or tracking performance. The full list of S1 disclosure requirements from S1-5 to S1-17 is recited on pages 61-62, but only S1-5, S1-6, S1-9 and S1-14 are given content.

Characteristics of the undertaking's employees

Reference: printed pages 57-58.

Headcount at 31.12.2025 is 450 employees: 213 women and 237 men (page 57).

Age structure at the same date (page 57): 20-30 years, 11 people; 31-40 years, 39 people; 41-50 years, 156 people; 51-60 years, 234 people; over 60 years, 10 people. Education: "105 people with higher education; 345 people studied media" (page 57).

The workforce is contracting steadily. The six-year table (page 58) gives opening headcount, hires, leavers and closing headcount:

A month-by-month 2025 table on the same page tracks the fall from 505 in January to 450 in December, with 8 hires and 63 departures across the year. That is a turnover of 14% on the opening headcount and a net reduction of 55 people, on top of a 49% fall since 2020.

Gap. No breakdown by contract type (permanent, temporary, non-guaranteed hours) or by full-time and part-time, no breakdown by country, no gender split within any of those categories, and no statement of the methodology or of whether the figures are headcount or full-time equivalent at period end. The employee numbers are not cross-referenced to the financial statements.

Collective bargaining coverage and social dialogue

Reference: printed pages 58, 59, 62-63; IRO table pages 60-61.

Artego discloses the existence and role of collective bargaining but not its coverage.

Collective bargaining. "The general rights and obligations of the Company's employees are stipulated in the Collective Labor Agreement (CCM), this document being the result of social dialogue and collective bargaining between Management and employees" (page 62). The company lists among its social commitments the "conclusion of a Collective Labor Agreement specific to the Company's employees" and "permanent communication on all major aspects of the Company's evolution with employees" (page 58). The CCM also carries "special provisions regarding: Social protection measures and facilities granted to employees, or Professional Training" (page 59) and the employer's obligation to protect life and health, with compensation where protective measures are not possible (page 63).

Social dialogue. The formal body is the Health and Safety at Work Committee, "consisting of: the head of the company, the head of the labor protection department, a representative of the medical service and representatives of the employees", which "fulfills the duties established by its Regulations, approved by order of the Ministry of Labor, Social Solidarity and Family" (page 59). Employees are also involved in governance: measures to control personnel risk include "involving employees in the board of directors" (page 59), and the majority shareholder is the PAS Artego employees' association, which acquired 51% in 1999 and held 85.88% of the share capital at 31.12.2025 (pages 1, 7 of the annual activity report).

Social dialogue and collective bargaining are both listed as sub-topics of the material "Working conditions" group in the S1 IRO table, carrying a positive impact from "respecting the rights of its own employees" (pages 60-61).

Gap. No percentage of employees covered by collective bargaining agreements, no percentage covered by workers' representatives, and no breakdown by country or by region for the European Economic Area.

Diversity metrics

Reference: printed pages 57-58; also pages 7-8 and 74-75.

Gender. At 31.12.2025 the workforce of 450 comprises 213 women (47.3%) and 237 men (52.7%) (page 57). At top management level, the Board of Directors has three members - one executive, David Viorel, and two non-executive, Anglitoiu Florian and Buse Diana Loredana (pages 7-8, 74-75). The company does not state the board gender split or express it as a ratio, and the composition can only be inferred from the names.

Age. The distribution at 31.12.2025 is: 20-30 years, 11 people (2.4%); 31-40 years, 39 (8.7%); 41-50 years, 156 (34.7%); 51-60 years, 234 (52.0%); over 60 years, 10 (2.2%) (page 57). On the ESRS bands that is roughly 11 employees under 30, 195 between 30 and 50, and 244 over 50 - more than half the workforce is over 50, against 2.4% under 30, which sits behind the company's stated concern about "a lack of qualified personnel due to the departure of employees due to natural causes" (page 16) and eight hires against 63 departures in 2025 (page 58).

The company adds an educational split - 105 employees with higher education and 345 with secondary education (page 57).

Diversity commitments appear in the S1 IRO table: "there is a policy of non-discrimination and equal treatment, remuneration is similar for both women and men", and "Diversity and inclusion within teams, including people with disabilities, is ensured" (pages 60-61). Equal opportunities are operationalised through transparent promotion "taking into account the necessary professional competence and experience", continuous training and "creating optimal working conditions for staff stabilization" (page 59).

Gap. No gender distribution at top management expressed as a number or percentage, which is the S1-9 datapoint proper.

Health and safety metrics

Reference: printed pages 61-62; context page 59.

Two figures are given.

Accidents. "During the period 01.01.2025 - 31.12.2025, two work accidents were recorded within the Company" (page 62).

Incident rate. The S1-5 indicator table reports the Total Recordable Incident Rate at 0.20 for 2024 and 0.44 for 2025, defined as covering occupational injuries and illnesses where the incident "results in death, days off work, restricted work or transfer to another job, medical treatment beyond first aid or loss of consciousness" (page 61). The rate more than doubled year on year and the company offers no commentary on the movement.

The management system behind them is ISO 45001 certified, audited internally and externally each year (page 63), with a Health and Safety at Work Committee including employee representatives (page 59) and an annual prevention and protection plan drawn up under the Methodological Rules for Law No. 319/2006, whose measures "have annual resources allocated for their implementation in the approved Revenue and Expenditure Budget of the Company" (page 57). Occupational medicine examinations are carried out "once every 12 months" for all employees (page 59). The company also identifies its exposure plainly: "Industrial workers face health and safety risks from exposure to heavy machinery, moving equipment, and electrical hazards" and workers are exposed to "Heat; Noise; Chemicals and dust" (pages 21, 59).

Gap. No percentage of own workforce covered by the health and safety management system, no number of fatalities from work-related injuries or ill health among employees or other workers on sites, no number of days lost to injuries, accidents, fatalities and work-related ill health, and no cases of recordable work-related ill health. The denominator behind the TRIR is not stated.

Policies related to value chain workers

Reference: printed page 67; context pages 65 and 78. Disclosed although the company's double materiality assessment did not conclude that value chain workers are material: the DMA summary table scores S2 - key topic "Occupational hazards in the rubber supply chain" - at impact 3, risk 3, financial magnitude 3 and financial probability 3, and records the Material? verdict as "On the edge" (page 24). The S2 chapter is consistent with that: the financial effects "were assessed as low, with no financial risks for the company" (page 66) and every impact tabulated is positive.

The S2-1 section is short and opens with a nil return on incidents: "There have been no reported cases of non-compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, within the Company's operations or in its upstream and downstream value chain. At the Company level, there are specific policies designed to eliminate discrimination, including harassment, to promote equal opportunities and other ways of promoting diversity" (page 67).

The operative commitment is contractual rather than a standalone policy: "As a result of signing the contract with the Company, each supplier undertakes to respect human rights, as well as other obligations established at national and international level (the Universal Declaration of Human Rights and the United Nations Convention on the Rights of the Child, as well as the International Labor Organization Conventions). These are communicated and found within the contractual conditions" (page 65). Suppliers and subcontractors also undertake to respect "The Company's Ethical Guide and Anti-Corruption Code of Conduct", a "Sustainable development clause" and GDPR (page 78), and the Supplier Relations Charter places "the prohibition of forced or child labor" first among its fundamental values (page 67).

Gap. No general policy document on value chain workers is named or described, no scope or coverage is stated, no accountability is assigned, and there is no statement on whether the policies address trafficking, forced labour or child labour beyond the Charter reference. The chapter also does not reconcile its opening claim - "The Company's activities do not affect employees in the value chain" (page 65) - with the sector IRO register's identification of "Potential labor rights risks in: Natural rubber plants; Chemical supplier operations" (page 21).

Processes for engaging with value chain workers about impacts

Reference: printed page 67. Disclosed although the company's double materiality assessment did not conclude that value chain workers are material: the DMA summary table scores S2 - key topic "Occupational hazards in the rubber supply chain" - at impact 3, risk 3, financial magnitude 3 and financial probability 3, and records the Material? verdict as "On the edge" (page 24). The S2 chapter is consistent with that: the financial effects "were assessed as low, with no financial risks for the company" (page 66) and every impact tabulated is positive.

The S2-2 section states plainly that no engagement process exists: "The Company conducts a materiality analysis process, which assesses both the risks and opportunities associated with suppliers in the value chain and their employees. The grievance policy and appropriate channels are applicable and available to workers in the value chain, and are presented as part of the ESRS G-1. Through these channels, the Company will initiate consultations that will take place directly with workers in the value chain. All complaints will be taken into account for resolution, and the perspectives of workers in the value chain will influence decisions on managing the actual and potential impact. The company has not adopted a general process for collaboration with employees in the value chain, in accordance with the requirements of the new ESRS standards" (page 67).

The engagement described is therefore prospective, not actual. Everything before the final sentence is written in the future tense, and the channels referred to are the company's own Anti-Corruption Policy contacts under G1 - the email address artedir@artego.ro and its Targu Jiu postal address (page 79) - rather than any route designed for or communicated to workers in the supply chain.

Gap. No stage at which engagement occurs, no type or frequency of engagement, no function or role with operational responsibility for it, no involvement of credible worker representatives or proxies, and no assessment of how effective the engagement is. Whether workers in the natural rubber and chemical supply chains identified in the sector IRO register (page 21) are aware of any channel is not addressed.

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

Reference: printed pages 67-68. Disclosed although the company's double materiality assessment did not conclude that value chain workers are material: the DMA summary table scores S2 - key topic "Occupational hazards in the rubber supply chain" - at impact 3, risk 3, financial magnitude 3 and financial probability 3, and records the Material? verdict as "On the edge" (page 24). The S2 chapter is consistent with that: the financial effects "were assessed as low, with no financial risks for the company" (page 66) and every impact tabulated is positive.

The section describes supplier selection criteria rather than a grievance mechanism: "In compliance with applicable regulations, the Company establishes objective criteria for selecting its suppliers and service providers. These criteria are based on the performance of suppliers and their compliance with ethical and sustainable development values and rules. Among the fundamental values mentioned in the Supplier Relations Charter, which occupy the first place in their selection, is the prohibition of forced or child labor" (page 67).

The rest is anti-corruption: the company "prioritizes, in its relations with its suppliers, service providers and customers, the fight against corruption of public or private agents", none of its employees "may offer or receive, except in exceptional circumstances and on their behalf, invitations or gifts that may only be symbolic, not in the form of money and of a small value", and "All business partners are informed of the anti-corruption policy through a package of anti-corruption and GDPR clauses attached to all concluded contracts" (pages 67-68).

The channel itself is only cross-referenced: S2-2 says "The grievance policy and appropriate channels are applicable and available to workers in the value chain, and are presented as part of the ESRS G-1" (page 67). The G1 chapter's channels are the email address artedir@artego.ro and the company's postal address, established under the Anti-Corruption Policy for "employees and third parties" (page 79), together with whistleblower confidentiality and "an Intranet-type Ethics Platform" (pages 77-78).

Gap. No process for providing or enabling remedy, no assessment of whether value chain workers know about or trust the channels, no protection against retaliation for those workers specifically, and no volume of grievances received.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: printed pages 66-67. Disclosed although the company's double materiality assessment did not conclude that value chain workers are material: the DMA summary table scores S2 - key topic "Occupational hazards in the rubber supply chain" - at impact 3, risk 3, financial magnitude 3 and financial probability 3, and records the Material? verdict as "On the edge" (page 24). The S2 chapter is consistent with that: the financial effects "were assessed as low, with no financial risks for the company" (page 66) and every impact tabulated is positive.

The S2-5 section is a nil return: "Specific targets related to employees in the value chain have not been adopted according to the ESRS standards. The adoption of specific targets related to workers in the value chain has not yet been carried out within an internal process, based on materiality. The company did not set targets for impact management during 2025 because this was not the case" (page 66). The indicator table that follows on page 67 has a single row with dashes for both 2024 and 2025.

The same section carries the company's statement on anticipated financial effects: "The financial effects on the Company in the short, medium and long term of the significant risks and opportunities arising from the impacts associated with employees in the value chain were assessed within the framework of the dual materiality process and were assessed as low, with no financial risks for the company. However, the anticipated financial effects of risks and opportunities related to the value chain have not been assessed or quantified in detail, with 2025 being the second reporting year under the new ESRS standards" (page 66).

The only S2 requirement the company lists as presented within its ESRS S2 framework is S2-5 itself (page 67).

Gap. No target of any kind, no base year, no measure of effectiveness in the absence of a target, and no involvement of value chain workers or their representatives in setting or tracking any objective.

Policies related to affected communities

Reference: printed page 69; context pages 68-69. Disclosed although the double materiality assessment found affected communities immaterial: the DMA summary table scores S3 - key topic "Noise, smell, traffic" - at impact 2, risk 2, financial magnitude 2 and financial probability 2, with the Material? verdict recorded as "NOT" (page 24).

The S3-1 section is one sentence and it is a nil return on incidents rather than a policy: "There were no reported cases of non-compliance with the UN Guiding Principles on Business and Human Rights or the ILO Declaration on Fundamental Principles and Rights at Work in the Company's operations" (page 69).

The surrounding chapter supplies the company's position. "It was considered that the Company's operations do not have a significant negative impact on the Communities in the relevant areas where the Company operates. The indigenous population is not found on the territory of Romania" (page 68), and the communities that could be affected are identified as "individuals, legal entities, industry, public institutions and public authorities", whose views the company says its "strategy and business model are built around respecting" (page 68).

Where a policy-like commitment does exist it is statutory: "In the authorization process in the field of environmental protection, for the implementation of projects with environmental impact, public consultation is a mandatory requirement", under GEO No. 195/2005 on environmental protection, Law No. 292/2018 on environmental impact assessment, and Order No. 1798/2007 on the environmental authorisation procedure (page 69). The S3 IRO table records a positive impact because "communities in the area are consulted in the process of obtaining authorizations" (page 69).

Gap. No community policy document is named or described, no accountability is assigned, and there is no statement on whether policies address the human rights of affected communities or align with the UNGPs, the ILO declaration or the OECD Guidelines beyond the nil-incident sentence above.

Processes for engaging with affected communities about impacts

Reference: printed pages 69-70. Disclosed although the double materiality assessment found affected communities immaterial: the DMA summary table scores S3 - key topic "Noise, smell, traffic" - at impact 2, risk 2, financial magnitude 2 and financial probability 2, with the Material? verdict recorded as "NOT" (page 24).

The section headed "Collaborative processes with affected communities regarding impacts / ESRS S3-2" reports sponsorship rather than engagement: "The company has demonstrated that it is a trusted partner for the community, granting, even in 2025, a series of sponsorships to associations, foundations, institutions and other non-profit organizations, with a view to supporting their mission and activity" (page 70). No recipient, amount or theme is named. The strategy chapter adds "supporting disadvantaged individuals and/or communities through sponsorships" among the company's social commitments (page 59).

The engagement mechanism the company actually relies on is regulatory: "In the authorization process in the field of environmental protection, for the implementation of projects with environmental impact, public consultation is a mandatory requirement", citing GEO No. 195/2005, Law No. 292/2018 and Order No. 1798/2007 (page 69). That is reflected in the S3 IRO table, where the "Freedom of expression / Freedom of assembly / The impact on human rights defenders" row records a "Positive impact: communities in the area are consulted in the process of obtaining authorizations" (page 69).

The SBM-2 statement that opens the chapter says the company "respects the views of the communities that could be affected by its activities, as these are essential for taking their interests into account" (page 68).

Gap. No stage, type or frequency of engagement outside permitting; no function or role with operational responsibility for community engagement; no engagement with indigenous peoples, which the company treats as inapplicable in Romania; and no assessment of how effective the engagement is. Sponsorship spend is not quantified.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: printed page 70. Disclosed although the double materiality assessment found affected communities immaterial: the DMA summary table scores S3 - key topic "Noise, smell, traffic" - at impact 2, risk 2, financial magnitude 2 and financial probability 2, with the Material? verdict recorded as "NOT" (page 24).

The S3-5 section is a nil return: "The company did not set targets for impact management during 2025 because this was not the case", followed by an indicator table with a single row and dashes for both 2024 and 2025. The section closes: "No specific targets have been adopted in accordance with the requirements of the ESRS standard for the communities in which the Company operates" (page 70).

S3-5 is the only S3 requirement the company lists as presented within its ESRS S3 framework (page 70).

The reasoning behind the nil return is the chapter's materiality conclusion: the company's operations "do not have a significant negative impact on the Communities in the relevant areas where the Company operates" (page 68) and "No financial risks were identified within the framework of the dual materiality analysis" (page 69), consistent with the DMA summary table's "NOT" verdict for S3 (page 24).

Gap. No target, no base year, no measurable outcome and no measure of effectiveness in the absence of a target. There is no description of how the company tracks whether its community engagement - sponsorships and statutory public consultation - achieves anything, and affected communities are not stated to have been involved in setting or reviewing any objective.

Policies related to consumers and end-users

Reference: printed page 73; context pages 71-72.

The S4-1 section begins mid-thought - "However, at the Company level, the UN Guiding Principles on Business and Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work are respected" - and then sets out the objectives established "according to the Policy and management commitment established within the Company through the Integrated Management System" for the customer relationship (page 73):

• "maintaining clear, direct and effective communication both within the organization and outside it, with stakeholders and in particular with customers"
• "continuous improvement of the quality of the product and services offered to customers, 24 hours a day, by promptly resolving problems"
• "constant measurement of customer satisfaction"

The wider quality framework sits in the same chapter. The company plans "to implement and recertify an integrated management system (quality, environment, SSM) appropriate to the new requirements, as a trust for understanding and satisfying the requirements of customers and stakeholders", with objectives including "Compliance with legal requirements or other requirements to which the company adheres regarding quality, environment and OHS to avoid penalties" (page 72). Product conformity is controlled through the RENAR-accredited Central Laboratory, which issues test reports feeding the "Quality Certificate/Declaration of Conformity... according to the customer's requirements" (page 14).

The chapter is candid that this is not an ESRS policy: consumer interests "are integrated into the Company's business model, but a specific strategy has not been established, according to the requirements of the ESRS standards" (page 71).

Gap. No policy is identified that addresses the S4 sub-topics directly - information-related impacts, personal safety, and social inclusion of consumers - and there is no accountability, scope or availability statement.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: printed pages 73-74.

The S4-5 section is a nil return with a date attached: "The company did not set targets related to impact management during 2024 and 2025 because this was not the case", followed by an indicator table with a single row and dashes for both years. The section closes: "Targets related to managing significant negative impacts, promoting positive impacts and managing significant risks and opportunities have not been adopted in accordance with the new ESRS requirements. These are to be set for 2026" (pages 73-74).

S4-5 is the only S4 requirement the company lists as presented within its ESRS S4 framework (pages 73-74).

The stated reason - "because this was not the case" - sits against the company's own DMA, which scores consumers and end-users as material with the verdict YES (page 24), and against an S4 IRO table whose three rows all record positive impacts and opportunities: consumers "are periodically informed about the quality of products and services", the company "ensures quality of products and services in accordance with legal requirements for safe consumption", and "All consumers have rights equal access to the Company's products and services" (pages 72-73).

Gap. No target of any kind, no base year, no measurable outcome, and no description of how effectiveness is tracked in the absence of a target. Consumers and end-users are not stated to have been involved in setting or reviewing any objective. The quality objectives listed on page 72 are corporate objectives rather than consumer outcome targets, and none is quantified.

Business conduct policies and corporate culture

Reference: printed pages 77-78; context pages 75-76.

The G1-1 section states the framework and its limits in the same breath: "Both within the organization and in interaction with stakeholders, the Company rigorously complies with applicable legislation and international conventions, including the UN Global Compact, the human rights legislative framework and the OECD Guidelines for Multinational Enterprises." The company aims to comply fully with its "Anti-corruption Code of Conduct ('Code') - annex to the Internal Regulations; Anti-corruption and anti-fraud policy; The provisions and legislation in force on the prevention of corruption; Fundamental principles in the relationship with suppliers". Then: "For the year 2025, the Company does not have a Policy drawn up in accordance with the provisions of the new ESRS standards. The existing Policy will be updated in accordance with the new requirements" (pages 77-78).

Whistleblower protection. "Regarding whistleblowers, the Company is committed to maintaining the confidentiality of all requests and to providing the necessary assistance depending on the situation" (page 78). The G1 IRO table adds that "Through an Intranet-type Ethics Platform, people who make reports are protected and are not discriminated against in any way" (page 76).

Corporate culture. The company describes its values as adaptability and creativity, responsibility, business ethics ("our commercial relationships are characterized by honesty, integrity, communication and mutual trust"), collaboration, commitment and confidentiality (page 75), and commits to "establishing mechanisms for declaring conflicts of interest and reporting unethical or illegal behavior or breaches of employee integrity; prohibiting any form of bribery or corruption in business or work relationships; compliance with all forms of legally established embargoes; prohibiting any form of evasion" (page 76).

Gap. No description of how corporate culture is established, developed and promoted, no training coverage figures, no mechanism for investigating incidents, and no statement on protection of reporters beyond the confidentiality commitment. Animal welfare and political engagement are both recorded as "That is not the case" in the G1 IRO table (page 76).

Management of relationships with suppliers

Reference: printed page 78; context pages 14-15 and 67-68.

The G1-2 section describes selection and audit: "Suppliers and subcontractors play an important role in ensuring the continuity of services, contributing to the efficiency and quality assurance of the services offered by the Company. The company evaluates and audits suppliers regularly." Suppliers and subcontractors undertake to respect the Company's Ethical Guide and Anti-Corruption Code of Conduct, procurement processes and procedures, clear and consistent communication with designated contacts, confidentiality agreements, GDPR, "Sustainable development clause", the company's data and IT security clause where applicable, and to "Negotiate honestly and fairly and adopt the required principles of behavior" (page 78).

Conduct rules run both ways. The company "prohibits suppliers from proposing and offering any form of request for gifts or invitations, secretly or through an unknown or identified person, receiving undue benefits, violating applicable local regulations". On its own side it "respects the right to competition and undertakes not to take actions that could affect competition, such as agreements or practices between enterprises that could lead to its restriction", and "avoids abusive behavior in a given market". A nil return follows: "In 2025, there were no legal actions regarding anti-competitive behavior or violations of antitrust and monopoly legislation" (page 78).

The S2 chapter adds the Supplier Relations Charter, whose first-ranked value in supplier selection is "the prohibition of forced or child labor", and records that "All business partners are informed of the anti-corruption policy through a package of anti-corruption and GDPR clauses attached to all concluded contracts" (pages 67-68). Named suppliers span Romania, China, Serbia, Poland and Bulgaria (pages 14-15).

Gap. No consideration of social and environmental criteria in supplier selection beyond the sustainable development clause, no statement on vulnerable suppliers, and nothing on how the company avoids creating risks in its supply chain through its own purchasing practices.

Prevention and detection of corruption and bribery

Reference: printed page 79; context pages 76-78.

The G1-3 section rests on the code and the reporting channels: "The Company undertakes to comply with the Anti-Corruption Code of Conduct, which describes the principles and acts aimed at respecting its commitment to prohibit, without any reservation, any form of corruption and similar or equivalent behavior and to comply with the regulations and best practices in this field. This Code is an integral part of the Company's existing internal policies and procedures, which must also be respected" (page 79).

Channels. "The company has established various communication channels that can be used by employees and third parties to express their complaints in accordance with the adopted Anti-Corruption Policy, as follows: Email address: artedir@artego.ro; Postal address: Tg. Jiu, Ciocarlau Street, No. 38" (page 79). Whistleblower confidentiality is committed to under G1-1 (page 78), and the G1 IRO table records that reporters are protected through "an Intranet-type Ethics Platform" (page 76).

Reach. All business partners receive "a package of anti-corruption and GDPR clauses attached to all concluded contracts" (page 68), and the company states it prioritises "the fight against corruption of public or private agents" in its relations with suppliers, service providers and customers (page 67). The G1 IRO table treats prevention and detection of corruption and bribery as a material sub-topic, with a "Potentially negative impact - if internal codes and procedures regarding corruption and bribery are not followed" and the risk of "Damage to the Company's reputation and violation of legal requirements" (page 77).

Gap. No description of the procedures used to prevent, detect and address allegations, no statement of whether investigators or the investigating committee are separate from the chain of management involved, no reporting line to the administrative, management and supervisory bodies, and no anti-corruption training coverage by function or by at-risk group.

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

Reference: printed page 77; context pages 76 and 78.

The statement was prepared under the 2023 ESRS, where business conduct targets fell under MDR-T rather than a standalone G1 targets disclosure. Artego addresses the point twice on the same page and both times in the negative: "The company did not set targets related to impact management during 2025 because this was not the case", with an indicator table carrying a single row and no values for either 2024 or 2025; and, after listing the G1 disclosure requirements it treats as covered, "No targets were adopted related to managing significant negative impacts, promoting positive impacts and managing significant risks and opportunities according to the new requirements in the ESRS" (page 77).

MDR-T's other limb is effectiveness tracking in the absence of a target, and there are two mechanisms the company does describe. Suppliers are monitored: "The company evaluates and audits suppliers regularly", against undertakings that include the Ethical Guide, the Anti-Corruption Code of Conduct, procurement procedures, a sustainable development clause and GDPR (page 78). And outcomes are reported, at least for competition: "In 2025, there were no legal actions regarding anti-competitive behavior or violations of antitrust and monopoly legislation" (page 78). Reports of unethical conduct are handled through the Intranet-type Ethics Platform, where "people who make reports are protected and are not discriminated against in any way" (page 76).

Gap. No target value, base year or target year for any business conduct measure - corruption training coverage, supplier screening rate, incident closure, or payment days - and no stated method for judging whether the anti-corruption framework is working. The two G1 IROs the company scored as material, supplier relationship management including payment practices and prevention of corruption and bribery (page 77), each carry a described control but no measured outcome.