Aspo Oyj

Governance roles

Reference: pages 20-22 (listed in the ESRS content index, Appendix 1, page 76; also cross-referenced under G1 at page 20).

Aspo Plc's governing bodies are the Annual General Meeting, the Board of Directors and the CEO. "The Board of Directors is responsible to the shareholders, and the CEO to the Board" (page 20). The Annual General Meeting confirms the financial statements, elects the Board members, the auditor and the auditor of the Sustainability Statement. A Shareholders' Nomination Board prepares the Board election proposals.

Composition (page 20): the Articles of Association require five to eight members. "In 2025, the Board of Directors consisted of seven members, 57% of whom were men, and 43% were women." There is no personnel representative on the Board and members are not employed by the Group; two members are dependent on significant shareholders.

Committees (page 20): an Audit Committee and a Human Resources and Remuneration Committee. The Audit Committee "monitors the company's internal control's operations and effectiveness at its meetings". The Group Executive Committee assists the CEO.

Expertise (page 21): "Aspo's Board of Directors' members have expertise in all three ESG elements, both directly and indirectly, through specialists and training... This expertise covers Aspo's material matters (E1, S1, G1)." Board members receive training on sustainability matters and may use external specialists.

Information provided to the administrative, management and supervisory bodies

Reference: page 21 (ESRS content index, Appendix 1, page 76).

Aspo describes a chain running from the sustainability organisation up to the Board. "The Board of Directors bears overall responsibility for assessing the company's operations' sustainability impacts, risks and opportunities. The Board of Directors approves Aspo's sustainability targets and monitors their progress. Furthermore, the Board of Directors is responsible for monitoring and assessing the sustainability reporting system and its assurance" (page 21).

• The Audit Committee monitors the sustainability reporting process, digital reporting, the identification of information to be reported, the effectiveness of internal control, audit and risk management, and the implementation of assurance (page 21).
• The Group Executive Committee "is responsible for the implementation of sustainability policies and strategic goals. It also validates impacts, risks and opportunities" and reports to the Audit Committee (page 21).
• The Senior Vice President of Legal and Sustainability and the sustainability organisation run the double materiality assessment and prepare proposals on materiality, targets, policies and action plans.

Frequency: the CEO presents the sustainability targets to the Board; the SVP Legal and Sustainability "statements the status of the key targets on a quarterly basis at the Board of Directors' meetings" (page 21). Bodies are notified of material IROs when the DMA is updated. During the reporting period they "addressed all material sustainability impacts, risks and opportunities the company had identified" (page 21).

Trade-offs are covered: "Compromises mean situations where an investment cannot be made because it does not sufficiently support environmental, social and governance (ESG) targets" (page 21).

Sustainability performance in incentive schemes

Reference: pages 21-22 (ESRS content index, Appendix 1, page 76; also cross-referenced under E1, page 76).

Long-term incentive (page 21). Aspo Plc has a three-year share-based long-term incentive plan (LTI 2025-2027) covering nine key individuals, including the Group Executive Committee and the CEO. "The incentive plan's earning criteria is based on Aspo's total share return (TSR, weight 80%) and the company's sustainability targets (20%). One of the sustainability metrics is Telko's EcoVadis score (weight 10%), and the other is based on ESL Shipping's SBT targets (weight 10%)." Payment is partly in Aspo shares and partly in cash.

Short-term incentive (pages 21-22). Part of the 2025 short-term remuneration earned by the CEO, the Group Executive Committee and other key individuals will be paid in Aspo Plc shares. "In short-term remuneration, earnings metrics include the operating result, as well as the two sustainability metrics (weight 20%): emission intensity CO2 (t) / per net sale (EUR k) and the total recordable injury frequency (TRIF)." TRIF "has already been used as a possible personal sustainability metric for Aspo's personnel."

"The emission intensity target's earning metric is based on ESL Shipping's vessels' Scope 1 emissions reductions. In determining earnings, the achievement of the emission intensity target is assessed in accordance with these emission reductions, as well as Aspo's net sales" (pages 21-22).

Statement on due diligence

Reference: page 22, Table 2 "Mapping the due diligence process in the sustainability statement" (ESRS content index, Appendix 1, page 76).

Aspo maps the five core elements of due diligence to the paragraphs of the statement:

The statement on due diligence is also listed in Appendix 2 as an SFDR-derived datapoint (ESRS 2 GOV-4, paragraph 30) with a page 22 reference (page 79).

Risk management and internal controls over sustainability reporting

Reference: page 22. The ESRS content index gives the source as "Sustainability Statement/Annual Report", page 22 (Appendix 1, page 76).

Aspo is unusually explicit about the limits of its controls. "Aspo's sustainability reporting does not have its own risk management and internal control process but the management of risks related to sustainability reporting are currently implemented as part of the Group's general risk management and internal control processes" (page 22). Risk management is coordinated by the Group CFO; the internal audit function supports management; the Audit Committee monitors effectiveness.

Stated gaps (page 22):

• "Regarding sustainability reporting, the company has identified controls for risks related to the reporting of quantitative information. Risks related to the reporting of qualitative information have not been assessed, and no specific controls have been defined for it."
• "There is no separate risk assessment or risk prioritization model in place for sustainability reporting. The likelihood or impact of the realization of risks related to sustainability reporting has not been evaluated."

Controls that do exist (page 22): a comprehensive control description prepared as part of the risk management framework, covering completeness, accuracy, validity and access restriction of data; and, for manual data reporting, "double checks performed by different individuals and comparison of the reported data with the previous year". Risks are reported to the sustainability reporting steering group and, when necessary, to the Executive Committee, Board and Audit Committee.

Strategy, business model and value chain

Reference: pages 22-24, with Figure 1 "Aspo's value chains" on page 23 (ESRS content index, Appendix 1, page 76).

Business model (pages 19, 22). Aspo Group comprises the parent company Aspo Plc and, in 2025, three businesses: ESL Shipping (dry bulk, breakbulk and project cargo shipping), Telko (distributor of plastic raw materials, industrial chemicals and lubricants) and Leipurin (raw materials and expert services to bakery, food industry and food service). All serve corporate customers. "Aspo Group operated in 18 countries and employed 798 professionals" (page 22). Aspo announced in August 2025 that it will divest Leipurin; "The divestment was completed in March 2026" (page 19).

Fossil-fuel and chemical exposure, as required by the SFDR-derived datapoints (pages 22-23). "In 2025, turnover from the transportation of fossil fuels, i.e., coal for energy production, totaled EUR 3 805 595." "Telko's profit from the oil refining industry in 2025 was EUR 139 436. Telko does not produce chemicals but mixes and packages them." Telko has no activities within the manufacture of pesticides and other agrochemical products under Annex I to Regulation (EC) No 1893/2006.

Value chain (pages 23-24). The Group's value chain is three sector value chains plus crosscutting activities such as logistics and waste management. ESL Shipping's chain runs "from raw materials for shipbuilding to chartering and decommissioning of vessels"; Telko's central upstream parts are raw material production and processing, downstream customers, wholesale, end-users and end-of-life treatment; Leipurin's runs from raw material production through its own R&D to food producers, retail, food service and consumers.

Interests and views of stakeholders

Reference: pages 24-25 (ESRS content index, Appendix 1, page 76; also cross-referenced under S1 at page 24, page 77).

"Aspo Group's parent company, Aspo Plc, considers its most important stakeholders to be personnel, owners, investors and financiers such as banks. Customers and suppliers are also key stakeholders through the Group's businesses" (page 24). Satisfaction is monitored using the Net Promoter Score survey, and the Group "regularly conducts personnel surveys to better understand the needs and views of its own workforce".

How views reach the Board (page 25). "Stakeholders' views and expectations related to material sustainability matters were an important part of the double materiality assessment updated in 2025, which utilized information obtained from stakeholder interviews. As part of the double materiality assessment, administrative, management and supervisory bodies obtain information about affected stakeholders' views and interests."

Examples of outcomes (page 25). Stakeholder views are addressed "for example by adding hybrid vessels with lower environmental impact to ESL Shipping's fleet". In 2025 "Leipurin conducted a survey among its suppliers to assess their readiness to promote supply chain transparency, product information availability, and cooperation."

Limitation stated by the company (page 25): "Aspo aims to further strengthen stakeholder interaction and address the views obtained which may lead to changes in the strategy and business model. A more detailed schedule for this is not yet available."

Material impacts, risks and opportunities

Reference: pages 25-28, with the IRO tables on pages 26 (Table 3, E1), 27 (Table 4, S1) and 28 (Table 5, G1). The ESRS content index also cross-references SBM-3 under E1 (pages 28-29) and S1 (page 28) (Appendix 1, pages 76-77).

Material themes (page 25). "Aspo Group has identified the following as the Group's material sustainability themes: climate change mitigation, climate change adaptation and energy (Climate change, E1), working conditions and equal treatment and opportunities for all (Own workforce, S1), as well as corporate culture, protection of whistleblowers, corruption and bribery, and prevention and detection of corruption and bribery (Business conduct, G1)."

Changes in 2025 (pages 25-26). Two new material areas were added: climate change adaptation and prevention and detection of corruption and bribery. Five previously reported topics no longer exceed the threshold: secure employment, working time, work-life balance, training and skills development, and employment and inclusion of persons with disabilities. "During 2025, Aspo conducted a scenario analysis... As a result of this work, climate change adaptation emerged as a material theme, and at Group level, a total of seven material risks and opportunities related to climate change adaptation were identified."

Resilience (page 25). "Aspo Group conducted a resilience analysis of its strategy and business model in 2025. Aspo has not identified any assets that involve a significant risk of material adjustment in the next financial year."

Forced and child labour (page 28). "In its double materiality assessment, Aspo has not identified that any of its operations would be at significant risk of forced labor or child labor in terms of either the type of operation or geographic area."

Climate-specific risk identification and scenario analysis is also presented under E1-2 (2025 ESRS numbering), and the climate resilience conclusions under E1-3.

Processes to identify and assess material IROs

Reference: pages 29-31, with the topic-specific IRO-1 sections for climate and E2-E5 on pages 31-32 and for business conduct on page 32 (ESRS content index, Appendix 1, page 76).

Process (pages 29-30). "Aspo updated its double materiality assessment in spring 2025, which resulted in elimination of overlaps related to impacts, risks and opportunities... The update is based on the scoring and thresholds of the double materiality assessment conducted in 2023. Aspo will review its materiality assessment again in 2026." The DMA "consisted of stakeholder discussions, a review of material ESRS topics, an expert assessment of impacts, risks and opportunities, and a Group-level analysis". During spring 2025 financiers, suppliers and customers were interviewed.

Thresholds (pages 29-30). Scoring is on a 1-5 scale. "The threshold is three for the materiality of impacts and four for financial materiality." Impact materiality used scale, scope, irremediable character (negative impacts only) and likelihood; financial materiality multiplied likelihood by a segment-specific monetary risk limit in EUR million. "Not all matters material at a segment level were considered material at a Group level."

Scope and governance (pages 30-31). The DMA "covers its own operations, in addition to which the assessment has addressed impacts related to the upstream production chain and downstream value chain". An external advisor participated; "Segment representatives, the Group Executive Committee, the Audit Committee and the Group's Board of Directors approved the results". "The double materiality assessment did not identify any sector-specific material impacts, risks or opportunities that are not included in the ESRS."

Topics not screened (page 32). Aspo states plainly that it "has not screened its sites and businesses" for pollution (E2), "has not assessed its assets and activities" for water and marine resources (E3), "has not systematically identified and assessed" biodiversity IROs (E4) and "has not screened its assets and activities" for resource use and circular economy (E5).

Disclosure requirements covered by the sustainability statement

Reference: page 32, with the index itself in Appendix 1 "Disclosure requirements and references" (pages 76-78) and Appendix 2 "Data points derived from other EU legislation" (pages 79-81). The content index lists IRO-2 at pages 29-30 and 32 (Appendix 1, page 76).

"A list of the disclosure requirements that Aspo has complied with in preparing the Sustainability Statement is presented as a content index in Appendices 1 (Disclosure requirements and references) and 2 (Data points derived from other EU legislation) at the end of this Sustainability Statement" (page 32).

What the index covers. Cross-cutting: BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2, and the minimum disclosure requirements MDR-P, MDR-A, MDR-M and MDR-T. Topical: ESRS E1 (E1-1 to E1-6 with page references; E1-7, E1-8 and E1-9 marked "Not relevant for Aspo"), ESRS S1 (S1-1 to S1-6, S1-9, S1-14, S1-16 and S1-17 with page references; S1-7, S1-8, S1-10 to S1-13 and S1-15 marked "Not relevant") and ESRS G1 (G1-1, G1-3 and G1-4 with page references; G1-2, G1-5 and G1-6 marked "Not relevant").

No E2, E3, E4, E5, S2, S3 or S4 disclosure requirement appears in Appendix 1. Those standards appear only in Appendix 2, where every E2, E3, E4, E5, S2, S3 and S4 datapoint is marked "Not relevant" or "Not applicable to Aspo" (pages 79-81).

The "Further information" column records where voluntary datapoints were not answered, for example S1-1 to S1-5 "Voluntary data points not responded to" and S1-6 "Responded to voluntary data points 52a and b" (page 77). Aspo states that "The opportunity to include data by reference has been applied in Appendix 1. The utilized phase-in requirements can also be found from Appendix 1" (page 19), but Appendix 1 carries no explicit phase-in flag.

Transition plan for climate change mitigation

Reference: pages 42-43, with Figure 2 (Aspo's transition plan) and Figure 3 (ESL Shipping's transition plan) on page 42 and Table 6 on page 43 (ESRS content index, Appendix 1, page 76).

"In 2025, Aspo and ESL Shipping set science-based emission reduction targets and prepared transition plans for their part to limit global warming to 1.5°C in accordance with the Paris Agreement. Aspo's near-term targets and ESL Shipping's near-term and long-term targets (Net Zero targets) have been verified by the Science Based Targets initiative (SBTi) and are aligned with the Paris Agreement" (page 42).

Scope. "Aspo's transition plan covers ESL Shipping and Telko. Telko's transition plan is not presented separately, as Telko is included in Aspo's SBT targets. ESL Shipping has set separate SBT targets, which is why its transition plan is presented separately in the report. Leipurin is excluded from the transition plan, as Aspo announced during 2025 that it will divest the Leipurin business" (page 42).

Approval. "The transition plans have been approved by Aspo's Board of Directors and the Group Executive Committee" (page 42).

Levers (Table 6, page 43). Fleet renewal; renewable fuels ("All ESL Shipping vessels can use renewable marine diesel, and two vessels can use biogas. The Green Handy vessels to be completed in 2027 and 2028 can use green methanol as fuel"); other measures (expanding the Virtual Arrival model, more shore power in port, smaller energy-efficiency investments); discontinuation of coal transport by 2028; and supplier commitment to SBTi.

Financing (page 43). "In 2025, ESL Shipping signed two loan agreements to finance Green Handy vessels: a EUR 45 million loan agreement with the Nordic Investment Bank and a EUR 70 million loan agreement with Svenska Skeppshypotekskassan." "The transition plan is aligned with ESL Shipping's and Aspo's business strategy and financing plan."

Lock-in. "Telko is a distribution business, making it challenging to assess carbon lock-ins." "Aspo is not excluded from Paris-aligned benchmarks under the EU framework" (page 42).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 (climate), where this content is disclosed in the FY2025 report (pages 31-32), and from SBM-3 (pages 25, 28-29). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risk classification (page 26, Table 3). Aspo's climate IRO table labels each row as a physical risk (chronic, or acute and chronic) or a transition risk (policy and regulatory changes, technical development), and names the business segment it belongs to. The seven adaptation rows added in 2025 cover extreme weather and changing ice conditions for ESL Shipping, raw material cost increases and supply chain disruption for Leipurin, supply chain disruption and falling fossil-product demand for Telko, and two transition opportunities.

Methodology (pages 31, 28). "In 2025, Aspo conducted a climate risk analysis (including scenario and resilience analysis), which identified climate-related risks and opportunities for Aspo's businesses... Aspo's climate risk analysis covers the entire value chain." The analysis ran February-April 2025 and "utilized CSRD and TCFD frameworks as well as IPCC climate scenarios". Two workshops were held per business, the first to identify risks and opportunities per scenario, the second to define mitigation measures and assess the ability to manage them. "The main assessment criteria used in evaluating risks and opportunities were impact and likelihood, which were scored on a scale of 1-5."

Scenarios (paragraph 17 items) (page 31). For transition events Aspo uses a 1.5°C scenario: it "requires a very significant transformation across the economy to achieve global carbon neutrality by 2050". For hazards it uses a high-emission 3°C scenario, in which "global temperature rises by more than 3°C by 2100, leading to widespread deterioration of living conditions and irreversible impacts such as rising sea levels". Named scenario sources beyond "IPCC climate scenarios" are not given.

Scope (page 31). "In ESL Shipping's scenario analysis, the focus was on its own operating area. In Telko's and Leipurin's scenario analyses, the entire value chain was taken into account, and no geographical areas were excluded."

Time horizons (pages 28, 31). Short term 0-5 years, medium term 5-15 years, long term over 15 years, aligned with five-year strategic planning and the SBTi target years 2030 and 2040. Vessels' "average service life spans several decades, exceeding the time horizons used in the analysis, and they are not discussed in more detail here" (page 31).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 (pages 25, 28-29) and the climate IRO-1 section (page 31), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

A resilience analysis was performed (page 25). "Aspo Group conducted a resilience analysis of its strategy and business model in 2025. Aspo has not identified any assets that involve a significant risk of material adjustment in the next financial year." The method is described at page 28: "Finally, measures to improve resilience and meet regulatory and market expectations were reviewed. The resilience analysis was carried out by evaluating the risk tolerance of the business operations."

Results by business (pages 28-29).

• ESL Shipping: "Significant opportunities... are emphasized in the 1.5°C scenario, as the business has the opportunity to grow as a partner for customers choosing lower-emission transport. ESL Shipping has already made significant investments in lower-emission vessels and therefore major transition risks are more related to the possibility of reduced climate targets." Its "ability to adapt its strategy to climate-related risks is at a sufficient level for almost all transition and physical risks", but physical risks "must be actively monitored, especially in the 3°C scenario".
• Telko: sees significant opportunities under 1.5°C from demand for alternative products, but is exposed to declining fossil-product demand. "For short-term and most medium-term risks, Telko has the ability to adapt its strategy to climate-related risks. For long-term and some medium-term risks, the company should develop new measures to reduce risks."
• Leipurin: adaptation ability "is at a sufficient level for almost all transition and physical risks. However, in the short term, a rapid and sharp increase in raw material prices would cause acute problems for customer segments dependent on those raw materials, and Leipurin's ability to influence the situation is very limited."

Uncertainty named (page 29). "Although the risk was not identified as material in the double materiality assessment, a short-term climate risk has been identified as the potential change in political regulation related to the green transition, which is difficult to prepare for due to limited visibility."

Link to the response (page 31). "In the second workshop, mitigation measures were defined for significant risks and the business's ability to manage these risks was assessed. Mitigation and adaptation measures can reduce the impact or likelihood of risks, which also demonstrates the business's resilience in risk management." Aspo also states it "has identified assets and businesses that are not compatible with the transition to a climate-neutral economy" (page 31). No quantified financial resilience or capacity-to-adapt figures are given.

Policies related to climate change mitigation and adaptation

Reference: page 43 (ESRS content index, Appendix 1, page 76; MDR-P is indexed at pages 43, 63 and 73).

"In accordance with Aspo's sustainability policy, Aspo is mitigating and adapting to climate change by striving to lower CO2 emissions in all of its operations... All Aspo's segments share the ambition to reduce emissions in the entire supply chain, improve energy efficiency and deploy renewable energy when operationally and financially feasible" (page 43).

Scope and its stated limit. "Aspo's sustainability policy covers all material impacts, risks and opportunities. The sustainability policy applies to Aspo Group and all its segments, with main focus on own operations and therefore excluding the upstream and downstream value chain" (page 43). Value chain reach is instead handled through the Code of Conduct: "Aspo's suppliers are required to commit to Aspo's Code of Conduct, which requires suppliers to comply with environmental legislation and obtain the required environmental permits for operations."

Accountability and availability. "The Group's CEO and the Managing Directors of subsidiaries are responsible for implementing the sustainability policy. A monitoring process is carried out once a year. The sustainability policy is available on Aspo's website" (page 43).

Commitments (page 43). "Aspo Group and its businesses are committed to the UN Global Compact, the UN Universal Declaration of Human Rights, and the ILO Declaration on Fundamental Principles and Rights at Work."

Actions and resources in relation to climate change policies

Reference: pages 46-47 (ESRS content index, Appendix 1, page 77; MDR-A is indexed at pages 46-47, 64-67 and 73-74).

Fleet renewal (page 46). "Fleet renewal continued in 2025. AtoBatC Shipping sold its oldest vessel during the year, and ESL Shipping sold Kallio, built in 2006. At the end of 2025, AtoBatC Shipping, a subsidiary of ESL Shipping, operated nine Green Coaster vessels, with three more on order. The plug-in hybrid vessels equipped with a shore power connection and a 1 MWh battery are among the most energy-efficient in the world in their size category, and their GHG emissions per cargo unit transported are almost 50% lower than the previous generation of vessels." A multi-year time charter has been signed for six low-emission 5,900 dwt vessels, and in October 2024 ESL Shipping ordered "four 17,000 dwt general cargo vessels capable of operating fully fossil-free using green methanol", for delivery in 2027 and 2028.

Operating measures (page 46). "In 2025, the share of renewable fuels in vessels' fuel consumption increased to 0.4%. This reduced CO2e emissions by 0.4%. The reduction in CO2 emissions achieved with the Virtual Arrival, which optimizes vessel speeds, was an average of 20% in voyages in which Virtual Arrival was used." Customer cooperation continued with Metsä Forest (a 30% per ton-mile reduction by 2030 against 2022) and with EFO, "under which at least 10% of the fuel consumed in EFO's annual transportation operations will be replaced with renewable fuels".

Telko and Leipurin (pages 46-47). "In 2025, Telko began actively communicating its climate actions to suppliers and simultaneously initiated the systematic collection of product-level carbon footprint data from them." Telko holds an ISCC certificate for bio-based mass balance plastics. "In 2025, Leipurin introduced a new emission calculation tool that enables calculation of emission factors at product and category level", and a Swedish inventory-reduction project was launched to cut food waste.

Resources. "ESL Shipping's capital expenditure allocated to the vessel investments is described in the EU Taxonomy section. Investment commitments for the Green Handy and Green Coaster vessels are reported in the financial statements. Aspo has not identified any significant future operational expenses related to vessel investments" (page 46).

Targets related to climate change mitigation and adaptation

Reference: pages 42-46, with Table 7 (Aspo's targets) and Table 8 (ESL Shipping's targets) on page 45 (ESRS content index, Appendix 1, page 76; MDR-T is indexed at pages 43-46, 64-65, 73 and 75).

Aspo's SBTi-verified targets, 2023 base year (page 44):

1. "reduce absolute Scope 1 and 2 greenhouse gas emissions 42.0% by 2030 from a 2023 base year" (boundary includes land-use related emissions and removals from bioenergy feedstocks);
2. "engage 50.0% of its suppliers by emissions covering purchased goods and services to have science-based targets by 2029 (scope 3)";
3. "reduce absolute Scope 3 emissions from use of sold products for distributed fossil fuels 100% by 2030 from a 2023 base year".

ESL Shipping (page 44): net zero across the entire value chain by 2040. Near-term: lifecycle Scope 1 and 3 emissions from shipping operations down 59.6% per ton-mile by 2030 versus 2023 (a 47.1% absolute reduction), and indirect emissions from transported fossil fuels down 100% by 2030. Long-term: 97.8% per ton-mile by 2040 (97.1% absolute) and all remaining Scope 3 down 90% by 2040.

Progress (Table 7, page 45). Scope 1 and 2: 192,919.1 tCO2e (2023 base) to 179,691 (2024) to 149,319 (2025), a 22.60% reduction against a 42% target and a 2030 target value of 111,893. Supplier coverage: 13.90% to 14.91% to 15.97%, against 50% by 2029. Scope 3 from distributed fossil fuels: 2,231,926 to 779,519 to 567,995 tCO2e, down 74.55%.

Methodology (page 45). "ESL Shipping's targets have been set using the SBTi maritime pathway. Aspo's target-setting has applied the cross-sector pathway." The baseline did not change in 2025; the recalculation threshold is 5% of total emissions.

Group intensity target (pages 45-46). Reducing emission intensity CO2 (t) / revenue (EUR thousand) by 30% by 2025 from a 2020 baseline of 0.44: "The result for 2025 was 0.23 and the result for 2024 was 0.30", against a 2025 target level of 0.30. "Stakeholders have not participated in setting the emission intensity target."

No target is set for climate change adaptation.

Energy consumption and mix

Reference: pages 47-50, with Table 9 (Group), Table 10 (Group intensity), Tables 11-16 (segments) on pages 48-49 and the measurement methodology on page 50 (ESRS content index, Appendix 1, page 77).

Group (Table 9, page 48). Total energy consumption 588,597 MWh in 2025, down from 677,070 MWh in 2024.

• Fossil: 576,729 MWh, 97.98% of the total (2024: 98.47%). Crude oil and petroleum products 534,738 MWh; natural gas 41,417 MWh; purchased electricity, heat, steam and cooling from fossil sources 574 MWh. Coal and coal products: 0.
• Nuclear: 1,371 MWh, 0.23%.
• Renewable: 10,497 MWh, 1.78% (2024: 1.34%), of which fuel from renewable sources 5,005 MWh and purchased renewable electricity, heat, steam and cooling 5,492 MWh.

The narrative adds: "Crude oil and petroleum products have the highest share, 93%" (page 47).

Intensity (Table 10, page 48). "In 2025, Aspo Group's energy intensity was 0.000955" MWh per EUR of net revenue from high climate impact sectors, down 16% from 0.001143, on net revenue of EUR 616,339,000. All Group net revenue is treated as coming from high climate impact sectors.

By segment (page 47). ESL Shipping is the largest consumer, with marine fuels "more than 99.9% of its energy consumption": oil-based fuels 92.5%, LNG 7.1%, renewables 0.3%; energy intensity 0.0031259. Telko: fossil 19.4%, renewable 64.6%, nuclear 16%; intensity 0.000024. Leipurin: renewable 82.2%, fossil 15.5%, nuclear 2.3%; intensity 0.000032.

Method (page 50). "The energy mix has been measured using a market-based Scope 2 metric, where the energy sources used in the consumption of electricity, cooling and heating are broken down by country in accordance with the International Energy Agency's (IEA) energy mix for electricity generation."

Aspo does not report self-generated non-fuel renewable energy.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 50-60, with Table 17 (Group), Table 18 (SBT boundary), Table 19 (intensity) and Table 20 (excluded categories) on pages 51-53 and segment tables on pages 55-59 (ESRS content index, Appendix 1, page 77).

Group totals (Table 17, page 51). "Aspo Group's GHG emissions in 2025 totaled 713,121 tCO2e" location-based (713,005 market-based), down 6% on 2024.

• Scope 1: 149,220 tCO2e, down 17% (21% of the total), "the majority of which consists of the fuel consumption of ESL Shipping's vessels".
• Scope 2: 439 tCO2e location-based and 323 tCO2e market-based (under 1% of the total). Market-based rose 21%.
• Scope 3: 563,461 tCO2e, down 2% (79% of the total). Category 1 purchased goods and services is 447,219 tCO2e, "accounting for 79% of the Group's Scope 3 emissions"; category 3 fuel and energy-related activities 32,906; category 12 end-of-life treatment 25,995; category 4 upstream transport 21,152; category 2 capital goods 15,002; category 10 processing of sold products 9,182; category 13 downstream leased assets 6,069.

SBT boundary (Table 18, page 52). Excluding Leipurin, total emissions were 611,400 tCO2e location-based, with Scope 1 149,051 against a 2030 milestone of 131,002.

Intensity (Table 19, page 53). 0.0011570 tCO2e per EUR of net revenue location-based, down 9%.

Data quality, stated by the company (page 50). "Aspo Group's Scope 1, 2 and 3 GHG emissions do not include primary data. The emission factors used do not come directly from Aspo's own value chain, and no supplier-specific emission factors have been used." Twelve energy attribute certificates were used for market-based Scope 2.

Exclusions (Table 20, page 53). Category 8 upstream leased assets is not included because leased vessels and leased cars and facilities are consolidated into Scopes 1 and 2 under operational control. Categories 10, 11 and 12 are only partly included, with the GHG Protocol intermediate-product provision cited; categories 14 and 15 are nil.

Aspo also reports direct biogenic CO2 emissions separately (page 54) and no Scope 1 emissions from regulated emission trading schemes are stated in Table 17.

Policies related to own workforce

Reference: page 63 (ESRS content index, Appendix 1, page 77, which notes "Voluntary data points not responded to"; MDR-P is indexed at pages 43, 63 and 73).

Sustainability policy (page 63). "The sustainability policy for managing sustainability topics covers the entire Aspo Group and its own workforce. A monitoring process is carried out once a year."

Human rights (page 63). "Aspo is committed to respecting internationally accepted human rights as defined in the UN's Universal Declaration of Human Rights and the UN Guiding Principles on Business and Human Rights. The company does not accept any discrimination based on education, competence, position, personality, way of life, work experience, ethnic origin, religion, gender, sexual orientation, age, nationality, abilities or other qualities... The policies also address appropriate working conditions and zero tolerance for human trafficking, child or forced labor, or other human rights violations across the value chain." Aspo notes a gap: "There are no specific actions to remedy human rights impacts or enable such remedies."

DEI policy (page 63). "Aspo has a Diversity, Equity and Inclusion (DEI) policy, which defines principles that obligate all employees to prevent all forms of discrimination and harassment... Aspo's goal is for 40% of the Group's senior managers and supervisors, excluding sea personnel, to be of the underrepresented gender by 2030. There are no separate commitments related to implementing diversity." The DEI policy applies Group-wide, the CEO is responsible for its implementation, and it is available on the intranet.

Health and safety (page 63). "Occupational health and safety programs and supplementary occupational safety guidelines have been prepared on a segment-specific basis." Work environments "range from cargo vessels to chemical warehouses and offices".

Appendix 2 confirms page 63 as the reference for the SFDR-derived S1-1 datapoints on human rights policy commitments, ILO due diligence, trafficking prevention and workplace accident prevention (page 80).

Processes for engaging with own workforce and workers' representatives

Reference: pages 63-64 (ESRS content index, Appendix 1, page 77, "Voluntary data points not responded to").

Structures (pages 63-64). "Aspo has an occupational health and safety committee which meets bi-annually to extensively discuss matters related to employee well-being at work, and occupational health and safety." Responsibility for maintaining communication with the workforce sits with the Group's SVP Legal and Sustainability and the HR Director. "In 2025, discussions in accordance with the Act on Co-operation within Undertakings were held with personnel in Aspo's businesses. Based on these discussions, development plans for workplace were updated."

Collective representation (page 64). "Aspo's Finnish companies adhere to five different collective agreements. The collective agreements of the Technology Industries of Finland and the Finnish Seafarers' Union cover most of the personnel." ESL Shipping is a member of the Finnish Shipowners' Association, which represents it in collective bargaining, and complies with the Maritime Labour Convention.

Personnel survey (page 64). "An annual personnel survey measures the Group's own workforce's commitment and job satisfaction. The People Power index represents the survey's key results, which are part of the Group's sustainability targets." A sustainability section has been included since 2023 and a wellbeing section since 2024. Results are reviewed in staff meetings and by supervisors with their teams.

Stated gap (page 64). "No specific action has been defined to gain an insight into the perspectives of people in Aspo's own workforce who may be particularly vulnerable to impacts or marginalized." One vulnerable-group issue is named: "In ESL Shipping it has been identified that retaining women in the industry, especially after parenthood, is a development area."

A DEI working group established in 2023 coordinates DEI activities; in 2025 DEI policies, training and materials were made available to all personnel on the intranet (page 64).

Processes to remediate negative impacts and channels to raise concerns

Reference: page 64 (ESRS content index, Appendix 1, page 77, "Voluntary data points not responded to"; Appendix 2 cites page 64 for the SFDR datapoint S1-3 paragraph 32(c) grievance and complaints handling mechanisms, page 80).

Channels (page 64). "Aspo Group uses a shared wholly anonymous whistleblowing channel for the entire personnel through which they can express concerns about inappropriate conduct or suspicions of abuse." In addition, "the personnel can disclose suspicions and shortcomings to their supervisor or the HR department". Aspo also has "a working community mediation process that provides employees with the opportunity to address shortcomings and sensitive challenges related to teams or individuals, even when they are not to be addressed directly with the nearest supervisor". All ESL Shipping vessels follow a Maritime Labour Convention complaint procedure "that allows sea personnel to lodge a complaint on any matter that is considered to be in breach of the MLC requirements".

Remediation (page 64). "All notifications are handled using the procedure most suitable for the situation, and corrective measures are taken immediately... In addition to the management, the HR department acts as a supervisory body to remedy any shortcomings and follows Aspo's mediation process in remedies."

Two stated gaps (page 64). "Trust in the process is not assessed separately." And: "Aspo does not have a formal process to assess whether remedies are effective."

Each segment has its own occupational health and safety action plan describing the working environment's key elements, the physical and psychological risk factors, and the practices to minimise accidents (page 64).

Taking action on material impacts on own workforce

Reference: pages 64-67, with the action plans in Table 28 (safety, page 66), Table 29 (underrepresented gender, page 67) and Table 30 (violence and harassment, page 67). The ESRS content index gives S1-4 at pages 64-67 (Appendix 1, page 77).

Safety actions during 2025 (Table 28, page 66). Statutory occupational healthcare, occupational safety organisation and accident insurance; safety training including first aid; accident reporting and "harmonisation of occupational accident reporting and definitions of occupational accidents"; reporting of safety observations in all business segments; bi-annual health and safety committee meetings; "Launch of Telko's safety culture project"; and "Occupational safety certificate ISO 45001 for ESL Shipping's Finnish operations". Planned for 2026 onward: an ISO 45001 system for Telko's site, a management-team practice for addressing all safety matters, employee safety surveys, and extending ESL Shipping's ISO 45001 certification to Swedish operations.

Vessel-level safety (page 65). "In addition to the Group-level occupational health and safety committee, each ESL Shipping vessel has an occupational health and safety committee... A total of 94 safety meetings were held on vessels during 2025."

Equality actions (Table 29, page 67). Equality plans reviewed and updated by end-2025; job grading system implementation at Group level "to report equal pay from 2026", with anchor positions defined; DEI training and materials provided every three weeks January-May 2025; Code of Conduct training; HR system development to support the expression of gender identity. Planned: anonymised first-round recruitment, extended DEI training and a recruitment policy.

Pay equity project (page 65). "The consistency of the personnel's job descriptions and related remuneration is strengthened through a development project started in 2024... a shared job grading classification system will be deployed in the Group. This will also support Aspo to prepare for the EU Pay Transparency Directive."

Resources (page 65). "The action plans are not expected to cause any significant operating expenses." The plans cover own operations only and are geographically global.

Targets related to own workforce

Reference: pages 64-67 (ESRS content index, Appendix 1, page 77; MDR-T is indexed at pages 43-46, 64-65, 73 and 75).

Three targets are disclosed, each covering Aspo's own operations globally.

1. People Power index (page 64). "Progress in these goals is tracked especially by the People Power index, where the target is to achieve the AA+ level by 2030. Progress is compared to 2023, when the AA level was achieved. In 2025, the AA rating was again achieved, consistent with the comparison year 2024. The People Power Index (PPI) score developed positively from 2024 to 2025, increasing from 76.3 in 2024 to 77.4 in 2025."

2. Occupational safety, TRIF (page 65). "The TRIF target for 2025 was 4.0, and the outcome was 7.0. The Total Recordable Injury Frequency (TRIF) was higher in 2025 due to an increased number of reported occupational accidents compared to 2024. The long-term target is zero accidents." The base year is 2022, when TRIF was 8.1. The target covers own workforce plus leased employees on ESL Shipping-owned and pooled vessels.

3. Gender balance in management (page 65). "Another target is to increase the proportion of the underrepresented gender in senior management and managerial positions, excluding sea personnel, to 40% by 2030. The base year is 2024, when the figure was 36.4%. In 2025, the proportion... was 24%."

Governance of targets (page 65). "Targets are prepared annually by Aspo's social sustainability steering group, which started operating in 2025... Group-level targets are then approved by the Group Executive Committee and the Board of Directors." A supporting working group of employee representatives prepares the action plans; both groups meet two to four times a year.

Stakeholder involvement (page 65). "Some of Aspo Group's stakeholders have participated in setting the goals described in this section at a general level in various workshops, especially regarding equality. External stakeholders have not been engaged in setting numerical targets."

Aspo also notes it has one fewer S1 target than in 2024; the dropped target related to improving employee, customer and principal experience (page 20).

Characteristics of the undertaking's employees

Reference: pages 68-70 and 72, with Table 31 (gender), Table 32 (countries), Table 33 (contract type) and Table 34 (turnover). The ESRS content index notes "Responded to voluntary data points 52a and b, no other voluntary data points responded to" (Appendix 1, page 77).

Headcount (page 68, Table 31). "At the end of 2025, Aspo Group employed a total of 798 people, of which 163 were employees of Leipurin" (2024: 800). By gender: 537 male, 260 female, "Other" not reported. Split onshore/maritime: 619 onshore and 179 maritime. "Sea personnel are predominantly male. Approximately 60% of the onshore personnel are men."

By country (Table 32, page 69). Finland 367 (188 onshore, 179 maritime), Sweden 211, Latvia 29, Lithuania 29, Ukraine 28, Estonia 25, Poland 23, Denmark 16, France 15, Kazakhstan 13, China 11, Germany 9, Belgium 8, Uzbekistan 5, Norway 4, the Netherlands 2, India 2. A restatement is disclosed: in 2024 sea personnel from outside Europe were reported under "Non-EU countries" (43 individuals); they are employed by a Finnish company and are now reported under Finland, with 2024 corrected accordingly.

Contract type (Table 33, page 70). 710 permanent and 88 temporary; 773 full-time and 25 part-time; zero non-guaranteed-hours employees.

Turnover (Table 34, page 70). 64 employees left during 2025; turnover 8.0% (2024: 8.6%).

Basis (pages 68, 72). Headcount at 31 December 2025 from HR and payroll systems. "The total number of employees corresponds to the figure reported in the financial statements section 3.6." "The 2025 data only includes employees in an employment relationship directly with Aspo's companies."

Diversity metrics

Reference: page 71, Table 35 (ESRS content index, Appendix 1, page 77).

Senior management (page 71). "At the end of 2025, 19 of Aspo's senior managers were men, and six were women. The senior management consists of Aspo Plc's Group Executive Committee and the management teams of Aspo's businesses." That is 76.0% male and 24.0% female across 25 people, against 16 men and 5 women (76.2% / 23.8%) in 2024.

Age distribution (Table 35, page 71). "Most of Aspo Group's employees are aged between 30 and 50. The average age is 46."

The table "includes all employees who have stated their gender as male or female" (page 71). Age groups are taken from HR and payroll systems by date of birth, at 31 December 2025 (page 72).

Board diversity is reported separately under GOV-1: seven members, 57% men and 43% women (page 20), and is listed in Appendix 2 as the SFDR datapoint ESRS 2 GOV-1 21(d) at page 20 (page 79).

Health and safety metrics

Reference: pages 71-72, Table 36 (ESRS content index, Appendix 1, page 78, "Voluntary data points not responded to"; Appendix 2 cites page 72 for the SFDR datapoints S1-14 88(b) and (c) and 88(e), page 80).

2025 metrics (Table 36, page 72), with 2024 comparatives:

"During 2025, Aspo Group reported fourteen work-related accidents leading to an absence or medical treatment. Of these, 0 resulted in the death of an employee" (page 71).

Restatement (page 20). "Aspo identified one error in the 2024 reporting, where the lost time injury frequency (TRIF) was reported as 4.4. The calculation of the lost time injury frequency was reviewed during 2025, and the actual TRIF for 2024 was 4.9."

Method and its stated limitation (page 72). "The TRIF measurement is based on the number of work-related accidents leading to an absence or medical treatment per one million working hours." And: "Aspo does not have an accident and occupational disease monitoring system covering all Group companies, and the accuracy of data provision is the responsibility of individuals. It is therefore possible that not all individual cases have been reported. The 2025 data only includes employees Aspo's companies employ directly. The aim is to correct this in future reporting through central monitoring."

Compensation metrics (pay gap and total compensation)

Reference: page 72, Table 37 (ESRS content index, Appendix 1, page 78, "Voluntary data points not responded to"; Appendix 2 cites page 72 for the SFDR datapoints S1-16 97(a) unadjusted gender pay gap and 97(b) excessive CEO pay ratio, page 80).

"In Aspo Group's businesses, the gender pay gap is 26.5%. The highest earner's annual pay is 15.5 times the rest of the personnel's median pay" (page 72).

Both metrics moved slightly against the company year on year.

Method (page 72). "The 2025 pay gap data only includes employees Aspo's companies employ directly." For shore personnel, monthly or hourly pay is taken from the HR system for each employment relationship valid at 31 December 2025, converted to full-time equivalents where necessary and divided by average monthly working hours from local full-time hours. For sea personnel, "Total pay for 2025 has been obtained from the HR and payroll system, divided by the number of working days recorded on board and further by the length of the working day, which is eight hours. According to the collective agreement, the regular working day for sea personnel is eight hours, while the working day for onshore personnel is 7.5 hours. Annual holiday pay is not included in total pay."

The pay gap sits against the material IRO "Limited representation and gender pay gap" (page 27) and the job grading project intended to enable equal-pay reporting from 2026 (pages 65, 67).

Incidents, complaints and severe human rights impacts

Reference: page 72 (ESRS content index, Appendix 1, page 78, "Voluntary data points not responded to"; Appendix 2 cites page 72 for the SFDR datapoint S1-17 103(a) incidents of discrimination, page 80).

"In 2025, no discrimination cases were reported within the Aspo Group, including cases of harassment. During the 2024 reporting period, one harassment case was recorded within the organization. The case was handled in accordance with HR processes between the parties involved and HR. A total of EUR 0 in fines was imposed for violations of laws in 2024 and 2025. Aspo did not receive any complaints through the whistleblowing channel related to working conditions, terms of employment, equal treatment and opportunities or other work-related rights" (page 72).

This is a nil return across all four limbs of the disclosure for 2025: no incidents of discrimination or harassment, no complaints through the whistleblowing channel or the Maritime Labour Convention channel, no fines, and no severe human rights incidents reported.

The channels behind the figure are described under S1-3: a wholly anonymous Group whistleblowing channel operated by an external supplier, supervisor and HR routes, a working community mediation process, and the MLC complaint procedure on ESL Shipping's vessels (pages 64, 73). Appendix 2 marks the related datapoint S1-17 104(a), non-respect for the UNGPs and OECD Guidelines, as "Not relevant" (page 80).

Business conduct policies and corporate culture

Reference: pages 73-74, with Table 38 "Actions related to business conduct" on page 74 (ESRS content index, Appendix 1, page 78; Appendix 2 cites page 73 for the SFDR datapoint G1-1 10(b) United Nations Convention against Corruption, page 81).

Corporate culture (page 73). "Key elements of business sustainability are discussed as a separate item at the meetings of Aspo's Board of Directors and the Group Executive Committee approximately once a month." "In accordance with its Code of Conduct, Aspo is committed to conducting business honestly and in an ethically sustainable manner... All employees of Aspo Group must complete annual Aspo Code of Conduct e-training."

Whistleblowing (page 73). Employees may report to their supervisor, the CEO, the legal or HR department or internal audit, and "an electronic whistleblowing channel is available on the website at https://report.whistleb.com/aspo. It allows employees to submit notifications anonymously, and external parties can also use the channel." An external supplier manages it, notifications are reported to the Board, and personal data is processed under the GDPR.

Whistleblower protection (page 73). "In whistleblower protection, Aspo complies with the EU Whistleblower Directive (Act on the protection of people who report breaches of EU and national law (December 20, 2022/1171)). Reporting concerns is never a punishable act... Aspo does not accept any retaliatory action, including discharges, pay reductions or the prevention of promotion, against any person who has sincerely submitted a notification." The policy also covers former Aspo employees.

Scope and its stated limit (page 73). "Aspo's Code of Conduct and whistleblower protection policy apply to Aspo Group and all its segments, focusing mainly on its own operations. They do not apply to the upstream and downstream value chains." The CEO is responsible for implementation.

Anti-corruption policy (page 73). "Aspo's anti-corruption and anti-bribery policies are compliant with the UN Convention: corruption or bribery is not accepted in any form... The goal is to have no cases of bribery or corruption." Aspo identifies those most at risk as "those working in managerial positions in the company, as well as ship officers".

Telko is additionally committed to the UNCAC principles and the FECC Code of Conduct (page 73).

Prevention and detection of corruption and bribery

Reference: page 75, with the related actions in Table 38 on page 74 (ESRS content index, Appendix 1, page 78, "Voluntary data points not responded to").

Training (page 75). "Aspo Group has ethical principles (Code of Conduct) and related training for all personnel. In addition to Code of Conduct training, an online training course on preventing bribery and corruption was organized for targeted groups in autumn 2025. The main message is zero tolerance for any form of corruption and bribery." "All Aspo Group employees must complete annual Aspo Code of Conduct e-training, which also includes anti-corruption and anti-bribery guidelines and rules. The training also covers functions in which individuals are at a higher risk of exposure to bribery and corruption attempts."

Reporting and investigation (page 75). "Any suspicions of corruption or bribery must be reported to either the nearest supervisor, the Compliance Officer or through the whistleblowing channel. The company will investigate all suspicions raised. Notification receipt options ensure that investigation is always carried out by a party not involved in the case."

Escalation (page 75). "The Senior Vice President, Legal and Sustainability reports significant suspicions to the Audit Committee. In addition to the Audit Committee, Aspo's Board of Directors discusses corruption and bribery cases on a quarterly basis."

Sector cooperation (page 75). "In addition to Group-level training, ESL Shipping is committed to fighting corruption as a member of the Maritime Anti-Corruption Network (MACN). ESL Shipping's vessels mainly operate in Northern Europe, but the company is aware that corruption remains a significant problem in some of the countries where its vessels operate."

Table 38 adds the 2025 actions: completion of the planned online trainings, development of the annual review of compliance risks, measuring "how ethical Aspo is from employees' perspective (e.g. People Power Index)", and self-assessments for internal control and compliance (page 74).

Targets related to business conduct

Back-filled from the business conduct chapter (pages 74-75), where targets are addressed as part of the MDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone targets DR only in the 2025/2026 ESRS; the report was prepared under the 2023 ESRS, in which G1-3 was "Prevention and detection of corruption and bribery". The ESRS content index lists MDR-T at pages 43-46, 64-65, 73 and 75 (Appendix 1, page 76).

Two business conduct targets are stated.

1. Code of Conduct training completion, 100% (page 75). "The 100% target applies to 2025 and is compared to the base year 2021, when Code of Conduct training was completed by 88% of the personnel. The target was achieved in 2025. The 100% target was also reached in 2022, 2023, and 2024. The target covers Aspo's own operations globally." A second limb covers role-based compliance training: "Depending on tasks, employees must also complete compliance training regarding various themes such as anti-bribery and anti-corruption, competition law, and data protection. The target is that everyone in the target group for compliance training completes it."

2. Zero corruption and bribery cases (page 73). "The goal is to have no cases of bribery or corruption. The goal covers Aspo's own operations globally." Performance against it is reported under G1-4: no suspected incidents in 2025 and EUR 0 in fines (page 75).

Stakeholder involvement (page 75). "Some of Aspo Group's stakeholders have participated at a general level in the setting of the objectives described in this section through various workshops. External stakeholders have not been involved in the setting of numerical targets."

Effectiveness tracking, MDR-T's other limb (page 74). Table 38 lists ongoing measurement rather than a single metric: "The development of the annual review of compliance risks will continue", "Measuring how ethical Aspo is from employees' perspective (e.g. People Power Index)", "Self-assessments for internal control and compliance", and, for 2026 onward, "Annual Code of Conduct and anti-corruption and anti-bribery training, and other compliance trainings every other year" and "Continuous improvement of internal control based on risks and self-assessments".

Incidents of corruption or bribery

Reference: page 75, Table 39 (ESRS content index, Appendix 1, page 78, "Voluntary data points not responded to"; Appendix 2 cites page 75 for the SFDR datapoints G1-4 24(a) fines for violation of anti-corruption and anti-bribery laws and 24(b) standards of anti-corruption and anti-bribery, page 81).

"In 2025, Aspo Group did not become aware of any suspected incidents of corruption or bribery. A total of EUR 0 in fines was imposed for breaches of the law" (page 75).

Table 39, corruption or bribery incidents during the reporting period (page 75):

This is a nil return, disclosed as such rather than omitted.

Basis (page 75). "Aspo Group's actions to prevent corruption and bribery are discussed under G1-3. Information related to corruption and bribery cases is obtained from Aspo's systems, and no limitations have been identified in the measurement methodologies."

The material G1 IROs behind this disclosure are the potential negative impact "Possibility of corruption" and, new in 2025, the potential positive impact "Promoting employee awareness of corruption risks and preventing incidents" (page 28).