ASSA ABLOY

Reference: pages 74-76 (ESRS index entry: SS 74-76).

Governance runs Board of Directors > CEO > Executive Team > Divisional Boards, with five divisions (Opening Solutions EMEIA, Opening Solutions Americas, Opening Solutions Asia Pacific, Global Technologies, Entrance Systems) and a Sustainability Council reporting process covering sustainable innovation, supply chain integrity, environmental, social and ethical, and health and safety (page 73).

"The Board of Directors and the CEO are responsible for the reported information in the sustainability statement in accordance with the Corporate Sustainability Reporting Directive (CSRD). They oversee the preparation of the sustainability statement and review its content, and the Board of Directors approves the sustainability statement" (page 75). The Audit Committee prepares the Board's work on sustainability disclosures; sustainability is an integrated part of the report submitted to it ahead of each quarterly meeting, and its Chairperson reports to the Board at every subsequent Board meeting (page 75). The Board addresses sustainability "as needed and at least annually".

Board composition (page 74, paragraph 21(d)-(e) datapoints). Seven AGM-elected members are tabled with independence and gender: gender diversity ratio (male:female) 3:4, 57 percent female. All seven are independent of the company and its management; three are also independent of major shareholders. Two employee representatives with one deputy each are appointed by the unions and sit outside the table.

Expertise is described rather than mapped: the Board and Audit Committee "consist of professionals with long experience from different senior positions in global industrial companies", supported by the Group's Head of Sustainability (page 75).

Reference: pages 74-76 (ESRS index entry: SS 74-76).

Information flow is disclosed through the Audit Committee route rather than as a separate schedule of matters. "Sustainability is an integrated part of the report submitted to the Audit Committee ahead of each quarterly Audit Committee meeting. The Chairperson of the Audit Committee reports from each Audit Committee meeting to the Board of Directors at every subsequent Board meeting" (page 75).

The matters covered are listed: "The Board of Directors addresses sustainability matters as needed and at least annually, including material impacts, risks and opportunities, implementation of due diligence, and results and effectiveness of policies, actions, metrics and targets adopted to address them, and sustainability disclosures" (page 75).

Specific instances of Board involvement are given elsewhere in the statement: the double materiality assessment findings "were presented to our Executive Team and the Board of Directors" for both the impact and financial legs (page 78); the DMA outcomes on water were "presented and consulted with our Board of Directors, stakeholders and other affected communities" (page 97); the transition plan "is approved by the Board of Directors" (page 90); and Group policies are adopted by the Board (pages 74, 88, 112). Progress against sustainability targets "is tracked quarterly using key performance indicators" and reviewed by the cross-divisional Sustainability Council (page 76).

No count of meetings at which sustainability was discussed, and no summary of the trade-offs considered, is given.

Reference: page 76 (ESRS index entry: SS 76).

"Climate and other sustainability-related targets are factored into the variable remuneration of all members of the Executive Team reporting to the CEO, as well as management teams throughout the divisions. These targets are usually linked with decreasing our energy consumption, which is a key driver for decreasing our Scope 1 & 2 carbon emissions; the reduction targets are aligned to our annual emissions reduction as part of our science-based targets. This and other sustainability-related targets, such as health and safety and people strategy, are typically in the form of short-term variable remuneration and usually 3 to 5 percent of the total short-term variable remuneration target" (page 76).

So the climate link is disclosed as a proportion of short-term variable pay, not of total remuneration, and the split between the climate component and the health, safety and people components is not given. The statement does not disclose a percentage of remuneration recognised in the current period that is linked to climate considerations, nor whether GHG reduction targets sit in long-term incentive plans. Responsibility for achieving targets "lies with the CEO and Board of Directors" (page 76).

Reference: pages 76-78 (ESRS index entry: SS 76-78). Also mapped in Appendix B as an SFDR-derived datapoint at pages 76-78 (page 116).

"ASSA ABLOY has adopted the Organization for Economic Cooperation and Development (OECD) Due Diligence Guidance for Responsible Business Conduct" (page 76), and the statement maps the six OECD elements onto its own disclosures:

• "Embed responsible business conduct into policies and management systems" > the Policy matrix (page 88)
• "Identify and assess adverse impacts in operations, supply chains and business relationships" > the double materiality analysis (pages 77-85)
• "Cease, prevent or mitigate adverse impacts" and "track implementation and results" > the environmental and social sections
• "Communicate how impacts are addressed" > "This sustainability statement forms part of how we meet the requirement" (page 76)

Remediation is covered in the topical chapters rather than in the mapping: the whistleblowing process is open to external parties (pages 102, 113), suppliers found in breach are given corrective action plans and can be placed on "new business hold" or the prohibited list (pages 108-109), and product issues can trigger recalls or production halts (page 111).

Reference: pages 75-76 (ESRS index entry: SS 75-76).

The company discloses a control environment that is not yet complete for ESRS purposes: "ASSA ABLOY has established governance, policies and due diligence processes for sustainability matters. However, internal controls specifically related to ESRS data collection and reporting are still being further developed and will be reviewed and strengthened during 2026" (page 75).

What is in place: a Group sustainability reporting database accessible through the intranet section for sustainability managers (page 75); the annual Internal Control Self-Assessment (ICSA), used for example to verify that a local health and safety audit has been performed (page 103); and the Audit Committee's quarterly review of the sustainability report (page 75).

Sources of estimation and outcome uncertainty (page 75). Scope 3 is calculated from a mix of primary site-level data and "recognised secondary data sources, including industry average emission factors". "The reliance on secondary sources and generic emission factor databases introduces inherent measurement uncertainty". Outcome uncertainty is "further influenced by acquisition related data gaps, including the current unavailability of complete Scope 3 data for HHI". Mitigation is to expand primary data use and to strengthen carbon reporting requirements in supplier contracts.

No risk assessment methodology, risk-prioritisation scale or list of identified reporting risks is disclosed.

Reference: page 72 (ESRS index entry: SS 72), with the value chain map on the same page.

The value chain is "modelled across upstream, own operations and downstream highlighting the respective material topics for the Group. Stakeholders such as our investors, the environment and society are impacted across the full value chain. Our suppliers are impacted in upstream, employees in own operations and customers in downstream" (page 72).

Upstream covers material extraction, suppliers and transport, with material topics E1, E3, E5, S2 and G1. Own operations covers innovation plus manufacturing and logistics, with E1, E3, E5, S1 and G1. Downstream covers distribution to customers and customers and end-users, with E1, E5 and S4 (page 72).

Scale is given across the statement: over 1,100 sites in 70 countries (page 93), customers in more than 180 countries (page 103), 62,083 employees (page 105), close to 9,072 direct material suppliers (page 110), and Taxonomy turnover of SEK 152,409 million (page 89).

Two limitations are disclosed. "We are unable to present revenue per ESRS sector due to disaggregation of the Group's revenue. However, as seen in Note 2, revenue is broken down by geography/product group" (page 76). And Appendix B marks the SBM-1 datapoints on involvement in fossil fuel, chemical production, controversial weapons and tobacco as "Not Applicable" (page 116).

Reference: pages 77-78 (ESRS index entry: SS 77-78, "SBM-2 Interests and views of stakeholders - general").

Stakeholder engagement is disclosed as an input to the double materiality assessment. "We conducted stakeholder surveys with over 500 stakeholders to understand the concerns and priorities of various stakeholders, including employees, customers, suppliers, investors, industry associations and NGOs" (page 78). Internal subject matter experts, divisional representatives and all functional heads attended the impact materiality workshop, preceded by "a series of education and awareness sessions" on what CSRD reporting would entail. "The output from the stakeholders was aggregated into focus areas to ensure the stakeholder input from the surveys was taken into account during the impact materiality workshop" (page 78).

Findings were validated by "a verification team made up of function heads and subject matter experts", then "presented to our Executive Team and the Board of Directors" (page 78).

Ongoing channels are described in the topical chapters: the annual Voice of the Employee survey with debrief sessions and team-level action planning, union representatives on the Board and a country coordination network (page 102); the Voice of the Customer programme with Net Promoter Score, owned by the CCO (page 111); and supplier audits in which "the auditor reviews operations and meets with both management and workers" (page 108).

How stakeholder views have changed strategy is not disclosed; the company states instead that after the DMA "it was clear there are no major changes required for either our business model or Group strategy" (page 78).

Reference: pages 79-85 (ESRS index entry: SS 79-85).

"We have summarized our material impacts, risks and opportunities into a set of tables per material topic, based on the outcome of our double materiality assessment process including key stakeholder's input. Timeframes considered are medium-term to 2030 and long-term to 2050. ASSA ABLOY does not consider short-term timeframes, for example twelve months" (page 79).

Seven topic tables are printed: E1 (page 79, 6 rows), E3 (page 80, 2 rows), E5 (page 81, 5 rows), S1 (page 82, 3 rows), S2 (page 83, 4 rows), S4 (page 84, 4 rows) and G1 (page 85, 3 rows). Each row gives sub-topic, the material impact or risk, a description, mitigation or action, whether it sits in own operations or the value chain (upstream/downstream), tick columns for positive impact, negative impact, opportunity and risk, and the policy referenced. Financial magnitude is banded rather than quantified: "Opportunities/risks as a % of annual sales - Very high is >10%, High 6-10%, Medium 2-5%, Low <1%".

The DMA produced "fifteen negative impact material sub-topics" and "twelve financial material sub-topics" (page 78). Interaction with strategy is stated at a high level: "it was clear there are no major changes required for either our business model or Group strategy. Our current business model and strategy are sufficient to ensure we can disclose to CSRD Minimum Disclosure Requirements (MDR) as well as progress towards our sustainability goals and objectives" (page 78).

Reference: pages 79-85 (ESRS index entry: SS 79-85), with the process described on pages 77-78.

"In preparation for the CSRD, we carried out a double materiality assessment during 2023 and 2024" (page 77). The process steps are: stakeholder survey; workshop 1 impact materiality; workshop 2 financial materiality; analysis of survey, workshops and written documents; workshop 3 validation of the draft list of material matters (page 77).

Thresholds are stated explicitly (page 77). Impact severity is graded on scale (large/small), scope (large/small), irremediability (high/low) and likelihood (high/low). "A sustainability matter is determined as material when: there is an actual impact or a potential impact with a high likelihood, with a value of large/high for at least two out of three negative severity factors (scale, scope, irremediability), and/or with a value of large for at least one out of the two positive factors (scale, scope)." Financial materiality is graded on likelihood (high/low) and magnitude (large/small), and "a sustainability matter is determined as material when it has a value of high likelihood and large magnitude in terms of either being a risk or an opportunity, or both". "For financially-material matters, the material subtopics match the sub-topics that are material from an impact perspective" (page 77).

For climate specifically, the financial leg drew on the TCFD reporting the Group has produced since 2021 and on the RCP 6 and RCP 2.6 scenario analyses (pages 77-78, 86-87). Appendix B marks the three ESRS 2 IRO-1 E4 datapoints as "Not Applicable" (page 117).

Reference: pages 114-118 (the ESRS index entry gives its own location as SS 114-118).

The statement prints a real ESRS content index headed "ESRS index", tabling each disclosure requirement against a section marker (SS = Sustainability statement, FS = Financial statement) and a page reference (pages 114-115). It covers BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2, MDR-P, MDR-A, MDR-M and MDR-T; E1-1 to E1-9; E3-1 to E3-5; E5-1 to E5-6; S1-1 to S1-17; S2-1 to S2-5; S4-1 to S4-5; and G1-1 to G1-6. No E2, E4 or S3 disclosure requirement is listed, consistent with the DMA outcome on page 77.

The left-hand column names the sub-topics covered: for E1 "Climate change mitigation & Energy" (climate change adaptation is not listed); for E3 "Water"; for E5 "Resource inflows, including resource use / Resource outflows related to products and services / Waste"; for S1 "Working conditions / Other work-related rights"; for S2 the same two; for S4 "Personal safety of consumers and/or end-users"; and for G1 "Corporate culture / Protection of whistle-blowers / Management of relationships with suppliers including payment practices / Corruption and bribery" (pages 114-115).

Appendix B lists the datapoints deriving from other EU legislation with SFDR, Pillar 3, Benchmark Regulation and EU Climate Law columns and a page or "Not Applicable" marker (pages 116-118). E2-4, the three E4-2 policy datapoints, the ESRS 2 IRO-1 E4 datapoints and the S3-1 and S3-4 datapoints are marked "Not Applicable".

The company flags that the index is not a claim of completeness: "As this is only the second disclosure, there are gaps between ESRS and ASSA ABLOY disclosures" (page 73).

Reference: pages 93-96 (ESRS index entry: SS 93-96), with the plan narrative on pages 90-94.

"Our transition plan to realize our long-term climate commitment is approved by the Board of Directors. Sustainability is part of everything we do and is integrated into our overall business strategy; the transition plan is aligned to our business strategy and financial plans" (page 90).

Scope 1 and 2 pathway (page 93). A waterfall runs from a 2019 base of 414 kTons CO2eq to a 2030 target of 207 kTons, a 50 percent cut, across four levers: (1) Manufacturing Footprint Program, consolidating duplicated sites acquired through M&A; (2) industrial CO2 elimination, chiefly ending the use of freon as a blowing agent in door insulation; (3) strategic sites energy overhaul - "ASSA ABLOY operates over 1,100 sites in 70 countries. The top 25 most energy-intensive sites account for more than 60 percent of Scope 1 & 2 emissions"; (4) continuous improvement, with sustainability one of four pillars of the operational excellence strategy. "The four-pronged strategic approach is replicated in all divisions, all business units and at the factory level... and tracked on a quarterly basis".

Scope 3 pathway (page 94). From 5,638 to 4,060 (CO2eq, thousand tons) by 2030, via supply chain decarbonisation, sustainable innovation, value analysis/value engineering, and logistics.

Locked-in emissions (page 90). "There are potential locked-in carbon emissions in our own operations in the form of our operations infrastructure such as heating, ventilation and air conditioning (HVAC) systems, space heating equipment, compressors, transformers, heating and electrical process equipment. When this plant comes to its end of life, we will work to upgrade with low-carbon and increased energy efficiency alternatives."

Funding is not quantified. "The investments needed to realize this plan are related to lever three and four. We do not have a separate investment vehicle to realize the plan, all investments are made through our capital expenditure process and follow the same rules as all other capital investments. Due to difference in the definition of CapEx and OpEx between EU Taxonomy and our financial statements... our financial statement CapEx and OpEx does not tally with investments in carbon improvements" (page 93). "ASSA ABLOY has not identified which assets and business activities are incompatible with or need significant efforts to be compatible with transition to climate-neutral economy" (page 87). Appendix B marks the E1-1 Paris-aligned benchmark exclusion datapoint as "Not Applicable" (page 116).

Back-filled from ESRS 2 IRO-1 and the TCFD subsection, where this content is disclosed in the FY2025 report (pages 79, 86-87). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 79, 86-87.

Risk classification (paragraph 15). The TCFD blocks label each risk PR (physical) or TR (transition) explicitly (page 86). Under RCP 6: coastal factories at risk of flooding (PR); supply chain uncertainty, materials availability, customer expectation, ability to get insurance and higher costs for emissions (all TR). Under RCP 2.6: availability of low-carbon materials (TR), need to upgrade and retrofit older sites (PR & TR), carbon taxes and market regulations (TR), customer expectation (TR), M&A in higher risk geographies (TR), energy quality and availability (TR). The E1 IRO table adds "Factories at risk due to physical changes such as higher water levels. Supply chain risks, policy changes, in both 1.5 °C and 3.7 °C scenarios. Electricity/utility risk in 3.7 °C scenario" (page 79).

Methodology and exposure (paragraph 16). "For both scenarios we reviewed the potential impact on our supply chain, our own operations and our market and our customers; as well as assets and business activities. The focus areas were based on material financial risk and opportunity across the value chain. This included assessing countries where we operate, source from and markets where we are present. For example, by 2030 for our factories we assessed locations that are potentially exposed to acute risk such as flooding, sea-level rise and exposure to cyclones in regions that are at and close to sea-level; as well as locations that are exposed to chronic risk such as prolonged extreme heat and drought in countries such as United Arab Emirates and India" (page 87). A cross-functional internal team with global sector expertise performed the assessment.

Scenario analysis (paragraph 17). Two IPCC scenarios, reviewed rather than rerun in 2025: "We reviewed our climate scenario analysis during the year to confirm it is still valid" (page 86). RCP 2.6 ("Realizing the Paris Agreement"), "a temperature increase up to 2.3 °C warmer by the end of the century", and RCP 6 ("The Rocky Road"), "up to 3.7 °C warmer". Horizons are 2030 and 2050; "ASSA ABLOY does not consider short-term timeframes" (pages 79, 87). Categories assessed were market and technology, reputation, policy and regulation, and physical risk. Output is banded as a share of sales: "we developed the process to be able to quantify our climate-related risk, in terms of percentage of sales from low risk to very high risk" (page 86).

Gap worth noting: no high-emission scenario in the RCP8.5/SSP5-8.5 class and no 1.5 °C no-or-limited-overshoot scenario were used; RCP 6 at up to 3.7 °C is the upper case and RCP 2.6 at up to 2.3 °C the lower. Key assumptions on public policy, macroeconomics, energy mix and technology are not itemised.

Back-filled from ESRS 2 SBM-3 and the TCFD subsection, where this content is disclosed in the FY2025 report (pages 86-87). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 86-87.

Results of the analysis (paragraph 19(a)). "When conducting the scenario analyses, we reviewed several parameters to determine our resilience, both for RCP 6 and RCP 2.6... Our strategy and business model, coupled with our focus to increase our sustainability maturity in our supply chain, our own operations and innovation, through our sustainability target commitments and objectives, will ensure our Group is resilient to the potential risks presented by both RCP 6 and RCP 2.6" (page 87). Exposure is characterised: "For both scenarios, there is potential physical risk in our supply chain and own operations. Our operations have very limited exposure to acute and chronic risks, while our agile supply chain and innovation strategy will enable us to adapt to and/or mitigate risks as well as realize opportunities" (page 87).

Uncertainty (paragraph 19(b)). The company states none: "There are no obvious uncertainties resulting from our analysis" (page 87). That is a bare assertion, offered without supporting sensitivity work, and it sits awkwardly beside the Scope 3 measurement uncertainty acknowledged on page 90 and the estimation uncertainty on page 75.

Capacity to adjust or adapt (paragraph 19(c)). Two concrete adaptation routes are given: "We have implemented a process for upgrading facilities with lower energy efficiency to reach a higher energy efficiency and reduce our emissions in the coming five years. We will review the potential for trainings and ongoing learning opportunities for our personnel to make sure that our workforce remains resilient for future climate change challenges" (page 87). The transition plan's own levers, notably the strategic sites energy overhaul and the Manufacturing Footprint Program, are the asset-side response (page 93). Financial flexibility is not addressed, and "ASSA ABLOY has not identified which assets and business activities are incompatible with or need significant efforts to be compatible with transition to climate-neutral economy" (page 87).

The resilience analysis was reviewed rather than refreshed in 2025 (page 86), which ESRS E1 AR 9 permits.

Reference: pages 88, 93 (ESRS index entry: SS 88, 93).

The governing policy is the environmental sustainability policy, tabled in the policy matrix on page 88. It is "obligatory and available for all divisions, entities, employees within the Group and third parties; defines the commitment, roles and responsibilities regarding environmental impact and KPIs (energy, water, waste, solvents, CO2 emissions, etc.); if the local/third parties' standard is more restrictive we follow it." Its intention is "mitigating the environmental footprint from own operations, value chain, logistics, products and solutions", and it is owned by the Board of Directors / Executive Team. It references the Code of Conduct, the Code of Conduct for Business Partners, the materiality analyses, the supplier sustainability audit and the Green Team Playbook, and is published on the intranet and the ASSA ABLOY website.

The company states the policy's limits plainly: "The policy does not specifically address climate change adaptation, energy efficiency, renewable energy deployment or detail exactly how climate change will be mitigated" (page 88). Elsewhere it notes "Our environmental sustainability policy is aligned with our climate commitment" (page 90).

The E1 IRO table cites the environmental sustainability policy against all six climate and energy rows (page 79). No separate climate policy, energy policy or internal carbon policy is disclosed.

Reference: pages 93-96 (ESRS index entry: SS 93-96), with supporting detail on pages 90-92.

Scope 1 and 2 actions (page 93). Site consolidation through the Manufacturing Footprint Program; elimination of freon as a blowing agent in door insulation ("Freon is a potent source of carbon emissions. By eliminating the use of Freon in our operations, we have dramatically reduced our Scope 1 emissions"); an energy overhaul targeted at the top 25 energy-intensive sites, which "account for more than 60 percent of Scope 1 & 2 emissions"; and continuous improvement embedded in the operational excellence maturity assessment. Page 90 attributes 2025 progress to "increased energy efficiency, installation of onsite renewable energy, manufacturing site consolidations and the impact of updated emission factors" (page 91).

Scope 3 actions (pages 92, 94). Supply chain decarbonisation, sustainable innovation through the sustainability compass, value analysis/value engineering, and low-carbon logistics prioritising sea, rail and road. A suite of three tools was deployed to support the Scope 3 target: the compass calculator (product-level footprint, integrating supplier EPDs and recycled content), sustainable portfolio planning (footprint multiplied by units sold, with scenario modelling), and the aggregated portfolio view (divisional plans consolidated to Group level, with yearly planned-versus-actual KPI tracking). "To date, we have trained about 700 employees, with a strong focus on R&D, sourcing, and product managers" (page 92). "Each division is required to define projects within their portfolios that contribute to the Scope 3 28 percent reduction target."

Resources. No monetary amount is attached. "We do not have a separate investment vehicle to realize the plan, all investments are made through our capital expenditure process" (page 93). Excluded Scope 3 categories are those "not relevant to our organization; for example, upstream/downstream leased assets, as well as excluding categories which represent less than 0.2 percent of Scope 3, for example, capital goods, as approved by the Science Based Targets initiative" (page 91).

Reference: pages 69, 93-96 (ESRS index entry: SS 69, 93-96), with the target list on page 75 and the 2030 programme on pages 70-71.

Science-based targets, base year 2019 (pages 75, 90). Near-term to 2030: reduce absolute Scope 1 and 2 by 50 percent and absolute Scope 3 by 28 percent. Long-term: "realize net-zero carbon emissions no later than 2050, which is to reduce all scopes by 90 percent". "Our climate action targets are ratified by the Science Based Targets initiative" (page 76) and "have been ratified by the Science Based Targets initiative (SBTi)" (page 73).

The E1-6 table adds annual target rates and milestone years: Scope 1 and 2 at 4.17 percent a year, Scope 3 at 2.543 percent a year, with 2030 milestones of 89,230 tCO2eq (Scope 1), 135,091 (Scope 2 location-based), 134,400 (Scope 2 market-based) and 4,059,507 (Scope 3), and 2050 values of 16,484, 24,957, 24,829 and 563,820 (page 96). Footnote 3 qualifies the Scope 3 ambition: "Near-term Scope 3 target is aligned to well-below 2°C, annual target reduction rate will increase in line with ASSA ABLOY's net-zero target requirements from 2030" (page 96), which sits against the page 90 statement that "Our targets are aligned to a 1.5°C trajectory".

Progress (pages 69, 71). The 2019-2025 programme target of a 25 percent absolute Scope 1 and 2 cut was met and exceeded at -34 percent (414,412 to 273,629 metric tons). Scope 3 stood at 4,868,843 tCO2eq against 5,638,204 in 2019, a 13.6 percent reduction (page 90). The new 2030 programme restates the two science-based targets and adds operations targets of -30 percent energy, water and waste intensity from a 2025 base, 30 percent renewable energy and 95 percent ISO 14001 certification (pages 70-71).

Targets were set for the Group, not per division: "Sustainability goals and targets are set at Group level and are not performed on a divisional level" (page 74). Appendix B records the E1-4 GHG emission reduction target datapoint at pages 69, 93-94 (page 116).

Reference: page 95 (ESRS index entry: SS 95).

Total energy consumption for comparable units was 821,141 MWh in 2025 against 850,436 MWh in 2024. "The total Group energy consumption which reached 851,400 MWh, includes entities acquired before June 30, 2025" (page 95, footnote 1). Comparable units are defined as all legal entities acquired up to June 30, 2024, "to ensure consistency with the 2024 reporting boundary".

Direct energy, 380,304 MWh (2025): gas 352,648 MWh, oil 4,579 MWh, biofuel/biomass 927 MWh, with propane reported for the first time in 2025 and coal reported at trace levels (page 95). Indirect energy, 440,837 MWh: electricity 425,160 MWh and district heat 15,677 MWh.

Energy intensity fell to 10.3 MWh/SEK M from 16.5 in 2019, a 38 percent reduction against a 25 percent target (page 69); the E1-6 table gives total energy consumption from high climate impact sector activities per net revenue as 5.39 in 2025 against 5.66 in 2024, down 4.9 percent (page 96). "Energy intensity was reduced by 10 percent in 2025. This was realized through our continued focus on energy effectiveness and efficiency initiatives. Increased production output also resulted in higher value added" (page 67).

Renewable energy is reported both as a proportion purchased and as onsite generation, the latter first reported in 2024; the 2030 programme sets a target of 30 percent renewable energy (page 71). Appendix B marks the E1-5 fossil-source disaggregation and the energy intensity datapoints for high climate impact sectors as "Not Applicable" and records energy consumption and mix at page 95 (page 116).

Caution for readers: the 2024 total "has been updated to align with the reporting boundary used for 2025 comparatives... Earlier years (2019-2023) remain unchanged" (page 95).

Reference: page 96 (ESRS index entry: SS 96).

2025 gross emissions (tCO2eq), with 2019 base and 2024 comparatives (page 96):

• Scope 1: 108,711 (2019: 164,845; 2024: 111,822), down 2.8 percent year on year. "Percentage of Scope 1 carbon emissions from regulated emission trading schemes" is reported as a dash.
• Scope 2 location-based: 164,918 (2019: 249,567), down 3.6 percent. Market-based: 162,383 (2019: 248,291), down 8.4 percent.
• Scope 3: 4,868,843 (2019: 5,638,204; 2024: 4,945,390), down 1.5 percent.
• Total location-based: 5,142,472; total market-based: 5,139,937, down 1.6 and 1.8 percent respectively.

Scope 3 is broken down by category. Purchased goods and services is the dominant one at 3,508,320 (down 5.1 percent), followed by use of sold products 731,600 (up 6.1 percent), end-of-life treatment of sold products 219,507 (up 21.7 percent), downstream transportation 119,572 (up 13.4 percent), upstream transportation and distribution 99,679 (up 19.7 percent), fuel and energy-related activities 65,960, employee commuting 54,833, business travel 36,216 and waste generated in operations 33,155. Capital goods, upstream and downstream leased assets, processing of sold products, franchises and investments are all reported as dashes; capital goods is excluded as under 0.2 percent of Scope 3 "as approved by the Science Based Targets initiative" (page 91).

Intensity: total carbon emissions per net revenue 33.74 (location-based) and 33.72 (market-based) tCO2eq per monetary unit, against 34.82 and 34.86 in 2024 (page 96).

Restatements: "Scope 1 & 2 carbon emissions were restated to include the impact from all acquisitions between 2019-2024" including HHI; "Scope 3 data has been restated to include acquisitions where the data is available; not including HHI" (page 96). The company anticipates "the inclusion of HHI will have a material impact on our base year for Scope 3 emissions" once restated in 2026 (page 91). Twenty percent of market-based Scope 2 is covered by contractual instruments such as RECs or Guarantees of Origin, and "ASSA ABLOY does not purchase unbundled contractual instruments" (page 95).

Reference: page 91 (ESRS index entry: SS 91).

A nil return. "We do not have carbon removal projects in place and do not utilize carbon credits or offsets" (page 91). The statement therefore carries no removals in tCO2eq, no carbon credit retirements and no breakdown by project type, standard or vintage, because there are none.

The point is reinforced by the target architecture: the net-zero commitment is expressed as reducing all scopes by 90 percent by 2050 rather than as a residual to be neutralised (page 75), and the Scope 1 and 2 reduction waterfall on page 93 runs entirely on operational levers (Manufacturing Footprint Program, industrial CO2 elimination, strategic sites energy overhaul, continuous improvement) with no removals or credits line.

Appendix B records the E1-7 datapoint "GHG removals and carbon credits paragraph 56" against page 91 (page 116).

The one related exclusion is disclosed under Scope 1: "Biogenic emissions are not included in the Scope 1 & 2 disclosure" (page 95, footnote 2).

Reference: page 91 (ESRS index entry: SS 91).

A nil return. "We do not have a carbon pricing scheme at ASSA ABLOY" (page 91). No internal carbon price, no shadow price and no internal carbon fee is applied, so no price per tCO2eq, no share of emissions covered and no description of how a price is applied in decision making is reported.

The absence is consistent with the capital allocation model disclosed for the transition plan: "We do not have a separate investment vehicle to realize the plan, all investments are made through our capital expenditure process and follow the same rules as all other capital investments" (page 93), meaning climate projects compete on ordinary investment criteria without a carbon price adjustment.

The company does report a related sensitivity qualitatively rather than through pricing: "higher costs for emissions" is listed as a transition risk under the RCP 6 scenario, and "carbon taxes and market regulations" under RCP 2.6 (page 86).

Reference: pages 79, 86 (ESRS index entry: SS 79, 86). Appendix B places the paragraph 66(a) and 66(c) datapoints at page 86 and the paragraph 69 datapoint at pages 79 and 81, and marks paragraph 67(c) (real-estate carrying value by energy-efficiency class) as "Not Applicable" (page 117).

What is disclosed is a banded, qualitative exposure, not monetary amounts. The IRO tables carry a legend reading "Opportunities/risks as a % of annual sales - Very high is >10%, High 6-10%, Medium 2-5%, Low <1%" (pages 79-85), and the TCFD section explains the method: "we tried to understand both the qualitative and quantitative aspects, especially for climate-related risk. We developed the process to be able to quantify our climate-related risk, in terms of percentage of sales from low risk to very high risk. Depending on the level of risk, the financial risk is then determined as percentage impact on total annual sales" (page 86).

Physical exposure is located but not valued: by 2030 the Group "assessed locations that are potentially exposed to acute risk such as flooding, sea-level rise and exposure to cyclones in regions that are at and close to sea-level; as well as locations that are exposed to chronic risk such as prolonged extreme heat and drought in countries such as United Arab Emirates and India" (page 87). "Coastal factories at risk of flooding" is the named acute physical risk (page 86).

The company states the limitation directly: "ASSA ABLOY has not assessed the financial impacts of material risks and opportunities on financial position, financial performance and cash flows and material risks and opportunities; for which there is significant risk of material adjustment within the next annual reporting period to carrying amounts of assets and liabilities reported in related financial statements due to limitation of data" (page 76). So no disaggregation of monetary amounts by acute and chronic physical risk, and no carrying value of assets at material physical risk, is given.

Reference: pages 88, 97 (ESRS index entry: SS 88, 97). Appendix B records the paragraph 9 datapoint at pages 97-98, the paragraph 13 dedicated policy datapoint at page 88, and the paragraph 14 sustainable oceans and seas datapoint at page 97 (page 117).

Water sits under the environmental sustainability policy tabled on page 88, which "defines the commitment, roles and responsibilities regarding environmental impact and KPIs (energy, water, waste, solvents, CO2 emissions, etc.); if the local/third parties' standard is more restrictive we follow it". The policy is owned by the Board of Directors and Executive Team, is obligatory for all divisions, entities, employees and third parties, and is published on the intranet and the company website.

Scope and boundaries are stated on page 97: "We identified water and marine resources as material for ASSA ABLOY, considering impact materiality. We assessed this based on our own operations and our value chain... We do not have water-intensive processes in areas with low water quality, which may jeopardize the quality of our products. We have a systematic process in place to mitigate the environmental impact and water risk of our operations in high water-stress areas and downstream value chain. Use of water is seen as material regarding our own operations, but does not impact on oceans and seas." Discharge quality is addressed as policy: "We take necessary steps to make sure the water we use and dispose to the municipalities from our operational processes such as painting, plating and cleaning is of the same quality level as water withdrawn."

Suppliers are held to the same standard: "Within our supply chain, we carry out the same assessment as for our own operations... We ensure our suppliers have the same diligent controls as we do in our own operations" (page 97). No standalone water policy, and no commitment to a specific external water framework, is disclosed.

Reference: pages 69, 97 (ESRS index entry: SS 69, 97).

Actions are infrastructure-led and site-targeted. "We continue to upgrade the infrastructure at our sites e.g. piping, additional meters to reduce leaks and implement monitoring systems at top water consuming sites, as well as introducing principles and processes to improve water efficiency. During 2025, water withdrawal decreased by 11 percent and water intensity by 19 percent as a result of improvement activities and infrastructure upgrades" (page 97).

The action scope is defined by process and site: "the most water-intensive processes are the painting, plating and cleaning processes. There are 20 such entities, located mainly in the US, Europe and Asia, accounting for more than 60 percent of our total water consumption" (page 97). Recirculation is the main efficiency lever: "An increasing proportion of the water is recirculated and used again after purification. A wide range of purification methods are used across the Group, such as filtration, sedimentation, flocculation, ion resin exchange and reverse osmosis. The actions we take to improve our water efficiency and reduce consumption are applicable for each site which operates within the Group including entities located in areas at water risk. In 2025 the total amount of recycled water amounted to 20 percent of the total water consumption."

Certification is used as a control: "Risk mitigation in our own operations includes work to ensure that all factories with significant environmental impact and significant water-demanding processes are ISO 14001 certified" (page 97); ISO 14001 coverage reached 88 percent of sites in scope in 2025 (page 69). Contamination is managed through annual site contamination mapping reviewed by a third party, spill kits, secondary containment, and agreed remediation plans with authorities (page 97). No monetary resource allocation is disclosed.

Reference: pages 69, 71, 98 (ESRS index entry: SS 69, 71, 98).

Two target generations are disclosed. The closing 2019-2025 programme set a 25 percent reduction in water intensity from a 2019 base; the outcome was -59 percent, from 44.5 to 18.2 m3/SEK M, marked "KPI achieved" (pages 67, 69).

The new programme carries a fresh baseline: "As part of our new sustainability program 2030, our target is to reduce water intensity by 30 percent across all entities we operate in by the end of 2030, against our 2025 base year. There are no changes compared to the previous sustainability program regarding measurement methodologies, significant assumptions, limitations, sources or adopted processes in data collection. The target is not mandatory based on legislation, but it is mandatory internally, which means all the divisions are required to contribute to realize the target" (page 97). The 2030 summary table gives the 2025 baseline as 28.9 m3/SEK M against the -30 percent target (page 71); this differs from the 18.2 figure in the closing programme because the 2030 baseline covers all entities while the closing programme excluded HHI.

Target setting is Group-level: "Sustainability goals and targets are set at Group level and are not performed on a divisional level" (page 74). No target is set for water withdrawal in absolute terms, for discharge, or specifically for sites in areas of water stress, and no stakeholder involvement in setting the water target is described.

Reference: page 98 (ESRS index entry: SS 98). Appendix B records the paragraph 28(c) recycled and reused datapoint and the paragraph 29 consumption per net revenue datapoint at page 98 (page 117).

2025 water balance, comparable units (page 98). Total withdrawal 1,884 thousand m3 (2024: 2,121; 2019: 1,911), of which purchased water 1,823 (97 percent), on-site wells 52 (3 percent), rainwater 9 and surface water 0. Total consumption including units acquired up to June 30 2025 "reached 1,936 (1,000 m3)". Water intensity 18.2 m3/SEK M against 22.4 in 2024 and 44.5 in 2019.

Usage: industrial processes 1,012 thousand m3 (53-54 percent), sanitary and drinking 691 (37 percent), cooling 71 (4 percent), other 110 (5-6 percent). Discharge, stated as equal to withdrawal at 1,884 thousand m3: municipal pretreated 997 (53 percent), municipal untreated 640 (34 percent), other recipient untreated 199 (11 percent), other recipient pretreated 48 (2 percent). Recirculated water is 20 percent of consumption.

Water stress: "Total water consumption in areas of water stress (1,000 m3): 386", based on the World Resources Institute Aqueduct Water Risk Atlas (page 98).

Two limitations are disclosed. "We do not currently collect the data for the water storage and do not monitor water storage changes e.g. sprinklers, firefighting purposes, rainwater harvesting etc. In 2026 we are planning to add additional data points to our sustainability reporting system to be able to disclose the data" (page 98). And the 2024 comparative differs from last year's statement because HHI was integrated into the totals for the first time; historical numbers were adjusted with proforma data for comparable units, excluding HHI (page 98, footnotes 2-3).

Reference: page 80 (ESRS index entry: SS 80, "E3-5 Anticipated financial effects from material water and marine resources-related risks and opportunities").

The page 80 E3 IRO table carries two rows, both water consumption, one for own operations and one for supply chain operations, with the same banded legend used across the IRO tables: "Opportunities/risks as a % of annual sales - Very high is >10%, High 6-10%, Medium 2-5%, Low <1%". The descriptions are operational rather than financial: "Our own operations need to reduce water consumption, improve processes and efficiency, increase water reuse and recirculation" and "Reduction of water in the value chain, improve processes and efficiency, increase water reuse and recirculation". Mitigation listed for both rows covers the sustainability programme and actions, best practice sharing, the sustainability compass, supplier sustainability audits, the Green Team Playbook, monitoring systems, ISO 14001 implementation, infrastructure overhaul investments, consultations with affected communities and senior management, third-party and key stakeholder engagement.

No monetary anticipated financial effects are disclosed. The company states the reason across all topics: "ASSA ABLOY has not assessed the financial impacts of material risks and opportunities on financial position, financial performance and cash flows and material risks and opportunities; for which there is significant risk of material adjustment within the next annual reporting period to carrying amounts of assets and liabilities reported in related financial statements due to limitation of data" (page 76).

Supporting context sits in E3: 386 thousand m3 of consumption is in areas of water stress (page 98), and the 20 most water-intensive entities account for more than 60 percent of total water consumption (page 97).

Reference: pages 88, 101 (ESRS index entry: SS 88, 101).

The governing instruments are the innovation directive and the environmental sustainability policy, both tabled or referenced in the policy matrix on page 88. The E5 IRO table cites the innovation directive against the resource inflows and resource outflows rows and the environmental sustainability policy against the waste row (page 81).

The company states a gap directly: "ASSA ABLOY does not have a circular economy policy; this will be reviewed during 2026" (page 101).

What stands in its place is described on pages 99-101: "Our handbook for circular economy practices gives guidance and recommendations on how to make circularity an integral part of our product innovation process. The ASSA ABLOY sustainability compass visualizes sustainability aspects in every new project. The sustainability compass is our own sustainable innovation tool, based on lifecycle thinking and circularity principles" (page 100). Intended direction is set out rather than adopted: "we will develop our circularity strategy that will define the starting point and future direction for our circular economy journey. This will also clarify resource allocation, and the funding needed going forward"; the approach "will be guided by circular economy standards like ISO 59004, ISO 59010 and ISO 59020" (page 101). A first Director & Head of Circular Economy for the Group was appointed during 2026 (page 101).

The design philosophy is stated: "The most effective resource management strategy involves maximizing utilization and the product's longevity... sustainable design practices and design for repairability and durability, with high-quality components and regular service and maintenance is the best option for extended life expectancy of our products" (page 99).

Reference: pages 69, 100 (ESRS index entry: SS 69, 100).

In operations. "In our operations ASSA ABLOY employs advanced manufacturing methodologies such as lean manufacturing, value analysis and value engineering, and error-proofing techniques such as poka yoke to minimize waste generation and maximize resource efficiency" (page 99). All sites follow the waste hierarchy, "placing strong emphasis on preventing waste first, then maximizing opportunities for reuse and recycling" (page 67). ISO 14001 roll-out continued, with an additional 10 percent of sites in scope certified in 2025 to reach 88 percent (pages 67, 69).

In product development. The sustainability compass "supports circularity in development with the sections of reuse, recycled content and recyclability that ensures that we design products with circularity in mind from the outset. We have the next generation of the sustainability compass under development to be released during 2026" (page 101). "New products and solutions are designed for serviceability and upgradeability where possible, to extend the useful life of the product" (page 81).

Planned actions. "The transition to a circular economy will be an iterative process where we first document internal best practice from the sites where we currently apply circular business models." ASSA ABLOY "has joined a circularity development program, a collaborative effort aimed at accelerating the implementation of circular products in the construction industry", and states that "our actions will be to further develop our policy, strategies, and measurements for circularity during 2026 and onwards" (page 101).

Constraints are disclosed: adopting circular practices "requires adjustments to procedures in areas such as logistics, repair and testing", products must be retested after installation for CE compliance, and the model "requires a sufficient and reliable inflow of products and components to our circularity repair centers" (page 101). No monetary resources are quantified.

Reference: pages 69, 99, 100 (ESRS index entry: SS 69, 99, 100).

Closing 2019-2025 targets, base year 2019 (pages 67, 69, 99). "ASSA ABLOY has targets to 2025 compared to base year 2019 to reduce non-hazardous waste and hazardous waste intensity by 25 percent." Outcomes: hazardous waste intensity -34 percent (94.5 to 62.8 kg/SEK M) and non-hazardous waste intensity -27 percent (589 to 432 kg/SEK M), both marked achieved; organic solvents intensity -69 percent against a -50 percent target. "The targets are related to layer one in the waste hierarchy, prevention and minimization. The targets are not required by legislation" (page 99).

New 2030 target. "As part of our new sustainability program 2030 we have a new target to reduce our total waste intensity by 30 percent by 2030, compared to our 2025 base year" (pages 99-100), with the 2025 baseline given as 581 kg/SEK M (page 71). A further product-side target is set: "80 percent of portfolio revenue must be covered by the product sustainability methodology" by 2030, with the 2025 position "Will be presented in 2026" (pages 71, 92).

The company names what it has not set: "We do not currently have targets related to increase of circular product design, increase of circular material use rate, minimization of primary raw material, sustainable sourcing and use" (page 100). Targets are Group-level only (page 74).

Reference: page 99 (ESRS index entry: SS 99).

The one quantified inflow figure is a total product weight split: "For the total weight of products, the technical and biological materials used during the reporting period is 733,000 tons and divided between 99.97 percent technical and 0.03 percent biological" (page 99).

Secondary materials are not quantified, and the company says why: "ASSA ABLOY does not currently collect data regarding the absolute weight of secondary reused or recycled components, secondary intermediary products and secondary materials used" (page 99). It also states "During 2026 we will build up the measures for recycled content in our internal systems to support reporting and awareness which is currently not possible for either products, material or packaging material" (page 99), and "ASSA ABLOY does not have the information to determine materials sourced from by-products or waste streams" (page 100).

Sourcing practice is described qualitatively: "We source material and components based on low Global Warming Potential (GWP), as well as on high grade of recycled content. We utilize the same environmental data sets for our internal development phase as we do when sourcing material and components. This simplifies calculations and allows us to steer sustainability optimization throughout the life cycle of a product" (page 99). Data granularity is expected to improve "thanks to Environmental Product Declaration (EPD) based data on our most developed suppliers, as well as our internal environmental data harmonization project"; 318 EPDs have been published (pages 66, 99). The largest purchasing categories are named under E1: "steel, electronics, aluminum, brass, zinc and other metals and materials" (page 90).

Reference: page 100 (ESRS index entry: SS 100). Appendix B records the paragraph 37(d) non-recycled waste and paragraph 39 hazardous and radioactive waste datapoints at page 100 (page 117).

2025 outflows, comparable units (page 100). Waste metal for recycling 71,774 metric tons (73,842 including units acquired up to June 30 2025), described as "our single largest waste stream". Total hazardous waste 5,248 metric tons (5,319 including 2025 acquisitions), made up of other types of toxic waste 3,099, metal sludge 1,737, oil for recycling 267 and electrical and electronic waste 145; hazardous waste intensity 78 kg/SEK M. Total non-hazardous waste 32,015 metric tons (33,612 including 2025 acquisitions): household deposited 11,692, paper and cardboard for recycling 5,510, wood waste 5,371, household incinerated/recycled 4,691, other 2,746, plastic 1,786 and glass 220; intensity 478 kg/SEK M.

Disposal routes. Hazardous waste: recycling 5 percent, "waste to be processed and disposed by authorized companies" 95 percent. Non-hazardous waste: recycling/incineration 55 percent, landfill 45 percent (page 100). "ASSA ABLOY does not generate radioactive waste."

Product durability and design for circularity are described but not quantified: "Durability of our products is both calculated and tested during development and then incorporated into our manuals. Since we develop so many products, we will not disclose this here on a product basis. In many cases the durability is driven from regulations and thereby we follow the industry standard" (page 100). No rates of recyclable content in products or packaging are reported.

The year-on-year movement is explained by boundary rather than performance: "The increase in total waste generated and processed compared with 2024 is mainly driven by the full integration of HHI into the Group's reporting... the reported increase largely reflects the acquisition rather than a change in underlying performance" (page 100).

Reference: page 81 (ESRS index entry: SS 81, "E5-6 Potential financial effects from resource use and circular economy-related impacts, risks and opportunities"). Appendix B also cites page 81 for the E1-9 paragraph 69 climate-opportunity exposure datapoint (page 117).

The E5 IRO table on page 81 carries five rows across resource inflows, resource outflows and waste, with the standard banded legend "Opportunities/risks as a % of annual sales - Very high is >10%, High 6-10%, Medium 2-5%, Low <1%". The commercially framed rows are the circularity opportunity ones: "Potential positive impact through better product lifecycle management. Re-use and repurpose materials", supported downstream by controlled servicing that makes it "possible to initiate reverse logistics on selected circular components, because we have control over the status of the product"; and "Prolonged life time of the products", where "New products and solutions are designed for serviceability and upgradeability where possible".

Demand-side context is given in the E5 chapter: "We see a trend that demand for sustainable solutions is increasing, and that more customers are eager to embrace circular options. Some customers are willing to pay a premium price for circular products" (page 99).

No monetary effects are quantified. "ASSA ABLOY has not assessed the financial impacts of material risks and opportunities on financial position, financial performance and cash flows... due to limitation of data" (page 76). Resource allocation for circularity is explicitly deferred: the future circularity strategy "will also clarify resource allocation, and the funding needed going forward" (page 101).

Reference: page 100 (ESRS index entry: SS 100; the index left column names "Waste" as an E5 sub-topic, pages 114-115).

Twelve waste streams are reported, sourced directly: "Waste data from our twelve waste streams, disclosed on page 100 waste management table, is obtained directly from our waste management providers" (page 99). Where actual data is missing, "we make calculations with proxy data, based on average figures for similar sites in our organization".

2025 totals, comparable units (page 100). Hazardous waste 5,248 metric tons (5,189 in 2024; 4,058 in 2019) at an intensity of 78 kg/SEK M; non-hazardous waste 32,015 metric tons (33,970 in 2024; 25,310 in 2019) at 478 kg/SEK M; metal for recycling 71,774 metric tons. Including units acquired up to June 30 2025 the totals are 5,319 and 33,612 metric tons.

Diverted from and directed to disposal (page 100). Hazardous waste: 5 percent recycling, 95 percent "waste to be processed and disposed by authorized companies". Non-hazardous waste: 55 percent recycling/incineration, 45 percent landfill. "ASSA ABLOY does not generate radioactive waste."

Performance against target (pages 67, 69). Hazardous waste intensity fell 1 percent in 2025 "achieved through targeted waste reduction initiatives, where production processes were further improved to reduce hazardous waste"; non-hazardous waste intensity fell 12 percent, with "All sites follow the waste hierarchy, placing strong emphasis on preventing waste first, then maximizing opportunities for reuse and recycling". Against 2019 both beat the -25 percent target, at -34 and -27 percent. A single total waste intensity target of -30 percent by 2030 against a 2025 base replaces the two (pages 71, 100).

Absolute increases against 2024 are attributed to the full integration of HHI rather than to underlying performance (page 100).

Reference: pages 88, 102-103 (ESRS index entry: SS 88, 102-103). Appendix B records the paragraph 20 human rights policy commitments datapoint at pages 102-103, the paragraph 21 ILO due diligence datapoint at pages 88, 102 and 107, and the paragraph 22 trafficking datapoint at pages 102-103 (page 117).

The governing instruments are the Code of Conduct and the people, safety and human rights policy, the latter tabled on page 88 as including "references to Code of Conduct, UN Guiding Principles on Business and Human Rights at work and connected UN Conventions. UN Global Compact, ILO Declaration on Fundamental Principles and Rights at work, ILO Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy, OECD Guidelines for Multinational Enterprises". Its stated intention is to "promote safe, equal and fair working conditions... Identify impacts and risks and address those. Accident prevention. Elimination of discrimination including grounds of discrimination", and it is owned by the Board of Directors / Chief Human Resources Officer.

"In the Code of Conduct, we have committed to respect human rights; making sure that our employees are treated with respect and fairness, and upholding high ethical standards in our operations. Our Code of Conduct addresses forced or bonded labor, children and young workers, prisoners and illegal workers. All our employees and non-employees (as defined in the ESRS) in our operations need to comply with that commitment" (page 102).

New in the year: "During 2025 we created a responsible AI policy to address AI risks on people" (page 102). A health and safety directive based on ISO 45001 is mandatory for all units and covers all employees, requiring a yearly local audit (page 103), and a recruitment and selection directive held by the CHRO governs equal employment practices (page 103).

Reference: page 102 (ESRS index entry: SS 102).

"In our own operations we engage our workforce continuously through the Voice of the Employee survey that is conducted annually. The employee survey gives us insights if there are any vulnerable groups that have specific impacts or being marginalized. The employee survey process includes a debrief session and triggers improvement activities to all teams within the organization" (page 102).

Representative engagement runs through the Board: "We engage with trade union representatives from the Board of Directors, where we have union representatives giving their perspective on decisions, the ASSA ABLOY targets and how we track against our targets. For our local business, we have a country coordination network to ensure consultation is made" (page 102). Two employee representatives with one deputy each are appointed by the unions (page 74), and union representatives from the Board sit on the Code of Conduct Committee chaired by the CHRO (page 102).

Accountability for engagement is stated at Board and Executive Team level through the governance model rather than assigned to a named role for S1-2.

A limitation is disclosed: "ASSA ABLOY does not currently use quantitative measures to assess the effectiveness of our processes engaging our own workforce" (page 102).

Reference: pages 102-103, 112 (ESRS index entry: SS 102-103, 112).

"Any potential human rights or Code of Conduct violations can be reported in multiple ways, from directly to a manager to our whistleblowing process which is also available for external parties so that we can take action. Retaliation against any reporter in good faith is prohibited in the Code of Conduct. Employees are trained on the Code of Conduct and ethical business practices and how to report any violations on a regular basis" (page 102).

Channels are listed on page 113: "Employees are expected to report concerns to either their manager, divisional compliance officer or HR representative, via e-mail or regular post, or through a third-party managed reporting tool." Anonymity is protected: "If whistleblowers choose to remain anonymous, neither ASSA ABLOY nor our external online reporting tool provider can track or identify the reporting individuals" (pages 109, 113).

Case handling is formalised: "We have also established a more detailed case management process to ensure that allegations and investigations are rigorously and objectively investigated. In most cases the investigations are carried out by internal resources - which may include representatives from the HR, legal and internal audit departments... If needed, external expertise is also engaged" (page 113). "The more severe Code of Conduct issues and Code of Conduct oversight, including effectiveness of reporting is governed by the ASSA ABLOY Code of Conduct Committee which is chaired by our Chief Human Resources Officer and where union representatives from the Board of Directors are represented. Whistleblowing cases are followed up in a tool to be able to track and monitor the cases" (page 102).

Remedy focus is stated: "The main human right-related risk to our employees and non-employees in our operations relates to health and safety; this is also where most of our remedy work is focused, for instance when it comes to rehabilitation" (page 102). No measure of workers' awareness of or trust in the channels is reported for own workforce.

Reference: pages 82, 102-106 (ESRS index entry: SS 82, 102-106).

Health and safety. "Our ambition and vision is to be an injury-free workplace... We identify our risks locally and also from a Group and divisional perspective. Our health and safety scope and metrics include both employees and non-employees under our direct control" (page 102). The health and safety directive is based on ISO 45001, is mandatory for all units, and "require[s] a yearly local audit to be performed by an internal or external party with sufficient competence in health and safety. Compliance with this requirement is monitored through our annual Internal Control Self-Assessment (ICSA)" (page 103). Actions include workshops on risks and behaviours, and "we have launched mental health first-aid programs to cater to local needs" (page 103). The largest exposure is named: "Typically, our biggest risks are employees who are working outside our premises with activities that can range from driving, business travel or work at our customer sites."

Acquisitions are treated as a distinct action area: "Often, the acquired companies exhibit a poorer safety performance than ASSA ABLOY. To succeed with our safety agenda, we ensure that acquired companies are onboard with our health and safety program with the implementation of the health and safety directive and activities to establish a safety culture" (page 103). The 2025 injury-rate bridge shows acquisitions including HHI adding a net 0.4 while the existing business and acquisitions delivered -1.2 since 2019.

Diversity and talent. Graduate programmes, diversity networks, digital courses, internal and partner leadership programmes, an internal women's network and an encouraged 50-50 gender balance in graduate programmes (page 103). "We understand that we are only at the beginning of our diversity and inclusion journey, and still have work to do to achieve our goals."

Resources: "We do not have a separate investment vehicle to realize the targets, all investments are made through our capital expenditure process" (page 104).

Reference: pages 69, 104-105 (ESRS index entry: SS 69, 104-105).

Closing 2019-2025 targets and outcomes (pages 68-69, 104). Injury rate -33 percent target, outcome -27 percent (3.0 to 2.2 injuries per million hours worked), marked missed; injury lost day rate -33 percent target, outcome -8 percent (60.0 to 55.1), missed; gender diversity 30 percent of females in management positions, outcome 29 percent, missed, up 5 percentage points from 24 percent in 2019. By level in 2025: level 2 (reports to CEO) 10 percent, level 3 16 percent, level 4 26 percent, level 5 31 percent, levels 2-5 combined 29 percent (page 69).

New 2030 targets (page 71). Injury rate -20 percent and injury lost day rate -20 percent from a 2025 base of 2.2 and 53.2 respectively. The gender diversity target does not reappear in the 2030 programme summary table.

Method. "We set targets by benchmarking; the health and safety targets were set against the best performing industrial companies with similar activities while for example employee turnover we use benchmarks from Mercer with a country breakdown. Targets are set to fulfil our people strategies and policies. External targets are typically set with a five year horizon" (page 104). "Our social targets are benchmarked against leading practices in our sector and are aligned to international standards such as the UN Sustainable Development Goals" (page 76).

No involvement of the own workforce or its representatives in setting these targets is described.

Reference: pages 105, 153 (ESRS index entry: SS. FS 105, 153, i.e. partly incorporated by reference to Note 35 of the financial statements).

Headcount at 31 December 2025: 62,083 (page 105). By contract type and gender: permanent 60,948 (18,699 female, 42,075 male, 121 other, 53 not disclosed) and temporary 1,135 (453 female, 674 male, 8 other, 0 not disclosed). By gender overall: male 42,749, female 19,152, other 129, not reported 53.

By region: Europe 24,091 (28 percent women), North America 20,849 (30 percent), South America 3,405 (37 percent), Africa 759 (42 percent), Asia 11,184 (35 percent), Pacific 1,795 (30 percent) (page 105). A country table on page 106 lists 37 countries, led by the US 15,747, China 5,077, Mexico 3,578, France 3,006, the United Kingdom 2,859, Germany 2,408, Brazil 2,354 and Sweden 2,353.

Turnover: 17.5 percent, with "The total number of leavers was 10,640 for all units including acquisitions" (pages 103, 105).

The basis of the headcount is flagged repeatedly: "Not comparable to financial statement, headcount defined as actual number of people employed at the end of the reporting period" (page 105), and the country list is "Not comparable with the list of number of employees per country in the financial statement due to other data source and data definitions" (page 106). No breakdown of employees by type of employment contract split between full-time and part-time is given.

Reference: pages 69, 103-106 (ESRS index entry: SS 69, 103-106).

Gender by management level, 2025 (page 105). Level 2 (reports to CEO) 9 percent women, level 3 16 percent, level 4 26 percent, level 5 31 percent; levels 2-5 combined 29 percent; all employees 32 percent. The seven-year series on page 69 shows the same 2025 values against a 2019 base of level 2 20 percent, level 3 17 percent, level 4 20 percent, level 5 25 percent and levels 2-5 24 percent.

Top management, reporting levels 1-3 (page 105). 158 people: male 133 (84 percent), female 25 (16 percent), other 0, not reported 0. Nationalities of management teams at levels 1-3: North America 38 percent, Europe excluding Sweden 32 percent, Asia 9 percent, Sweden 8 percent, South America 6 percent, Pacific 6 percent, Africa and Middle East 1 percent.

Age distribution of employees (page 105): under 30 years 14 percent, 30-49 years 54 percent, 50 years and over 32 percent.

Board gender diversity is reported separately under GOV-1: ratio 3:4, 57 percent female among AGM-elected members (page 74).

Context is given on page 103: "we measure how many of our senior manager roles are held by women, and this increases every year. We reached 24 percent in 2019, and 29 percent in 2025. To support such efforts, we have an internal women's network and encourage a 50-50 gender balance in our graduate programs."

The headcount basis is flagged as "Not comparable to financial statement" (page 105).

Reference: pages 69, 103-106 (ESRS index entry: SS 69, 103-106), with a partial omission declared on page 104.

2025 metrics, comparable units (page 105). Fatalities 0. Lost time injuries 261. Lost days (working days) 6,499; lost days (calendar days) 9,047. Including units acquired during the year: "the total lost time injuries was 268, the total lost working days was 6,674 and the total lost calendar days was 9,500".

Rates (pages 69, 103, 106). Injury rate 2.2 injuries per million hours worked in 2025 (2.1 including units acquired during the year), against 3.0 in 2019, a 27 percent reduction; "if adjusting the 2019 base year for the acquisitions, the injury rate decreased by 36 percent" (page 103). Injury lost day rate 55.1 lost days per million hours worked (53.2 including acquisitions), against 60.0 in 2019, a reduction of 8 percent; the rate rose 5 percent in 2025. Lost days per injury 24.9 including units acquired during the year (page 106). The injury-rate bridge on page 103 attributes a net +0.4 to acquisitions including HHI against -1.2 from the existing business and acquisitions.

Coverage. The health and safety directive is based on ISO 45001, is mandatory for all ASSA ABLOY units and "covers all employees"; scope and metrics "include both employees and non-employees under our direct control" (pages 102-103). No percentage of own workforce covered by a health and safety management system is stated as a figure.

Declared gap. The company states it is "either missing the data, or do not have reliable data for 2025... S1-14 relating to work related ill-health and total recordables" (page 104), so cases of recordable work-related ill health and days lost to ill health are not reported. Lost days are reported on both working-day and calendar-day bases "until 2025 due to the 2025 target of injury lost (working) day rate" (page 104).

Reference: pages 102-103 (ESRS index entry: SS 102-103, "S1-17 Incidents, complaints and severe human rights impacts - general").

2025 outcomes (page 102). "During 2025, 190 cases were reported in the whistleblowing tool, no severe human-rights incidents were substantiated, and no incidents of discrimination were substantiated."

Two limitations are stated in the same passage: "ASSA ABLOY does not have a process to capture fines, penalties and compensation relating to human rights, discrimination, and harassment issues. ASSA ABLOY is not aware of any complaints filed to National Contact Points for OECD Multinational Enterprises" (page 102). So no monetary amount of fines or compensation is reported, and the 190 figure is a count of reports received rather than of substantiated incidents by category.

The reporting and oversight architecture behind the number is described: multiple channels including line manager, divisional compliance officer, HR representative and a third-party managed tool; anonymity protected because "neither ASSA ABLOY nor our external online reporting tool provider can track or identify the reporting individuals"; retaliation prohibited under the Code of Conduct and the whistleblowing directive; and severe cases governed by the Code of Conduct Committee chaired by the Chief Human Resources Officer with union representatives from the Board present (pages 102, 113).

Related risk framing: "The risk that there is forced labor, child labor, and trafficking in any of our locations is addressed in the Code of Conduct and monitored through internal controls, Voice of the Employee and whistleblowing process" (page 102). Appendix B records the ESRS 2 SBM-3 S1 datapoints on risk of forced labour and child labour at pages 102-104 (page 117).

Reference: pages 88, 107 (ESRS index entry: SS 88, 107).

The governing instrument is the Code of Conduct for Business Partners. "Our suppliers must commit to and fulfill the requirements in the Code of Conduct for Business Partners, which stipulates what we believe are necessities in terms of sustainable, legally compliant and fair business. It covers business ethics, human rights and labor standards, environment, and health and safety. This is in line with our people, safety and human rights policy (see policy matrix) which promotes safe, equal and fair working conditions and combat human rights violations" (page 107). The policy matrix records the people, safety and human rights policy as referencing the UN Guiding Principles, UN Global Compact, the ILO Declaration and Tripartite Declaration, and the OECD Guidelines for Multinational Enterprises, owned by the Board and the CHRO (page 88).

Scope is defined explicitly: "The Code of Conduct for Business Partners applies to all partners that provide ASSA ABLOY with products or services, such as suppliers, consultants, distributors, agents and other representatives... The above means that all workers at upstream tier 1 suppliers are included in the scope. It also applies to the suppliers' subcontractors while they are engaging with ASSA ABLOY. Further, agents, distributors and similar on the downstream side are also included" (page 107).

Content: vulnerable groups singled out are "children and young workers"; the code "also covers forced or bonded labor, prisoners and illegal workers"; parental leave is guaranteed "in accordance with applicable legislation without negative repercussions"; and no discrimination is tolerated on grounds of "race, ethnic origin, nationality, sexual orientation, gender, religion, age, disability, political opinions, or any other potential grounds" (page 107). It "reinforces our support for the right to freedom of association and collective bargaining, as well as other working conditions, such as contracts, working hours and fair salary compensation" (page 109). "ASSA ABLOY currently does not have any global framework agreements in place" (page 107).

Reference: pages 107-109 (ESRS index entry: SS 107-109).

Engagement with value chain workers happens through the audit process rather than through a direct channel. "The auditor reviews operations and meets with both management and workers. The audit process follows an established set of tasks and questions. Any identified concerns are documented and made clear in the audit report" (page 108). "This input is gathered during every audit, which occurs every six to 36 months, depending on the score and rating of the audits; the worse the score the more frequently we carry out audits and vice versa" (page 108).

Responsibility is assigned: "The supplier development function reports to the divisional Procurement Director, who has the overall responsibility for ensuring that engagement takes place and that the views of the value chain workers are being respected" (page 108). Audits are performed by "internally trained and certified ASSA ABLOY auditors", occasionally supplemented by third-party auditing "which strengthens the audit process through benchmarking and process calibration" (page 108).

Effectiveness is assessed qualitatively: "The effectiveness of gathering the workers' input is evaluated by looking at the improvement rate during the following re-audit. It is, however, not something that we have a numerical metric for" (page 108).

The company states the limits of its reach plainly: "We currently do not conduct employee surveys at our suppliers to get additional insights regarding job satisfaction, safety, equality, wages or similar and neither do we have formal feedback channels like anonymous digital platforms or committees. Instead, we refer to our whistleblowing function" (page 110). Downstream visibility is weaker still: findings "primarily refer to upstream activities as we have much less insights into the downstream flow" (page 109).

Reference: pages 107-109 (ESRS index entry: SS 107-109).

The primary channel is the Group whistleblowing process, opened to third parties. "Apart from our own audits, everyone is able to submit reports of suspected violations. Any potential human rights violations can be reported in multiple ways from direct manager to our whistleblowing process which is also available for external parties" (page 109). "At ASSA ABLOY, we do not accept any form of retaliation against someone who speaks up, expressing concerns or opinions in good faith. This is outlined in the Code of Conduct for Business Partners and our whistleblowing directive. If whistleblowers choose to remain anonymous, neither ASSA ABLOY nor our external online reporting tool provider can track or identify the reporting individuals" (page 109).

Suppliers are required to run their own mechanism, and it is verified: "we also investigate in our sustainability audits whether the suppliers have a whistleblowing program of their own and that their workers and stakeholders are informed about how to use it. This step also includes making sure there is an identity protection scheme in place and verifying that everything is at an acceptable level in interviews with supplier employees" (page 110). The audit protocol instructs auditors to look for evidence of "regular communications and feedback channels with workers to hear their issues and bring appropriate resolutions" (page 109).

Remediation runs through corrective action plans: "If and when any deviation is found, it is noted in the audit report, with a necessity for the supplier to mitigate the problem." Failure to remediate leads to "new business hold" or the prohibited list (pages 108-109).

The company states the residual gap: "It is, however, difficult for ASSA ABLOY to assess that all value chain workers are familiar with, and trust, the structures to address concerns or violations" (page 109). It also notes it has "no formal guidelines on compensation for damages due to forced labor practices" (page 110).

Reference: pages 107-109 (ESRS index entry: SS 107-109).

Coverage in 2025 (pages 69, 107, 110). 89 percent of direct material and indirect spend suppliers had signed the Code of Conduct for Business Partners, up 3 percentage points, against a 95 percent target that was missed. Sustainability audit coverage "went from 92 percent by spend in 2024 to 95 percent in 2025, which means we met our target". 761 audits were conducted (701 in 2024) across close to 9,072 direct material suppliers.

Findings and consequences (page 110). "By the end of 2025, 1,126 of the 1,148 suppliers audited had satisfied our minimum sustainability requirements - equivalent to 94 percent of our total spend in identified risk countries. During 2025 the Group added 433 new suppliers to the audit scope. During the year, 11 percent of those new suppliers were audited. One supplier was added to the list of prohibited suppliers and prevented from doing business with us, and 33 were put on 'new-business hold'."

Mechanism. A five-colour traffic-light rating: green (re-audit after three years), yellow, orange and purple (conditional approval, follow-up typically after one year), red ("severe sustainability problems", re-audit after six months, new business hold in the interim). "The contract is automatically terminated if a supplier is rated 'red' for longer than six months" (page 108). High-risk countries are identified using the World Bank Worldwide Governance Indicators, the UN Human Development Index, Transparency International's CPI and the US State Department trafficking report, and the list "covers all countries described as hotspots for child labor according to the International Labor Organization and for forced labor according to the United States Department of State" (pages 107-108).

Findings and limits. "the most common reasons for suppliers' severe sustainability problems are health and safety, and environmental issues"; "Severe negative impacts, like child labor, have been very rare with mostly no cases found each year" (page 109). "There are, however, no formal guidelines on what constitutes major or minor non-conformities, but this is up to the individual assessor's judgement" (page 109). "We currently do not have any form of training for suppliers", "no incident reporting system for addressing health and safety incidents at our suppliers", and "For the time being, ASSA ABLOY does not have any figures to provide regarding current and future financial, or other, resources allocated to the continued improvement of the situation for workers in the value chain" (pages 107, 109).

Reference: pages 69, 107, 109 (ESRS index entry: SS 69, 107, 109).

Two supplier targets are reported against, both process-based (pages 69, 71, 107). Sustainability audit coverage: "Proportion of spend in identified risk countries represented by sustainability audited direct material suppliers" reached 95 percent in 2025 against a 95 percent target, marked achieved and carried forward unchanged to 2030. Code of Conduct signature: "Proportion of spend of direct and indirect material suppliers who have signed the Group's Code of Conduct for Business Partners" reached 89 percent against a 95 percent target, marked missed. "While not reaching the target, there has been significant improvement since we started to measure a combination of direct and indirect suppliers in 2019, when the corresponding value was 68 percent. In ASSA ABLOY's new sustainability program to 2030, we will continue to have 95 percent as the target. For indirect spend, efforts are ongoing to raise the number of signed Code of Conduct to match the strong performance achieved with direct material suppliers" (page 107). The signature target applies "to suppliers with sales to ASSA ABLOY entities that have an annual supplier spend exceeding USD/EUR 1 million" (page 69, footnote 7).

The company states there is no outcome target and explains the consequences: "Currently, ASSA ABLOY does not have any outcome-oriented targets related to measuring progress in number of material negative impacts and/or advancing positive impacts on value chain workers. Hence there is also no involvement with value chain workers in such a target setting, nor is there any involvement in identifying improvements as a result of ASSA ABLOY's performance. For the same reason, we cannot state a baseline value or year, or the methodologies and stakeholder involvement behind the targets and similarly and changes in targets" (page 110).

Effectiveness is instead tracked through "the compliance rate (share of suppliers that have signed our Code of Conduct for Business Partners) and audit scores and ratings. We do not have metrics in place for incident rates, worker satisfaction or engagement" (page 107).

Reference: pages 88, 111 (ESRS index entry: SS 88, 111). The ESRS index names the covered sub-topic as "Personal safety of consumers and/or end-users" (page 115).

The governing instrument is the innovation directive. "Governed by the divisional CTO's, our innovation directive mandates customer relevance and compliance as overarching priorities for all our products and solutions" (page 111). The E5 and S4 IRO tables cite the innovation directive against every consumer and end-user row (pages 81, 84).

The company states the policy's limits without softening them: "The innovation directive does not reference any other external standard, only internal standards. There is no human rights policy related to consumers and end-users. The innovation directive is not aligned with internationally recognized instruments" (page 111).

Two supporting commitments are disclosed. "We adhere to the Code of Conduct to acknowledge customer input and comply to General Data Protection Regulation (GDPR) to ensure safe handling of personal data" (page 111). And on standards development: "We actively participate in relevant organizations to drive the development of standards in our industry."

Product safety practice is set out under the same directive: "By developing products that comply to relevant safety and security standards as well as following our innovation directive we ensure privacy for our consumers and end-users" (page 84), and "Our user and service manuals offer clear instructions that help customers maintain products together with support by our service organization so that durability and longevity can be maximized, reducing the risk of malfunction, and ensuring safety and security" (page 111).

Reference: page 111 (ESRS index entry: SS 111).

Engagement runs through a named programme with an owner. "Our Voice of the Customer (VOC) program owned by the CCO includes the Net Promoter Score (NPS) research metric, and all divisions are expanding their use of the NPS; supplemented with qualitative customer experience research" (page 111). Scope is cross-functional: "As the VOC covers both technical and commercial aspects of customer demand, we take a cross-functional approach and include product managers, sales, and marketing teams as well as R&D in the process."

A worked use is given: "The input from the VOC can be used to explore any type of questions for example to enable wheelchair accessibility to a building as described in the beginning of this section" (page 111).

Feedback is fed into design: "We utilize regular customer feedback as a basis for design changes and, depending on severity of issues, this feedback can result in product recalls or production halts. Our product development process is designed to continuously track customer satisfaction and compliance with standards and regulatory requirements, to mitigate negative impact on end-users" (page 111).

A second workstream is user experience: "User experience (UX) is another focus area with several initiatives to improve UX maturity and leverage design systems across the Group. Our goal is to improve the customer experience across all touchpoints with our brands, and we are dedicating resources and directing investments to better understand our customers' journeys" (page 111).

The company withholds the quantitative result: "The result and the base year of calculation is kept only as internal matrix only" (page 111).

Reference: page 111 (ESRS index entry: SS 111).

Channels are stated: "Customers can reach us through our commercial organizations and online channels if any issues occur with our products. We adhere to the Code of Conduct to acknowledge customer input and comply to General Data Protection Regulation (GDPR) to ensure safe handling of personal data. We also facilitate a whistleblowing function for anonymous feedback, which can be accessed through various media such as ASSA ABLOY's website" (page 111).

The S4 IRO table treats free feedback as a positive impact in its own right: "Can feedback freely regarding our products and services... Regardless of what feedback customers have they can use our channels to describe how they perceive our products", mitigated by "Providing personal data protection and whistleblowing functions ensures that customer and end-users can freely report any issues with product or services" (page 84).

Remediation is described in outcome terms: "If our products have a material impact effecting our customers, we address the issue promptly and solve this in best possible way for our customer or end-user" (page 111), and severity-dependent feedback "can result in product recalls or production halts". The recall capability is set out under E5: "If a person is harmed, nearly harmed or assets are damaged due to a product failure, we have the requisite knowledge and infrastructure to carry out a product recall to investigate the root cause and take the necessary steps to remediate the issue" (page 99).

Two limits are disclosed. Severe human rights issues connected to customers and end consumers are cross-referred to S1 rather than dealt with here, and "We will not reference to customer or end-user-specific material impacts in the sustainability statement" (page 111). No measure of end-user awareness of or trust in the channels is given.

Reference: page 111 (ESRS index entry: SS 111).

Personal safety. "Governed by the divisional CTO's, our innovation directive mandates customer relevance and compliance as overarching priorities for all our products and solutions... Our user and service manuals offer clear instructions that help customers maintain products together with support by our service organization so that durability and longevity can be maximized, reducing the risk of malfunction, and ensuring safety and security. Due to this, accidents occur on a low and individual frequency" (page 111). The IRO table records the underlying negative impact as "End-users may be injured during product use. Defective products or not serviced products could have a negative safety impact on people", mitigated "By following the innovation directive and being compliant with applicable standards from development" and by using ASSA ABLOY's own service so that "products will continue to stay safe over its lifetime" (page 84). Trained employees and subcontractors maintain compliance, "of particular importance for safety and emergency-related products", with on-site validation "done by a trained service technician" (page 81).

Social inclusion and accessibility. "The median age globally is increasing leading to an aging population with impairment or disabilities. Accessibility and inclusive product design is therefore key in ensuring that buildings can be accessed and used by everyone. The correct design of a door environment makes a dramatic difference to individuals with reduced muscle or grip strength, or for those utilizing a pushchair, or a wheelchair. Our revolving doors create spacious entrances, ensures smooth functionality and safe traffic flows with advanced sensor technology. Side doors are added for increased accessibility and faster evacuation. Our doors can operate at low speeds to ensure safe passage for those with limited mobility. We also consider the weight of the door, fittings that can be easily gripped and reached, visual considerations and the distance a door needs to be clear of any obstructions when opening" (page 111).

Effectiveness is tracked through the VOC/NPS programme and the product development process, but the results are held internally (page 111). No resources are quantified.

Reference: page 111 (ESRS index entry: SS 111, "S4-5 Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities (consumers and end-users)").

No public outcome target is disclosed, and the company says so directly. "Targets related to product development are for internal steering only and not set or followed up by customers or end users to keep the steps of development as our internal property" (page 111). For the customer experience metric: the VOC programme includes the Net Promoter Score and "all divisions are expanding their use of the NPS; supplemented with qualitative customer experience research. The result and the base year of calculation is kept only as internal matrix only" (page 111).

Consistent with MDR-T's second limb, effectiveness is described in the absence of published targets: "Our product development process is designed to continuously track customer satisfaction and compliance with standards and regulatory requirements, to mitigate negative impact on end-users. Changes to the products are done within our development organizations" (page 111). Customer feedback can escalate to product recalls or production halts, and the recall infrastructure is described under E5 (page 99).

One adjacent product-side target does sit in the 2030 programme, though it is framed as a Scope 3 climate measure rather than an S4 target: "80 percent of portfolio revenue must be covered by the product sustainability methodology" by 2030, with the 2025 baseline "Will be presented in 2026" (pages 71, 92).

No target on personal safety incidents, accessibility coverage or data privacy is published, and no involvement of consumers or end-users in target setting is described.

Reference: pages 88, 112 (ESRS index entry: SS 88, 112). The ESRS index names the G1 sub-topics covered as "Corporate culture / Protection of whistle-blowers / Management of relationships with suppliers including payment practices / Corruption and bribery" (page 115).

The policy stack is the Code of Conduct, the anti-corruption policy, the Code of Conduct for Business Partners, the whistleblowing directive, the third-party due diligence process and the trade compliance policy (pages 85, 88, 112).

"ASSA ABLOY is committed to acting ethically and responsibly and does not tolerate any bribery or corruption. In addition to the Code of Conduct, which covers a broad scope of business conduct-related topics, our specific anti-corruption policy supplements and builds on the Code of Conduct. This policy emphasizes a zero-tolerance policy on bribery and corruption... Like all our Group policies, it is approved by the Board of Directors, and it applies to all employees" (page 112). It is "aligned with international standards, consistent with the UN Convention against Corruption", is "regularly evaluated and updated when needed", and is published on the company website alongside the Code of Conduct and the Code of Conduct for Business Partners.

Whistleblower protection is set out on page 113: multiple channels including a third-party managed tool, a documented case management process, protection of anonymity, and oversight of high-risk cases by the Code of Conduct Committee chaired by the Chief Human Resources Officer.

Trade compliance is treated as part of business conduct: a restricted countries list with red, yellow and green categories, screening procedures, and prohibition of trade with sanctioned parties (pages 88, 112).

Culture is asserted rather than measured; no metric of corporate culture is reported.

Reference: page 113 (ESRS index entry: SS 113).

"ASSA ABLOY fosters a collaborative and ethical partnership with our suppliers, ensuring mutual respect and adherence to shared values. It goes both ways in creating a sustainable business relationship. Key principles include: Ethical standards - both parties to adhere to high standards of integrity and fair dealing, including compliance with laws and regulations; Sustainability and responsibility - mutual long-term sustainability and social responsibility, aiming to build sustainable relationships; Human rights and labor standards - mutual respect for human rights and labor standards and health and safety; Environmental responsibility - there is a strong focus on environmental responsibility, with suppliers expected to comply with environmental laws and strive for continuous improvement in their environmental performance" (page 113).

Social and environmental criteria in supplier selection are described under S2: the Code of Conduct for Business Partners must be signed, and supplier sustainability audits are run in identified risk countries with a five-colour rating governing consequences up to automatic contract termination for a supplier rated red for longer than six months (pages 107-108). "Each division is also responsible for ensuring that current and new suppliers understand and comply with our requirements" (page 75), and governance sits with the Operations Board, which "sets supplier sustainability targets, coordinates activities and follows up on progress" (page 110).

Vulnerability of suppliers to late payment is addressed in the payment practices passage on the same page. No policy on preventing late payment to SMEs is in place; see G1-6.

Reference: page 112 (ESRS index entry: SS 112, "G1-3 Prevention and detection of corruption or bribery").

Risk-based approach. "We conduct business worldwide and we recognize that some of our business activities, specific functions, and geographic areas, carry a greater risk for corruption or bribery. Guided by a risk-based approach, we aim to focus our efforts accordingly. A large part of our sales is handled by external partners, such as distributors. A major focus of our anti-corruption efforts is dedicated to making sure that such third parties acting on our behalf operate in line with ASSA ABLOY's ethical and compliance standards" (page 112).

Third-party due diligence. A step-by-step process held by Group Legal, requiring business representatives to be "carefully reviewed and used only for a legitimate business purpose, on arms-length commercially reasonable terms", with six defined steps ending in signature of the Code of Conduct for Business Partners (page 88). "Regions where the risk of corruption is perceived to be higher, such as emerging markets and countries with a low score on Transparency International's latest Corruption Perception Index, are primarily in focus for heightened diligence measures. According to our policies all business representative relationships must be formally memorialized in a written agreement including our standard compliance clauses or equivalent" (page 112). Acquisitions carry "an integrated compliance process, designed to identify, assess and address potential issues and risks as early as possible".

Detection. "The implementation of the Code of Conduct and related policies and procedures is reviewed through our established process for internal control in all operating companies and internal audits. Further, in 2025 we conducted targeted anti-corruption reviews on entities operating in Asia, the Middle East, South America, North America and Europe" (page 112). Whistleblowing channels are separate from the management chain, with a third-party managed tool and oversight by the Code of Conduct Committee (page 113), and the whistleblowing directive specifies "that all corruption reports are to be treated as high risk" (page 88).

Training. Code of Conduct e-learning at onboarding, repeated every three years, plus a specific anti-corruption and bribery course "mandatory for selected target groups... managers as well as sales, purchasing and sourcing employees. Consequently, we believe that all functions at risk are covered by anti-corruption training requirements" (page 113). Completion: Code of Conduct 90 percent, anti-corruption 90 percent of functions at risk (page 113). Training is not broken down by AMSB members.

Back-filled from the business conduct chapter, 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 ESRS index records MDR-T at pages "69, 93, 97, 98, 100-113", which reaches the G1 chapter (page 114).

Reference: pages 69, 71, 112-113.

Stated targets that bear on business conduct sit in the supply management block of the sustainability programme (pages 69, 71): "Proportion of spend of direct and indirect material suppliers who have signed the Group's Code of Conduct for Business Partners" - 89 percent in 2025 against a 95 percent target for 2025, marked missed, and carried forward unchanged as a 95 percent target for 2030; and "Proportion of spend in identified risk countries represented by sustainability audited direct material suppliers" - 95 percent against a 95 percent target, marked achieved and retained to 2030. Both are governed by the Operations Board, which "sets supplier sustainability targets, coordinates activities and follows up on progress" (page 110).

Effectiveness tracking in the absence of an outcome target, which is MDR-T's other limb, is described for corruption and bribery. Two training completion metrics are reported: Code of Conduct 90 percent of all employees required to take the e-learning, and anti-corruption 90 percent of functions at risk, each on a three-year repetition cycle (page 113). Implementation "is reviewed through our established process for internal control in all operating companies and internal audits", supplemented in 2025 by "targeted anti-corruption reviews on entities operating in Asia, the Middle East, South America, North America and Europe" (page 112). Whistleblowing cases "are followed up in a tool to be able to track and monitor the cases", with the Code of Conduct Committee responsible for oversight of the overall process and all high-risk cases (pages 102, 113).

No numeric target is set for corruption incidents, whistleblowing case resolution, payment practices or lobbying. Targets are set at Group level only: "Sustainability goals and targets are set at Group level and are not performed on a divisional level" (page 74).

Reference: page 112 (ESRS index entry: SS 112).

A nil return on convictions and fines: "We have not been convicted for violations of anti-corruption and anti-bribery laws and consequently no fines have been paid" (page 112).

The statement does not separately report a number of confirmed incidents of corruption or bribery, a number of confirmed incidents in which employees were dismissed or disciplined, or a number of confirmed incidents relating to contracts with business partners. The nearest figure sits under S1: "During 2025, 190 cases were reported in the whistleblowing tool, no severe human-rights incidents were substantiated, and no incidents of discrimination were substantiated" (page 102), which is a count of all whistleblowing reports rather than a corruption-specific breakdown.

The detection and reporting architecture behind the nil return is described on pages 112-113: internal control review in all operating companies, internal audits, targeted anti-corruption reviews in 2025 covering entities in Asia, the Middle East, South America, North America and Europe, and a whistleblowing process with a third-party managed reporting tool. Under the whistleblowing directive "all corruption reports are to be treated as high risk" (page 88), and the Code of Conduct Committee chaired by the Chief Human Resources Officer "is responsible for oversight of the overall process as well as all high-risk cases to ensure appropriate and timely resolution" (page 113).

Reference: page 112 (ESRS index entry: SS 112).

The index lists G1-5 at page 112, but the content at that reference is thin. The only political material on page 112 is the list of components of the anti-corruption policy: "Gifts and entertainment, political and charitable contributions, risk assessments, employee training, conflicts of interest, third-party due diligence, and reporting are some of its essential components" (page 112). The policy is available on the company website at the anti-corruption compliance page cited there.

Nothing further is disclosed against the requirement. The report contains no monetary or in-kind political contributions figure, no breakdown by country, no EU Transparency Register or equivalent registration number, no named lobbying topics or positions, and no disclosure of whether any AMSB member held a comparable position in public administration in the two years before appointment. The word "lobbying" appears in the report only in the ESRS index line for G1-5 itself (page 115).

The company does describe participation in standards bodies, though it frames this as product policy rather than political influence: "We actively participate in relevant organizations to drive the development of standards in our industry" (page 111), and it references driving "change in building codes" as a climate-related opportunity in the E1 IRO table (page 79).

Readers should treat this entry as reported-by-index rather than substantively disclosed.

Reference: page 113 (ESRS index entry: SS 113).

Standard payment terms are given: "The standard payment terms are 90 days from the date of invoice receipt, although in some cases it may be less if mandated by local law. This assures the suppliers that the payments will not be late. This is valid for all suppliers, including SMEs" (page 113). Terms "are communicated to all suppliers during negotiations and onboarding", and "Our ethical business practices in the Code of Conduct includes the timely payment of suppliers... ASSA ABLOY therefore shall pay within the payment term agreed, assuming the supplier is providing the correct and complete invoice documentation."

The company then lists what it cannot report, item by item (page 113). "We currently do not track any of the following metrics on a Group level: Average number of days to pay invoice from date when contractual or statutory term of payment starts to be calculated. Percentage of payments aligned with standard payment terms. Number of outstanding legal proceedings for late payments." And: "We are currently not able to share the below, as this is missing in formal directives or similar: Disclosure of contextual information regarding payment practices. Description of policy to prevent late payments, especially to small and medium enterprises (SMEs)."

So all four G1-6 datapoints are absent and the absence is explained. The G1 IRO table treats payment practices as both a negative impact and a positive one: "Fines, reputation damage, supply shortages, loss of sales" against "Suppliers keen to continue investing in their relationship with us", with mitigation "Negotiate reasonable payment terms, pay invoices on time" and the policy reference recorded as "Not referenced" - the company states that paying on time "is recommended... but not formally a part of any currently existing policy or directive" (page 85).