Atlantic Grupa

Reference: page 172

Governance is dual-board: Supervisory Board, Management Board and General Assembly. "The Supervisory Board provides oversight of the Management Board's activities, including sustainability-related matters, while the Management Board is responsible for implementing strategies and managing day-to-day operations" (p.172).

Four Supervisory Board committees are described (p.172-173): the Public Responsibility and Corporate Governance Committee, the Audit Committee (which "monitors the sustainability reporting process", "monitors the performance of the sustainability report assurance" and "proposes the appointment of an audit firm to perform the sustainability report assurance"), and the Leadership Development and Compensation Committee. Below board level sit the Coordination Committee for Sustainability, Corporate Sustainability Management, and Investor Relations and ESG Reporting (p.173).

Composition (p.172): Management Board 8 members, 6 male / 2 female (73% / 27%, ratio 0.4); Supervisory Board 9 members, 5 / 4 (59% / 41%, ratio 0.7); Audit Committee 4 members, 3 / 1 (75% / 25%). "66.7% of the Supervisory Board are independent members, 75.0% of the Audit Committee are independent members." Representation of employees and other workers: None. Under-represented social groups: None.

Member experience is incorporated by reference to the section Management and Supervisory Board (p.171).

Reference: page 172

Disclosed jointly with GOV-1 under the heading "ESG Governance GOV-1, GOV-2" (p.172). The Management Board "develops and implements the Company's strategy and business plans which include aspects that relate to or may affect sustainability matters" and "review and approve double materiality assessment" (p.173).

Information flow is described as running upward from operational teams: the Coordination Committee for Sustainability "oversees the execution of targets, initiatives, and action plans, monitors progress and ensures effective information flow between operational teams and the central sustainability functions" (p.173). The Investor Relations and ESG Reporting team, with Corporate Sustainability Management, carries out the double materiality assessment and "subsequently present the assessment results to the Management Board for final approval. Following the Management Board's approval of the double materiality assessment, the applied methodology as well as the identified impacts, risks, and opportunities are explained and presented to the Audit Committee" (p.174).

On an annual basis Corporate Sustainability Management "conducts a structured review comparing planned and achieved targets. The results of this assessment are presented to the Coordination Committee for Sustainability and subsequently to the Management Board" (p.174). Board competence: members "possess relevant knowledge on sustainability and our material IROs, based on their previous and current experience and training", and where expertise is lacking "they are encouraged to seek assistance from consultants and experts" (p.175).

Reference: pages 174-175 (ESRS 2), page 197 (E1)

"Since 2021, the achievement of defined sustainability KPI targets... has been reflected in the incentive programmes for the Management Board members. In 2024, the model was further expanded, and from 2025 onwards, sustainability goals are also integrated into the incentive programs of all general managers in SBUs and SDUs, as well as selected executive directors and heads of Central Functions, SBU Marketing, R&D, and Operations" (p.174).

"The proportion of variable remuneration tied to sustainability-related targets ranges from 6% to 10%, depending on whether the bonus is allocated to the Management Board members or other eligible functions" (p.174). Restated in the E1 chapter: "The proportion of variable remuneration tied to sustainability-related targets for the Management Board amounts to 10%, and for the SBU general managers to 8%" (p.197).

Mechanism: annual targets are set for twelve ESG KPIs and a weighted performance index (the AG Sustainability Index) is calculated at year-end; "The same methodology and KPI set apply at both corporate and SBU levels (AG and SBU Sustainability Index), while for SDUs, the Sustainability Index is limited to five ESG KPIs under the Employees pillar" (p.174). The emissions pillar "represents 15% of the total weight of the AG and SBU Sustainability Indexes... Therefore, 1.5% of total remuneration of the Management Board is linked to climate-related considerations" (p.197). Pillar weights are set out on p.178-179: Emissions 15%, Water 15%, Recycling 15%, Employees 40%, Products 15%.

Reference: pages 176-177

A due-diligence mapping table is provided that ties each core element of the due diligence process to the paragraphs of the sustainability statement where it is reflected (p.176):

• Embedding due diligence in governance, strategy and business model - ESRS 2 GOV-2; ESRS 2 GOV-3; ESRS 2 SBM-3
• Engaging with affected stakeholders in all key steps of the due diligence - ESRS 2 SBM-2; ESRS 2 IRO-1
• Identifying and assessing adverse impacts - ESRS 2 IRO-1; E1 IRO-1; E3 IRO-1; E4 IRO-1; E5 IRO-1; S1-3; S2-3; S4-3
• Taking actions to address those adverse impacts - E1-3; E3-2; E4-3; E5-2; S1-4; S2-4; S4-4; G1-1; G1-2; G1-3
• Tracking the effectiveness of these efforts and communicating - E1-4; E1-6; E3-3; E3-4; E4-4; E4-5; E5-3; E5-4; E5-5; S1-5; S2-5; S4-5; G1-1; G1-2

Elsewhere the Company states that information collected through all communication channels "is regularly reviewed as part of the Company's due-diligence process, embedded within the ISO 9001-certified quality management system and aligned with the OECD Guidelines for Multinational Enterprises" (p.187).

Reference: pages 176-177

Sustainability reporting risks are integrated into the group risk management and internal control system; the enterprise risk management (ERM) risks themselves are incorporated by reference to the section Risks of Atlantic Grupa (p.171, 176). Four components are described (pp.176-177): (1) risk identification and assessment across the reporting cycle, "including data collection, calculation, consolidation, validation, and disclosure"; (2) control activities, including "documented calculation methodologies, clear allocation of roles and responsibilities, segregation of duties, data validation checks, and review and approval procedures"; (3) information and communication; (4) monitoring activities through management reviews and internal audit.

"In 2025, no material risks related to sustainability reporting were identified; however, this area will be further assessed and refined in future reporting periods" (p.176).

Two developments are disclosed: "At the end of 2025, the internal audit department initiated an internal audit over the calculation of 12 key sustainability KPIs across the Company's five sustainability pillars", and "in January 2026, the implementation of the Sustainability Reporting Tool ("ESG Core tool") was completed, enabling improved data reliability, stronger internal controls, enhanced data validation processes, and greater transparency in sustainability reporting" (p.177).

Reference: pages 177, 181-183

Atlantic Grupa is a South-East European FMCG manufacturer and distributor: 13 production sites, 17 distribution centres, a fleet of more than 1,000 vehicles with direct access to over 70,000 points of sale, 5,807 employees and EUR 1,190.0 million of sales revenue in 2025 (pp.7, 182-183). Eleven brands have sales above EUR 25 million (p.7). Elements of SBM-1 are incorporated by reference to the sections Corporate strategy of Atlantic Grupa, About the company and Integrated Quality Management Systems (p.171).

The value chain is set out on pp.182-183 as upstream (over 4,500 suppliers of raw and packaging materials, machines, equipment and services), own operations (R&D, production, distribution) and downstream (customers/buyers, consumers, recycling and circular economy).

Sustainability is organised into five corporate priority pillars mapped to SDGs, ESRS topics and KPIs (pp.178-179): Emissions (E1), Water (E3), Recycling (E5), Employees (S1) and Products (S4). Twelve ESG KPIs carry 2030 commitments, for example direct and indirect emissions "58% less compared to 2020" (27,982 tCO2e in 2025 vs 52,797 in 2020), water withdrawal for operations of 2.0 m3/t products, and a minimum 51% share of women in managerial positions.

Reference: pages 184-187

Stakeholders are defined in the Code of Corporate Governance as "individuals or groups that assume certain direct or indirect risks associated with the Company", and in addition to shareholders include "employees, customers and users of the Company's services, suppliers, creditors, the local community and public authorities" (p.184).

A table (pp.186-187) sets out communication channels, main areas of interest and impact on strategy for two groups: key directly affected stakeholders (employees; consumers and shoppers; customers; external principals; suppliers) and other users of sustainability statements (local communities and vulnerable groups; shareholders and creditors; NGOs; public authority bodies; supervisors). Examples of interests recorded include "Products with low environmental impact", "Animal welfare", "Convenient and recyclable packaging" for consumers, and "Supply chain with low environment impacts, preserving biodiversity, fair human rights and animal welfare practices" for suppliers.

"Feedback from these engagement processes is continuously reported to the Management Board" (p.184), and senior leaders are expected to own their stakeholder domain - "for example, the Chief Procurement Officer maintains a detailed understanding of supplier needs, participates in the materiality assessment and advocates for supplier interests" (p.185).

Reference: pages 188-189, plus topical SBM-3 tables at pages 200-201 (E1), 227 (E3), 235 (E4), 244 (E5), 256-257 (S1), 275 (S2), 284-285 (S4), 299 (G1)

The double materiality assessment "was conducted for the first time in 2024". The 2025 review "has led to some changes in the material IROs. As part of this review, eight previously identified material impacts and one material opportunity are no longer considered material, reducing the total number of material IROs to 35. This refinement does not alter the list of material ESRS topics" (p.188).

A consolidated table on p.188 lists all 35 material IROs by topic: E1 4, E3 2, E4 1, E5 4, S1 12, S2 1, S4 6, G1 5. Types are given in the topical SBM-3 tables and are heavily impact-weighted: 26 positive impacts, 4 negative impacts, 4 opportunities and a single risk ("Increase in the cost of relevant raw materials as a consequence of climate change", a physical risk located upstream, p.200).

The four negative impacts are GHG emissions in operations and in the value chain (p.200), water withdrawal for technological operations in water-scarcity areas Skopje and Izola (p.227), and deforestation in the value chain to obtain additional agricultural land (p.235).

"The reduction in the number of material IROs is the outcome of a more mature, evidence based and structured assessment process carried out in 2025" (p.188).

Reference: pages 189-191, with topical processes at pages 200-202 (E1), 227 (E3), 236 (E4), 243 (E5), 300 (G1)

The DMA "follows a structured process designed to identify, assess and prioritise sustainability related impacts, risks and opportunities (IROs) across its operations and value chain, in line with ESRS 1 and ESRS 2 (IRO1)" and was carried out by a Double Materiality Assessment Team "comprising experts from Corporate Sustainability Management, Investor Relations and ESG Reporting, and Risk Management", with workshops involving Procurement, Corporate Security, Energy and Environmental Management, Marketing, Sales, and People & Culture (p.189).

Scope: "conducted at the consolidated level, covering all business units, distribution units and all countries in which the Company operates", considering "its own operations as well as its direct and indirect business relationships across both the upstream and downstream value chain" (p.189).

Thresholds (p.189). Impact materiality: severity from scale (1-5), scope and irreparability, multiplied by likelihood, "with a maximum possible score of 25 and a materiality threshold set at 12.5". Financial materiality: probability multiplied by scale "based on the estimated impact on the Company's EBITDA", same 1-5 scale, "maximum possible score is 25, with the materiality threshold set at 12.5".

Results are classified into five categories - "minimal, informative, moderately important, important and critical" - with the top three treated as material (p.190). The Risk Management Director sits on the DMA Team so that the assessment is integrated with ERM. "The results of the double materiality assessment, including the applied methodology, were reviewed and approved by the Management Board and finally by the Audit Committee" (p.190). The procedure is formally established and "the assessment is updated on an annual basis" (p.190).

Reference: pages 167-169, with the Appendix B datapoint table at pages 306-309

A full ESRS content index is printed under the heading "Disclosure index IRO-2" (p.167): "The following index lists all the ESRS disclosure requirements in ESRS 2 and the eight topical standards that are material to Atlantic Grupa and have guided the preparation of our sustainability statement." Datapoints "were determined using qualitative mapping based on an in-depth examination at a content level of the identified impacts, risks, and opportunities. The mapping is based on the criteria defined in para. 31 of ESRS 1."

The index (pp.168-169) gives a page reference for every listed DR across ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1), E1 (E1-1 to E1-6), E3 (E3-1 to E3-4), E4 (E4-1 to E4-5), E5 (E5-1 to E5-5), S1 (S1-1 to S1-11, S1-13 to S1-17), S2 (S2-1 to S2-5), S4 (S4-1 to S4-5) and G1 (G1-1, G1-2, G1-3, G1-6).

Scope exclusions are stated in the same paragraph: "Following a comprehensive examination of our business activities and locations, we assessed the topical standards ESRS E2 - Pollution and ESRS S3 - Affected Communities as not material" (p.167).

A second table at pp.306-309 lists the Appendix B datapoints derived from other EU legislation, marking each as reported in a named section, "Not material" or "Not relevant". A list of disclosures incorporated by reference (BP-1 scope of consolidation, GOV-1 member experience, three SBM-1 items, GOV-5) is given on p.171.

Reference: pages 197-199

"The following net zero transition plan addresses Scope 1 and Scope 2 GHG emissions, aligning with the Paris Agreement (2015) to limit global warming to 1.5°C" (p.197). "Atlantic Grupa has committed to reduce GHG emissions (Scope 1 and Scope 2 - market-based) by 58% compared to emissions in 2020. Emissions and targets were recalculated in 2024 using the Science Based Target Initiative (SBTi) methodology, applying the absolute approach... The Company used the publicly available SBTi calculator, while targets have not been officially approved by the SBTi organization" (p.197). By 2050 the goal is a 90% reduction, "reaching a total of 5,280 tCO2e" (p.199). "Atlantic Grupa is not excluded from the EU Paris-aligned Benchmark" (p.197).

Levers and quantification (p.198). A bridge from the 2020 base of 52,797 tCO2e to the 2030 target of 22,163 tCO2e shows Scope 1 reductions of -2,298 (replacing fossil fuels with renewables, 6%), -1,179 (waste heat recovery, 3%), -786 (energy efficiency, 2%), -1,910 (fugitive emissions, 5%), and Scope 2 reductions of -1,402 (4%), -28,457 (purchased renewable energy, 79%) and -39. Achieved reduction to date is 24,815 tCO2e.

Resourcing (p.199). "An investment of EUR 15 million in long-term assets, representing approximately 30% of the realized capital investments in 2025, is required for these measures by the end of 2029. These investments are integrated into the long-term financial planning of each business area." "The planning of OpEx is still underway, so the Company is unable to provide an estimate at this time. At this moment, Atlantic Grupa has not adopted the CapEx plan to align economic activities with the required criteria set by the EU taxonomy."

Governance and locked-in emissions. "The Management Board of Atlantic Grupa has approved the transition plan and Strategic business and distribution units integrated this transition plan into their business plans during the long-term financial planning process in 2025" (p.199). More than 20 energy-related projects are prepared at the conceptual stage. "A detailed analysis identified the "locked-in" emissions from fossil fuels that cannot be reduced or replaced by 2030 due to current technological limitations" (p.199). Scope 3: the Company "is in the process of preparing its Scope 3 transition plan... we aim to complete the plan over the next five years" (p.198).

Reference: pages 200-202

Back-filled from ESRS 2 IRO-1 and the E1 IRO-1 climate section, where this content is disclosed in the FY2025 report (pages 200-202). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification (p.200). The single material climate risk is classified explicitly as a physical risk: "Increase in the cost of relevant raw materials as a consequence of climate change - Physical Risk", located upstream, short, medium and long term.

Methodology (pp.200-201). "Building on the climate-related assessments conducted in 2023 and 2024, the 2025 analysis introduced a more structured and comprehensive methodology. For physical risks, the Climatig Tool was used to identify relevant climate-related hazards." Hazards considered were "hail, heat wave, forest fire, cyclones, droughts and others". The Company "analysed how its assets and activities may be exposed to these identified climate-related hazards, considering the geographic location of its various sites". Scope covered "our own production and distribution sites", with "Particular attention... given to agricultural commodities that are essential to our production processes".

Scenarios (p.200). Physical risk was assessed under two IPCC scenarios: "RCP 4.5 - a moderate-emissions pathway assuming stabilization by mid-century" and "RCP 8.5 - a high-emissions trajectory". Transition risk used the IEA "Net Zero Emissions by 2050 (NZE) scenario... aligned with the Paris Agreement objective of limiting global warming to 1.5 °C" (p.202). No global average temperature projection is quantified per scenario.

Time horizons (p.200). "Short term: up to 2030; Medium term: up to 2040; Long term: up to 2050."

Outcomes. Physical risk in own operations was assessed as non-material because a small number of higher-exposure sites had resilience measures already in place (p.201); upstream cocoa and coffee physical risk is material (p.202). Transition events were categorised "policy, liability, technology, market, and reputation" in line with TCFD, scored qualitatively on likelihood and magnitude, and "all identified transition risks were assessed as non-material due to their limited scale and impact on our business model" (p.202).

Reference: pages 201-203

Back-filled from the E1 IRO-1 section headed "Resilience of our strategy and business model to climate change" and the surrounding scenario-analysis text, where this content is disclosed in the FY2025 report (pages 201-203). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Results of the analysis. For the higher-exposure sites identified under RCP 8.5, "we conducted a detailed resilience analysis. This analysis showed that all necessary activities and measures to minimise potential negative impacts on Atlantic Grupa's operations or financial performance have already been implemented. The results of this analysis were integrated into our double materiality assessment as potential risks with a high likelihood of occurrence but with low magnitude" (p.201).

"The outcomes of the scenario analysis for climate-related physical and transition risks provide Atlantic Grupa with important insights into potential business and financial impacts and serve as a key input into the Company's medium- to long-term strategic planning" (p.202).

Adaptive capacity (p.202-203). Four responses are named: hedging against commodity price volatility ("Atlantic Grupa actively hedges coffee and continuously monitors market insights and indicators... enabling the Company's procurement function to develop timely and informed hedging proposals"); sourcing commodities responsibly, deforestation-free, with traceability systems; investing in technology and upskilling to meet climate-related legislation; and "continually evolving its portfolio towards more sustainable products", where "the breadth of Atlantic Grupa's portfolio and the strength of its core brands enhance the Company's ability to absorb potential impacts".

Uncertainty (p.202). "Despite the progress made, significant uncertainties remain regarding the extent, timing, and geographic distribution of both physical and transition climate risks affecting Atlantic Grupa's business. These uncertainties reinforce the importance of continued monitoring, adaptability, and long-term resilience planning."

No quantified financial resilience analysis is presented, and no transition risks were found material.

Reference: pages 202-203

Three policy instruments are described.

Corporate Quality Policy (high-level climate policy). "Atlantic Grupa has a high-level climate change policy defined within its Corporate Quality Policy, which includes adaptation and mitigation measures, energy efficiency, use of renewable energy, and reduction of GHG emissions. This policy has been approved by top management and is further detailed within individual processes and their operational procedures" (p.203).

Climate change adaptation policy in the supply chain. The raw-material cost risk is managed "through its procurement process, based on a policy available via the organizational procedure that includes risk identification and adaptation measures. This policy applies to all procurement processes for direct materials, and the Executive Director of Central Procurement is accountable for its implementation. The objective is to anticipate potential risks... and to implement timely risk-mitigation measures, including hedging strategies and the procurement of predetermined quantities" (p.203).

Policy of GHG Emission Management. Within the Energy management process, this policy "summarizes Atlantic Grupa's approach to energy, climate change, Scope 1 and Scope 2 emissions, and the use of renewable electricity within the scope of its operations. The Group Vice President for Finance, Procurement, and Investment is accountable for this policy." Its objective is "to ensure a structured transition from fossil fuels to renewable energy sources, enhance energy efficiency across operations, phase out the use of fluorinated gases in equipment, procure electricity from renewable sources wherever available, and further invest in on-site solar energy solutions" (p.203).

New in the year: "In 2025, the Policy for GHG Emissions in the Value Chain was additionally developed as a corporate working procedure. The policy defines the Scope 3 GHG calculation process" and targets deforestation-free commodities, eco-design, regenerative agriculture and direct supplier decarbonisation work (pp.203-204). The Corporate Sustainability Management Director is responsible for it. All policies "are available to employees and, upon request, to key stakeholders" (p.202).

Reference: pages 205-207

"All energy-significant locations of Atlantic Grupa are certified according to the ISO 50001 standard" (p.205). Five action groups are set out.

1. Renewable electricity. "Since 2021, Atlantic Grupa's policy has been to purchase electrical energy from renewable sources wherever available (Guarantee of Origin). In 2024, the Company procured electrical energy from 100% renewable sources, with guarantees of origin in all three major markets where it has operational control (Slovenia, Croatia, and partially Serbia). Accordingly, in 2025... the Company also began procuring renewable electricity in Bosnia and Herzegovina" (p.205). Own generation: "In 2025, solar panels were installed at the Hadzici production site in Bosnia and Hercegovina with a capacity of 540kW", a project was prepared for Ljubovija in Serbia, and "By the end of the investment cycle, planned for 2027, 18% of the total electricity consumption of Atlantic Grupa will be generated by its own solar panels" (p.205).
2. Energy efficiency. 2025 investments included "a new efficiency refrigerator unit in Sarajevo, the isolation of the tunnel pasteurizer at the Igros site, new isolation of roof at Simanovci coffee production site and renovation of factory building at the Rogaska Slatina production site" (p.205).
3. Waste heat recovery. At Atlantic Grand Belgrade "heat recovery from the coffee roaster is used to preheat raw coffee"; at Izola "an upgrade of the roasting technology was implemented... enabling the utilization of waste heat and the recovery of heat from steam venting for building heating and domestic hot-water preparation. The impact of this upgrade will be visible in 2026" (pp.205-206).
4. Fuel switching. "Replacing fossil fuels with renewables at the Simanovci coffee production site. Space heating has been partly shifted from natural-gas boilers to heat pumps that use electricity from renewable energy sources" (p.206).
5. Fugitive emissions. Servicing of cooling equipment to minimise HFC releases (p.206).

Scope 3 actions in 2025: improved Scope 3 calculations distinguishing FLAG (LM, LUC) from industrial emissions, with country-specific sLUC data for coffee and supplier primary emission factors for cocoa; a top-down identification of the four most relevant categories for FLAG reduction; and introduction of the Sphera Supply Chain Sustainability platform to track supplier progress toward emission reduction targets (p.206).

Reference: page 207

"In 2023, Atlantic Grupa set a short-term objective to reduce greenhouse gas emissions by 2030, covering total emissions from Scope 1 and Scope 2, in line with the Paris Agreement's goal to limit global warming to 1.5°C" (p.207).

"In accordance with the above and respecting the level of ambition required by the Science Based Target Initiative, Atlantic Grupa aims to reduce Scope 1 and Scope 2 (market-based) emissions by 58% compared to the base year. The base year was not normalized because production quantities are key drivers, and this increase was included in the transition plan" (p.207). The base year is 2020 (52,797 tCO2e) and the 2030 target is 22,163 tCO2e (p.199); by 2050 a 90% reduction to 5,280 tCO2e (p.199).

Progress: "Since the base year, a reduction of 24,815 tCO2 in Scope 1 and Scope 2 emissions has been achieved... In 2025, compared to 2024, emissions were lower primarily due to purchased renewable energy in Bosnia and Herzegovina, decreasing from 29,892 tCO2 to 27,982 tCO2 for Scope 1 and 2" (p.207). A related renewable-energy commitment is "100% procurement of electrical energy from renewable sources" by 2030, at 29.7% in 2025 (p.178).

No Scope 3 target is yet set. "Atlantic Grupa recognizes the necessity of setting a target for Scope 3 emissions in line with the Science Based Target Initiative. As a significant share of upstream value-chain emissions originates from the agricultural sector... the Company anticipates defining two separate and distinct targets: one aimed at reducing FLAG (Forest, Land and Agriculture) emissions related to raw materials, and a second target focused on reducing non-FLAG industrial emissions" (p.207). The targets have not been validated by SBTi (p.197).

Reference: pages 208-209

"Data are collected from each location, either through direct measurement or from utility bills, without validation by external bodies. In 2025, no biomass was used. All operations are within high climate impact sectors" (p.207).

2025 energy consumption (MWh, with 2024 and the 2020 base year) (p.208):

• Coal 0 (0; 0)
• Natural gas 42,749 (40,472; 43,159)
• Crude oil and petroleum products 21,516 (20,679; 18,937)
• Heating oil 1,450 (1,527; 2,861)
• Vehicle fuel 29,881 (28,299; 18,746)
• Total fuel from fossil fuels 95,596 (90,977; 83,703)
• Purchased heat from fossil fuels 8,460 (8,154; 8,523)
• Electricity from fossil fuels 3,198 (6,393; 42,488)
• Total energy from fossil fuels 107,254 (105,524; 134,715), a 70.3% share (71.1%; 97.0%)
• Nuclear 0 (0; 3,416)
• Renewable heat generated 0 (377; 531); renewable electricity purchased 42,863 (40,373; 0); renewable electricity generated 2,442 (2,130; 249)
• Total renewable energy 45,305 (42,879; 779), a 29.7% share (28.9%; 0.6%)
• Total energy 152,559 (148,403; 138,911); total heat 104,056; total electricity 48,503

Intensity (p.209): total energy consumption per net revenue 0.13 MWh/EUR '000 in 2025 (2024: 0.14; 2020: 0.20), with 100% of consumption in high climate impact sectors. "For energy intensity, total energy consumption is divided by total net revenue. The figure for total net revenue can be found in the financial statements, income statement, on page 330."

Reference: pages 209-217

2025 emissions (tCO2e; 2024; 2020 base year) (p.216): Scope 1 23,112 (22,850; 20,923); Scope 2 location-based 28,881 (27,900; 27,773); Scope 2 market-based 4,870 (7,042; 31,875); significant Scope 3 354,013 (347,202; 290,410). Total location-based 406,006 (397,952; 339,106); total market-based 381,995 (377,094; 343,208). Scope 1 under regulated emission trading schemes is reported as n.a.

Largest Scope 3 categories in 2025: purchased goods and services 304,349; capital goods 7,702; fuel- and energy-related activities 7,332; upstream transportation and distribution 11,630; processing of sold products 4,718; use of sold products 6,948; downstream transportation 904; end-of-life treatment 431; waste generated in operations 937; employee commuting 8,569; business travel 163.

"If GHG emissions generated in the upstream value chain of final goods from external principals purchased for resale are also included, a high level estimation of the Company's total Scope 3 GHG emissions in 2025 amount to 376,000 tCO2e (for FY24: 300,500 tCO2e)" (p.214).

Intensity (p.217): total location-based emissions per net revenue 0.34 tCO2e/EUR '000 (2024: 0.36; 2020: 0.48); market-based 0.32 (0.34; 0.48).

Method and quality. GHG Protocol, operational control boundary; IPCC AR6 GWPs for Scope 1 and 2, with FAOSTAT agricultural emissions on AR5 - "This results in a methodological mix that is currently unavoidable and not materially impact the comparability" (p.213). AIB residual-mix factors are used for market-based Scope 2; North Macedonia uses locally sourced factors. "Atlantic Grupa purchases 93% of its electricity with a Guarantee of Origin (in 2024: 86%)" (p.210). Primary cocoa emission factors "represent 8% of the total Scope 3 emissions" (p.211). "Emissions from both upstream and downstream activities in the value chain represent 93% (in FY24: 92%) of Atlantic Grupa's total GHG emissions" (p.210). "The calculations have not been externally verified" (p.211). Divested Montana data was removed from all categories back to the baseline year (p.211). A per-category methodology table with share of primary data is given on pp.212-213.

Reference: pages 227-228

Two instruments cover the material water IROs.

Concession agreements (water consumption). "Water consumption in beverage production is regulated by concession agreements rather than direct policies. These agreements set the allowed quantities for production, which are adhered to within the business plans of SBU Beverages and BU Donat. Production teams at the plants are responsible for maximising and efficiently managing the use of allowed quantities. The general manager of each business unit is accountable for implementing these regulations in SBU/BU operations" (pp.227-228).

Rules of Energy and Water Management (water withdrawal). "Policies related to water withdrawals for operations are defined within the corporate Rules of Energy and Water Management and are managed by process owners of the Energy Management System. SBU Directors of Operations are responsible for implementing the policy in SBU operations. Key elements of the policy include reducing water withdrawal and ensuring responsible water use. The corporate rules are derived from organisational procedures covering all requirements of ISO 50001, and they are applied across all production sites within the Company" (p.228).

Water is treated across its life cycle rather than only as an input: "Even in locations where water availability does not present significant challenges, the volumes of water discharged at the end of the production cycle require appropriate treatment to prevent environmental impact and ensure compliance with water protection standards" (p.227). The Appendix B table marks the E3-1 datapoints on water and marine resources, dedicated policy and sustainable oceans and seas as disclosed in this section (p.307).

Reference: pages 228-229

Water consumption. For beverage production "the volume of water withdrawn from wells is determined by the concession terms; therefore, no additional measures beyond full regulatory compliance are required. Regular measurements of groundwater levels in wells are carried out. All wells are fenced, locked, and under constant video surveillance. Daily monitoring is conducted by the security service. Microbiological and chemical analyses of well water and finished products are performed each day during production" (p.228). "In 2025, the phase-out of one water-bottling program resulted in a reduction of our water concessions by one" (p.229).

Water withdrawal for operations. Continuous efforts listed are "preventing failures that can cause unnecessary water spills through telemetry monitoring and alert systems; optimisation of cleaning procedures and production processes to reduce water needs; investing in advance technological upgrades that require less water; implementing technological solutions for water reuse; and raising employees' awareness about the economical use of water" (pp.228-229).

Specific measures: 2024 introduced free-cooling technology at Izola and a water-recirculation system for bottle rinsing at Apatovec, so that "the volume of evaporated water in cooling systems decreased from 13,095m3 in 2024 to 5,479m3 in 2025"; in 2025 "the Smoki production line was equipped with an automated CIP (Clean-in-Place) cleaning system" and at Igros "the installation of a system for partial water recirculation on the pepper-roasting line was completed" with the full effect expected next year (pp.228-229).

"For the coffee factory in Skopje, the Company's only production site in a high water-risk area, no investments are planned due to low water withdrawal" (p.229). "While Atlantic Grupa has not established a detailed transition plan similar to the one for emissions reductions, the Company's energy team prepares an annual operational plan with activities aimed at reducing water withdrawal at each location in line with the 2030 target" (p.229).

Reference: page 229

Two targets are disclosed.

Compliance target for water consumption. "The target is 100% annual compliance with the requirements defined in the concession agreement for SBU Beverages and BU Donat, for the entire duration of each individual concession agreement and this target was achieved in 2025. The Company does not hold concessions for water consumption in high water-risk areas" (p.229).

Withdrawal intensity target. "The target for water withdrawal is 2.0 m3 per tonne of product by 2030, calculated as the total water withdrawal across all production sites divided by total production quantities (tonnes). While the target level has already been achieved, maintaining it remains appropriate and operationally robust, as water-saving investments are offset by factors that increase operational water needs, such as higher production volumes, changes in product mix, and a growing number of recipes requiring additional cleaning cycles" (p.229). Performance was 1.8 m3/t in 2025 against 1.7 in 2024 and 2.1 in 2020 (p.230).

"This KPI is one of twelve ESG KPIs within the five pillars of sustainable goals set at the corporate level; it contributes 15% to the Atlantic Grupa Sustainability Index. For the first time, targets are also being developed at the SBU and site levels, including for locations in high water-risk areas. All targets are set voluntarily... These targets are not based on conclusive scientific evidence but rather reflect current technological processes and capabilities, as well as assessments of future business trends" (p.229). Stakeholders in target setting are "the Management Board, energy experts, and employees" (p.229).

Reference: pages 230-231

"Water withdrawal and water consumption data (the reported data for water withdrawal represent the quantities as directly measured on sites)... These data have not been validated by an external body" (p.230).

2025 (2024; 2020) (p.230):

• Total water withdrawal from all sources and for any use: 402,031 m3 (410,469; 445,707)
• Total water consumption for food production: 89,855 m3 (91,469; 81,221)
• Total water withdrawal for operations (technology + cleaning): 297,413 m3 (299,309; 338,874)
• Water withdrawal for operations per production unit: 1.8 m3/t (1.7; 2.1)
• Total water consumption in high water-risk areas: <1 m3 (<1; <1)
• Recycled water: 16,813 m3 (15,700; 0)
• Stored water: 0 m3

Intensity (p.231): water consumption per net revenue 74.4 m3/million EUR in 2025 (2024: 86.9; 2020: 119.6), "calculated as total water consumption divided by total net revenue".

Definitions are given for each line (pp.230-231), including that "In 2025, the calculation method was upgraded to also include water used for products manufactured at the SBU Snacks production sites", that high water-risk consumption "includes a coffee factory and a distribution warehouse in Skopje, as well as distribution warehouses in Cacak and Nis" and is "considered negligible based on the nature of the technological process at these sites", and that recycled water is estimated from the Apatovec bottle-rinsing and Igros pepper-roasting recirculation systems.

Reference: page 235

A nil return with a stated basis: "Atlantic Grupa has not identified any material risks in the area of biodiversity. As a result, the Company does not have a transition plan in place" (p.235).

The position is consistent with the topical IRO-1, which records that "The Company has not identified material transitional, physical, or systemic risks" for biodiversity (p.236), and with the single material E4 IRO, which is a negative actual impact rather than a risk: "Deforestation in the value chain to obtain additional agricultural land (raw materials from the EUDR Regulation)", located upstream, described as "Deforestation to obtain additional agricultural land (for coffee and cocoa production)" and covered by the Approval of suppliers policy (p.235).

Biodiversity is nonetheless connected to strategy through sourcing: "Coffee and cocoa represent 58% (in FY24:53%) of our total spend on direct materials. One of the Company's strategic priorities is to maintain and strengthen its leadership in the coffee segment, which serves as the cornerstone of its business. As product volume increases, it becomes increasingly important to minimise the negative impact on biodiversity. By carefully selecting suppliers and ensuring transparency and traceability in the supply chain, Atlantic Grupa will ensure that the extraction of raw materials, especially strategic raw materials coffee and cocoa, does not affect already established ecosystems" (p.235). Sourcing origins are mapped: coffee from Brazil, Colombia, India, Ethiopia, Guatemala, Rwanda, Peru, Costa Rica, Mexico, Uganda and Vietnam; cocoa from Ivory Coast and Ghana (p.235).

Reference: pages 236-237

"The Supplier Approval Policy stipulates the requirement to sign the Code of Conduct, which defines the core principles and expectations for suppliers. Together, the Policy and the Code embed supplier-related requirements and outline fundamental standards in environmental responsibility, social practices, and corporate governance (ESG). These include preventing deforestation by ensuring sourcing practices do not negatively impact forests, lands, or protected areas" (p.236).

Scope and accountability: "The policy applies to all new suppliers of direct materials, including contract manufacturing suppliers. All previously approved suppliers have also received the Code of Conduct for signature and are required to comply with its provisions. This policy addresses Atlantic Grupa's material impact on deforestation in the value chain, particularly related to raw materials listed in the EU Deforestation Regulation (Regulation (EU) 2023/1115) on deforestation-free products. The highest level accountable for implementation is the Executive Director of Central Procurement" (p.236).

Certification is partial and explicitly qualified: "While the Company has not committed to third-party certifications organisation-wide, selected sites maintain Rainforest Alliance, Organic, and Cocoa Horizons certifications, ensuring segregated traceability of certified raw materials to products" (p.236).

Site-level policy: "Our policy for managing the site located within and outside a protected area is to continuously monitor and adapt to environmental legislation and other requirements related to environmental management and biodiversity preservation" (p.237). The only own operation in a protected area is "the beverage production plant in Apatovec, which is positioned within the preserved area Natura 2000. However, the Company does not expand, construct, or exceed emission limits in this area, operates in full compliance with applicable local legislation, and has not identified this as a material impact" (p.236). The Appendix B table maps the E4-2 sustainable land/agriculture and deforestation policy datapoints to this section (p.307).

Reference: pages 237-239

"Since the targets have not yet been defined, Atlantic Grupa does not have detailed action plans to achieve them" (p.237). The Company nonetheless sets out one direct action and four indirect measures.

Direct: geolocation traceability and EUDR implementation. "From 2024, Atlantic Grupa's efforts were directed towards adhering to the new EUDR (Regulation (EU) 2023/1115). The implementation is being conducted in phases, with some aspects still ongoing... Atlantic Grupa has already agreed with suppliers to source coffee with proven origin with the traceability to geolocations in 2025 and has introduced new metric... Despite the fact that the EUDR is not yet officially in force, the share of coffee with verified origin already stands at 27.5%" (p.237). "Additionally, the Company has purchased software to automate requested EUDR process. The Company intends to establish a supplementary system to verify how suppliers implement effective forest conservation practices within their operations and verifies geo-locations of all EUDR-relevant commodities it uses: coffee, cocoa, palm oil, soy, and wood. This system also incorporates data from independent third-party verification schemes such as Rainforest Alliance, RSPO... and FSC" (p.237).

Indirect measures (pp.237-239): working with high-ESG-awareness suppliers, including introduction in 2025 of the Sphera Supply Chain Sustainability platform; sustainable sourcing of natural resources, with only IUCN "least concern" wild species used - "yellowfin tuna (Thunnus albacares), skipjack tuna (Katsuwonus pelamis), European sardine (Sardina pilchardus), and Atlantic mackerel (Scomber scombrus)"; certified sustainable raw and packaging materials (Rainforest Alliance, Bio, Organic, MSC, FSC cardboard for Argeta, Barcaffe and Cedevita); and recipe adaptation away from palm oil, "replacing palm oil with rapeseed oil in Prima products and continued this initiative by using locally sourced sunflower oil for the Smoki brand" (p.239).

Limits are stated plainly: "The provision of remedy is not relevant, as Atlantic Grupa does not work directly with farmers. Biodiversity offsets are not included in the action plan, and local and indigenous knowledge has not been incorporated" (p.237). "The Company did not conduct direct consultations with affected communities" (p.236).

Reference: page 238

No biodiversity targets have been set, and the reason is given: "Atlantic Grupa is proactively preparing for upcoming regulatory and voluntary requirements related to nature and biodiversity. This involves conducting in-depth research to better understand the negative impact within its value chain and implementing effective mitigation measures. These efforts will enable the Company to assess its readiness to establish specific goals with metrics related to land degradation, which currently cannot be set as the Company is awaiting the forthcoming EUDR legislative proposal and our main goal in 2026 is to proper implement EUDR regulation. Additionally, the Company plans to implement a transparent traceability system to collect geodata for EUDR-relevant commodities such as coffee and cacao" (p.238).

In the absence of targets, effectiveness is tracked through the metrics reported under E4-5, principally the share of sourced coffee with geolocation traceability (27.5% in 2025), the share of certified cocoa and coffee, the share of palm oil in the fats and oils purchase category and the share of MSC-certified tuna (p.238). Targets are therefore an acknowledged gap rather than an omission without explanation.

Reference: page 238

Primary metric. "The reduction of negative impact is measured by the metric: % of sourced coffee with geolocation traceability (compliance with EUDR) in 2025: 27.5%" (p.238). "Data were obtained from: incoming documentation provided by suppliers, internal records of DDS (Due diligence statement creation in the Traces NT system, defined in Regulation (EU) 2023/1115) and total quantity data from the ERP system."

Additional metrics for indirect mitigation measures (p.238):

• % of certified cocoa and coffee within total purchased coffee and cocoa: 0.3% in 2025 vs 2.0% in 2024, with the note "In 2025, no certified cocoa was procured".
• Share of palm oil within the fats and oils purchase category: 13% in 2025, 13% in 2024, 38% in 2023, 41% in 2022.
• Share of MSC-certified tuna within the total fish segment sale: 3.8% in 2025 vs 5.0% in 2024.

Both declines are explained: "In 2025, due to the gradual phase-out of part of the chocolate programme, the share of certified cocoa within the overall coffee and cocoa category decreased. Additionally, the share of MSC products within the overall fish segment decreased due to the expansion of the fish spreads category and a 22% reduction in the volume of products with the MSC certificate" (p.238). Palm oil: "In 2025 new recipes were adopted with lower quantities of palm oil however due to the increase in overall production, the metric percentage remains the same" (p.238).

"The calculation has not been validated by an external body; however, traceability and proper identification of certified materials have been confirmed through product certification" (p.238).

Reference: page 245

"As of 2025, all IRO-related policies are consolidated into a Corporate Environmental Process. Atlantic Grupa's operational procedure Environmental process management, for which the Environmental Process Manager is accountable, establishes a unified approach to environmental management based on circular economy principles. It drives packaging innovations in product development to minimize material weight, reduce non-functional secondary packaging, and promote the use of recycled and recyclable materials. Additionally, the procedure sets clear rules for waste management at all locations the Company operates in, ensuring compliance with local and national legislation, minimizing landfilled waste, and fostering continuous improvement. The Company actively seeks solutions to prevent, reuse, or recycle all types of waste generated in direct operations, with separately collected waste handed over to contracted partners for further processing or disposal" (p.245).

The policy sets four requirements, each mapped to a material IRO (p.245): enabling that product packaging is recyclable; minimising packaging quantity to reduce post-consumer waste; reducing non-functional secondary packaging and developing other innovations with better environmental impact; and preventing improper waste practices in the Company's operations.

"Following the policy above, all business units determine their action plans and set the criteria for materials in material specifications, taking care they are also aligned with customer demands (e.g. responsible retailers). The procurement team ensures appropriate raw materials that meet the business objectives" (p.245). Policies "are available to all employees and, upon request, to affected stakeholders", and the Company follows "the principles of ISO 14001, under which it is also certified" (p.245).

Reference: pages 245-247

Recycled content. "The brand Donat introduced 100% recycled PET on all markets in 2021 and closed the loop in cooperation with the supplier. In 2025, Cockta introduced 100% recycled PET packaging in the Croatian and Bosnian markets. Other good practices include introducing 50% recycled heat shrinkable foils in operations and the wider application of stretch foil containing 30% recycled material. Virgin plastic is still used in HDPE caps, duplex, and triplex foils, as there are currently no suitable technological alternatives in the food industry to replace these materials" (p.245).

Recyclability. "In 2025, 94% (in FY24: 93%) of all packaging placed on the market was recyclable, while non-recyclable packaging primarily consisted of triplex foils used for coffee products. Development efforts are focused on transitioning to mono-material, biodegradable, and aluminum-free foils. Additionally, in 2025 Atlantic Grupa initiated preparations in new packaging technology at its Izola location, enabling the testing and broader adoption of next-generation materials starting in 2026" (p.245).

Lightweighting. "In 2025, Atlantic Grupa improved the environmental impact of 52 existing SKUs through initiatives such as lightweighting and reducing the number of colors in packaging design, including the redesign of Grand Gold with one fewer color" (p.245).

Waste actions (pp.246-247). Wasted granulate and broken candies from Cedevita are used as animal feed supplement; at Izola "activities have been initiated to remove the waste status of big bags"; Atlantic Argeta in Bosnia and Herzegovina "signed a contract with a local collector for the collection of waste bones... these waste streams shifted from being a cost to generating revenue"; Igros implemented separate collection across all streams; biowaste separation continued at Apatovec and Vukovina; food waste dehydration equipment "was successfully tested at the Cedevita site in 2025"; Atlantic Brands in Simanovci purchased its own press container.

Resourcing is stated as unquantified: "For all above actions, financial resources are planned in the annual plans for each business unit, but due to price fluctuations and complex Opex planning, we are currently unable to estimate the amount of financial and other resources on a consolidated level. The provision of remedy is not relevant in our case" (p.246).

Reference: pages 246-247

Three targets are disclosed, all voluntary and all part of the Sustainability Index (p.247).

1. Recycled plastic. "Plastic materials have the highest share in Atlantic Grupa's packaging materials, so the Company set the corporate ESG goal to constantly - year to year - increase the share of recycled plastic in the total amount of purchased plastic. The Company measure progress on the corporate level using the ESG KPI "Recycled plastic use ratio". The increase in recycled content is also mandated by Directive (EU) 2019/904 which came into force in 2019 and was incorporated into the new Packaging and Packaging Waste Regulation (PPWR) regulation in 2025. Both set targets of 25% recycled PET in bottles by 2025 and 30% by 2030, and the Company will align its goals accordingly" (p.246). Performance: 21.1% in 2025, 14.4% in 2024, 0.1% in 2020 (p.248).

2. Recyclable packaging. "Recognising the large quantities of all packaging, Atlantic Grupa strives to ensure that 100% of its materials will be recyclable by 2030. However, technological limitations and the availability of next generation materials may delay this achievement. This is a voluntary target. Currently, 94% of the company's materials are recyclable" (p.247).

3. Waste recovery. "Atlantic Grupa's continuous and short-term goal, based on planned activities, is to significantly increase the proportion of waste recovered across operations, aiming for 78% by 2026" (p.246); 77.5% was achieved in 2025 against 70.5% in 2024 (p.249).

A fourth, product-side commitment is that "The Company's continuous and long-term goal by 2030 is that 100% of innovations and changes to existing packaging have better environmental impact", achieved at 100% in 2024 and 2025 (pp.247, 249). "All the above three targets are related to own branded products, produced in own and outsourced operations and are part of Atlantic Grupa's Sustainability Index" (p.247).

Reference: page 247

Overall total weight of products and materials used (p.247):

• Raw materials (biological): 132,957 tonnes in 2025 (84%), against 103,828 tonnes in 2024 (82%)
• Packaging materials: 25,422 tonnes (16%), against 23,348 tonnes (18%)
• Total: 158,379 tonnes, against 127,176 tonnes

"The largest and most strategic raw material categories by tonnage are coffee, cocoa, poultry, sugar, and oils and fats. Out of the total purchased materials, Atlantic Grupa purchased 0.1% in 2025 of sustainably sourced raw materials with certificates (in FY24: 0.2%)" (p.247).

Packaging materials by type, 2025 (2024) in tonnes (p.247): cardboard and paper 10,595 (8,379); glass 4,878 (4,973); PET preforms 3,120 (3,452); metal 2,132 (1,998); triplex flexible foil 1,434 (1,440); plastic packaging and closures 1,248 (1,273); duplex flexible foil 811 (761); other flexible foils 899 (731); other packaging materials 305 (340).

Recycled content is reported alongside: "The absolute quantity of recycled content in this KPI for 2025 is 1,531 tonnes (in FY24: 1,106 tonnes)", equal to a 21.1% recycled plastic use ratio (p.248).

"Quantities are obtained from the ERP system, which records purchased quantities for all metrics in this chapter. There is no overlap between categories" (p.247). A limitation is disclosed for aluminium: "Aluminium, which is used in pate tins, is known for its multiple recycling options and is available on the market with a high share of recycled content. However, the percentage varies, making it impossible to provide an exact number" (p.247).

Reference: pages 248-249

Packaging outflow metrics (p.249). "Share of packaging materials which are recyclable": 94% in 2025, 93% in 2024, 88% in 2020, calculated "by dividing the amount of the recyclable packaging by the total amount of packaging, both spent on finished production orders in the reporting year", with quantities from the ERP system and the ESG KPI reporting tool. "The category of recyclable materials includes single-layer uniform materials, cardboards of all types, aluminium with polypropylene, varnished cans DA, HDPE in LDPE, PP, metallized polypropylene, etc. For double-layer materials, Atlantic Grupa follows the criteria set in international guidance (CEFLEX Designing for a Circular Economy Guidelines) and it collects the declarations of conformity from suppliers. Other materials which are not in the category "recyclable" are triplex foil (alu/plastic) and PVC."

"Share of annually improved packaging with better environmental impact (related to all changes of packaging)": 100% in 2025 and 2024, 84% in 2022 (p.249).

Design limitation stated: "Atlantic Grupa's general goal is to achieve circular recycling, i.e. transforming used packaging into new packaging. Since its products are intended for consumption, repaired or recycled content is not relevant... As the Company operates in the FMCG industry, its packaging is designed for single use rather than multiple reuse" (pp.248-249).

Waste outflow data are reported in the same disclosure and are summarised under the separate Waste entry: total waste 9,055 tonnes in 2025, of which 7,017 tonnes (77.5%) processed for recovery (p.249).

Reference: page 249

Waste by treatment route, tonnes (p.249):

Non-hazardous waste 2025: preparation for reuse 1,811; recycling 2,168; composting 625; incineration for energy use 2,374; incineration 11; landfill 2,009; total 8,999 (2024 total 8,994). Hazardous waste 2025: preparation for reuse 2; recycling 37; incineration for energy use 0.1; incineration 17; total 56 (2024: 85). Total 2025: 1,813 / 2,205 / 625 / 2,374 / 28 / 2,009 = 9,055 tonnes (2024: 9,079).

Summary (p.249): non-recycled waste (incineration, landfill and incineration for energy use) 4,411 tonnes or 48.2% in 2025 (2024: 4,518 t, 49.8%); other waste 4,643 tonnes or 51.3%; waste processed for recovery (preparation for reuse, recycling, composting and incineration for energy use) 7,017 tonnes or 77.5% (2024: 6,402 t, 70.5%).

Composition: "At Atlantic Grupa's locations, given its operations in the food industry, 5,615 tonnes of organic waste (62% of total waste) were generated in 2025 (in FY24: 5,444 tonnes of organic waste - 66% of total waste)" (p.249).

Boundary and source: "The data in the table above includes all different waste types generated in Atlantic Grupa's production and distribution sites, except waste collected in Farmacia's operations, that represents less than 0.5% of total waste. The listed waste processing methods are reported based on the information provided by waste disposal contractors. The Company does not have radioactive waste" (p.249).

A landfill constraint is disclosed: "In some markets (e.g. North Macedonia, Bosnia and Herzegovina), there is a lack of better waste treatment solutions locally. Consequently, not only municipal waste but also separately collected waste is disposed of in landfills" (p.246).

Reference: pages 258-259

"Atlantic Grupa's principles on human rights, equal opportunities, safe and healthy working conditions, and collective bargaining are embedded in the Company's Code of Corporate Governance... Occupational Safety and Health Protection Rules covering Atlantic Grupa d.d. and its affiliated companies provide detailed guidance on workplace safety. Additionally, the People and Culture Processes document outlines policies on diversity, adequate wages, secure employment, gender equality and equal pay for work of equal value, work-life balance, training and skills development, collective bargaining, health and safety, and measures against violence and harassment in the workplace" (p.258).

"Diversity is defined broadly, encompassing racial and ethnic origin, colour, sex, sexual orientation, gender identity, disability, age, religion, political opinion, national extraction or social origin, and other attributes" (pp.258-259).

Alignment: "Atlantic Grupa aligns its policies with internationally recognised frameworks such as the UN Global Compact, the ILO Declaration on Fundamental Principles and Rights at Work, as well as the OECD Guidelines for Multinational Enterprises" (p.259). The Code of Corporate Governance "sets out a zero-tolerance approach to child labour and forced or compulsory work" (p.259).

Accountability: "Accountability for implementation of People and Culture Processes rests with the Chief People Officer, supported by the People and Culture team and operational managers. For Occupational Safety and Health Protection Rules, responsibility lies with the Corporate Security and General Affairs Department" (p.259). Value chain coverage is via the Supplier Code of Conduct, which "includes provisions addressing worker safety, the prohibition of child labour, forced labour and human trafficking" (p.259). "In Atlantic Grupa's double materiality assessment, the risk of child labour and forced labour was evaluated as low... Consequently, these subtopics were assessed as non-material" (p.259).

Reference: pages 259-260

"The Company's comprehensive communication infrastructure serves a dual purpose: it facilitates regular information sharing and provides channels for collecting employee feedback. A cornerstone of this process is the annual employee engagement survey, conducted for more than a decade and overseen by the People and Culture department and the Chief People and Culture Officer. The survey measures overall employee satisfaction and specific aspects of people management. Based on survey results, team-level action plans are developed by team leads to address identified areas for improvement" (p.259).

"Additional mechanisms include targeted surveys, focus groups, stay and exit interviews, and annual performance development discussions. Regular meetings between management and trade union representatives ensure that operational contributors have a meaningful voice in decision-making. Furthermore, through People Business Partners, the Company provides dedicated support to vulnerable employees, such as foreign workforce and persons with disabilities" (pp.259-260).

2025 results (p.260): "Atlantic Grupa maintained its strong employee engagement performance, matching last year's results. With an 89% participation rate, the engagement score remained steady at a high-performing 88%. Additionally, 90% of respondents continued to advocate for Atlantic Grupa as a desirable place to work."

"Participation rates and satisfaction scores serve as indicators of the effectiveness of the Company's engagement practices" (p.259). Scope is stated as "All people in Atlantic Grupa's own workforce (employees and freelancers across all markets)", with collective bargaining the one topic that "does not apply to freelancers" (p.258).

Reference: pages 259-260

Two channels are described.

Whistleblowing. "Atlantic Grupa's whistleblowing process ensures a structured and confidential mechanism for reporting irregularities. Employees and affiliated persons can report concerns via email, post, phone, or in-person meetings to a designated confidential person. Reports are acknowledged within seven days, investigated, and feedback provided within 30 to 90 days. Whistleblowers are protected from retaliation, and their identity remains confidential unless disclosure is required by law. All reports are documented, and Atlantic Grupa takes measures to prevent retaliation and ensure compliance with whistleblower protection laws" (p.259).

Grievance mechanism (p.260). "Grievance Email: Atlantic Grupa has established a dedicated email address for grievances, dostojanstvo@atlanticgrupa.com, localised for each market with the corresponding country prefix (SI, MK, RS, etc)." Cases are handled by an "Internal Investigation and Response Committee: Each grievance is handled by an appointed Committee, which includes relevant experts for each market. Depending on local specifics, members may include People and Culture Heads, Legal, and Health & Safety representatives." "Accessible Procedures: Detailed procedures for submitting grievances and the Committee's role are documented and available to employees via the Company's internal intranet."

Awareness metric. "In the 2024 annual engagement survey, over 89% of employees said they are familiar with the process for submitting formal reports about human rights concerns within the workplace. In 2025, this level of awareness increased to 91%, demonstrating improvement in employees' understanding of the company's human rights reporting channels" (p.260).

Reference: pages 260-263

"Within its sustainability strategy, Atlantic Grupa has defined four strategic KPIs that directly support the goal of fostering an empowered organization through care and responsibility: employee engagement, average training hours per employee, work-related injury rates (Injury Rate - IR and Lost Days Rate - LDR) and share of women in managerial positions" (p.260).

"As of 2025, Atlantic Grupa has achieved all long-term targets defined for its material topics... Given the consistent progress in these areas, no additional corrective action plans have been deemed necessary... The final remaining long-term goal, Training & Skills Development, has also been reached in 2025, with the Company achieving its target for average training hours per employee" (p.260).

Actions by topic (pp.261-263). Secure employment: the share of permanent employees on open-ended contracts rose "from 92% in 2024 to 92.8% in 2025". Adequate wages: "in 2025 salary adjustments were granted to 80% of employees with an average increase of 12%, and supplements were raised for 45.2% of the workforce" (2024: 83% of employees, averaging 17%). Work-life balance: the Work-from-Home Day Bank and Anchor Day continued, plus "a free day for employees' birthdays, an additional day off for parents of first graders on the first day of school, and complimentary medical checks", a sabbatical programme, and in 2025 "subsidised sport cards (Multisport, PassSport, FitPass and Sport Master)". Health and safety: "In 2025, Atlantic Grupa invested more than EUR 73,000 across all its markets to strengthen preventive measures", and "provided training to 861 external contractors, ensuring that complex and high-risk tasks were completed with zero injuries among external contractors at Company locations". Diversity: the Company "signed the Diversity Charter". Gender equality: "Building on the Equal Pay Certification first obtained in 2024, the Company once again earned the prestigious Equal Pay Champion title", with the gender pay gap "further decreasing from 1.1% in 2024 to statistically negligible 0.7% in 2025".

Training initiatives named are the Trade Academy ("291 training sessions attended by over 1,430 employees", Best HR Practice 2025 - Gold award) and the Digital Literacy programme ("2,211 training participations... 802 unique employees, 15% of the workforce") (pp.262-263).

Reference: pages 263-265

"Atlantic Grupa's target-setting process involved direct engagement with workforce representatives and the use of structured employee feedback mechanisms. This included regular consultations with unions and an analysis of insights from the employee engagement survey. The feedback collected through these channels was benchmarked against the organisation's current performance on each topic and against leading industry standards, forming the basis for long-term targets for 2030" (p.263). "For targets defined within the Company's sustainability strategy, progress is measured against the 2020 base year. For all other targets, 2024 serves as the baseline" (p.263).

Targets and 2025 performance (pp.264-265):

• Secure employment: less than 15% fixed-term contracts consistently; 7.2% in 2025 (2024: 8.20%)
• Adequate wages: fewer than 5% paid below the adequate wage benchmark; "In 2025, none of the employees were paid below the applicable adequate wage benchmark"
• Collective bargaining: more than 67% coverage consistently; 87% in 2025 and 2024
• Work-life balance: engagement survey score above 85% on "I am generally able to balance my work and my personal responsibilities"; 92% in 2025 (2024: 93%)
• Occupational health and safety: max 4.5 IR and max 90 LDR; IR 2.4 and LDR 48.6 in 2025 (2024: 3.0 and 69.8; 2020: 6.1 and 102.9)
• Gender equality: maintain pay gap below 5%; 0.7% in 2025 (2024: 1.1%)
• Training: 17 average training hours per employee; 20 in 2025 (2024: 17; 2020: 12)
• Violence and harassment: fewer than one verified case consistently; no verified cases in 2025 or 2024
• Diversity: minimum 51% women in managerial positions; 51.8% in 2025 (2024: 53.2%; 2020: 52.4%)

Each target carries a stated methodology basis, for example ILO standards on decent work for secure employment, ISO 45003 for work-life balance, GRI formulas for IR and LDR, and the WEF Future of Jobs Report and EU Skills Agenda for training (p.264).

Reference: pages 265-267

"Atlantic Grupa reports employee characteristics based on the average headcount during the reporting period across all operating countries, excluding freelancers and contractors" (p.265).

Headcount by gender (p.265): female 2,955 (2024: 2,882); male 2,661 (2,648); other 0; not reported 0; total 5,616 (5,530).

By country (p.265): Croatia 2,232 (2,153); Serbia 2,129 (2,171); Slovenia 680 (661); other 575 (546).

By contract type, 2025 (female / male / total) (p.266): permanent 2,723 / 2,472 / 5,195; temporary 232 / 189 / 421; full-time 2,919 / 2,654 / 5,574; part-time 36 / 6 / 42; non-guaranteed hours 0. The 2024 comparatives are permanent 5,158, temporary 373, full-time 5,482, part-time 48.

Turnover (p.267): "In 2025, a total of 563 employees left Atlantic Grupa, resulting in a reduced employee turnover rate of 10.0%, compared with 661 employees and a turnover rate of 12.0% recorded in 2024. This rate is calculated by dividing the total number of leavers by the average number of employees during the reporting period."

Definitions for each contract category are given on p.267, and personnel costs and average headcount are cross-referenced to Note 6 "Staff Costs" in the consolidated financial statements.

Reference: page 267

"Atlantic Grupa engages freelancers primarily to address specific business needs. Most are contracted to meet seasonal workforce demands during peak periods, ensuring operational continuity. Others provide time-limited project support, offering specialised expertise or assistance for particular initiatives. Additionally, freelancers are occasionally engaged for administrative or part-time support roles to enhance efficiency" (p.267).

"In 2025, the headcount of freelancers increased to 207, compared with an average of 198 freelancers engaged throughout the reporting period in 2024" (p.267).

The population is consistently scoped elsewhere in the chapter: "All people in Atlantic Grupa's own workforce (employees and freelancers across all markets) are included in the scope of this Report... All material topics apply to the entire own workforce, with the exception of Collective Bargaining, which does not apply to freelancers" (p.258). Freelancers and contractors are excluded from the S1-6 employee counts, the diversity, age, training, adequate wage and collective bargaining calculations (pp.265, 268-269).

Only a single headcount figure is given; there is no breakdown by type of non-employee (self-employed versus workers provided by undertakings primarily engaged in employment activities), and the methodology used to compile the number is not described.

Reference: pages 261, 267

"Total percentage of collective bargaining coverage" was 87% in both 2025 and 2024 (p.267).

Coverage rate by market, for countries with more than 50 employees representing more than 10% of total employees (p.267): Croatia in the 60-79% band in both 2025 and 2024; Slovenia in the 80-100% band in both years. For non-EEA employees the Adria region is shown in both years, and the bands 0-19%, 20-39% and 40-59% are listed in the table structure.

"Coverage is calculated by dividing the total number of employees covered by collective bargaining agreements by the total number of employees in Atlantic Grupa, excluding freelancers and contractors. For entities with significant employment (more than 50 employees and representing at least 10% of total employees), coverage is calculated at the market level" (p.267).

On social dialogue and the treatment of uncovered employees: "Atlantic Grupa ensures equal rights for all its employees in relevant markets by applying the same and most favourable rules and rights to everyone, regardless of their coverage under a collective agreement. If there is no collective agreement in the market, local legal regulations and Atlantic Grupa's internal acts harmonised with local legislation are applied to employees. Atlantic Grupa strongly supports the right of association of its employees and the work of its unions. In 2025, 87% of Atlantic's employees remain covered with collective agreements" (p.261). A material positive impact is recorded for "Working conditions beyond minimum legal requirements... based on the collective agreement" (p.256). No separate figure for workers' representation in the EEA is given.

Reference: page 268

Gender distribution in senior positions, 2025 (p.268): Management Board 8 members, 6 male / 2 female (73.3% / 26.7%); Supervisory Board 9 members, 5 / 4 (59.3% / 40.7%); senior managers 586, 279 / 307 (47.7% / 52.3%); total 602, 290 / 312 (48.2% / 51.8%).

2024 comparatives (p.268): Management Board 7 members, 6 / 1 (85.7% / 14.3%); Supervisory Board 9, 6 / 3 (66.7% / 33.3%); senior managers 686, 316 / 370 (46.1% / 53.9%); total 702, 328 / 374 (46.8% / 53.2%). "The Audit committee consists of three members of the Supervisory Board (also included in the numbers above)."

"Senior positions at Atlantic Grupa include all managerial roles and members of the Supervisory Board. Gender distribution in these positions is calculated based on the average headcount of men and women during the reporting period, excluding freelancers and contractors" (p.268).

Age distribution of all employees (p.268): under 30, 762 in 2025 (2024: 787); 30-50, 3,380 (3,358); over 50, 1,473 (1,385); total 5,616 (5,530). "This calculation is based on an average taken over the reporting period."

The share of women in managerial positions is one of the four strategic S1 KPIs, with a minimum 51% target maintained at 51.8% (pp.260, 265).

Reference: page 268

"Atlantic Grupa ensures compliance with all legal wage requirements in the markets where it operates, guaranteeing that no employee is paid below the mandated minimum. The Company determines the lowest wage for each country by considering basic pay and any fixed guaranteed supplements and assessing this amount against the applicable adequate-wage benchmark. The Company evaluates adequate wages against relevant national minimum wages and applicable collective agreements" (p.268).

"Beyond regulatory compliance, the Company maintains competitive and fair wages by regularly conducting and participating in market salary research, using industry benchmarks and best practices to guide its compensation strategy. This approach ensures remuneration reflects employee skills, experience, and market conditions, supporting well-being and long-term business sustainability" (p.268).

Result. "Same as previous year, in 2025, none of the employees were paid below the applicable adequate wage benchmark. Freelancers and contractors are excluded from this calculation" (p.268). This is a complete nil return against a target of "Less than 5% of the employees paid below the applicable adequate wage benchmark" (p.264).

Appropriate salaries are also recorded as a material positive impact under Adequate wages: "Employee satisfaction with fair and adequate compensation, supported by the Company's practice of regular and timely salary payments, has improved year-over-year as reflected in engagement survey results" (p.256).

Reference: page 269

"All Atlantic Grupa employees are covered by social protection measures in line with applicable laws, including illness, unemployment, work-related injury and acquired disability, parental leave, and retirement" (p.269).

Beyond the statutory position the Company describes a supplementary scheme: "Beyond legal compliance, Atlantic Grupa operates a Solidarity Programme for employees and their families. This programme provides assistance in cases of natural disasters (such as floods, earthquakes, or fires), scholarships for children of deceased employees, coverage of additional medical expenses for serious illness or injury, and free psychotherapeutic support" (p.269).

The disclosure covers all five major life events named in the standard - sickness, unemployment starting from when the employee is working, employment injury and acquired disability, parental leave, and retirement - and states full coverage rather than reporting countries where employees are not covered. No breakdown by country or by category of worker is provided, and the position of freelancers under the scheme is not stated separately.

Reference: page 269

Average training hours per employee (p.269): female 26 in 2025 (2024: 21; 2020: 13); male 14 (15; 11); total 20 (17; 12). A second basis is given for 2025 in line with the ESRS headcount requirement: female 24, male 13, total 19.

"Training hours include time spent on various learning activities such as on-site training, online courses, workshops, certification programs, and mandatory compliance education. They exclude trainee programs, course development, and instructor time. Hours per employee and by gender are calculated by dividing total recorded training hours by full-time equivalent (FTE) for each gender... Freelancers and contractors are excluded. Additionally, in accordance with ESRS requirements, for 2025 HC training hours per employee and by gender are calculated by dividing the total recorded training hours in Atlantic Grupa by the headcount for each gender" (p.269).

Performance and development reviews. "Atlantic Grupa conducts annual Performance & Development Talks (PDT) between employees and managers to review objectives, performance, and career development. Same as previous year, in 2025, this process covered 79% of our professionals and managers. Within this population, 57% were women and 43% were men... Taking into consideration the ESRS requirement (% of the total HC involved in Performance and Development Talks), 26% of the total HC population is included in PDT. The gender split is 58% women and 42% men" (p.269).

The 2030 target of 17 average training hours per employee was reached and exceeded in 2025 (pp.260, 264).

Reference: pages 270-271

"All employees of Atlantic Grupa and its affiliated companies are fully covered by the occupational health and safety system (100%). This coverage also applies to all individuals present or performing work at Atlantic Grupa locations. The Company maintains detailed records of all workplace injuries and work-related illnesses, including cases involving non-employees" (p.270).

Work-related injuries, 2025 (2024; 2020) (p.270): minor injuries 29 (37; 52); major injuries 3 (2; 10); fatalities 0 (0; 0); total 32 (39; 62). Injury rate 2.4 (3.0; 6.1); lost day rate 48.6 (69.8; 102.9).

"In 2025, Atlantic Grupa recorded zero work-related fatalities. The fatality rate from occupational injuries remained at 0. No cases of occupational diseases were reported, nor were any illnesses or injuries identified that could be linked to work activities or conditions. The injury rate among external contractors performing work and/or services at Atlantic Grupa locations and affiliated companies was also 0" (p.270).

"During 2025, a total of 636 workdays were lost due to work-related injuries or illnesses. This represents a significant improvement compared to 2024, when 914 workdays were lost. Additionally, no workdays were lost due to fatalities caused by work-related injuries or illnesses in 2025" (p.270).

Method: IR and LDR are "per 1,000,000 hours worked", with "Working hours are estimated annually and adjusted by a multiplier of 1.13 to account for specific business activities (pharmacy and production) occurring on non-working days and multiple shifts" (p.270).

Reference: page 271

"Atlantic Grupa ensures that all employees are entitled to family-related leave in accordance with employment terms and conditions outlined in employee handbooks and contracts" (p.271).

Take-up of family-related leave (p.271). 2025: female parental leave 4.2%, first day in school 1.5%, total family-related leave 5.7%; male 0.6%, 1.2%, 1.8%; total 4.9%, 1.3%, 6.3%. 2024: female 5.0%, 1.4%, 6.4%; male 1.2%, 2.5%, 2.6%; total 7.5%, 2.6%, 8.9%.

The disclosure gives the percentage of employees who actually took family-related leave, disaggregated by gender, and states that entitlement is universal rather than reporting a separate entitlement percentage. The categories reported are parental leave and the additional day off for parents of first graders, which is described among the benefits under S1-4: "A free day for employees' birthdays, an additional day off for parents of first graders on the first day of school, and complimentary medical checks remained the most popular work-life balance benefits across the organisation, with the majority of employees making use of them in 2025" (p.261).

Work-life balance is a material positive impact covering "maternity and paternity leave, sabbaticals, part-time arrangements after parental leave, and hybrid work options" (p.256), and is tracked against an engagement-survey target above 85%, at 92% in 2025 (p.264).

Reference: page 271

Gender pay gap: 1.1% in 2024 and 0.7% in 2025 (p.271). "The gender pay gap is calculated based on all employees' gross hourly pay, including taxable and non-taxable salary elements. The calculation subtracts the average gross hourly pay of female employees from that of male employees, divides the difference by the average male pay, and multiplies by 100" (p.271).

Annual total remuneration ratio: 38.3 in 2024 and 33.4 in 2025 (p.271). "The annual total remuneration ratio is calculated by dividing the highest-earning employee's total remuneration by the median annual remuneration for all employees, excluding the highest earning employee. Total remuneration includes taxable and non-taxable income" (p.271).

A market-level breakdown of the ratio is also given for 2024 and 2025 (p.271): Atlantic Grupa d.d. 17.8 and 16.8; Austria 4.4 and 4.1; Bosnia and Herzegovina 4.2 and 3.8; Montenegro 2.6 and 2.6; North Macedonia 11.3 and 12.5; Serbia 13.7 and 13.2; Russia 2.0 and 2.3; Slovenia 14.1 and 16.4; other legal entities on the Croatian market 14.0 and 13.4. "Atlantic Grupa conducts this analysis at the market level to reflect significant legal and economic differences in salaries across regions. This approach ensures realistic comparisons by considering local conditions such as regulatory frameworks, tax policies, and labour cost structures" (p.271).

Context is given under S1-4: "Atlantic Grupa's longstanding performance based compensation system continues to deliver statistically negligible gender pay differences" and the Company "once again earned the prestigious Equal Pay Champion title" (p.262).

Reference: pages 263, 271

Human rights incidents. "Same as previous year, in 2025, there were no reported cases of human rights violations defined in accordance with the UN Guiding Principles on Business and Human Rights (the Declaration of the International Labour Organization (ILO) on Fundamental Principles and Rights at Work and the OECD Guidelines for Multinational Enterprises)" (p.271).

Violence and harassment. "Same as previous year, no verified cases of workplace violence or harassment reported in 2025" (p.263), against a long-term target of "Number of Verified Cases less than 1, consistently" (p.264). "Atlantic Grupa upholds a zero-tolerance policy against violence and harassment, reinforcing a culture of respect and inclusion. The Company's policy framework is embedded in its Code of Corporate Governance, and clear reporting mechanisms are in place to ensure full compliance" (p.263).

Supporting measures reported alongside the nil returns are the whistleblowing system and grievance system "with a dedicated confidential reporting channel", and the annual engagement survey, where awareness of formal reporting processes increased "from 89% in 2024 to 91% in 2025" (p.263).

No fines, penalties or compensation for damages relating to workplace incidents are reported, and no amount is disclosed; the report states only that no verified cases arose in either year.

Reference: pages 276-277

"Atlantic Grupa's approach to managing its material impact on workers in the value chain is embedded in the Approval of the Supplier procedure, which requires ESG risk evaluation, verification of supporting documents, and completion of ESG questionnaires via the Sphera SCS platform prior to approving suppliers of raw materials and packaging. Signing the Supplier Code of Conduct is mandatory before initiating any business collaboration. This policy is designed to cover all value-chain workers connected to relevant suppliers" (p.277).

"The Supplier CoC sets Atlantic Grupa's commitment to respect human rights and labour rights of value-chain workers and is aligned with the UN Guiding Principles on Business and Human Rights, the ILO Declaration, and the OECD Guidelines for Multinational Enterprises. It explicitly covers child labour and child protection, forced or compulsory labour and human trafficking (including prohibition of recruitment fees and coercive practices), non-discrimination and fair treatment, freedom of association and collective bargaining, working time and fair wages, and occupational health and safety. These topics are embedded in supplier approval and ongoing compliance" (p.277).

Monitoring and remedy expectations: "Atlantic Grupa monitors supplier practices through the ESG assessment process and the contractual acceptance of the Supplier CoC, and requires suppliers to maintain appropriate grievance mechanisms and to implement corrective actions where non-compliance is identified" (p.276). "The Supplier CoC is available on the Company's official website" (p.277), and it is available in six languages (p.303).

Reference: page 277

Engagement is indirect and the Company says so. "Atlantic Grupa engages with value chain workers indirectly through its suppliers by collecting ESG-related information via the Sphera SCS platform. Suppliers are required to submit ESG questionnaires and supporting documentation, which enables the Company to obtain insights into working conditions, human-rights practices, and the existence of worker grievance mechanisms in the value chain" (p.277).

"In 2025, the implementation of Sphera SCS provided a more consistent and structured approach to supplier engagement, improving the quality and comparability of information received about value chain workers. This digital tool also helps identify potential labour-related impacts that may arise within supplier operations" (p.277).

"In addition to indirect engagement, the Company continues to conduct direct assessments of service providers working at its BSCI-certified Atlantic Stark Belgrade production site. These assessments remain an ongoing component of supplier oversight to ensure continuous compliance with social and labour standards" (p.277).

A granularity limitation is disclosed: "The Supplier Code of Conduct and the Company's ESG evaluations apply to all groups of workers across the value chain, meaning that the related risks and opportunities concern the entire workforce rather than specific sub-groups. The Company notes that the ESG questionnaire submitted via Sphera SCS platform collects information at a general level for all worker categories and therefore does not provide the granularity needed to assess individual worker groups" (p.277). No worker representatives or credible proxies are named, and no stage in the process is identified where value chain workers themselves are consulted.

Reference: page 277

Two routes are described.

Supplier-operated mechanisms. "Atlantic Grupa requires its suppliers to maintain effective grievance mechanisms as set out in the Supplier Code of Conduct. Information on these mechanisms is collected through ESG questionnaires submitted via the Sphera SCS platform, allowing the Company to understand how suppliers receive, process, and resolve worker complaints within their operations" (p.277).

Direct channel to Atlantic Grupa. "For concerns related directly to Atlantic Grupa, suppliers and their workers may submit grievances via nepravilnosti@atlanticgrupa.com, which forms part of the Company's Whistleblowing Procedure Rules disclosed under G1-1 Corporate culture and business conduct policies. This contact is also indicated in the Supplier Code of Conduct provided to suppliers and is additionally accessible through the Supplier Portal on the Company's official website" (p.277).

Maturity is stated candidly: "As the Supplier Code of Conduct and Sphera SCS platform were introduced at the end of 2024 and extended in 2025, the Company is gradually integrating grievance-related information submitted by suppliers into its regular monitoring activities. While the Company does not directly evaluate the level of worker awareness or trust in supplier grievance mechanisms, it will continue to rely on SCS-based disclosures to monitor this area as part of its ongoing supplier oversight" (p.277).

Outcome for the year: "In 2025, the Company identified no cases of non-respect of the UN Guiding Principles, ILO Declaration or OECD Guidelines involving workers in its value chain" (p.277).

Reference: pages 277-278

"Atlantic Grupa addresses its material impact on value chain workers through actions integrated into the Approval of the Supplier procedure and the implementation of the Sphera SCS and Sphera SCRM systems. From 2025, ESG risk evaluation, verification of supplier documentation, and signing of the Supplier Code of Conduct became mandatory for approving suppliers of raw materials and packaging. ESG compliance checks have been incorporated into both regular and emergency supplier approvals. This fulfils the commitment announced in 2024 to introduce mandatory Supplier CoC signing from 2025 and to digitalise supplier assessments in line with ESRS S2 requirements, with implementation now completed for relevant suppliers" (p.277).

Risk mapping is disclosed with named geographies: "Among 37 key suppliers of raw materials, packaging, and energy providers, all operate in low-risk countries according to the Human Development Index (HDI)" (p.275). "Tier 2 suppliers, particularly in coffee and cocoa agriculture, may operate in high and very high-risk countries according to HDI, such as Rwanda, Ethiopia, Uganda, India, Ivory Coast, and Ghana, where there is potential risk of child or forced labour. Although the Company does not interact with these suppliers directly, these risks are mitigated indirectly through cascading requirements to tier 1 suppliers and strengthened traceability" (p.276).

"Effectiveness of these actions is monitored through Sphera-based indicators, including the level of CoC coverage among raw-material and packaging suppliers, the completeness and quality of ESG questionnaires, and changes in supplier-level social-risk signals generated by SCRM" (p.277).

"During 2025, no indications of human rights violations were identified in the supply chain. No significant operational expenditures (Opex) or capital expenditures (Capex) were required for these activities" (p.278).

Reference: pages 278, 296

"Atlantic Grupa aims to strengthen the management of social and human-rights-related risks in its supply chain by further integrating insights from the Sphera SCS assessment data with dynamic risk indicators from the Sphera SCRM system. The Company's qualitative objective is to enhance early detection of potential labour and human rights risks and to support suppliers in improving their social practices through more targeted corrective actions" (p.278).

Quantified target. "To reinforce this approach, Atlantic Grupa has set a quantitative and time-bound target for at least 50% of direct materials suppliers and outsourced suppliers to complete the Sphera SCS assessment, which includes social and human-rights-related requirements defined in the Supplier Code of Conduct, by the end of 2026, as further outlined in section G1-2" (p.278).

Baseline. "In the initial rollout year (2025), just under 30% of direct materials suppliers and outsourced suppliers completed the SCS assessment and confirmed compliance with the Supplier Code of Conduct" (p.304). The governance chapter opener states the same two figures side by side: 30% achieved in 2025 against a 2026 target of at least 50% (p.296).

The target is an input measure covering assessment completion rather than an outcome measure for working conditions, and no separate target is set for the tier 2 coffee and cocoa geographies identified as higher risk (p.276). The report does not state whether value chain workers or their representatives were engaged in setting the target.

Reference: pages 284-286

"Atlantic Grupa manages material impacts affecting consumers and end-users through a comprehensive set of policies and procedures. These policies reflect our commitment to respecting human rights, as defined by the UN Global Compact principles and Atlantic Grupa's Code of Corporate Governance. They are aligned with internationally recognized standards, including the ILO Declaration on Fundamental Principles and Rights at Work and the OECD Guidelines for Multinational Enterprises" (p.284).

Six policies are described and each is mapped to a material IRO (pp.284-286):

• Personal Data Management Policy - control over collection, processing and storage of personal data; a Personal Data Protection Advisor and market-level Data Protection Officers are appointed, with "ultimate responsibility resting with the Director of Corporate Services", and data processing agreements reviewed for GDPR compliance.
• Corporate New/Existing product development policy - a stage-gate model where "Sustainability criteria are integrated from the earliest stages of product development".
• Corporate policy for authorisation and labelling of products - "a standardized process for authorizing and labelling food, food supplements, and other FMCG products to ensure compliance across all markets", owned by the Director of Corporate Quality Management.
• Consumer Impact and Safety Policy - "principles for ethical, transparent, and responsible marketing communication, advertising, and promotional activities across all markets... with special attention to vulnerable consumer groups". Marketing Directors of SBUs hold ultimate responsibility.
• Food Safety Culture Policy (FSCL) and the set of Corporate Safety and Quality Policies - owned by the Food Safety and Quality sector within Corporate Quality Management, applying "where applicable... also to subcontractors and contract distributors handling Atlantic Grupa's own-label products".

"All the above-mentioned policies are available to all employees via the intranet across all markets" (p.286). On human rights outcomes: "As we had no reports of human rights violations, we did not implement measures to provide and enable remedies" (p.285).

Reference: page 286

"Atlantic Grupa engages with consumers through multiple communication channels and structured research activities, aligned with its stakeholder engagement process described in ESRS 2 SBM-2. To understand preferences, expectations, and potential impacts of products and services, the Company conducts customer satisfaction surveys, market preference studies, competitive analysis, brand recognition research, loyalty assessments, and online feedback analysis. These processes involve direct consumer participation and provide insights that inform strategic decisions and product development" (p.286).

"Responsibility for implementation lies with marketing departments within each SBU, starting with brand managers and extending to marketing directors, ensuring that consumer feedback is integrated into business objectives" (p.286).

"Effectiveness of engagement is assessed through market research, consumer surveys, and a formal complaints mechanism, which enables tracking and resolution of consumer concerns. Additionally, proactive collaboration with consumers during new product development ensures alignment with expectations and strengthens trust" (p.286).

Concrete 2025 examples are given: "SBU Coffee conducted neuromarketing studies, blind product tests for Turkish and instant coffee, and packaging design evaluations to optimize product appeal. SBU Savoury Spreads carried out concept tests for new salad products, user segmentation studies, and halal consumer research in France to tailor offerings for international markets. SBU Snacks implemented multiple concept and post-launch tests for Smoki Protein, Prima biscuits, and Stark products, supported by retail tracking and continuous feedback through call centres" (p.291).

Reference: pages 286-287

"Atlantic Grupa provides multiple channels for consumers to raise concerns, including a dedicated Contact Centre accessible via toll-free phone, email, and online forms indicated on product packaging. The Contact Centre handles inquiries, suggestions, and complaints, ensuring accessibility for vulnerable consumers through language support and disability-friendly options. Privacy is strictly protected, and all processes comply with consumer protection laws and GDPR requirements" (p.286).

"Every complaint is logged and processed through an official procedure. Cases are forwarded to the Quality Control department for analysis, with involvement from brand managers, Legal Affairs, and Corporate Communications to ensure resolution and preventive measures. Responses are provided promptly and within legally defined deadlines. If a consumer is dissatisfied, escalation options include mediation or independent bodies before legal action" (p.286).

Volumes and performance (p.287). "In 2025, Atlantic Grupa recorded a total of 20,101 consumer communication contacts, which represents a 24% decrease compared to 26,678 contacts in 2024. This reduction is primarily the result of lower brand activity, particularly fewer prize-game campaigns, most notably in the Serbian market." "Across all markets, 737 complaints were received in 2025, compared to 810 in 2024, reflecting a 9% year-on-year decrease." "In both reporting years, 2024 and 2025, no complaints related to human rights violations were recorded."

Service metrics: average response time improved "from 00:00:04 in 2024 to 00:00:03 in 2025", average handle time 00:05:44 in 2024 and 00:05:39 in 2025 "consistent with the industry standard of 2-6 minutes", and customer satisfaction "an average score of 4.6 out of 5 in 2024 and 2025" (p.287).

Reference: pages 287, 290-293

Actions are set out against each of the six material consumer impacts (pp.290-293).

Data privacy. "Atlantic Grupa ensures lawful collection and processing of personal data through robust technical and organizational measures, regular employee training, and compliance monitoring. External partners are required to adhere to the same data protection standards." "In 2025, as in 2024, no claims or violations related to consumer privacy were reported" (p.290).

Product safety and quality. "In 2025, the Company completed 68 supplier on-site audits and 32 transportation service assessments, compared with 58 supplier audits and 78 transportation assessments in 2024, demonstrating strengthened supplier monitoring and a more targeted approach to transportation service assessments" (p.291). Food safety risks are managed through HACCP studies and food fraud risks through VACCP studies; effectiveness is measured "through key indicators, including consumer complaints, food safety culture index, and incidents of non-compliance such as product withdrawals/recalls" (p.291).

Product information. Labels carry "ingredients, storage and preparation instructions, waste separation guidance, recommended daily doses, nutritional and health claims, and certified scheme labels (e.g., organic, responsible fishing)" (p.291).

Products for specific expectations. 2025 launches include "Smoki WOW and Prima, both certified as Vegan and Halal, and Smoki Protein, which in addition to Halal and Vegan certifications contains 20% protein and no palm oil", Barcaffe Bio, Barcaffe Flora (Rainforest Alliance certified with fully recyclable packaging) and Barcaffe Single Origin Peru with blockchain traceability, six new additive-free Argeta products, three gluten-free Boom Box products, Donat herbal waters and Lemonish (pp.292-293).

Responsible marketing. All communications "undergo rigorous review by legal, regulatory, and quality control teams... and to prevent misleading or unsubstantiated claims, particularly regarding environmental benefits. Special attention is given to communications targeting children" (p.293). "The above-mentioned actions do not require significant financial resources" (p.293).

Reference: page 293

One quantified target is disclosed. "Atlantic Grupa has established a target extending to 2030 related to the material impact Regular and proactive collaboration with consumers in the development of new products, with a focus on delivering sustainable innovations year after year that are aligned with consumer needs and expectations" (p.293).

Target and performance (p.293): share of new recipes per year in the claimed category, minimum 70% by 2030; 73% in 2024 and 76% in 2025. "In 2025, we exceeded the target, with the Company's share of new recipes within the claimed categories reaching 76%, compared to 73% in 2024."

Breakdown by unit: "In 2025, SBU Savoury Spreads, New Growth, BU Donat, and SBU Beverages achieved 100% of new products with claims, while SBU Coffee and SBU Snacks reached 64% and 63%, respectively. In total, 80 new recipes with claims were developed. This represents a notable improvement compared with 2024... Overall, 37 new recipes with claims were introduced in 2024, demonstrating substantial year-on-year growth across the portfolio" (p.293).

Method and accountability: "The methodology for setting targets is based on internal assessments of consumer expectations across markets and product categories, combined with planned development capabilities of each SBU. Insights were gathered through various communication channels, as described in ESRS 2 SBM-2." "This target applies to all businesses and is managed through the Sustainability Index, which is integrated into the management reward model for General Managers and Marketing/R&D Directors" (p.293).

Gap acknowledged: "For other material impacts, specific targets have not yet been adopted. However, effectiveness of policies and actions is monitored through Atlantic Grupa's integrated management systems, including daily internal monitoring, regular internal and external audits, continuous risk-management processes and evaluations performed by Internal Audit" (p.293).

Reference: pages 298-301

"At Atlantic Grupa, corporate culture is the backbone of our success... Atlantic's corporate culture is deeply embedded in its governance framework, guided by key documents such as Atlantic's Code of Corporate Governance and the Code of Ethics in Business. Leaders exemplify the Company's values of Passion, Care, Openness, and Growth through their daily interactions with teams" (p.300).

The Code of Corporate Governance, in its 2025 iteration, "defines processes that aim to ensure sustainable development and responsibility for the implementation of adopted policies and procedures as a framework for performance management and performance measurement, risk management, anti-corruption behaviour and prevention of conflicts of interest aligned with a strategic approach to ESG topics" (p.298). It is "made available to all individuals and our stakeholders upon request and it is also accessible on the Company's intranet... and the Company's website" (p.298).

Business conduct policy (p.300). Ten standards of conduct are listed, including "professionalism, expertise, impartiality; conscientiousness and honesty; prohibition of any form of discrimination and any form of harassment that violates a person's dignity; equality, justice and respect of human rights, integrity and dignity of a person; responsibility; transparency; compliance with the rules of business ethics; honesty in relations with business partners, shareholders and other stakeholders; avoiding conflicts of interest and managing the Company's assets with due care." Implementation is "overseen by the Group Vice President for Corporate Activities".

Whistleblower protection (pp.300-301). The Whistleblowing Procedure Rules allow "any person, being internal or external stakeholder, who has gained information through her or his professional activity with the Company" to report "in a safe and confidential manner, with full protection against retaliation". A Confidential Person and Deputy manage the process; results go to the President of the Management Board and the Audit Committee. "Atlantic Grupa enforces a zero-tolerance policy for retaliation." Outcome: "In 2025, one irregularity was reported (FY2024:1), which was, following a detailed analysis, resolved" (p.301).

Cultural effectiveness is evaluated "through regular engagement surveys, focus groups, and performance metrics" (p.300).

Reference: pages 301-304

"The basic principles for procurement and supplier relationship management are defined in the Purchasing Guidelines, the fundamental document of Atlantic Grupa's purchasing organisation... The Executive Director of Central Procurement is accountable for the implementation of the Purchasing Guidelines" (p.302).

Three key processes are described (pp.302-303): (A) Supplier qualification and performance monitoring - a model "introduced in 2014 and continuously improved since then", covering certificate and documentation verification and supplier questionnaires. "Supplier evaluation is conducted annually, and each supplier receives structured feedback regarding their performance rating and the required improvements." (B) Supply chain risk and sustainability management - "Using the digital platform Sphera SCRM (Supply Chain Risk Management), the Company assesses a wide range of risks affecting its key 500 suppliers... Through automated risk intelligence scanning of approximately 300,000 online media sources, the platform provides timely notifications and data-driven insights." In 2025 the complementary Sphera SCS platform was introduced for direct materials and outsourced suppliers, assigning "an internal risk rating (low, medium, or high)" and planning "corrective action plans for high-risk suppliers in the next reporting period". (C) Policies - the Supplier Code of Conduct, "available in six languages", covering environmental protection, human rights and fair work practices and governance and business ethics, and the Ethical Code of the Purchasing Organization.

Vulnerable suppliers. "Although no significant presence of vulnerable suppliers has been identified among Atlantic Grupa's direct suppliers so far, the Company remains focused on detecting such risks in the deeper layers of its supply chains" (p.302). Local sourcing is prioritised where possible, which "supports local communities, reduces transportation-related emissions, and strengthens regional supply chains" (p.303).

Target and progress (p.304). "In the initial rollout year (2025), just under 30% of direct materials suppliers and outsourced suppliers completed the SCS assessment and confirmed compliance with the Supplier Code of Conduct. Atlantic Grupa aims to increase the share... to at least 50% by the end of 2026."

Reference: pages 304-305

"Atlantic Grupa conducts its business in an ethical and principles-based manner, even in the absence of applicable regulatory requirements. The Company applies a coordinated, holistic, and risk-based approach to monitoring its conduct against regulatory obligations, societal expectations, and its own internal standards" (p.304). Approach to prevention and detection "is risk-based and comprehensive, ensuring alignment with legal obligations, societal expectations, and internal principles" (p.300).

The definition applied is broad: bribery and corruption "include practices such as facilitation payments, fraud, extortion, collusion, money laundering, and offering or receiving gifts, loans, fees, rewards, or other advantages as inducements for dishonest, illegal, or unethical behaviour. These terms also encompass embezzlement, trading in influence, abuse of function, illicit enrichment, concealment, and obstruction of justice" (p.304).

Reporting mechanism. "The reporting procedure for corruption-related misconduct is defined under the Whistleblowing Procedure Rules... The Company's Whistleblowing Procedure Rules comply with local regulations that are aligned with the United Nations Convention against Corruption. Any employee who observes or becomes aware of misconduct has the right, at their own discretion, to submit an anonymous report... Individuals appointed to lead the process after a report is submitted operate independently and outside the chain of management involved in the matter. Annual reporting on these issues is submitted to the Audit Committee" (pp.304-305).

Training (p.305). "The procurement department is the most exposed department to risks of bribery and corruption... To further strengthen awareness and compliance, an internal training session on ethical behaviour and business conduct was organized for the Central Procurement team. The training was focused on identifying corruption and bribery risks in procurement and reporting irregularities and conflicts of interest." Onboarding for Management Board and Supervisory Board members "includes a mandatory segment covering the Company's anti-corruption policies, procedures, and expectations". Elsewhere the report states there is an "absence of formal business conduct training" for the general employee population (p.301).

Targets related to business conduct

Back-filled from the G1 business conduct chapter, where targets are addressed as MDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS. Reference: pages 301, 304-305.

Atlantic Grupa states that it has no targets for two of the three business conduct areas, and tracks effectiveness instead.

Anti-corruption: "Atlantic Grupa has no specific targets related to the prevention and detection of corruption and bribery, as effectiveness is measured through the ongoing monitoring of all reports submitted via the designated communication system" (p.305).

Whistleblower protection: "The ambition of the whistleblowing programme is to handle all cases in an appropriate, objective, fair, and timely manner. No significant actions were needed in 2025, as we conduct effective monitoring as part of regular operations. Similarly, there are no targets regarding protection of whistleblowers as effectiveness is measured by tracking all reports through the designated communication system" (p.301).

One quantified business conduct target is set, for supplier management. "Atlantic Grupa is committed to strengthening supplier participation in its sustainability due diligence processes. As part of this effort, the Company monitors the adoption of sustainability commitments among suppliers of direct materials and outsourced suppliers assessed through the Sphera SCS platform" (p.303). "Atlantic Grupa aims to increase the share of direct materials suppliers and outsourced suppliers that confirm compliance with the Supplier Code of Conduct through the Sphera SCS platform to at least 50% by the end of 2026", from just under 30% in 2025 (p.304).

Payment practices carry no target, but the metric is tracked and the movement explained (p.305).

Reference: pages 304-305, with the datapoint mapping at page 309

A complete nil return is given for both years: "In both 2024 and 2025, the Company recorded no incidents, convictions, or fines related to violations of anticorruption and antibribery laws, nor any breaches of internal procedures or standards regarding antibribery and anticorruption. Consequently, no significant actions were required in 2025" (p.305).

Separately, one whistleblowing report was handled: "In 2025, one irregularity was reported (FY2024:1), which was, following a detailed analysis, resolved" (p.301). The report does not classify that irregularity as corruption-related.

Provenance note. G1-4 is not listed as a standalone disclosure requirement in the ESRS disclosure index, which shows GOV-1, SBM-3, IRO-1, G1-1, G1-2, G1-3 and G1-6 for business conduct (p.169). It is picked up instead in the Appendix B datapoint table, which lists "ESRS G1-4, 24 (a), Fines for violation of anti-corruption and anti-bribery laws" and directs the reader to the section "G1-3 Prevention and detection of corruption and bribery", while "ESRS G1-4, 24 (b), Standards of anti-corruption and anti-bribery" is marked "Not relevant" (p.309). The content is therefore indexed by the Company itself rather than inferred from surrounding narrative, but it is reported inside the G1-3 section and no separate G1-4 heading exists.

No breakdown of convictions and fines for violation of anti-corruption and anti-bribery laws is required in the absence of any incidents, and none is given.

Reference: page 305

"In 2025, the Company's standard payment term for suppliers was within 60 days. All suppliers, regardless of their size, are guaranteed equal treatment, and in specific circumstances certain suppliers were granted earlier payment terms" (p.305).

"In 2025, the average time the Company takes to pay an invoice, starting from the date when the contractual or statutory term of payment begins, is 64 days (FY2024: 55 days). For this calculation, all suppliers are taken into consideration for all our legal entities (which are part of the consolidation)" (p.305).

The year-on-year deterioration is explained and a second figure is given on a different basis: "This increase is primarily driven by the specific characteristics of the pharmacy business. If Farmacia is excluded, the average payment time would amount to 42 days (FY2024: 44 days)" (p.305).

"There are currently no outstanding legal proceedings for late payments" (p.305).

The disclosure covers the average payment time, the standard contractual terms and the legal proceedings datapoint. It does not give the percentage of payments aligned with standard terms, nor a description of the payment terms that apply to small and medium-sized enterprises specifically, beyond the statement that all suppliers regardless of size are guaranteed equal treatment. Timely payment is treated as a material positive impact under "Respecting business conditions with suppliers" (p.299), and prompt payment is described elsewhere as "An important contribution... the regular payment for delivered goods and services, i.e., payment of invoices within the agreed terms" (p.303).