Attendo

Governance roles

Reference: pages 48-50. Also cross-referenced in the content index as ESRS 2 GOV-1 (page 48) and ESRS 2 GOV-1-G1 (page 73).

Attendo has a Board of Directors, an Audit & Risk Committee, a CEO and Executive Management team, and two business areas (Attendo Scandinavia and Attendo Finland) run by Business Area Directors.

Allocation of responsibility (pages 48-50):

• The Board "approves the company's strategy, Group policies, annual sustainability report and quarterly reports", "decides to include sustainability targets in incentive programmes and approves Attendo's double materiality analysis", and "is the ultimate reviewer of Group impacts, risks and opportunities".
• The Audit & Risk Committee "prepares the board review of policies, financial reports (sustainability reporting) and Group risk assessment" and reviews the effectiveness of internal controls over external reporting. The Communications and Sustainability Director presents to it "bi-annually, at least".
• Responsibility for managing IROs is "operationally delegated to from the board to the CEO", then to the Business Area Directors.
• At Group level the Director of Communications and Sustainability and the Internal Control and Sustainability Reporting Manager are responsible for policy coverage of material IROs, the sustainability KPI framework and "CSRD compliance". Group finance is "ultimately responsible for ESG data collection". In 2025 Attendo recruited a Sustainability Controller at Group level (page 49).

Board composition (page 49): eight ordinary members elected by the AGM, all eight independent of the company, management and large shareholders; 3 women (38%) and 5 men (63%). The trade union Kommunal has appointed two employee representatives, both women.

Information provided to and matters addressed by the Board

Reference: page 51 (index, page 51).

The Board "has a wide range of experience on issues relating to care services, clients, relatives, workers and society". To cover material sustainability topics, "the Board as a whole underwent sustainability training in 2023 and 2024 covering key topics such as climate-related risks, social responsibility and corporate governance practices. The next training programme is planned for 2026, focusing on the ESRS report and climate-related issues" (page 51).

Attendo describes the effect of that training in measured terms: it "has equipped the board with a foundational understanding of material sustainability topics", and the Board "plans to supplement this knowledge with periodic updates" (page 51).

Frequency and content of reporting (page 49):

• Selected social-sustainability KPIs are included in Attendo's quarterly reports and sustainability issues are "discussed continuously throughout the year in Board meetings".
• A Sustainability Deep Dive is held once a year. Climate change and environmental issues are presented and discussed annually, in connection with the review of the annual report, led by the Director of Communications and Sustainability.
• At the 2025 Sustainability Deep Dive the Board "decided that the company will join the Science Based Target initiative (SBTi), and within 24 months of joining, set science-based climate targets at Group level".
• The Board works to an annual plan covering all material topics, with "annual deep-dives and routine reporting" on customers and employees (page 48).

Integration of sustainability performance in incentive schemes

Reference: page 51 (index, page 51). Also listed as ESRS 2 GOV-3-E1 at page 51.

Attendo's long-term performance share programme covers Group Management and around 50 senior executives. It is "linked to Attendo's performance, as well as customer and employee satisfaction targets (cNPS and eNPS)" (page 51).

Weighting disclosed (page 51): "A total of 25 percent of the weighting in the incentive programme is related to the sustainability KPIs cNPS (12.5 percent), eNPS (12.5 percent)."

Climate is explicitly excluded: "Climate-related considerations are not currently taken into account in the incentive programmes for Attendo's management or senior executives" (page 51). This is a clear nil return against the E1 limb of GOV-3 rather than an omission, and it is consistent with the absence of climate targets under E1-4 (page 60).

Terms and conditions are "stipulated in the Guidelines for remuneration to senior executives" (page 51). The Board "decides to include sustainability targets in incentive programmes" (page 48). Attendo separately notes that its credit facility is linked to eNPS targets (page 68) and to cNPS targets (page 72), so the two satisfaction KPIs carry financial consequences beyond the share programme.

Statement on due diligence

Reference: page 51 (index, page 51).

Attendo presents the standard mapping table of the five core elements of due diligence to the paragraphs of the statement. The table states "how Attendo applies the core elements of due diligence for people and the environment" and "indicates where this information is located in the sustainability report" (page 51). Each row is also tagged as relating to people, the environment, or both.

Mapping as printed (page 51):

• (a) Embedding due diligence in governance, strategy and business model - ESRS 2 GOV-2 page 51, GOV-3 page 51, SBM-3 page 57; SBM-3-E1 page 59; SBM-3-S1 page 66 and SBM-3-S4 page 70; SBM-3-G1 page 73.
• (b) Engaging with affected stakeholders in all key steps - ESRS 2 GOV-2 page 51, SBM-2 page 54, IRO-1 page 56; MDR-P E1-2 page 60; MDR-P S1-1 page 66 and S4-1 page 70; G1-1 page 73; S1-2 page 67 and S4-2 page 70.
• (c) Identifying and assessing adverse impacts - ESRS 2 IRO-1 page 56, SBM-3 page 56; SBM-3-E1 page 59; SBM-3-S1 page 66 and SBM-3-S4 page 70; SBM-3-G1 page 73.
• (d) Taking actions to address those impacts - MDR-A E1-3 page 60; MDR-A S1-4 page 67 and S4-4 page 71; E1-1 page 59; G1-1 page 73.
• (e) Tracking effectiveness and communicating - MDR-M E1-5 page 60 and E1-6 page 61; MDR-M S1-13 page 68 and S1-14 page 69; MDR-T E1-4 page 60; MDR-T S1-5 page 68 and S4-5 page 71.

Note that row (c) cites SBM-3 at page 56 while the SBM-3 section itself begins on page 57.

Risk management and internal controls over sustainability reporting

Reference: pages 51-52 (index, page 51).

"The Board of Directors holds ultimate responsibility for the company's internal control, including oversight of sustainability reporting. This responsibility is managed and evaluated through the Audit & Risk Committee." Operational responsibility is delegated to the CEO and then to the Business Area Directors (page 51). A Group internal control function "works according to an annual plan and reports to the Audit and Risk Committee", and in 2025 "work was undertaken to establish targeted internal controls for the reporting of sustainability data" which "have been integrated and implemented in Attendo's overall internal control system" (page 49).

Risks identified and the controls applied (page 52):

1. Data quality risks. Estimates such as "calculating carbon emissions based on costs, supplier data or other indirect metrics"; mitigated by "standardised rules and methods for estimates with the help of experts in climate calculations" and use of the GHG Protocol. Survey data accuracy risks are tied to "response rates, representativeness and data validity", mitigated by review of survey design and "sample testing of survey responses".
2. Process-related risks. "The decentralised nature of Attendo's operations can lead to variations in data collection and reporting processes"; mitigated by uniform templates, training, and the annual self-assessment and review by the Group internal control function. Errors are mitigated by "cross-referencing reported data with underlying source documentation".
3. Focus on high-priority risks - employee engagement and customer satisfaction, with "enhanced monitoring, regular feedback loops".
4. Governance and oversight - annual reviews, with findings, deviations and action plans reported to the Audit & Risk Committee.

Strategy, business model and value chain

Reference: pages 52-54 (index, page 52).

Business model. Attendo provides social care in two business areas, Attendo Scandinavia and Attendo Finland, "mainly conducted by establishing and operating care homes in own operations" (page 54). Market overview as printed (page 52): revenue MSEK 18,991 (Scandinavia 7,891, Finland 11,100), 764 units (356 / 408) and 33,171 employees at period end (14,382 / 18,789).

Upstream (page 53). Purchases are "mainly food, consumables, personal protective equipment (PPE), medical equipment, workwear and technical solutions". First-tier suppliers are in Finland, Sweden and Denmark; in the second tier Attendo has direct contracts with some Swedish suppliers to first-tier wholesalers. Workwear is bought through a common Nordic supplier "which in turn manufactures the products in factories in Ukraine". Natural resources used include "biological resources (food, workwear), fossil resources (production and fuel), energy sources (renewable and non-renewable), and metals and minerals (medical devices and technologies)". The chain also includes property developers, where "transparency in their supply chain is limited". Transport from first-tier suppliers is "mostly by road and, to a lesser extent, by sea and rail" (page 54).

Downstream (page 54). "The downstream part of the value chain is shorter than the upstream part, as the organisation delivers directly to the end customer." Waste is "most of which is recyclable", with "a small proportion" of medical waste.

Long-term goals: "Preferred choice for customers and relatives, employees and clients", "A natural and fundamental part of society", "Sustainable and profitable growth" (page 52). The printed value chain diagram runs raw materials, suppliers and subcontractors, transports, food and consumables, care homes, people and people care, customers, society (page 53).

Interests and views of stakeholders

Reference: pages 54-55 (index, page 54). Also listed as ESRS 2 SBM-2-S1 and ESRS 2 SBM-2-S4, both at page 54.

"Attendo conducted a specific stakeholder dialogue on sustainability topics in 2023 as part of the double materiality analysis. In 2025, a review was carried out of stakeholder mapping, key stakeholders and how stakeholder dialogue is conducted" (page 54). So the topic-specific dialogue itself was not repeated in the reporting year; what was refreshed was the mapping.

Four key stakeholder groups, with forums and outcomes tabulated (page 54):

• Customers (consumers and end-users) - daily interactions, customer satisfaction surveys, quality of life assessments (RAI and ASCOT), unit-based customer councils in Sweden, a feedback channel on the website in Finland. Outcomes: updated care plans and routines.
• Relatives - unit-based relatives' meetings, satisfaction surveys, newsletters, Attendo's app for relatives (the Nära app, page 55).
• Employees (own workforce) - daily interactions with the manager, employee satisfaction surveys, Attendo's employee app, collaboration with unions. Outcomes include "Review of scheduling and planning" and "Changes to physical working environment".
• Clients - Swedish and Danish local authorities and Finnish welfare regions; ongoing dialogue, structured follow-up of agreements, client satisfaction surveys.

Satisfaction is tracked through cNPS, rNPS and eNPS (page 55). Attendo also states it works closely with real estate developers and owners, other suppliers, and "as a large employer, Attendo also has a natural and close relationship with its trade unions" (page 55). Learnings are "reported to operational managers, Business Area management teams, Attendo's executive management and Board" (page 55).

Material impacts, risks and opportunities

Reference: page 57 (index, page 57). Topic-level SBM-3 sections sit at pages 59 (E1), 66 (S1), 70 (S4) and 73 (G1).

The 2025 DMA produced seven material sub-topics across four topical standards - E1, S1, S4 and G1 (pages 56-57). Attendo states: "Attendo has not identified any company-specific topics that go beyond topics covered in ESRS standards" (page 57).

The outcome table as printed (page 57):

Every material IRO is a negative impact. Attendo states plainly: "None of the sustainability issues are currently material from a financial position" (page 57), and under IRO-1 that "This year's double materiality analysis has not identified any significant financial risks or opportunities related to sustainability issues" (page 56). The E1 section repeats it: "No significant risks or opportunities have been identified in these areas during the period" (page 59).

The E1 SBM-3 table on page 59 places the two climate impacts across "Upstream, Own operations, downstream", which is wider than the "Upstream, Own operations" shown for the same two rows on page 57.

Process to identify and assess material IROs

Reference: pages 56-58 (index, page 56). Also listed as ESRS 2 IRO-1-E1 and ESRS 2 IRO-1-G1, both at page 57.

"In 2025, a major review and update of the double materiality analysis initially prepared in 2024 was carried out" (page 56). The 2024 analysis "was assessed with the support of third parties"; the 2025 update "was carried out by the Sustainability Controller together with the Director of Communications and Sustainability, the Internal Control and Sustainability Reporting Officer and relevant teams within the business areas" (page 56).

Four steps (page 56): (1) update of preparatory analyses, value chain mapping and stakeholder mapping; (2) a gross list of IROs built "by evaluating Attendo's operations against all topics (including subtopics and their subtopics) included in the ESRS topic list", then grouped into a net list; (3) assessment of impact and financial materiality using "the ESRS definition and EFRAG's guidance", with adverse impacts scored on "severity - a combination of scale, scope and reversibility - and likelihood", severity "prioritised over the likelihood of impacts on human rights", and financial materiality graded on magnitude and likelihood using "Attendo's overall risk classification scale"; (4) validation by the Executive Board and then the Board of Directors. The impact-materiality threshold "was established internally, based on expert recommendation and experience" but the numeric thresholds are not disclosed.

Environment and governance screening (page 57): a general screening of assets and facilities was performed for the 2024 DMA and reviewed in 2025, using "interviews with relevant key roles" and "desktop analyses of reports from the Swedish Environmental Protection Agency and the Care Manual". "Waste generation and water use in the company's own operations were identified as two factors with a negative impact, but these were deemed immaterial given the nature of Attendo's operations."

Entity-specific IROs (page 56): "The double materiality analysis identified entity-specific impacts, risks and opportunities, but none of these were assessed as material in 2025."

Climate (pages 57-58): a comprehensive climate risk analysis of physical and transition risks was carried out in 2025. See E1-2 for the detail.

Disclosure requirements covered

Reference: page 58, with the content index at pages 75-76 and the EU-legislation datapoint list at pages 77-80.

Attendo prints a genuine ESRS content index headed "IRO-2 Disclosure Requirements in ESRS covered by the undertaking's sustainability statement", with three columns: List of material DRs, Page number and Other (pages 75-76). It also prints the separate "List of data points derived from other EU legislation" over pages 77-80, with a Material / Not material column and a page number for each datapoint.

What the index lists:

• ESRS 2 - BP-1, BP-2, GOV-1 to GOV-5, SBM-1, SBM-2, SBM-3, IRO-1, IRO-2 (pages 48-58).
• E1 - GOV-3-E1, E1-1, SBM-3-E1, IRO-1-E1, E1-2, E1-3, E1-4, E1-5, E1-6 (pages 51-61). E1-7, E1-8 and E1-9 are absent.
• S1 - SBM-2-S1, SBM-3-S1, S1-1 to S1-7, S1-13, S1-14, S1-17 (pages 54-69). S1-8 to S1-12, S1-15 and S1-16 are absent.
• S4 - SBM-2-S4, SBM-3-S4, S4-1 to S4-5 (pages 54-71).
• G1 - SBM-3-G1, GOV-1-G1, IRO-1-G1, G1-1, G1-2 (pages 54-74). G1-3 to G1-6 are absent.
• No E2, E3, E4, E5, S2 or S3 rows appear at all.

The only phase-in flagged sits in the "Other" column against S1-14: "Attendo has chosen to apply the option of phasing in paragraph 88d on the number of cases of recordable work-related illness, and 88e on the number of days lost due to work-related injuries" (page 76).

Attendo also states that "These company-specific disclosures have been integrated into disclosure requirements related to own workforce (S1) and consumers and end-users (S4)" (page 58), which is where the cNPS, rNPS, RAI and ASCOT metrics sit.

Transition plan for climate change mitigation

Reference: page 59 (index, page 59).

Attendo has no transition plan. The disclosure opens: "Attendo does not currently have a formal transition plan to align the Group's strategy and business model with the transition to a sustainable economy and to limit global warming to 1.5 degrees, in line with the Paris Agreement. In connection with the development of climate targets, Attendo will develop a transition plan" (page 59). The trigger for that is the Board's 2025 decision to join the SBTi and, "within 24 months of joining, set science-based climate targets at Group level" (pages 47, 52, 59).

Levers named, but not quantified (page 59): "key actions will include ensuring that energy and heat come from fossil-free and sustainable sources, reducing fuel use, and actively deciding to purchase goods that emit less greenhouse gases in the value chain."

The central dependency is the leased estate (page 59): "Climate change mitigation in Attendo's value chain in large part relates to how the care facilities (real estate and property) are constructed and developed. As a general rule, Attendo does not own the land or the facilities. Attendo rents the care facilities under long-term lease agreements. Attendo therefore has limited ability to influence decisions on the details of a building or to initiate all development or investments to reduce climate impact on its own." Where Attendo carries more maintenance responsibility under a lease, it "has greater opportunity to implement changes".

Today the work is described as running "through Attendo's regular strategy and business processes, which are implemented locally in the operations in the daily work", focused on "cooperation with the real estate owners" and "selective choices in other procurement areas" (page 59). Attendo says it "will set a specific strategic climate goal that will clarify how strategy and business model are linked to significant climate issues".

No locked-in emissions assessment, no Paris-aligned benchmark exclusion statement and no transition-plan CapEx are given; E1-3 states there are "no significant operating expenses (Opex) or investments (Capex) linked to environmental action plans" (page 60).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1, where this content is disclosed in the FY2025 report (pages 57-58). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

A climate risk analysis was carried out in 2025 and it is classified in the ESRS way: "To identify and then assess climate risks, a comprehensive climate risk analysis of physical risks (impacts of climate change) and transition risks (risks that arise as society adapts to climate change) was carried out in 2025" (page 57).

Physical risks analysed (page 57): "both acute and long-term effects of extreme weather, such as temperature changes, storms and heavy rain, which can lead to increased risk of damage, higher costs for building measures taken in care facilities and temporary disruptions in home care services. Long-term effects such as higher temperatures and rising sea levels can increase rent, electricity costs and the cost of cooling." Attendo notes its exposure is indirect: "Attendo leases all properties where operations take place and therefore has no property portfolio that can be affected in Attendo's ownership."

Transition risks analysed (page 57): "policy and regulatory changes, market impact and reputation. These can lead to increased demands from policy makers and investors, higher costs for electricity, transport and materials, and potential revenue losses if procurement requirements are not met."

No scenario analysis was performed, and Attendo says so (page 58): "In 2026, Attendo will develop a more in-depth climate scenario analysis with relevant methodologies that include climate scenarios with a high emission scenario and a low emission scenario." No scenario is named, no temperature projection is given and no time horizons are attached to the risk analysis, because the analysis that would carry them has not yet been done. Under the adopted E1-2, paragraph 17 applies only where scenario analysis was used, so its absence here is not a gap.

Conclusion reached (page 58): "possible climate risks can be identified, but these are not currently considered to have a significant financial impact on Attendo from a Group perspective... climate risks may lead to temporary higher costs, but these would probably not affect so many units at the same time that the increased costs are deemed significant from an overall Group perspective."

Screening for the environmental sub-topics used "interviews with relevant key roles" and "desktop analyses of reports from the Swedish Environmental Protection Agency and the Care Manual" (page 57).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the E1 strategy discussion, where this content is disclosed in the FY2025 report (page 59). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Attendo states that it has not carried out a climate resilience analysis. From the E1 "Link to strategy and business model" text: "Attendo's strategy is based on resilience and adaptability to changing environmental demands. The work includes improving energy efficiency, reducing resource use and engaging widely with relevant stakeholders. However, the resilience of Attendo's business model and strategy still needs to be analysed in a resilience analysis. Attendo plans to carry out such an analysis in 2026 in connection with climate risk analysis. The purpose of the resilience analysis is to map the resilience of Attendo's business model and strategy to different climate scenarios and thereby further strengthen the Group's long-term sustainability" (page 59).

That is the finding, and it is disclosed plainly rather than dressed up. There are no results of a resilience analysis, no stated areas of uncertainty in such an assessment, and no disclosure of capacity to adjust or adapt over short, medium and long term in the terms of the adopted E1-3.

What the report does offer in place of it (page 59): the qualitative claim that resilience rests on cooperation with property owners, since "Attendo rents its facilities" and "By working closely together, the parties can jointly reduce the climate footprint, especially with regard to the use of electricity and heating for which Attendo is not responsible"; on integrating environmental considerations into "planning, construction, operation and maintenance"; and on the vehicle fleet as "an important part of the effort to reduce fuel use".

The related financial conclusion sits under IRO-1: identified climate risks "are not currently considered to have a significant financial impact on Attendo from a Group perspective" and "would probably not affect so many units at the same time that the increased costs are deemed significant" (page 58). Attendo also uses the word resilience in the S1, S4 and G1 chapters (pages 66, 70, 73), but in the ordinary sense, not as an ESRS climate resilience analysis.

Policies related to climate change mitigation and adaptation

Reference: pages 59-60 (index, page 60).

Two policies are relied on: the Environmental policy and the Supplier Code of Conduct (page 59). The Environmental policy "aims to ensure that the operations are conducted with responsibility and consideration for the environment and climate by addressing key material impacts such as carbon footprint, transportation and food". The Supplier Code of Conduct addresses "carbon footprint and usage of water, energy and raw materials by Attendo's suppliers" (pages 59-60). Owners and implementers are tabulated on page 50: the Environmental policy is owned by the Director of Communications and Sustainability and implemented by the Business Area Director; the Supplier Code of Conduct is owned by the CFO and implemented by Procurement, and is "Available on the Attendo public website" while the Environmental policy is on the intranet.

Scope limits are stated rather than glossed (page 60): "These policies cover climate change mitigation and energy efficiency, but do not extend to climate change adaption or specific requirements on renewable energy deployment." And: "As of today, Attendo does not have a policy devoted towards climate change mitigation and adaption. When a transition plan has been set, appropriate actions, responsibilities and monitoring mechanisms will be defined and implemented."

Effectiveness monitoring is partly absent (page 60): "The effectiveness of the Supplier Code of Conduct is measured by the number of suppliers who have signed the Code of Conduct. There is currently no process for measuring the effectiveness of the environmental policy in a structured way across the Group. However, there are initiatives at unit level in the organisations."

All Group policies "are approved by the Board of Directors, reviewed for effectiveness and accuracy and updated as appropriate on an annual basis", with responsibility for implementation and monitoring sitting with "the purchasing functions in each business area" and reporting to business area management and to the Group Finance function (page 60). Stakeholder feedback from "real estate owners and suppliers, as well as investors, is considered in policy updates".

Actions and resources in relation to climate change policies

Reference: page 60 (index, page 60).

Because no targets exist, the actions are framed around impact concentration: "Since Attendo has not yet set climate-related targets, the ongoing work is focused on the areas where there is the greatest impact in Attendo's operations and value chain, based on current knowledge and data, i.e. real estate and purchasing" (page 60).

Actions disclosed (page 60):

• "choosing partners and suppliers who prioritise reducing their impact on climate change and increasing cooperation and commitments with real estate owners through new models such as green leases".
• Buying electricity "through contractual instruments that guarantee the origin of the electricity for which the company is responsible. These ensure that the electricity is fossil-free and renewable."
• The one dated action of the year: "In 2025, a new contractual instrument was signed that guarantees fossil-free electricity for the operations in the Finland business area. Attendo already buys fossil-free and renewable electricity in Sweden and Denmark."

That action has a measurable effect elsewhere in the chapter: market-based Scope 2 emissions fell from 58,972 to 23,697 tCO2e, which Attendo attributes to the Finnish contract (page 61). The instrument guarantees fossil-free electricity from nuclear power, and "Fossil-free nuclear power with a certificate of origin represents 78 percent of the total use of energy from nuclear sources" (page 62), which is why nuclear consumption rises from 16,535 to 70,072 MWh in the E1-5 table rather than renewable consumption.

Resources (page 60): "Sustainable development in real estate and procurement is dependent on available internal resources as well as contractual and welfare legislation requirements. The Group's emissions and energy use are monitored annually, in parallel with ongoing work to improve data quality and emission factors."

No money is attached: "Attendo currently has no significant operating expenses (Opex) or investments (Capex) linked to environmental action plans" (page 60). Measures "are being developed in line with the development of climate targets and a transition plan, which also clarifies future resource and financing needs".

Targets related to climate change mitigation and adaptation

Reference: page 60 (index, page 60).

Attendo has set no climate targets. The disclosure is two sentences in full: "Attendo has not yet set any specific targets for climate change mitigation and adaptation. Attendo will work to develop scientifically based climate targets over the next 24 months from application to SBTi" (page 60).

The commitment behind it is Board-level and dated: at the 2025 Sustainability Deep Dive "the Board of Directors decided that the company will join the Science Based Target initiative (SBTi), and within 24 months of joining, set science-based climate targets at Group level" (page 49), described elsewhere as "an important strategic step for Attendo to contribute to climate change mitigation in line with the Paris Agreement" (pages 47, 59). The report does not state the date of application or of joining, so the 24-month clock has no disclosed start.

There is therefore no base year, no target year, no absolute or intensity reduction figure, no scope coverage statement and no decarbonisation lever quantification against a target. The EU-legislation datapoint list marks "ESRS E1-4 GHG emission reduction targets paragraph 34" as Not material with no page reference (page 77), which is the same conclusion reached from a different direction.

Related quantitative context does exist in the chapter, but it is measurement rather than target setting: Attendo "has calculated its climate footprint since 2021 in accordance with the Green House Gas protocol" (page 59), and the E1-5 and E1-6 tables give two comparative years (pages 60-61). Absent targets, no progress-against-target reporting is possible, and none is claimed.

Energy consumption and mix

Reference: page 60 (index, page 60). Accounting policies at pages 61-62.

As printed (page 60), MWh unless stated, 2025 against 2024:

The headline movement is the halving of fossil energy and the fourfold rise in nuclear, both driven by one action: the 2025 Finnish contractual instrument "that guarantees fossil-free electricity from nuclear power", which "has increased the share of reported nuclear energy and reduced fuel consumption from fossil sources compared to benchmark figures" (page 62). Total consumption is close to flat, down 1.0%.

A material qualification on the renewable line (page 60, repeated page 62): the reported renewable figure "consist of renewable energy with a certificate of origin and renewable energy calculated with country-specific residual mix. Renewable energy with a certificate of origin corresponds to 11 percent of reported consumption of purchased or acquired electricity, heating, steam and cooling from renewable sources in 2025 and 2024, respectively." So roughly nine tenths of the 109,808 MWh renewable purchased-energy line is residual-mix attribution, not contracted renewable supply. Attendo buys certificate-backed renewable energy "for operations in Sweden and Denmark where the company is responsible for the electricity supply" (page 62).

"Reported energy use is based on the market-based methodology" (page 61). Attendo is not a high climate impact sector filer: the E1-5 energy-intensity datapoint for high climate impact sectors is marked Not material (page 77).

One footing note. The 2025 column does not foot: 54,498 + 70,072 + 110,627 = 235,197 against a printed total of 235,166, a difference of 31 MWh. The 2024 column foots exactly.

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: page 61 (index, page 61). Accounting policies at pages 62-63.

As printed (page 61), tCO2e:

Scope 3 is 86% of the location-based total. The market-based fall of 23% is attributed to the Finnish fossil-free electricity contract; district heating emissions in Scandinavia rose "due to the fact that the location-based emission factor has increased during the year" (page 61). Scope 1 rose "due to an increase in fuel consumption from self-owned cars in 2025 in the business area Scandinavia, as well as the collection of refrigerant leakage data in both business areas".

Data quality: "The share of estimated emissions based on primary data amounts to 62 percent of total Scope 3 emissions" (page 61). Categories 4 and 9 are reported for the first time in 2025 (pages 61-62). Category 7 was recalculated retroactively for 2024 after moving from third-party estimates to employee survey data. In 2025 a reclassification moved emissions from category 8 to category 11, which "only involves a reallocation of emissions between categories and has not affected either the calculation method or the overall outcome" (page 63). Categories 8, 10 and 12-15 are excluded as non-material, each with a stated reason (pages 62-63).

Biogenic emissions are given separately: 410 tCO2 for Scope 1, 45,535 tCO2 for Scope 2 from district heating, and 45.28 tCO2 for Scope 3 (page 61).

One footing note. The 2025 location-based total of 128,325 tCO2e exceeds the sum of its printed components (3,090 + 13,482 + 109,861 = 126,433) by 1,892 tCO2e. The 2024 column foots exactly. The intensity figures are calculated from the printed totals (128,325 / 18,991 = 6.8; 136,649 / 18,991 = 7.2), so the discrepancy sits in the location-based total line rather than in the intensity.

Policies related to own workforce

Reference: pages 66-67 (index, page 66).

The framework is the Code of Conduct for employees and the HR policy, both "adopted by the Board of Directors" and applying to all Attendo employees, "supported by national and local guidelines to address the conditions in each market" (page 66). Implementation sits with the HR functions in each business area, led by HR directors who sit on the business area management teams. Policies are "reviewed for effectiveness and accuracy and updated on an annual basis", with "input from employee engagement and surveys as well as consultations with union representatives" incorporated at update. Effectiveness is monitored "through employee surveys, compliance reviews, and the feedback mechanisms" (page 66).

Scope. The term workforce "includes own employees and non-employees, and the policies and actions described in S1-1, S1-2 and S1-3 cover the entire workforce unless otherwise stated" (page 66). "Attendo does not apply specific Group policies for specific groups within the workforce" (page 66).

Content of the Code (pages 66-67). It is "based on the company's core values - Care, Commitment and Competence", and is in three parts: how to raise concerns and report deviations; "Attendo's ten core principles which should guide all daily work"; and commitments to key stakeholders. It "is consistent with the UN 2030 Agenda, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, and the ILO Declaration on Fundamental Principles and Rights at Work", and "respects human rights, establishes zero tolerance for discrimination, harassment, child labour, forced labour, and respects the worker's right to freedom of association, the right to join a trade union, and whistleblower protection and freedom of communication".

The HR policy "builds on the Employee Code of Conduct, addressing diversity and inclusion and establishing zero tolerance for discrimination and harassment", covering "skill development and work environment" (page 67).

The EU-legislation datapoint list marks S1-1 human rights policy commitments (paragraph 20) and workplace accident prevention policy or management system (paragraph 23) as Material, page 66, but marks ILO due diligence strategies (paragraph 21) and processes for preventing trafficking in human beings (paragraph 22) as Not material (pages 78-79).

Processes for engaging with own workforce and workers' representatives

Reference: page 67 (index, page 67).

Engagement "occurs directly as part of operations (daily feedback, regular unit meetings and similar), through meeting representatives such as trade unions and works councils regularly as well as through employee surveys" (page 67). Accountability sits with the HR function in each business area, which is "accountable for ensuring that these engagements are conducted effectively and that workforce perspectives inform decision-making processes", assessed "through e.g., survey results and engagement metrics, with outcomes such as local action plans, improved policies and enhanced training programs" (page 67).

Union structures (page 67): "Attendo representatives and union representatives meet both locally and centrally in each Business Area, in accordance with local laws and collective agreements. Trade unions have appointed representatives to the Board of the listed Parent Company." Those are the two employee representatives appointed by Kommunal, both women (page 49).

Surveys as the main instrument (page 67): "The employee engagement and satisfaction surveys are very important tools in the engagement. They are carried out several times per year and cover matters such as willingness to recommend Attendo as employer and ability to raise concerns to the nearest manager. The outcome of the surveys is reviewed and discussed in each local unit, where action plans are developed... Identified measures and plans, as well as their impact, are continuously followed up by the manager's manager and supported by relevant service functions."

Outcomes are "aggregated and shared on several levels and forums in the company to identify key learnings and fuel best practice sharing throughout the Group". At stakeholder level the same channels are tabulated with outcomes including "Review of scheduling and planning" and "Changes to physical working environment" (page 54).

The disclosure does not name a Board or executive member with operational responsibility for workforce engagement, and it does not state whether the effectiveness of engagement is assessed against a defined benchmark beyond survey results.

Processes to remediate negative impacts and channels to raise concerns

Reference: page 67 (index, page 67). The EU-legislation list marks "ESRS S1-3 Grievance/complaints handling mechanisms paragraph 32(c)" as Material, page 67 (page 79).

Four escalating channels are named (page 67): (1) closest manager, "for daily feedback on work, planning, working conditions and environment"; (2) the manager's immediate manager, "for incidents as well as improvements in the unit or local leadership"; (3) the local HR contact or the business area HR department; (4) a relevant service function such as Quality, Legal or Communications.

"For serious concerns, Attendo's whistleblowing channel may be used. The whistleblowing channel is provided by a third-party and enables anonymous reporting" (page 67), with the detail carried in the G1 chapter (pages 73-74).

Statutory reporting duties are described alongside (page 67): "In both Attendo Scandinavia and Attendo Finland, there are legal requirements to report care related malpractice or medical injury (or the risk of such malpractice or medical injury) as well as work-related accidents and incidents. Attendo has specific systems for this reporting and trains all employees in the relevant requirements and routines. The routines include mandatory escalation, response/feedback and monitoring of outcome and actions."

Awareness and trust (page 67): guidance on which channel to use "is set out in the Code of Conduct for employees, but also included in on-boarding processes and mandatory trainings", and "the Code of Conduct training includes specific modules on the grievance and complaints handling policy". Attendo "regularly communicates with employees through various internal channels, including emails, newsletters, and our intranet, to remind them about the availability of grievance channels".

Effectiveness is tested through the survey: "Attendo reviews the perceived ability to raise concerns by questions on this in the recurring employee surveys. The outcome is reviewed and actions taken in each local unit" (page 67). No score for that survey question is published, and no figure is given for the volume of grievances handled through the four internal channels; only the whistleblowing volume is quantified, at 61 cases of which 11 qualified (page 69).

Taking action on material impacts on own workforce

Reference: page 67 (index, page 67).

Responsibility is allocated first: "The HR function in each of the Business Areas is responsible for taking a structured approach to managing impacts, risks and opportunities with respect to the workforce. In the local operations, the unit managers bear the ultimate responsibility for the employees and the working environment in the day-to-day operations, including to identify and take the actions that are needed" (page 67).

Health and safety actions (page 67): "To ensure safe and healthy working environments, Attendo will continue to work with preventive and mitigating efforts such as company-wide safety days and a combination of more general and targeted trainings, coupled with monitoring relevant KPI's. Additionally, Attendo will evaluate how internal reviews can enhance focus on health and safety and whether further follow-up mechanisms are warranted."

Training and competence actions (page 67): "the company will further increase the focus on and quality of training as well as leadership and competence development. This includes supporting employees in certifications, refining and adding training programs and upskilling leaders and employees in digital tools for care delivery and documentation. We are also working on enhancing Attendo's career pathways to empower employees to in their career progression, supported by their local leaders."

The average training hours per employee rose from 9 to 16 over the year (page 68), which is the closest thing to an outcome measure for these actions.

Resources (page 67): "Attendo has no significant operating expenses (OpEx) or investments (CapEx) related to action plans with material negative impacts at present." The same nil statement is repeated for S4 (page 71) and G1 (page 74).

The actions are written in the future and continuous tense throughout ("will continue", "will evaluate", "are working on"), with no dated milestones, no target completion, and no separately identified action for the third material impact, job security and working hours.

Targets related to own workforce

Reference: page 68 (index, page 68).

One target covers all three material S1 impacts: eNPS. As printed (page 68):

The target was met in 2025, but the trend is down: the average fell from 25 to 22 and the second-half reading (21) is the lowest of the four figures shown.

Governance and rationale (page 68): "The targets below have been developed and set by Attendo's Executive Management, in light of available results and trends and considering its long-term ambitions. The Board of Directors, including its employee representative, has reviewed the targets... Attendo aims to reach the long-term target every year." Attendo justifies eNPS as a proxy: "Since eNPS reflects employees' loyalty, commitment and willingness to recommend Attendo as a workplace, it is a broad measure of employee satisfaction. Attendo believes that the measure can also reflect how satisfied employees are with their work environment, including the significant impacts that have been identified" (page 68). The KPI carries financial weight: "Attendo has also linked its credit facility to targets related to eNPS" (page 68), and eNPS is 12.5% of the incentive programme weighting (page 51).

Worker consultation is explicitly limited (page 68): "Employees are regularly involved in discussions regarding the results and developments in relation to their workplace, but have not been consulted in setting Group-wide targets."

Coverage limits (page 69): "The eNPS surveys currently include care and administrative employees, excluding hourly workers in Scandinavia and employees in rehab operations in Finland. The excluded groups do not affect the overall analysis of eNPS development." Given that casual employees number 13,256 of 33,171 (page 68), the excluded population is not trivial.

No outcome-oriented target is set for accident rates, working hours, job security or training coverage, so the three material impacts have no measurable target of their own.

Characteristics of the undertaking's employees

Reference: page 68 (index, page 68). Head counts refer to employees at period end; gender is "as specified by the employees themselves".

Headcount and gender (page 68): total 33,171 (2024: 34,960), of which 26,439 women (79.7%) and 6,732 men. By country: Sweden 14,382, Finland 18,789 (2024: 15,504 and 19,456). The workforce shrank by 1,789 people, or 5.1%, year on year.

Turnover (page 68): 5,220 employees left in 2025 (2024: 5,230), an employee turnover rate of 24% in both years.

Contract types as printed (page 68):

Permanent plus temporary reconciles exactly to the total. The other rows do not: casual employees (13,256) are presented as a separate line rather than as a subset with a stated relationship to the permanent and temporary rows, and full-time plus part-time (19,915) falls 13,256 short of the total, which is exactly the casual figure. The report does not explain the relationship, so the reader has to infer that casual employees are excluded from the full-time and part-time split.

The employment mix is the backdrop to one of the material impacts: "Attendo operates in an industry where occupancy rates can periodically fluctuate, which requires flexibility in scheduling. Attendo therefore applies a combination of full-time and part-time employment, including hourly employees and employees on a needs basis. These forms of employment can lead to uneven working hours and long shifts, which can potentially have a negative impact on the labour force" (page 66).

No breakdown by region below country level, and no employees-who-left figure by gender, is given.

Characteristics of non-employee workers

Reference: page 68 (index, page 68).

Attendo reports the number of non-employees in its own workforce, disaggregated by business area (page 68):

The footnote defines the population: it "Refers to non-employees via temporary employment agencies in care as well as kitchen staff" (page 68). This matches the definition given at the head of the chapter: "Non-employees refer to temporary staff hired from employment agencies to reinforce the labour force in the activities" (page 66).

Non-employees are 293 people against 33,171 employees, so under 1% of the workforce. That is a small share for the sector and it is worth noting that Attendo's own definition captures only agency staff and kitchen staff, not self-employed people or workers provided by other undertakings performing employment activities more broadly.

The scope statement confirms these people are in scope for the qualitative disclosures: "The term 'workforce' in the Sustainability Statement includes own employees and non-employees, and the policies and actions described in S1-1, S1-2 and S1-3 cover the entire workforce unless otherwise stated" (page 66).

No comparative is given for 2024, and the 2024 column is not printed for this table at all, which is consistent with 2025 being Attendo's first ESRS reporting year (page 48). The health and safety metrics on page 69 are given for the workforce without separating employees from non-employees, so it is not possible to see whether the 293 non-employees are inside the 100% coverage figure for the health and safety management system.

Training and skills development metrics

Reference: page 68 (index, page 68).

This is the metric that answers Attendo's third material S1 impact, training and competence development (page 57).

Performance reviews, Group level (page 68):

Performance reviews, disaggregated (page 68):

The gap between 33% and 80% is one of population, and Attendo explains it: the Group figure uses "the total number of employees" as the population, while the disaggregated figure "refers only to Scandinavia", where "all employees on a monthly salary who have been employed for at least two months before the date of the review are entitled to a performance review. This definition constitutes the entire population for calculation at disaggregated level" (page 68). In Finland "all employees are entitled to performance reviews". Both sets of figures come from "appraisals recorded in HR systems".

Training hours (page 68): average training hours per employee rose from 9 in 2024 to 16 in 2025. The comparison is not like for like and the footnotes say so: the 2025 figure includes "online training, induction training and classroom training", while the 2024 figure covers "online training only". Training data is "collected from the digital training platforms, supplemented with estimations in order to also encompass other trainings" (page 69).

Comparatives for the Group-level review table "are not presented due to first-time adoption of ESRS" (page 68). No breakdown of training hours by gender or employee category is given.

Health and safety metrics

Reference: page 69 (index, page 69). This answers the material impact "Working conditions / health and safety", the only S1 impact classified as actual rather than potential (page 57).

As printed (page 69):

The accident rate rose 21% and the count rose 14%. The 2024 rate carries a footnote: "The figure is calculated retrospectively based on the ESRS definition of recordable work-related accidents per million hours worked" (page 69). The report offers no explanation for the increase, and no target sits against it under S1-5.

The other two footnotes on the page define what is counted: reported "cases of occupational injuries and occupational diseases or other ill health that may include stress-related illness", sourced in one year from "cases reported to the Social Insurance Agency or insurance companies" and in the other from "cases reported in internal HR systems or to insurance companies", so the sourcing basis differs between the two years shown. Data "on health and safety metrics as presented in this section is collected from insurance companies" (page 69).

A phase-in is claimed, and it is the only one in the whole statement. The content index records in its Other column: "Attendo has chosen to apply the option of phasing in paragraph 88d on the number of cases of recordable work-related illness, and 88e on the number of days lost due to work-related injuries" (page 76). Note the internal inconsistency: the list of datapoints derived from other EU legislation marks "ESRS S1-14 Number of days lost to injuries, accidents, fatalities or illness paragraph 88(e)" as Material with a page reference of 69 (page 79), although no days-lost figure appears on page 69.

The material impact narrative is specific about what drives it: "repetitive strain injuries, threats and violence, and irregular working hours are more prevalent than in many other sectors... Physical risks, such as ergonomic challenges, workload stress and risk of threats and violence are present in care service environments, particularly in areas like disability care, individual and family care and dementia care" (page 66).

Incidents, complaints and severe human rights impacts

Reference: page 69 (index, page 69).

As disclosed (page 69): "In 2025, Attendo received 61 cases through its whistleblowing channel, eleven of which were qualified in accordance with the definition of whistleblowing under Directive (EU) 2019/1937. All cases are handled according to policy and procedure by the legal function, which is responsible for the process. No fines or penalties have been paid in connection with these cases. There were no serious human rights incidents during the reporting year, hence no fines, penalties or compensation were paid in relation to such cases."

The same figures are repeated in the G1-1 disclosure, with the added detail that "In all cases, the identity of the whistleblower was handled in accordance with the applicable legislation" and that non-qualifying cases "are treated as complaints or similar, depending on their content" (page 73). All whistleblower cases "are treated by the Board (Audit Committee)" (page 73).

The EU-legislation datapoint list marks both S1-17 datapoints as Material with a page reference of 69: incidents of discrimination (paragraph 103(a)) and non-respect of the UN Guiding Principles on Business and Human Rights and OECD Guidelines (paragraph 104(a)) (page 79).

What is not separated out. ESRS S1-17 asks for the number of incidents of discrimination including harassment, and complaints filed through channels for people in the own workforce to raise concerns, separately from severe human rights incidents. Attendo gives a single whistleblowing total and a nil statement on severe human rights incidents. It does not break the 61 cases down by type, does not report a discrimination or harassment count, and does not report the volume of complaints raised through the four internal channels described under S1-3 (page 67) or through the National Contact Points for the OECD Guidelines. No comparative for 2024 is given.

Policies related to consumers and end-users

Reference: page 70 (index, page 70).

The governing documents are the Code of Conduct for employees and the Quality policy, both "adopted by the Board of Directors" and applying "for all employees and all customers within Attendo", supported by "national and local guidelines to address the conditions in each market" (page 70). The Quality policy "defines Attendo's quality objectives and focus areas, the Group-wide framework related to governance, management and development of quality work within Attendo as well as roles and responsibilities", and is implemented by "the Quality functions in each of the Business Areas, led by designated Quality directors" (page 70). Its policy-table entry names the Business Area Director as owner and Quality as implementer, and says it is "Based on the principles of the Code of Conduct for Employees" and available on the Attendo intranet (page 50).

International alignment (page 70): the Code of Conduct "is consistent with the UN 2030 Agenda, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, and the ILO Declaration on Fundamental Principles and Rights at Work" and "describes Attendo's principles for how we work, with a focus on caring for customers, their families and society".

Review and monitoring (page 70): "All Group policies are reviewed for effectiveness and accuracy and updated as appropriate on an annual basis. Input from customer and relatives' engagement and surveys is incorporated during the policy updates... The effectiveness of the policies and their implementation is monitored through customer surveys, compliance reviews and the feedback mechanisms. Reporting from the Quality function is done to the Business Area Management teams, to a Group-wide Quality Council and to the Board of Directors."

Scope (page 70): "All customers in Attendo's care who can be materially impacted by the company are included in scope of disclosure under ESRS 2."

The EU-legislation datapoint list marks "ESRS S4-1 Policies related to consumers and end-users paragraph 16" as Material, page 70, while "ESRS S4-1 Non-respect of UNGPs on Business and Human Rights and OECD guidelines paragraph 17" is marked Not material (pages 79-80).

Processes for engaging with consumers and end-users

Reference: page 70 (index, page 70).

"Cooperation with customers and their families takes place directly at the site through daily dialogue, regular meetings at the site, and quality of life measurements. Other contact mechanisms include regular customer and family councils and customer and family surveys" (page 70). Surveys are "carried out several times per year and cover matters such as willingness to recommend Attendo as care provider and the key concerns in relation to the care planning and experience", with outcomes "examined and discussed in each local unit, where action plans are developed" and then "continuously followed up by the manager's manager" (page 70).

Structured outcome measurement is the distinctive part (page 70). "Attendo has to implemented evidence-based quality of life outcome measurement processes. The aim is to measure, monitor and ensure that the care results in better health and increased quality of life. In Finland, the Residence Assessment Instrument (RAI) is now used, also linked to the legal requirement to use RAI within elderly care. In Scandinavia, a similar method is used, but based on the Adult Social Care Outcomes Toolkit (ASCOT). Both tools are validated by research and designed to measure and monitor key factors of an individual's quality of life in a social care setting. Based on specially designed interviews with care recipients and careful observations by trained staff, the methods provide outcomes on how care is experienced and how the experience evolves."

That matters for ESRS purposes because the data comes from the affected people themselves: "the primary source of information regarding the care and its impact is the customer", with individual results registered locally and aggregated per business area, and RAI assessments "updated at least every six months" so "the reported RAI score is a weighted average during the last six months" (page 72).

Accountability (page 70): "The Quality function and Customer Experience teams in each of the Business Areas are accountable for ensuring that these engagements are conducted effectively and that customer perspectives inform decision-making processes."

The disclosure does not name a Board or executive member with operational responsibility for consumer engagement, and it does not separately address how Attendo engages the most vulnerable customers, for example those with dementia, beyond noting that the tools rely on interviews and staff observation.

Processes to remediate negative impacts and channels to raise concerns

Reference: page 71 (index, page 71).

"Daily communication with clients and their families is a natural part of care planning. Comments, questions and suggestions for improvement are usually raised directly with the staff concerned and the local manager, and any changes are quickly incorporated into care plans, procedures or communications. To provide further structure to the dialogue, there are local customer councils and family meetings" (page 71). Attendo says it has "procedures in place to ensure that such needs are addressed, including immediate adjustments to individual care plans, adaptations in working methods and support from central functions when needed".

Deviation handling is the formal remediation route (page 71): "Attendo has clear procedures for reporting and handling deviations in care operations, which are an integral part of the daily quality work. After each report, the incident is analysed, and adapted measures are taken, such as extra support to the persons concerned, adjustment of procedures or targeted training. Local managers, with the support of the quality function, systematically monitor whether the measures have had the intended effect. This involves assessing whether the problem has been resolved, analysing the risk of recurrence and gathering relevant feedback from customers, staff and external reviewers."

An external route is named (page 71): "In the event of dissatisfaction, customers and relatives can lodge a complaint with the Health and Social Care Inspectorate (IVO) and with the municipality or welfare region concerned."

Testing whether the channels are trusted (page 71): "The combination of ongoing dialogue, structured feedback processes and regular surveys means that customers and their families know and trust the channels available... To ensure the accuracy of the picture, the results of the surveys are compared with internal and external quality reviews as well as employee surveys, providing confidence that the feedback is both reliable and representative."

The related volumes are reported under S4-5 rather than here: 40 reported Lex Sarah and Lex Maria cases in Sweden and 5 open AVI cases in Finland at year end (page 72). No count of complaints received through the customer councils or the local channels is given, and there is no statement of whether third-party grievance mechanisms are available to customers beyond the statutory inspectorates.

Taking action on material impacts on consumers and end-users

Reference: page 71 (index, page 71).

Responsibility first: "The quality function in each of the Business Areas is responsible for taking a structured approach to managing impacts, risks and opportunities with respect to the customers. In the local operations, the unit managers bear the ultimate responsibility for the customers in the day-to-day operations" (page 71).

Three key ongoing and planned actions are listed (page 71):

• Continued focus on individualized care experiences. "The work to tailor care solutions to each individual by collaborating closely with customers and their relatives will continue. This ensures that the care planning not only respects individual autonomy but also accommodates personal preferences and considerations, fostering a sense of dignity and trust."
• Comprehensive analysis of customer feedback. "Analysis of the feedback gathered from surveys, councils and the increased use of digital and real-time tools will continue to be improved to further pinpoint opportunities for both individual and structural improvements."
• Strengthened quality and safety monitoring. "Internal reviews will be further refined and expanded to increase their scope and effectiveness. This includes introducing more frequent reviews, more advanced analytical tools and structured follow-ups to ensure compliance with care standards and proactively managing potential risks."

Resources (page 71): "Attendo has no significant operating expenses (OpEx) or investments (CapEx) related to action plans with material negative impacts at present."

The wider approach is set out under SBM-3: managing the impact "is based on customer-centred ways of working: individual care plans, continuous competence development and digital care solutions that increase responsiveness and accessibility" (page 70).

As with S1-4, the actions are described in continuous and future tense with no dated milestones, no scope statement of how many units or customers each covers, and no stated budget. The EU-legislation datapoint list marks "ESRS S4-4 Human rights issues and incidents paragraph 35" as Not material (page 80). Effectiveness is tracked through the cNPS, rNPS, RAI and ASCOT outcomes reported under S4-5.

Targets related to consumers and end-users

Reference: pages 71-72 (index, page 71).

Satisfaction targets as printed (page 72):

Both targets were met and both improved year on year, in contrast to the eNPS trend under S1-5. "Attendo has also linked its credit facility to targets related to cNPS" (page 72), and cNPS carries 12.5% of the incentive programme weighting (page 51).

Quality of life outcomes, reported without a target (page 72):

Attendo explains why no target sits against them: "the applied tools are new - both within social care overall and Attendo - and there is none or little historical and/or comparable data as of today. As a result, Attendo has not yet set a specific target for ASCOT or RAI outcomes or established a base year to measure from. Attendo will continue to work with these measurements and outcomes and review the possibility and relevance of setting defined targets. In the meantime, the company tracks the effectiveness of its quality of life efforts through customer feedback surveys and channels" (page 72).

Deviations reported to authorities (page 72): Lex Sarah and Lex Maria reports in Sweden 40 (2024: 40); open AVI cases in Finland 5 (2024: 11), the fall attributed to supervision of elderly care transferring to the new welfare regions. Attendo argues the count should be read with care: "Unlike industries where a zero vision may be applicable - such as workplace safety or traffic accidents - social care operates within a complex and dynamic environment where deviations, when properly managed, serve as valuable learning opportunities", and a proactive reporting approach "aims to contribute to transparency, rather than indicating a specific level of quality" (page 72).

Governance and consultation (page 71): targets were "developed and set by Attendo's Executive Management" and reviewed by the Board; customers and relatives "have not been consulted in setting Group-wide targets".

Coverage limits are disclosed: cNPS for Scandinavia "covers the elderly care operations in Sweden"; rNPS in Scandinavia covers "nursing homes in Sweden"; ASCOT "is applied in nursing homes in Sweden" while RAI covers all elderly care in Finland (page 72).

Business conduct policies and corporate culture

Reference: page 73 (index, page 73).

"The Group's core business ethics principles are set out in Attendo's Code of Conduct for employees and suppliers, adopted by the Board of Directors. Both codes are based on Attendo's vision, mission, values and sustainable business strategy and international standards, and mirror each other" (page 73). Both are available on Attendo's website.

The Supplier Code (page 73) "is consistent with the UN Guiding Principles on Business and Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work. It also requires suppliers to respect the EU taxonomy's 'Do no significant harm' criteria, as well as to act according to minimum social safeguards... Attendo requires suppliers to comply with anti-corruption laws, and includes zero tolerance for bribery, corruption, human rights violations, child labour, forced labour and discrimination, as well as principles of transparency, the possibility to report complaints and misconduct."

Training (page 73): "All employees must undergo annual training in the Code of Conduct for employees, whereas training in the Supplier Code of Conduct is focused on employees with roles and responsibilities that are relevant to Attendo's relationships with suppliers." Implementation sits with the Procurement and Real Estate functions for the Supplier Code and with HR for the employee Code.

Mechanisms for reporting and investigating unlawful behaviour (page 73). Employees "may report serious offences, such as cases of bribery, fraud, and other inappropriate or illegal conduct, via the whistleblower reporting system". The system "is administered by an external third party through an online portal", and "ensures that matters are thoroughly and objectively investigated and that whistleblowers are protected from retaliation or discriminatory action, in line with legal requirements. If whistleblowers choose to remain anonymous, neither Attendo nor the third-party provider can track or identify the reporting individuals." The legal function owns the channel and "All whistleblower cases are treated by the Board (Audit Committee)". The function "receives relevant training on how to manage the reporting channel, as well as on how whistleblowers are protected".

Volumes (page 73): "During the year, 61 cases were received via Attendo's external whistleblowing channel, of which eleven were assessed as qualified" under Directive (EU) 2019/1937.

The EU-legislation list marks G1-1 United Nations Convention against Corruption (paragraph 10(b)) and G1-1 Protection of whistleblowers (paragraph 10(d)) as Material, page 73 (page 80).

Management of relationships with suppliers

Reference: page 74. Attendo titles this disclosure "Measures to protect whistleblowers and business conduct towards suppliers" and lists it in the content index as G1-2 at page 74 (page 76).

Supplier management (page 74): "Attendo manages its purchasing activities mainly at the central level, but at the same time enables local decision-making by suppliers. Attendo integrates social and environmental criteria into supplier selection by signing the Code of Conduct for Suppliers, and evaluates suppliers based on their ability and willingness to comply with Attendo's Code of Conduct. This also includes relevant frameworks such as ISO 14001, and their commitment to sustainability initiatives, such as ethical working conditions." Supplier compliance checks "are carried out on a random basis", and all suppliers who sign the Code "are authorised by Attendo to conduct compliance checks" (page 53).

Whistleblower protection measures, which Attendo places in the same disclosure (page 74): "To protect whistleblowers, Attendo has an external whistleblowing system that allows anonymity, and all employees are informed and trained on how to report irregularities and incidents. The whistleblowing system is available 24 hours a day, 7 days a week, in local languages. Information about the system and reporting procedures is available through several internal channels, and all employees must undergo annual training in Attendo's Code of Conduct."

Resources (page 74): "Attendo has no significant operating expenses (OpEx) or investments (CapEx) related to action plans with material negative impacts at present."

One caveat on materiality. Supplier relationship management is not a material sub-topic for 2025. The DMA records: "In 2024, the sub-topic of supplier relationship management was assessed as essential, but not in 2025. The change in the assessment comes following a reassessment of the importance of the topic in dialogue with auditors" (page 58). Attendo nevertheless kept G1-2 in its content index and disclosed against it, so the disclosure is voluntary in substance. Nothing is said about payment practices to suppliers, and no supplier screening or audit numbers are given beyond the spend-acceptance metric of 30% under the targets (page 74).

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are presented under a "Metrics and targets" heading as part of the MDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

Attendo sets two business conduct targets, both quantified, and misses both (page 74).

Group spend totalled MSEK 5,344, of which MSEK 1,608 came from suppliers who had accepted the Supplier Code of Conduct (page 74).

Why the training figure fell. The population changed, and Attendo says so: "The calculation for 2024 included all employees in Scandinavia. In Finland, however, only new hires in 2024 were included. From 2025, the training requirement will apply to all employees. The 2025 calculation therefore includes each person employed during the year. Because the training can be carried out jointly in groups of several people, the number of recorded trainings carried out does not necessarily reflect the actual number of employees who took part in the training" (page 74). So the 45% is measured over a much larger base than the 65%, and the recording method may understate it.

Rationale (page 74): the training metric "aims to ensure that all employees are aware of and work in accordance with the company's values and guidelines and that employees are aware of the whistleblowing system and the protection that applies to whistleblowers", which ties it directly to the single material G1 impact. The supplier metric works "towards increasing the proportion of suppliers who accept the Code of Conduct for Suppliers", since acceptance "means that the supplier commits to fulfil the requirements".

Governance and consultation (page 74): targets "have been developed and set by Attendo's Executive Management, in light of available results and trends and considering its long-term ambitions. The Board of Directors has reviewed the targets." And: "Suppliers have not been consulted in setting the target."

Both targets are described as levels to reach rather than dated, so no target year is given for closing the 25 and 40 percentage point gaps.