Axfood

The role of the administrative, management and supervisory bodies

Reference: page 42; see also pages 42-43.

"Axfood's sustainability governance is integrated into its management, with clearly defined responsibilities assigned to the Board of Directors and the Executive Committee. The Board is responsible for the strategic direction and the Group's overarching targets, while the Executive Committee is responsible for other targets, operational implementation and follow-up" (page 42).

Composition. "Axfood's Board consists of 11 non-executive members, eight of whom are elected by the Annual General Meeting (AGM), and three of whom are elected by employee organisations." Of the AGM-elected members, 63% (40) are independent. The gender breakdown on the Board is 36% women (30) and 64% men (70). The Executive Committee has 11 members, 55% women (55) and 45% men (45) (page 42).

Expertise. "The Board has solid knowledge of Axfood's operations and extensive experience of food retail, as well as experience of sustainability matters from previous and current assignments... The Board and the Executive Committee are both deemed to have sufficient expertise to review and challenge sustainability work" (page 43).

Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies

Reference: page 43.

"In 2025, the Board met eleven times. The Board continuously discusses current sustainability matters and the Group's sustainability reporting. The results of the materiality assessment and the Group's long-term strategy form the basis for the Executive Committee's preparation of Group-wide sustainability targets that are followed up annually" (page 43).

Reporting lines. "The Executive Committee discusses current sustainability issues on an ongoing basis and receives quarterly updates from the sustainability forum - an informational and preparatory body led by the Head of Sustainability." Subsidiary data is consolidated by the accounting and finance department "before being presented to the CFO, who in turn reports to the Executive Committee and the Audit Committee" (page 43). The Board is informed annually on business ethics by the General Counsel and receives an annual report on whistleblower cases (page 43).

Integration of sustainability-related performance in incentive schemes

Reference: page 43.

Axfood operates long-term share-based incentive programmes (LTIP) decided by the AGM and offered to senior executives and other key persons. "Each savings share is matched with up to seven performance shares depending on the extent to which a number of targets are met. The performance shares are divided into three classes for LTIP 2025 and four classes for previous programmes" (page 43).

The sustainability class. "One class is linked to sustainability and is assessed based on the target to increase the share of sales of sustainability-labelled products. Full vesting requires that the key performance indicator increases at least 10% during the three-year vesting period compared with 31 December of the year before the start year. The minimum level corresponds to an unchanged share of sales of sustainability-labelled products... The sustainability linked class corresponds to approximately 15% of the total number of performance shares in the incentive programmes" (page 43).

Explicit climate exclusion. "Axfood does not have any incentive targets linked to climate-related matters" (page 43). The underlying sales metric is reported under G1 at 26.6% (27.2) for 2025 against a 30% target for 2030 (page 98).

"The Board's Remuneration Committee is responsible for the actual design and management of the incentive programmes" (page 43).

Statement on due diligence

Reference: pages 43-44.

"Axfood's due diligence process is based on the Group's Supplier Code of Conduct, which all business partners are obligated to follow. The contents of the Code of Conduct are in line with the UN Guiding Principles on Business and Human Rights and are based on the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct" (page 43).

Mapping table (page 44), giving the pages in the sustainability report where each step is described:

Suppliers must demonstrate systematic compliance "through: referrals to social audits, collective bargaining agreement with trade unions, or projects with relevant stakeholders". "When needed, a risk database from the company Maplecroft is used to compare and validate suppliers' own risk assessments." Axfood is a member of the Ethical Trading Initiative (ETI) Sweden (page 43).

Risk management and internal controls over sustainability reporting

Reference: page 44.

"Axfood has implemented internal controls to manage risks that could impact the reliability and accuracy of its sustainability reporting. Management of these controls follows the same structure and system as the controls for financial reporting and is divided into four categories" (page 44).

The first category covers overall reporting processes: "materiality assessment, sustainability policy, guidelines for sustainability reporting, and targets and metrics". "The other three categories are based on the Group's environmental, social and governance reporting and include controls to ensure that data collection in each area is accurate, complete and reliable" (page 44).

"The results of these controls are reported to the Audit Committee, which then reports to the Board." "In 2025, the work on internal controls related to sustainability reporting was expanded to include new controls for relevant risks" (page 44). The statement received limited assurance from Deloitte AB (page 154).

Strategy, business model and value chain

Reference: page 44.

"Axfood operates in Sweden. In 2025, its net sales amounted to SEK 89,152 m (84,057). With 18,652 employees (18,472), the Group is a major employer" (page 44). Segments are Willys, Hemkop, City Gross, Snabbgross and Dagab (page 42).

Business model. "Axfood's business model consists of three primary processes: purchasing and assortment, product flow and logistics, and sales channels and concepts" (page 44).

Where the impact sits. "Most of the value chain's environmental impact arises upstream, mainly in primary production. This not only includes the majority of GHG emissions, but also significant environmental challenges such as pollution, impacts on biodiversity and high levels of resource use. There are also significant risks related to human rights in the supply chain at this stage" (page 44).

Value chain scope. "Axfood's value chain is extensive and begins upstream in primary production, followed by processing and packaging. Transports are then carried out by suppliers to Axfood's warehouses and on to Group- and retailer-owned stores as well as through e-commerce to consumers. Downstream in the value chain are the over six million customers reached by Axfood's various concepts every week as well the management of circularity, recycling and waste" (page 44).

Axfood applies the ESRS phase-in provision to SBM-1 (page 42).

Interests and views of stakeholders

Reference: pages 44-45.

"Axfood's most important stakeholders are customers, employees, suppliers, investors and the communities that impact, or are impacted by, its operations" (page 44). The stakeholder table on page 45 gives channels and material matters for each: customers (store meetings, consumer contact, focus groups, surveys) raise country of origin, animal care, carbon footprint and food waste; for employees "Work environment and good working conditions are the most material sustainability matters... both internally and at suppliers"; for suppliers "The climate is the most important sustainability matter"; investors emphasise "a reduction in carbon footprint"; and society raises "reduced carbon footprint, biodiversity and sustainable agriculture" (page 45).

A structural caveat worth noting. "During the materiality assessment, stakeholder insights are represented by internal representatives at Axfood. These individuals have close contact with each stakeholder group and convey their views as part of the assessment" - the CFO and Head of Corporate Communications for owners and investors, Dagab's Head of Private Label Products for suppliers, the Head of Sustainability for non-profit organisations and the Head of Human Resources for employees (page 45).

"The Board and the Executive Committee are regularly informed about the views of stakeholders" (page 45).

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

Reference: pages 45-46 and 49; also 51-52, 61, 64, 67, 72, 79, 85, 89, 92, 96 per the content index (page 103).

"None of the material impacts, risks or opportunities have changed compared to the previous reporting period" (page 45).

The overview table on page 49 maps 25 sustainability areas to IRO codes I1-I41, R1-R25 and O1-O3, with impact polarity, time horizon, value chain position and the ESRS standard and page for each. Each topical chapter then repeats the rows with a description, type label, time horizon and value chain position.

Risks. "Disruptions in global supply chains caused by extreme weather could impact Axfood's ability to source sufficient volumes of goods. This in turn could lead to shortages of goods in stores and lower sales... Supply disruptions can also arise as a result of overexploitation of natural resources both on land and at sea" (page 45). Other risks concern "inadequate due diligence in business relationships, insufficient human rights controls in the supply chain, and unethical conduct such as corruption" (page 46).

Axfood applies the ESRS phase-in provision to SBM-3 (page 42). Climate-specific risk identification and scenario analysis is also presented under E1-2 and climate resilience under E1-3 (2025 ESRS numbering).

Description of the processes to identify and assess material impacts, risks and opportunities

Reference: pages 46-49.

"Axfood has carried out a double materiality assessment to identify how the Group impacts, and in turn is financially impacted by, its operating environment. This work followed a structured five-step process: 1. Identification of material matters based on the EU's description of sustainability matters covered by the ESRS standards 2. Process and stakeholder review 3. Impact materiality assessment 4. Financial materiality assessment 5. Materiality mapping and documentation" (page 46).

"This first assessment yielded a list of 37 potentially material sustainability matters covering the value chain and various time horizons" (page 46).

Thresholds. Impact materiality was scored on severity (scale, scope, irremediable character) plus likelihood, each rated 1-5. "An impact is assessed as material at a value of 5 or higher on a scale of 0-10... These impacts were assessed as material at a value of 4 or higher on a scale of 0-7" for positive impacts (page 47). For financial materiality, "On a scale of 0-14, a risk or opportunity was assessed as material at a value of 8 or higher" (page 48). "These thresholds were subsequently approved by the Board" (page 47).

Result. "The materiality assessment showed that all ten relevant topical ESRS and 34 sustainability matters were assessed as material" (page 48).

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Reference: page 48; the content index itself is on pages 103-104.

"An analysis was carried out to identify which ESRS disclosures were consistent with the results of the assessment. The results were approved by the Board... For information on which ESRS disclosure requirements were identified as material, see the table on pages 103-104. Information about all datapoints reported that stem from other EU legislation according to ESRS 2 is presented in the table on pages 105-108" (page 48).

The index ("List of Disclosure Requirements - content index", pages 103-104) lists each covered DR with a page location. Every topical standard E1-E5 and S1-S4 plus G1 appears. E1-8 is listed with a dash in the location column and the note "Axfood does not use internal carbon pricing" (page 103).

Not listed in the index: E1-9, E2-6, E3-4, E3-5, E4-6, E5-6, S1-7, S1-11, S1-12, S1-13 and S1-15. Of these, all except E3-4 are named in the phase-in list on page 42: "Axfood has applied the ESRS phase-in provisions for the following disclosure requirements", which also covers SBM-1 and SBM-3. "Application of the phase-in provisions entails that the disclosure requirements will be applied gradually over the coming reporting years" (page 42).

The statement was prepared under Commission Delegated Regulation (EU) 2023/2772 (page 150) and covers pages 40-108 (page 154).

Transition plan for climate change mitigation

Reference: pages 52-53.

"To support this, Axfood has created a climate transition plan that explains in more tangible terms the work required to achieve the goal of reducing the Group's carbon footprint" (page 52).

Targets in the plan. Scope 1 and 2 emissions to fall "by at least 70% by 2030 at the latest (compared with the base year of 2024), which is well above the carbon footprint requirement in the Paris Agreement"; at least 70% of suppliers by spend to have science based targets by 2030; a FLAG target "to reduce emissions from agriculture by at least 30% by 2030 at the latest"; and carbon footprint per kilo of food sold down 10% by 2030 (page 52).

Quantified levers. "Actions in the Group's own operations (Scope 1 and 2) are to help reduce emissions by approximately 4,000 tCO2eq by 2030" through fossil-free transport and energy efficiency and refrigerants. "Actions in Scope 3 (FLAG) to help reduce emissions by 970,000 tCO2eq by 2030" through changes to the sales mix, a developed offering, agricultural innovation, sustainability criteria in assortment and purchasing, and reduced food waste (pages 52-53).

Benchmarks. "Based on available information, Axfood is not excluded from any EU reference values or benchmarks" (page 52).

No locked-in GHG emissions assessment is presented.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and SBM-3, where this content is disclosed in the FY2025 report (pages 44 and 46, with the E1 IRO table on page 51). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification. The E1 IRO table labels R1 and R2 physical risk and R3-R6 transition risk (page 51).

Methodology and its stated gap. "Axfood has not yet analysed which assets and operations may be exposed to these risks based on probability, scope, duration and geographic location. However, as part of the above-mentioned risk analysis, a mapping of climate-sensitive raw materials and geographic areas upstream in the value chain has been initiated" (page 46).

Scenarios and temperature projections (page 46):

Scope and timing. Developed in 2025, "based on a selection of goods from around 20 countries" (page 44), covering "seven climate-related threats, four classified as chronic and three as acute, over the time horizons 2030, 2040 and 2050" (page 46).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3, where this content is disclosed in the FY2025 report (page 44, with supporting text on page 46). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"Axfood has conducted a risk analysis, including a resilience analysis, based on how a changing climate in the short, medium and long term could impact its business plans, prices and supply chains. The analysis mainly covers activities upstream in primary production and was based on a selection of goods from around 20 countries" (page 44).

Results. "The results indicate that Axfood's operations, like the industry, are impacted by climate change and changing ecosystems... This could lead to a reduced supply of goods, higher purchase prices and lower quality... Extreme weather increasingly affects the world's food market, and raw materials such as coffee and cocoa are particularly vulnerable" (page 44).

Capacity to adapt. "To ensure a stable supply of goods, Axfood engages in risk diversification... Axfood believes that the Group's ability to manage these challenges is at least as good as that of its competitors" (page 44). Broadening the supplier base is recorded as opportunity O1 (page 51).

Stated limit. "Axfood has yet not conducted resilience analyses for other material impacts, risks and opportunities" (page 44).

Policies related to climate change mitigation and adaptation

Reference: page 53.

"Axfood's work to limit climate-impacting emissions is governed by the Group's codes of conduct, policies and guidelines. Among other areas, these documents cover products and assortment, energy and store establishment, transports and IT" (page 53).

Supplier Code of Conduct. Suppliers "are encouraged to set their own climate targets and to support the Paris Agreement and the EU Fit for 55 package". It "is included in all supplier agreements and followed up through dialogues, assessments and social audits" (page 53).

Own operations. "Within the Group's own operations, there are specific guidelines for products, sustainable IT, and sustainable store establishments and refurbishments. These guidelines set out requirements for energy efficiency, refrigerant selection, renewable electricity use and fossil fuel phase-out" (page 53). The products guidelines require that "the Group's own and leased vehicles are required to operate fossil-free"; the IT guidelines require "at least 15% better energy efficiency than the machines they replace" and the Energy Star label or equivalent (page 53).

Stated gap. "Currently, there is no group-wide guideline for sustainable establishment and refurbishment. During 2026, a guideline will be developed" (page 54). The sustainability function coordinates updates and reports annually to the Executive Committee (page 53).

Actions and resources in relation to climate change policies

Reference: pages 53-54.

"The focus is on agriculture, energy, transport, refrigerants and food waste - areas where the impact is most significant" (page 53).

Fossil-free transports. "Charging infrastructure has been built at the Group's warehouses and distribution centres, and Axfood is investing in new vehicles with a focus on electrification. Procured transports account for around half of the transport volumes. When signing agreements, Axfood includes requirements for renewable fuel and carbon footprint monitoring" (page 53).

Energy efficiency and refrigerants. "In 2025, 42 stores and one warehouse were converted to LED lighting. A total of 310 of 392 stores have been converted" (page 53).

Agricultural innovation. "Axfood's collaboration with the innovation company Nitrocapt and the food producer Dafgards to promote the farming of grain using fossil-free nitrogen fertiliser and its use in bread production" (page 54).

New establishment. In new construction the aim is "to achieve an energy performance at least 20% lower than the requirements set out in the Swedish National Board of Housing, Building and Planning's regulations". "Axfood's purchased electricity is 100% renewable and certified" (page 54).

Training. In 2025 purchasing and category staff "took part in a climate analysis of Axfood's most common purchase countries" (page 54).

Targets related to climate change mitigation and adaptation

Reference: pages 55-57.

"In December 2025, Axfood applied to have three climate targets validated by the SBTi... The targets have a target year of 2030 and a base year of 2024" (page 55). The three are: absolute Scope 1 and 2 GHG emissions down at least 70%; at least 70% of suppliers by spend to establish science based targets; and FLAG-related GHG emissions from agriculture down at least 30% (page 55).

(pages 55-57)

"The climate analysis have not been directly taken into account in formulating Axfood's climate targets, as these scenarios primarily aim to secure Axfood's future assortment and sourcing through diversification of the supply chain" (page 55).

Energy consumption and mix

Reference: page 57.

"Energy use for the year was 445,089 MWh (452,981). The energy mix consists of 99% (94) Swedish renewable energy, which consists of fossil-free electricity, primarily from hydroelectric power. Part of the mix also consists of self-produced solar power generated from solar cell systems installed on the roofs of warehouses and stores" (page 57).

Coal, natural gas, other fossil sources and nuclear are all reported as zero (page 57).

Caveat: "Energy use from company cars has been estimated and is therefore not as reliable" (page 57).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 57-59.

(page 58)

Exclusions. Categories 8, 10, 13 and 15 "were not deemed relevant to Axfood's operations and have therefore been excluded", each with a stated reason (page 59). "Information on biogenic emissions that arise in own operations and along the value chain in connection with the combustion of HVO fuel or biogas is excluded... At present, Axfood does not have the ability to calculate and report this type of emissions within its value chain in a reliable manner" (page 57). Share of primary data is 100% for Scope 1 and 2 but 0% for Scope 3 categories 1 and 2 (page 102).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 59.

"Emissions from Axfood's own operations, including purchased energy, refrigerants, business travel and transport from warehouses to stores, must be balanced with efforts to sequester carbon dioxide or counteract emissions in an equivalent amount elsewhere. For 2025, investments have been made in projects through Eken Financing AB, where forests are allowed to remain longer to sequester more carbon, and through Solvatten AB, which provides people in economic vulnerability with clean and hot water by purifying water with solar energy to reduce their need for firewood and coal" (page 59).

"These investments will cover the Group's emissions within its own operations, which during the year amounted to 20,086 tonnes of carbon dioxide equivalents. The carbon credits for the amount of emissions covered are planned to be cancelled in the future, ensuring that the climate compensation is permanent and cannot be double counted" (page 59).

Note the 20,086 tCO2eq figure is broader than the 7,512 tCO2eq reported for own operations under the Scope 1 and 2 target (page 55); the report does not reconcile the two.

Internal carbon pricing

Reference: page 103.

Axfood lists E1-8 in its own ESRS content index with a dash in the location column and the following entry under "Other information": "Axfood does not use internal carbon pricing" (page 103, "List of Disclosure Requirements - content index").

This is a nil return. ESRS E1-8 applies where an undertaking operates internal carbon pricing schemes; Axfood states it does not, so there are no carbon prices, scheme types or covered emissions to disclose.

No internal carbon price appears anywhere else in the E1 chapter (pages 50-59), which sets out targets, decarbonisation levers, actions, energy and GHG metrics without reference to a shadow price, an internal fee or a carbon-price assumption in investment appraisal. The E1 transition-risk narrative does discuss external pricing pressure - R5 covers the risk that "More stringent climate and energy regulations could increase costs" (page 51) - but that is a regulatory risk, not an internal pricing scheme.

Reader caution: because the index carries no page reference for this DR, the statement above is the whole of Axfood's E1-8 disclosure.

Policies related to pollution

Reference: pages 61-62.

"Axfood has established policies and guidelines that guide its work to limit pollution to air, soil and water. These policies and guidelines relate to the use of refrigerants and chemicals, packaging and non-food, and emissions from transports... Axfood has taken expectations from affected stakeholders... into consideration when drafting governance documents" (page 61).

Supplier Code of Conduct. It "particularly addresses the use and handling of chemicals, pesticides and other potentially harmful substances. These substances are to be identified, assessed and managed safely throughout their entire life cycle, from manufacturing and storage to recycling or waste management... This includes phasing out hazardous substances and carefully handling chemicals, even in primary production" (page 61).

Guidelines for products. "The guidelines are based on ChemSec's SIN list of substances to phase out and state that these substances are not to be used in products or packaging that comes into contact with food. For suppliers of non-food as well as chemical and cosmetic products, third-party certification is required" (page 61). "As a part of the guidelines, PFAS are forbidden in all non-food and packaging for the Group's private label products" (page 62).

Stated gap. "Guidelines for sustainable store establishments will be developed in 2026" (page 62).

Actions and resources related to pollution

Reference: page 62.

Global G.A.P. "Global Good Agricultural Practices (G.A.P.) is a certification that requires the controlled use of fertilisers and plant protection products, the safe storage of chemicals and the correct handling of waste in order to prevent the spread of hazardous substances and nutrient leakages... Axfood has required Global G.A.P. certification or the equivalent for several years for fruits, vegetables, grains and legumes. This work has been expanded to include packaged and processed private label plant products" (page 62).

Transport and logistics. "All of the vehicles Axfood purchases are to be rated Euro 6, a more stringent standard than the previous one when it comes to nitrogen oxide emissions. This classification requires vehicle manufacturers to use exhaust aftertreatment... Axfood is also electrifying a portion of its vehicle fleet, thereby completely eliminating these types of emissions from this portion of the fleet" (page 62).

Chemicals. "Carcinogenic, mutagenic, reprotoxic (CMR) substances and endocrine disruptors are forbidden in Axfood's cosmetic and chemical products." "On Axfood's initiative, an industry-wide list of pesticides that are permitted but inappropriate was prepared for fruit and vegetable production. The list is maintained by the Swedish Food Retailers Federation" (page 62).

Targets related to pollution

Reference: page 62.

Axfood discloses that it has set none, and gives its reasons: "Axfood currently has no quantitative targets or metrics to follow up material impacts, risks and opportunities related to pollution in its own operations or upstream in the value chain. This is primarily due to the difficulties involved in measuring and ensuring reliable data. While Axfood has good control over the production of private label products, challenges remain when it comes to measuring the presence of hazardous substances and chemicals in brands. This requires a combination of proactive requirements, effective measuring tools and expanded data collection in the supply chain" (page 62).

The one quantified target relevant to pollution sits in the climate chapter rather than here: the refrigerant target that all Group-owned stores and warehouses switch to natural refrigerants by 2030, at 70% converted in 2025 against a 100% target level, cross-referenced from E2 ("For more information about Axfood's targets related to refrigerants, see ESRS E1 on pages 57", page 62). Effectiveness is otherwise tracked through supplier certification requirements and third-party certification of non-food, chemical and cosmetic products (page 61).

Pollution of air, water and soil

Reference: page 62; the substantive finding is on page 61.

Axfood reports no quantified pollutant amounts and states why. "Axfood currently has no quantitative targets or metrics to follow up material impacts, risks and opportunities related to pollution in its own operations or upstream in the value chain. This is primarily due to the difficulties involved in measuring and ensuring reliable data" (page 62).

Where the impact sits. "Axfood's material impact in terms of pollution to soil, air and water mainly arises upstream in the value chain, primarily within agriculture. These impacts come from synthetic fertilisers and manure in livestock farming as well as pesticides used to protect crops. Heavy fertiliser use can lead to nitrogen and phosphorus leaching, which can cause eutrophication and degrade water quality, while ammonia emissions have a negative impact on air and the ecosystem" (page 61) - upstream, where the ESRS 1 value chain relief applies.

Substances of concern and substances of very high concern

Reference: page 62.

Axfood reports its management of substances of concern but no amounts. ESRS E2 paragraph 34 asks for the total amounts generated, used or procured, and the amounts leaving facilities split by main hazard class; neither limb is answered with figures.

What is disclosed. "Axfood manages and phases out hazardous substances in products, packaging and chemical products. The quality assurance function is responsible for monitoring substances in private label products and packaging... Carcinogenic, mutagenic, reprotoxic (CMR) substances and endocrine disruptors are forbidden in Axfood's cosmetic and chemical products. PFAS are not permitted in non-food items or packaging for private label products" (page 62).

On SVHC specifically. "Axfood applies the EU's candidate list of substances of very high concern (SVHC) and requires suppliers to report the presence of such substances" (page 62).

The material IRO is I9, "The use of refrigerants in warehouses, stores and transports has a negative impact on the ozone layer", with risk R7 on the cost and supply-security consequences of phasing out hazardous chemicals (page 61).

Stated reason for the absence of amounts. "Challenges remain when it comes to measuring the presence of hazardous substances and chemicals in brands... In 2025, work began on improving data collection" (page 62).

Policies related to water and marine resources

Reference: page 64.

"Axfood's approach to water and marine resources is governed by the Group's Supplier Code of Conduct, supplemented with specific procedures and guidelines. The Code of Conduct includes requirements related to human rights, health and safety, the environment and responsible water use" (page 64).

Water procedure. "The water procedure is implemented at the sub-national level based on the Maplecroft Water Stress Index... As part of the procedure, suppliers are required to indicate the geographic location of their agricultural operations." "In areas with an extreme risk of water stress, Alliance for Water Stewardship (AWS) certification or credible multi-stakeholder projects are required" (page 64).

Guidelines for seafood. They "set stricter requirements than the relevant legislation. Supplies are to come from sustainable stocks and be traceable", are "built on an ecosystem-based approach" and are linked to UN SDGs 12 and 14 (page 64).

Stated gaps. "There is currently no policy to address the prevention and reduction of water pollution or covering products produced by suppliers of branded products in areas under high water stress." "Product development does not currently take water-related issues or marine resource conservation into account" (page 64).

Actions and resources related to water and marine resources

Reference: pages 64-65.

Preventive work. "To manage these risks, Axfood requires suppliers to have effective procedures for water management and treatment, encourages purchasing that promotes responsible use of water resources, and participates in industry-wide initiatives related to sustainable water management. Vulnerable regions are actively monitored... Products are not to be sourced from regions under such high water stress that a water standard is not sufficient to ensure sustainable water use" (page 65). "In 2025, Axfood expanded the procedure to include products such as almonds, lentils, apricots, olives, figs and asparagus sold as private label products" (page 64).

Food retailers' water roadmap. "Along with other members of the Swedish Food Retailers Federation, Axfood was one of the driving forces behind a joint roadmap for sustainable water use, adopted in 2025. The water roadmap sets industry-wide requirements for suppliers in areas under high water stress, requiring them to actively pursue improvements and be able to demonstrate their certification according to recognised water standards" (page 65).

BalticWaters partnership. "The laboratory, which was completed in 2025, provides new opportunities to study Baltic cold-water fish, including herring and cod, at all life stages" (page 65).

Targets related to water and marine resources

Reference: page 65.

"Axfood has targets for managing material impacts, risks and opportunities related to marine resources, but lacks targets for water resources" (page 65).

Sustainability-labelled fish and shellfish.

(page 65)

"Axfood's target for marine resources is that all fish and shellfish sold will be eco-labelled or have a green rating in the WWF seafood guide by 2030... The share of seafood sales that was sustainability-certified or rated green in WWF's Seafood Guide amounted to 69.8% in 2025 (61.7). The 13% increase is primarily the result of intensified work toward increasing the supply of sustainably certified salmon. The reinstatement of sustainability certification for caviar also contributed positively to the outcome" (page 65).

Explicit gap. "Axfood does not have a target in place for the impact on water use in areas under high water stress" (page 65). The target year was moved from 2025 to 2030 in the preceding year "due to limited supply of affordable sustainability-labelled fish and shellfish" (page 65).

Transition plan on biodiversity and ecosystems

Reference: page 68.

"Axfood's transition work related to biodiversity brings together the Group's governance documents, processes and initiatives to reduce negative impacts on ecosystems and species. It is based on a biodiversity strategy and applies to the Group's own operations as well as the supply chain. By developing the assortment, setting clear requirements and governing procurement processes, Axfood supports more sustainable production methods and a food supply that preserves natural resources and ecosystems" (page 68).

"Axfood's biodiversity strategy serves as the foundation for its transition plan and guides the integration of biodiversity into business models and supply chains. The strategy describes the long-term direction for the Group's work to conserve and promote ecosystems and species as well as to reduce its negative impact" (page 68).

Stated limits. "The risk analysis is based on the current status and impact on biodiversity, since tools to cover longer time horizons are not yet available. The time horizon for the work is therefore short- and medium-term" (page 68). "Biodiversity loss has not been estimated or offset to date" (page 69).

Policies related to biodiversity and ecosystems

Reference: page 68.

Supplier Code of Conduct. "Axfood's Supplier Code of Conduct is a central governance document that covers all suppliers in the Group's value chain... Negative impacts include biodiversity loss, deteriorated ecosystems, deforestation and the use of harmful chemicals as well as air, soil and water pollution. The Code of Conduct also stipulates that the production and extraction of raw materials must not destroy natural resources or sources of income for socially or economically marginalised groups" (page 68).

Guidelines for products. "They restrict the use of chemical pesticides and forbid the use of chemicals in farming operations that could be harmful to workers, local communities or ecosystems. They also stress the importance of promoting organic production... The guidelines set out specific requirements for sourcing of risk commodities, meaning agricultural products that are difficult to replace and that are often associated with risks of deforestation, land use conversion or high water withdrawals" (page 68).

Water procedure. "Axfood has nine approved water standards, including Global G.A.P. SPRING, Alliance for Water Stewardship and Rainforest Alliance. These are required when purchasing water-intensive crops as well as crops purchased from water-scarce areas" (page 68).

Actions and resources related to biodiversity and ecosystems

Reference: page 69.

Certification of risk commodities. "All coffee, tea, chocolate and cocoa sold under the Garant, Eldorado and Dazzley private labels are organic or certified by the Rainforest Alliance or Fairtrade... Palm oil in the Group's products must be RSPO certified" (page 68).

Swedish Platform on Risk Commodities. Members "require suppliers to ensure that products containing soy and oil palm, including both branded products and private label products, are sustainability certified or compensated no later than 2025. Indirect use of oil palm through feed is to be phased out by 2027 at the earliest. The target for 2025 has been achieved and requirements for palm oil in feed are being introduced for 2026." Soy credits purchased for 2024 volumes "supported farmers that together protected approximately 20,000 hectares of domestic vegetation - 16% more than required by law" (page 69).

New establishment. Land use is offset by "planting trees and shrubs around parking lots and equipping facilities with green roofs full of sedum species. This work does not currently involve any particular procedures for facilities located in or near highly sensitive areas. Guidelines with procedures will be developed in 2026" (page 69).

Targets related to biodiversity and ecosystems

Reference: pages 69-70.

"Axfood has targets for managing material impacts, risks and opportunities related biodiversity" (page 69).

(page 69)

"Axfood is to increase the share of sales of organic food to at least 10% by 2030 the latest to contribute to more sustainable agriculture, to promote biodiversity and to reduce the use of chemicals in primary production. The aim is to avoid and minimise Axfood's negative impact. Organic food is defined as food items bearing the KRAV or EU organic sustainability labels. In 2025, the share of sales of organic food was 3.9% (4.2)" (page 69). The outcome has fallen in each of the last three years against a target of 10%.

Stated limits. "Stakeholders did not contribute to formulating the target and no offsetting has been used when setting it... Nor has Axfood taken ecological thresholds or entity-specific allocations into consideration when setting the target" (page 70). The target year was moved from 2025 to 2030 in 2024 because "Since 2016, sales of organic products across the entire food retail sector have plateaued and declined" (page 70).

Impact metrics related to biodiversity and ecosystems change

Reference: pages 69-70.

Facilities in close proximity to nature conservation areas.

(page 70)

"Of those facilities that Axfood leases, 11 (877) are deemed to be located in close proximity to nature conservation areas... None of the facilities are located within such areas. The total area of the facilities amounts to approximately 5.6 hectares" (page 70).

Method. "Axfood's assessment encompasses nature conservation areas in the Natura 2000 network, including the areas protected under the EU Habitats and Birds Directives... Axfood's assessment gives consideration to national nature reserves established by Sweden's county administrative boards and municipalities under the Environmental Code. The threshold for the definition of 'close proximity' has been set at 200 metres. Adjacent areas, such as parking lots or store entrances, are not included in the calculated area. Some facilities are located in close proximity to several nature conservation areas, which means that the same facility may be included several times" (page 70).

The organic sales share (3.9%) is used as "an indirect metric for the Group's impact on biodiversity" (page 66).

Policies related to resource use and circular economy

Reference: page 72.

"Axfood has taken key stakeholders into consideration when setting policies and guidelines. The guidelines for products and the Supplier Code of Conduct set out the Group's requirements for its own products and packaging with a focus on circularity" (page 72).

Supplier Code of Conduct. "Axfood's Supplier Code of Conduct states that suppliers are to ensure that the use of chemicals, pesticides and other material that is hazardous to people or the environment are identified, evaluated, labelled and handled carefully. This is done to guarantee safe handling, transport, storage, use, recycling or reuse and removal. Such materials should be used minimally. All business partners are required to read and sign the Supplier Code of Conduct" (page 72).

Stated gap. "Axfood does not currently have a policy or guidelines for waste management at its offices, stores and warehouses. However, circular economy guidelines will be established in 2026. Internal procedures for employees working at the Group's facilities, in collaboration with property owners, ensure that management is efficient and correct" (page 72).

Actions and resources related to resource use and circular economy

Reference: pages 72-73.

Packaging. "The amount of packaging material is minimised as far as possible without compromising on the quality of the contents or risking food waste. As of 2025, more than one hundred tonnes of plastic are saved every year by vacuum packaging Garant's mince and whole chickens in flowpack instead of using traditional plastic trays" (page 73). "Initiatives were carried out in 2025 to make packaging recyclable and to raise awareness among producers... To make recycling easier, packaging comes with recycling instructions" (page 73).

Food waste. Initiatives include "optimisation of orders, improved waste routines, reducing prices for products that are nearing their best-before dates... and charitable donations", plus "the use of handheld computers to identify products with a short shelf life, clearance prices... bargain bags and boxes with damaged fruits and vegetables in stores, and lower prices on day-old bread" (page 73).

Research. A Lund University-led project applies "naturally occurring, health-promoting and non-GMO bacteria... to leafy vegetables, carrots and tomatoes after harvest to inhibit spoilage organisms such as mould" (page 73).

Targets related to resource use and circular economy

Reference: pages 73-74.

(pages 73-74)

"The target of reducing food waste by 50% was already achieved in the 2024 financial year", one year early, and was replaced from 1 January 2025 by "a food waste target of no more than 0.7% by 2030" (page 74).

"None of Axfood's targets in resource use and circular economy have any scientific basis and stakeholders did not contribute to their formulation. Nor have the targets been set or revised based on legislation" (page 73).

Resource inflows

Reference: page 74.

(page 74)

Scope. "Resource inflows encompass all products that are produced upstream in the value chain at suppliers' production facilities, including private labels as well as branded products. Products are delivered to Axfood's warehouses and are then sold at the Group's stores. The products also include primary, secondary and tertiary packaging. In addition to products, resource flows also include IT equipment, software, furniture and company cars for offices. For warehouse operations, resource flows primarily include machinery, IT equipment and the vehicle fleet. For stores, resource flows primarily refer to store fittings and checkout equipment" (page 74).

Uncertainty in this area is also flagged at Group level on page 42.

Resource outflows

Reference: page 75.

(page 75)

Design for circularity. "Axfood's main products consist primarily of food, but also include non-food. Packaging and non-food are to be designed and produced according to the principles of circularity, in line with the Group's policies, guidelines, targets and sustainability strategy. The principles of circularity focus on using renewable and recycled materials as well as making packaging and non-food recyclable" (page 75).

Durability. "For Axfood's private label goods in all product groups, sustainability, which by nature is long term, is not significantly different from the industry average" (page 75).

The reported 0.0% is therefore a modelling assumption rather than a measurement, and the 95.0% packaging figure is estimated from private label data and extended across the assortment.

Waste

Reference: page 75.

"During the period, Axfood's total waste amounted to 56,853 tonnes (51,394), of which 99.9% (99.6) is recycled in some form. Up to 60% (58) of the waste consists of paper and corrugated cardboard. 35% (36) consists of what is called alternative raw materials and which mainly consist of combustible and organic food waste" (page 75).

(page 75)

Preparation for reuse is nil in both years for hazardous and non-hazardous waste.

"Axfood's operations contribute to various types of waste in its warehouses, stores and offices. Waste management is handled by the Group's two central waste suppliers and reporting is based on the number of emptyings... Reported information during the period is based on discharges carried out at 423 (484) collection points" (page 75).

Policies related to own workforce

Reference: pages 79-80.

"Axfood has several policies and guidelines that address material impacts, risks and opportunities related to employees. These include the Group-wide Code of Conduct, an HR and work environment policy, occupational health and safety guidelines, procedures for equal treatment and offensive treatment, guidelines for business ethics, guidelines and procedures for the whistleblower service, and a recruitment policy" (page 79).

Employee Code of Conduct. It "covers all employees as well as consultants, directors and other individuals representing the Group... Child labour, human trafficking and forced labour are not acceptable in any part of the operations." "The greatest risk for human rights violations arises in the global supply chain, not in Axfood's own workforce" (page 79).

HR and work environment policy. "Axfood's ambition is to reduce the number of accidents and the occurrence of ill health through targeted preventive measures. The policy emphasises the importance of early intervention and the identification and communication of physical and psychosocial work environment risks" (page 79).

Accessibility. For employees without intranet access, "their immediate supervisor is responsible for informing them of their rights and working conditions" (page 80).

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

Reference: page 80.

"Axfood's President and CEO has the overall responsibility for contact with the Group's employees, but has delegated the operational responsibility to the Group's Head of Human Resources. The HR manager at each subsidiary is responsible for the ongoing contact with employees at each company and for reporting to Group level" (page 80).

Employee survey. It is annual, anonymous and handled by an external party, covering an engagement index, eNPS, a leadership index, a team effectiveness index and an inclusion index. "A new index was introduced in 2025 to measure psychological well-being. It shows the extent to which employees feel they can express their opinions, take initiative and make mistakes without fear of negative consequences" (page 80). The inclusion index was "developed with the organisation Mitt Liv" (page 80).

Worker representation. "At the Group level, there is a work environment group made up of union representatives, the chief occupational safety officer, representatives from the subsidiaries and the central work environment function. Work environment initiatives at company level are conducted and monitored through work environment committees established at central, regional and local levels... At smaller workplaces without a local safety committee, work environment activities consist of safety inspections and employee meetings" (page 80).

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

Reference: page 80.

"Axfood's whistleblower service allows employees to report work-related irregularities concerning the operations. The service enables follow-up of Code of Conduct compliance and is an important tool for maintaining good corporate governance, protecting employee health and safety, and identifying and addressing shortcomings" (page 80).

How it works. "The whistleblower service covers all subsidiaries and consists of a Group-wide reporting channel as well as company-specific channels. The managing director of each subsidiary is responsible for reporting via the local channel. The whistleblower chooses the appropriate channel. An external party handles the technical solution that enables anonymous reporting. A law firm receives and classifies cases before conducting a legal review. Cases that qualify as whistleblower matters are handled in consultation with Axfood's internal whistleblower committee" (page 80). "Reporting can also be handled through external channels for the relevant authorities listed on the intranet" (page 80).

Stated limit on effectiveness testing. "Axfood does not specifically evaluate whether employees trust the whistleblower processes. Any dissatisfaction is expected to be revealed through regular contact such as employee surveys and well-being talks" (page 80).

Taking action on material impacts on own workforce

Reference: pages 80-81.

Health. "Mangers hold well-being talks with employees in the event of recurring sickness-related absences in order to take preventive measures. To ensure that managers have the required knowledge, training in systematic work environment initiatives, sickness-related absence, the rehabilitation process, and organisational and social work environments is mandatory" (page 80). "Analysis of this data enables absences at the regional and store level to be predicted and early action to be taken where it is needed most" (page 81).

Employee support. Employees have "access to phone calls to social workers and cost-free conversations with licensed psychologists or psychotherapists. Contact with a lawyer or economist can also be provided as necessary" (page 81).

Routes into the labour market. "Through Willys and Hemkop, Axfood collaborates with the non-profit initiative Nasta Generation Sverige to offer a work experience scheme... providing young people in vulnerable areas with their first job opportunity... Axfood has also joined Tent Sverige to support people with a refugee background in gaining labour market access through internships, jobs and targeted development initiatives" (page 81).

Job security. Work is under way "developing methods in stores to be able to offer more permanent positions that cover more working hours" (page 79).

Targets related to own workforce

Reference: page 81.

"Axfood has targets to manage material impacts, risks and opportunities in the area related to its own workforce. Sickness-related absence is to be low and the Group aims to have an even gender breakdown among its senior executives and a variety of employees from diverse backgrounds" (page 81).

(page 81)

"Sickness-related absence in 2025 decreased to 5.8% (6.2) compared with the previous period. The change is explained in part by continued investments in proactive health initiatives" (page 81). The target of below 5.3% was not met. "Data from Statistics Sweden is used to identify a reasonable comparable level when setting the current target. Sickness-related absence at the Group is not deemed to differ significantly from the national average in Sweden" (page 81).

Worker involvement in target setting. "Employees and unit managers does not directly contribute to formulating the targets, however the closest unit managers are involved in follow-up and participates in improvement measures concerning target outcome" (page 81).

Characteristics of the undertaking's employees

Reference: page 82.

All employees are in Sweden: "Axfood operates exclusively in Sweden" (page 82).

(page 82)

Gender breakdown by category (2025): management teams including the Executive Committee and Board 56.0% men / 44.0% women; employees with subordinates 47.2 / 52.8; retail employees 35.0 / 65.0; warehouse and e-commerce 75.3 / 24.7; salaried 50.6 / 49.4; hotel and restaurant 55.9 / 44.1; total 42.7 / 57.3 (page 82).

Age breakdown (2025): 48.8% under 30, 36.2% aged 30-50, 15.0% over 50. Among retail employees 56.8% are under 30 (page 82).

Turnover. Employee turnover was 16.2% (18.3) and hiring turnover 8.2% (13.0). Turnover among those under 30 was 27.1% (29.9) (page 83).

Method. "The information about number of employees is a snapshot as of 1 December 2025 to align with diversity measurements from Statistics Sweden. Employees without hourly contracts (secondary employment) are not included." Average number of employees is FTEs, "calculated as economic hours worked... divided by the annual working hours of 1,920" (page 82).

Collective bargaining coverage and social dialogue

Reference: page 82.

"All of Axfood's employees are covered by four national collective bargaining agreements" (page 82).

(page 82)

Axfood operates exclusively in Sweden (page 82), so there is no non-EEA coverage to report and the corresponding column is blank.

Definition applied. "The definition of employee representatives has been limited to safety officers at offices, warehouses and stores. The reason is that Axfood is responsible for appointing safety officers at its workplaces, meaning that the Group - rather than unionised employees - has control over them" (page 82). This is a narrower reading than trade union representation and is worth noting when comparing the social dialogue figure with other filers.

Union involvement is described elsewhere in the chapter: the Group-level work environment group is "made up of union representatives, the chief occupational safety officer, representatives from the subsidiaries and the central work environment function", and "there is an ongoing partnership between employers, employees and trade union representatives" (page 80).

Diversity metrics

Reference: page 82.

Gender at top management. Management teams of all companies including the Executive Committee and Board of Directors: 56.0% men and 44.0% women in 2025 (55.9 / 44.1). Employees with subordinates: 47.2% men and 52.8% women (48.0 / 52.0) (page 82).

Age distribution. Group total: 48.8% under 30 years old, 36.2% aged 30-50 and 15.0% over 50 (48.4 / 35.6 / 15.9). For management teams including the Executive Committee and Board: 0% under 30, 49.5% aged 30-50 and 50.5% over 50 (page 82).

International background (an entity-specific diversity metric):

(page 82)

"'International background' refers to employees who were either born outside Sweden or whose parents were both born outside Sweden. Senior executives are defined as employees with subordinates, including team managers with employee responsibility and members of the Executive Committee. The calculation is based on data from Statistics Sweden" (page 82). The share at the top of the house fell to 7.7% from 8.7%.

Adequate wages

Reference: page 82.

"All of Axfood's employees are covered by collective bargaining agreements, under which salaries are regulated in line with negotiated minimum wage levels" (page 82).

Axfood operates exclusively in Sweden (page 82). The disclosure rests on collectively bargained minimum wage levels rather than on a benchmark comparison against an external adequate wage reference such as a living wage estimate, and no share of employees paid below an adequate wage benchmark is given, consistent with all employees being covered.

The wider remuneration picture is reported alongside it: the unadjusted gender pay gap fell to 7.0% (7.9) and the total remuneration ratio between the highest paid individual and the median for all other employees was 28.0 (57.1) (page 83).

Adequate wages in the value chain are treated separately and are material there. Under S2 the Supplier Code of Conduct requires that "Suppliers must provide wages and benefits that allow for a decent standard of living for workers and their families" (page 85), and Axfood participates in "The Banana Retail Commitment on Living Wage... a collective initiative by retailers to ensure that workers in the banana supply chain receive a living wage" led by the Sustainable Trade Initiative (IDH) (page 86). Migrant workers in the supply chain are recorded as experiencing "low wages, long working hours and an unsafe working environment" (impact I28, page 85).

Health and safety metrics

Reference: page 82.

(page 82)

The absolute number of accidents rose to 1,517 from 1,408 while the rate per million hours worked fell to 57.0 from 58.9.

Definition applied. "Accidents refer to work-related injuries or ill health that lead to: fatalities, illness-related absence, restrictions or reassignment to other tasks, medical care beyond first aid, loss of consciousness or serious injury or ill health diagnosed by a doctor or other healthcare professional, even if the injury does not lead to [those outcomes]... minor injuries such as bruises or small cuts that require bandages are considered incidents rather than accidents" (page 82).

Scope exclusion. "Due to a lack of system support, employees at Urban Deli and Hall Miba are not currently included" (page 82).

Sickness-related absence, reported under S1-5, was 5.8% (6.2) against a target of below 5.3% (page 81).

Compensation metrics (pay gap and total compensation)

Reference: page 83.

(page 83)

Pay gap. "The unadjusted gender pay gap between men and women decreased to 7.0% (7.9) during the year. A contributing factor to differences in warehouse operations pertains to men working staggered working hours, extra hours, overtime, and night shifts to a larger degree than women, which results in more pay per worked hour. More men have professions in IT where salaries in general are higher than within support functions where more women are employed" (page 83).

"The data is based on salaries paid for the full year 2025 and includes own employees in all employment forms. Consultants and hired staff are not included. To ensure more reliable hourly wages, a threshold was set that each employee must have worked at least 40 hours during the year" (page 83).

Break in comparability. The halving of the ratio follows a method change: "the metric was revised so that it is based on actual full-time salaries paid instead of full-time salaries contracted" (page 83). Remuneration was also recategorised in 2025 "in line with the emerging practice according to ESRS S1 Section 73" (page 83).

Incidents, complaints and severe human rights impacts

Reference: page 83.

(page 83)

"During the year, 9 incidents (5) related to cases of discrimination, including harassment, were reported. The Group was also required to pay compensation for one incident amounting to SEK 15,000" (page 83).

Scope exclusion. "The data does not include non-employee workers in the Group's own workforce" (page 83).

No severe human rights incidents, complaints to National Contact Points for OECD Multinational Enterprises, or fines and penalties for severe human rights impacts in the own workforce are reported. Separately, "Nor have any material risks related to forced or child labour in its own workforce been identified" (page 79). Under G1, "no incidents have been confirmed as corruption, as validated by a law firm" and there were zero convictions (page 99).

Policies related to value chain workers

Reference: page 85.

"The interests of workers in the Group's supply chain were taken into consideration by Axfood when setting governing principles regarding social and working conditions. The Group has a specific procedure for addressing and remediating human rights violations. Operational grievance mechanisms in place in the value chain address ongoing matters related to working conditions and their effectiveness is reviewed within the framework of social audits" (page 85).

Supplier Code of Conduct. "The Code of Conduct stipulates prohibitation against human trafficking, child labour and forced labour. It guarantees the right to organise and bargain collectively and states that no worker exercising these rights may be discriminated against. The Code requires that written employment contracts be signed and that all workers know the basic conditions of their employment. Suppliers must provide wages and benefits that allow for a decent standard of living for workers and their families" (page 85). It "can be provided to suppliers in around 20 other languages" (page 85).

Framework. "These efforts are based on due diligence according to the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. Governance is based on codes of conduct and supplementary guidelines and procedures established by the Executive Committee and followed up annually" (page 85).

Processes for engaging with value chain workers about impacts

Reference: pages 85-86.

"Interactions with workers take place through industry initiatives and partner organisations, such as ETI Sweden. Where relevant, direct contact is also established with local players, including migrant worker organisations in Turkey, multi-stakeholder organisations in Spain and international organisations such as the International Organization for Migration (IOM). In complex cases, input is also obtained from NGOs and trade unions ahead of procurements and supplier visits" (page 86).

Groups identified. "Axfood has identified particularly vulnerable groups in the value chain, namely workers and hazelnut farmers working for suppliers in Turkey, migrant workers in Italy, Spain and Sweden, female seasonal workers at Moroccan fruit and vegetable farms, and rice farmers in Pakistan" (page 86).

Memberships. "Axfood is a member of Global Deal, Amfori BSCI and ETI Sweden." In 2025 it joined "ETI's Forest Berry Initiative aimed at ensuring better conditions for berry pickers in Sweden" (page 86). Responsibility rests with "the Head of Quality and Sustainability at Dagab" (page 85).

Stated limit. "The assessments are comprehensive, and while they do not always overlap directly with individual worker interactions, they are used together to govern the Group's priorities and actions" (page 86).

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

Reference: pages 86-87.

"Axfood is convinced that locally based grievance mechanisms, such as workers' committees or representatives, are often more effective than externally imposed systems. As such, suppliers are required to have effective local channels for reporting and dialogues. Amfori BSCI uses Speak for Change, an anonymous channel for reporting human rights violations. The programme has been introduced in various countries, including Vietnam, Turkey and India" (page 86).

Axfood's own channel and its stated limits. "Axfood has a whistleblower service available through its supplier portal. The service is primarily aimed at suppliers and partners and can provide support when other channels are not available; it is not aimed directly at migrant or seasonal workers and is not intended to replace local grievance mechanisms. The whistleblower is protected against retaliation" (page 86).

Remediation. "Serious deviations are to be addressed promptly and adequately. A checklist guides the process based on the principle of prioritising the human rights holders. Victims should first feel a sense of relief and security, followed by remediation. The measures taken are documented and followed up" (page 86).

Taking action on material impacts on value chain workers

Reference: page 87.

Risk countries and categories. "Axfood's suppliers and sub-suppliers of private label products operate in approximately 40 such countries, where social audits are required. Categories currently assessed as being at a high risk of child labour are rice, cocoa, cane sugar, hazelnuts, coffee and tea. Categories currently assessed as being at a high risk of forced labour are cocoa, seeds, wild berries, fresh fruit and vegetables, cotton, fish and coffee" (page 87). "In Sweden, Axfood requires all Swedish fruit and vegetable suppliers to be certified according to Svenskt Sigill's IP Arbetsvillkor or an equivalent standard" (page 87).

A named remediation outcome. "In 2024, deficiencies related to forced labour were identified at a Thai producer whose costs for migrant workers had not been paid. Thanks in part to pressure from Axfood, all of the affected workers were reimbursed in 2024-2025 and the producer has introduced new policies stating that all costs for migrant workers are to be covered" (page 87).

Standards accepted. "The Group accepts approximately 20 third-party standards. While audits are mainly carried out in accordance with Amfori BSCI, Sedex (SMETA) and SA8000 are also accepted" (page 87). In 2025 several Garant teas received Fairtrade certification and Gastrino rice was awarded the SRP-Verified label (page 87).

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

Reference: page 87.

"Axfood currently has no quantified targets in this sustainability area but follows up material impacts, risks and opportunities through sustainability assessments and social audits, action and improvement plans, projects and its sales... Audits therefore serve as a tool and metric for monitoring the effectiveness of Axfood's actions with respect to supplier compliance with the Code of Conduct" (page 87).

Effectiveness tracked through audits.

(page 87)

Fairtrade-labelled food was 6.3% of sales (6.6), used as a proxy metric (page 87). Comparatives are marked N/A because the grading system was widened in 2025 (page 87).

Policies related to affected communities

Reference: page 89.

"Axfood's work with affected communities is governed primarily by the Group's Supplier Code of Conduct and Code of Conduct for Human Rights. Together, these documents provide a basis for the Group's work pertaining to due diligence in the value chain. The policies cover all suppliers and business partners and set clear requirements for respecting human rights, good working conditions, environmental considerations and ethical business conduct" (page 89).

Supplier Code of Conduct. "Axfood's Supplier Code of Conduct describes the Group's commitment to identifying, preventing and addressing risks of violations. The policy is based on the UN Guiding Principles on Business and Human Rights. Axfood's Supplier Code of Conduct requires an assessment of the impact on local communities and populations in order to take action where necessary and avoid negative impacts. Axfood's negotiations in conflicts with local communities over land or natural resources are to ensure respect for individual and collective rights. This is to be based on local customs and traditions, even if these rights are not formally registered" (page 89).

Stated gap. "Axfood does not have its own policy to ensure protection from retaliation for stakeholders in the local community who file grievances", though provisions exist in the Supplier Code of Conduct and internal procedures (page 90).

Processes for engaging with affected communities about impacts

Reference: pages 89-90.

"Axfood does not currently have any fixed procedures for direct contacts with affected communities upstream in the value chain. Dialogue mainly takes place through memberships, contacts with suppliers and projects the Group participates in through industry organisations and networks" (page 89).

"Discussions with local players, civil society and trade unions provide insights into how people and communities are impacted by primary production and commerce. The results of these dialogues are used as the basis for sustainability assessments and risk analyses. In some projects, contact takes place indirectly through industry initiatives... This enables local perspectives to be integrated into Axfood's risk assessments, even when the Group has no direct relationships" (pages 89-90).

"Dagab's sustainability and quality function is responsible for contacts and dialogues in collaboration with the Group's central sustainability function, which follows up and reports to the Executive Committee" (page 90).

An acknowledged blind spot. "Axfood is not always given a full overview of the situation in the affected communities since information is often passed on through suppliers, who may themselves have limited contact with the local population" (page 89).

Processes to remediate negative impacts and channels for affected communities to raise concerns

Reference: page 90.

"Locally based grievance mechanisms, such as workers' committees or representatives, are often more effective than externally imposed international tools. Axfood therefore encourages suppliers to establish and maintain grievance handling systems that are based locally. In countries such as Vietnam, Turkey and India, where Amfori BSCI has implemented its Speak for Change tool, workers and other local players can report irregularities anonymously. This allows deficiencies and risks to be identified early, reducing risk of serious violations" (page 90).

Stated access gap. "It can be difficult for local stakeholders who are not workers to access these systems. The Group therefore participates in industry projects aimed at improving accessibility and efficiency, including the Improved Grievance Mechanism Project in Italy and Spain in cooperation with ETI Sweden" (page 90).

People in vulnerable situations. "Migrant workers and other groups at particular risk of vulnerability may find it difficult to raise grievances or demand remediation. Axfood therefore contributes to the development of Svenskt Sigill's IP Arbetsvillkor standard... The standard provides information in several languages about workers' rights and where workers can turn to with any grievances" (page 90).

Taking action on material impacts on affected communities

Reference: page 90.

"Improving working conditions and sustainability, especially in risk countries and industries with seasonal workers, is prioritised. Compliance with Axfood's Supplier Code of Conduct is ensured through sustainability assessments, social audits and follow-up visits. In 2025, visits were carried out to preserved canned tomato suppliers in Italy and to banana plantations in Colombia and Costa Rica" (page 90).

Improvement projects. "In 2025, Axfood conducted two projects in global value chains: one focusing on the working conditions for seasonal workers on hazelnut farms in Turkey and one related to the cashew nut industry in Vietnam. Axfood was also a driving force in ETI Sweden's Forest Berry Initiative aimed at implementing the Employer Pay Principle for berry pickers... At the end of 2025, an ETI project involving multiple stakeholders was resumed with the aim of improving the conditions for workers at fruit and vegetable farms in Morocco" (page 90).

Advocacy. "Axfood's engagement on behalf of Burmese migrant workers in Thailand has inspired the Group's suppliers to introduce their own initiatives for the children of migrant workers... In 2025, Axfood advocated for the introduction of rules under IP Arbetsvillkor and KRAV to ensure that migrant workers are not in debt when they are working in Sweden" (page 89).

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

Reference: page 90.

"Axfood currently has no quantitative, measurable targets in this area due to challenges with measuring and receiving reliable data in this part of the value chain. More information about these challenges is presented under ESRS 2 on page 42" (page 90).

How effectiveness is tracked instead. "To guide its purchasing, Axfood has a process whereby only approved suppliers and sub-suppliers are permitted to move forward in the procurement process. Over time, this means that suppliers with clear due diligence concerning their own risks and who respect human rights are favoured. Development work is ongoing to improve performance measures and governance" (page 90).

The disclosure is therefore an MDR-T "no target" return with a description of the effectiveness tracking used in place of one. In practice the S2 social audit metrics carry over, since the same audits and sustainability assessments cover the communities identified as most at risk: seasonal and migrant workers in Thailand's berry, nut and fruit and vegetable industry, migrant workers in Burma and Cambodia, populations near hazelnut farms in Turkey, communities affected by the Vietnamese cashew industry, and migrant workers in Italy and Spain (page 89).

Policies related to consumers and end-users

Reference: page 92.

"Axfood works thoroughly and systematically to offer healthy and food-safe products and protects customer privacy. This work is governed by various policies and guidelines that clarify responsibilities and requirements" (page 92).

Guidelines for products. "Axfood's guidelines for products are integrated into the procurement process and include commitments aimed at making healthy and safe food available to consumers... When developing these guidelines, Axfood took consumer health into consideration by setting requirements during the procurement process. The requirements include reducing the amount of salt, sugar and unnecessary additives. When new products are launched or checks are carried out of the existing assortment of private label products, an assessment is made of the product's quality, sugar and salt levels, and other contents" (page 92).

Personal data. "Axfood's policy and guidelines for processing personal data aim to ensure responsible processing of customer data and protection of consumer privacy. Processing of personal data is subject to technical and organisational protective measures, with systems and processes designed to comply with data protection principles. Customers are entitled to access stored personal data. When new customers join the store chains' loyalty programmes, information is provided to them digitally" (pages 92-93).

Processes for engaging with consumers and end-users about impacts

Reference: page 93.

"The most common interaction with customers takes place in stores when they buy food. Axfood also works systematically to collect and analyse customer feedback through surveys and returns" (page 93).

Customer surveys. "To gain a better understanding of customer experiences and behaviours, surveys are regularly conducted of members of the loyalty programmes at its store chains. The surveys are often conducted by external parties and the results are analysed carefully. They provide insight into various areas, including product availability, timing of foot traffic and perceptions of in-store reception" (page 93).

Returns and the consumer contact department. "Contact details for the Group's consumer contact department are provided on all private label products. The consumer contact department consists of case managers who address matters from consumers and end-users. The department is run by the Head of Communication and Quality at Dagab. Returns and viewpoints from consumers are processed in a special system, where cases are registered and followed up. The system is used to monitor trends, which is part of the preventive work to avoid selling products that are hazardous to health" (page 93).

Consumer views feed the materiality assessment through internal representatives: "Representatives from the store chains have a good understanding of consumer interests" (page 45).

Processes to remediate negative impacts and channels for consumers and end-users to raise concerns

Reference: page 93.

"Axfood has no specific process for compensating consumers for negative sustainability-related impacts. However, there are established procedures for handling complaints, returns and questions from consumers and end-users" (page 93).

"When complaints, returns or questions arise, consumers are initially referred to the respective chain's customer service function. Returns of branded products are handled by the respective supplier, while cases concerning private label products are handled by Axfood's consumer contact department. Internal procedures, including the Group's service policy, determine whether compensation is to be paid in the event of a return" (page 93).

Product alerts and recalls. "Serious recalls are communicated to the public via press releases... Quality assurance staff assess the severity of the alerts by sorting them according to different categories. The highest category entails a negative impact on consumer health and may include cases of salmonella, high levels of aflatoxin, indications of sabotage, allergy risks due to mislabelling or similar. Recalls are only carried out when harm can be confirmed." "Each product category has its own procedures for determining which authority is to be alerted" (page 93). A total of 112 (121) public recalls were made in 2025 (page 94).

Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions

Reference: pages 93-94.

Healthy offerings. "Product development and affordable options inspire consumers to choose fruits, vegetables, plant-based foods and products with less added sugar and salt. This work is carried out on an ongoing basis and followed up annually, including through measuring the share of sales of Keyhole-labelled foods" (page 93).

Generation Pep. Working with the foundation since 2023, "The cooperation agreement was extended until 2028." Joint output includes "hybrid products such as 'Not & Gront' mince and 'Not & Gront' sausages... equal amounts of minced beef and vegetables, with a lower carbon footprint and price than traditional minced beef", snack shelves in most Hemkop stores and a Willys fruit and vegetable campaign (page 93).

Food fraud. "To counteract food and product fraud among private label products, vulnerability assessments are conducted... cover all categories of food, non-food and consumables" (page 94).

Personal data. "Axfood uses AI in several areas... The technology has significant potential but clear limits are needed in terms of how data is used" (page 94).

Outcome. "No serious human rights issues or incidents related to consumers and end-users were identified in 2025" (page 94).

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

Reference: page 94.

"Axfood has targets to manage material impacts, risks and opportunities in the area related to consumers and end-users" (page 94).

(page 94)

"Axfood's target is that at least 25% of food sales are to comprise Keyhole-labelled products by no later than 2030 compared with the base year 2024. Follow-up is carried out at the Group level. The metric is in line with national goals for sustainable and healthy food consumption and is connected to the UN SDGs, in particular SDG 3 and SDG 12. In 2025, the share of sales of Keyhole-labelled food amounted to 20.1% (21.7). The result is a primarily due to that the share of sales of fruit and vegetables decreased in relation to total sales" (page 94). The outcome moved away from the target in its first year and now sits below the base year.

This is a new target: "In 2025, the Executive Committee decided that the share of food sales labelled with the Keyhole shall amount to at least 25% by 2030 the latest with a base year 2024" (page 94), listed as a new target in the changes table on page 42.

"The Group's stakeholders did not contribute to formulating the target and do not control follow-up of the target" (page 94).

Business conduct policies and corporate culture

Reference: pages 97-98.

"Axfood has several governance documents covering issues related to ethics, corruption and bribery. These include the Group-wide Code of Conduct, the Supplier Code of Conduct, the risk and regulatory compliance policy, business ethics guidelines, ethical conduct rules for employees and the governance document for equal treatment... They are prepared in accordance with Swedish legislation on corruption and meet the requirements in the EU's implementation of the United Nations Convention against Corruption (UNCAC) and the Code to Prevent Corruption in Business developed by the Swedish Anti-Corruption Institute (Swe: Institutet Mot Mutor, IMM)" (page 97).

Culture. "Axfood's ethical culture is a central part of its identity as a purpose-driven Group. It is based on openness, trust and responsibility and permeates everything from leadership and procurement to customer meetings and social dialogues" (page 97).

Whistleblowing. "The service is managed by an external party and reported cases are reviewed by an internal whistleblower committee who reports to the Board. The procedures follow Swedish law and guarantee that anyone who reports a case is protected against retaliation" (page 97).

Animal welfare. Industry-wide antibiotics guidelines state "that antibiotics are not to be used to stimulate growth" and that use is "only permitted with a prescription from a veterinarian" (page 97).

Management of relationships with suppliers

Reference: pages 97-98.

"As a rule, all suppliers and other partners who sign agreements with Axfood, regardless of whether it concerns private label products, external brands, or indirect procurement, are to sign the Code of Conduct" (page 97).

Supplier base. "The supplier base for private label products includes 537 suppliers and 1,842 sub-suppliers, of which 645 have production in risk countries according to Amfori BSCI. Ukraine has been excluded as a risk country since 2022 to avoid burdening suppliers during the ongoing war" (page 97). Equivalent controls apply to compound products "where at least 5% of food content includes a risk commodity" (page 97).

Control and follow-up. "Supplier agreements for food and non-food items are negotiated centrally within Axfood, creating a coordinated purchasing system and providing opportunities for greater control throughout the entire value chain... If deficiencies are not addressed within the agreed time, the partnership may be terminated" (page 98).

Payment practice policy. "The timing of invoice payments can have a major impact on the finances of smaller suppliers, which in turn can have a negative impact on conditions for their employees. Axfood's guidelines for business ethics emphasise the importance of authorising transactions and making payments within the agreed-upon timeframe" (page 98). The material IRO is I40 on sub-supplier standards (page 96).

Prevention and detection of corruption and bribery

Reference: page 98.

"All suppliers are to sign the Supplier Code of Conduct, which includes requirements for business ethics. All employees with authorisation rights agree to follow the Group's ethical conduct rules when they are hired and then every year thereafter" (page 98).

Where the risk sits. "The greatest risk for corruption among Axfood's own employees arises when large amounts of money are involved. This refers to functions that handle large contracts, supplier selection, category purchasing and private label products, which often have a relatively high degree of discretion and scope to act. These functions may therefore be exposed to pressure, gifts, favourable treatment or 'friendly agreements'" (page 98).

Training. "Special anti-corruption training was developed in 2025 for Axfood's employees in relevant roles, including salaried employees with authorisation rights and the Executive Committee" (page 98). No completion rate is given.

Investigation independence. "An independent external function receives, classifies and assesses all cases on a legal basis before they are forwarded to Axfood's internal whistleblower committee. The committee, in turn, reports to the Board" (page 98). The Board receives an annual report from the General Counsel on preventive anti-corruption work (page 43).

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

Reference: pages 98-99. This DR is a standalone requirement only from the 2025/2026 ESRS; the FY2025 statement was prepared under the 2023 ESRS (Commission Delegated Regulation (EU) 2023/2772, page 150), so business conduct targets sit under MDR-T in the G1 chapter.

"Axfood has targets for managing its material impacts, risks and opportunities through business conduct. These targets aim to increase the total share of sales of sustainability-labelled products and to increase the share of sales of sustainability-labelled meat. They are also based on expectations from consumers and society at large that Axfood is to contribute to sustainable development" (page 98).

(pages 98-99)

Basis. "Targets were set on a voluntary basis as a part of the Group's overall business strategy and are not a statutory requirement... The Group's stakeholders did not contribute to formulating the target" (page 98). No target is set for corruption incidents, training completion or payment practices; effectiveness there is tracked through audits, controls and the whistleblower function (page 98).

Incidents of corruption or bribery

Reference: page 99.

(page 99)

"In 2025, Axfood had incidents reported through central and local channels of the whistleblower function. To date, no incidents have been confirmed as corruption, as validated by a law firm. As a result, there were no convictions for violations of applicable anti-corruption and anti-bribery laws" (page 99).

The reporting route is described alongside: an external provider operates the service, "An independent external function receives, classifies and assesses all cases on a legal basis before they are forwarded to Axfood's internal whistleblower committee. The committee, in turn, reports to the Board. Cases that qualify as whistleblower matters are handled in consultation with the committee. If a case does not qualify as a whistleblower matter, it is sent to the central HR function or to the relevant function at the business concerned" (page 98). A separate report on whistleblower cases received is presented to the Board once a year (page 43). Nine discrimination incidents are reported under S1-17 (page 83).

Political influence and lobbying activities

Reference: page 98.

"Its policy advocacy efforts are non-partisan, without financial or other party contributions, and are carried out with the oversight of a policy council comprised of representatives from Axfood's Executive Committee and relevant roles. The council establishes priorities and ensures that Group's policy advocacy follows relevant regulations pertaining to, for example, political visits and meetings" (page 98).

Revolving door and register. "None of Axfood's directors has held a position at an authority, including supervisory authorities, in the last two years. Axfood is not listed in the EU Transparency Register and input to EU institutions is primarily provided indirectly through industry organisations" (page 98).

Main topics in 2025. "The issues that Axfood highlighted in 2025 included sustainable consumption and improved conditions for store establishments... responses were submitted in comment rounds concerning several prioritised issues, such as reducing or eliminating VAT on sustainability-labelled products... Axfood also promoted lowering the employer payroll tax for young people... Another prioritised area was keeping the grazing requirement and compensating dairy farmers accordingly" (page 98).

The Food 2030 report "includes over a hundred solutions for authorities, policy-makers and business" (page 98). Political engagement is recorded as impact I39 and risk R23 (page 96).

Payment practices

Reference: page 99.

(page 99)

"Axfood has grouped suppliers into four different categories based on the number of employees. This makes it possible to identify any differences in payment times according to the size of the supplier. All of the Group's suppliers in Sweden as well as globally are included in the data. Information about the number of employees for Swedish suppliers was taken from the Swedish Companies Registration Office. The assumption for international suppliers is that they are all large companies with more than 250 employees" (page 99).

The data shows the smallest suppliers are paid on time least often (58%) and wait longest by contract (30 days), the opposite of the pattern the Group's own guidelines aim for. No comparative figures for 2024 are given.