BE Semiconductor Industries

Governance roles

Reference: pages 74-76 (Annex 1 index, page 131).

Besi has a two-tier board. The Board of Management "consists of one male person who is Besi's Chief Executive Officer and Chairman of the Board of Management" and is responsible for defining and achieving the sustainability strategy (page 74). Diversity datapoints confirm it is 100% male (page 114).

The Supervisory Board has five members, all non-executive (100%) and independent (100%) under best practice provision 2.1.8 of the Dutch Corporate Governance Code, with a 60%/40% male/female ratio, 100% over 50 years old and none employed by Besi (page 75). Its committees are the Audit Committee (oversight of sustainability reporting) and the Remuneration Committee (review of sustainability-related remuneration) (page 76).

Day-to-day responsibility sits with the Management Team, SVPs and facility management (page 75). The Management Team has nine members, one female and eight male (11%/89%) (page 114). A Sustainability Team supports all three bodies (page 76). The governance chart runs Supervisory Board to Board of Management to CTO office, SVPs Product Groups, SVP Operations, VP Strategic Supply Management, VP Strategic Sourcing and SVP Finance (page 76).

Information provided to the boards

Reference: pages 74-76, 80-81, 104-105, 117, 123 (Annex 1 index, page 131).

Sustainability developments "are discussed regularly with the Supervisory Board where the Board of Management presents progress against goals and targets for sustainability-related issues which since 2020 has included regular quarterly reporting on sustainability topics" (page 74).

The Supervisory Board receives quarterly updates on governance of sustainability, execution of the strategy and achievement of targets, and "annually evaluates its own functioning through the conduct of a self-assessment which also includes sustainability topics" (page 75).

Reporting cadence below board level is set out explicitly: Management Team members "report to the Board of Management with regards to the facility and/or product-level sustainability performance on a quarterly basis as well as any new impact, risk or opportunity trends on a monthly basis" (page 76). All material findings from the internal control and risk management system are "discussed with the Board of Management on a monthly basis and with the Audit Committee as part of the Supervisory Board's review on a quarterly or semi-annual basis" (page 79).

The 2025 DMA review outcome "was approved by the Board of Management and the Supervisory Board in 2025" (page 68).

Sustainability in incentive schemes

Reference: page 77 (Annex 1 index, page 131; also cited under E1 at page 80).

Short-term incentive composition is 70% financial measures and 30% non-financial measures (page 77). The Remuneration Committee reviews performance against "ten equally weighted and pre-defined personal, non-financial and sustainability performance objectives representing 30% of the potential total STI bonus. Three of the objectives, representing 9% of the total STI bonus, are directly linked to the sustainability performance objectives" (page 77).

The objectives listed are: enhance the sustainability strategy; continue to report in alignment with the CSRD in 2025; implement the Climate Transition Plan to meet the Net Zero GHG commitment; achieve progress on people and wellbeing (inclusion and diversity, health and safety, employee development, engagement); and further enhance Besi as a responsible business including ethics, compliance and responsible supply chain (page 77). Note that five bullets are printed under a heading that describes three objectives.

"The above performance includes an aggregate assessment against Besi's sustainability targets but does not include performance against individual sustainability targets" (page 77). There is "no incentive scheme for the Supervisory Board with respect to sustainability-related issues" (page 77).

Statement on due diligence

Reference: pages 77-78 (Annex 1 index, page 131).

Besi maps the five core elements of due diligence to specific paragraphs of the statement in a table on page 78:

• (a) Embedding due diligence in governance, strategy and business model - ESRS 2 GOV-2, GOV-3 and SBM-3, pointing to the governance of sustainability and DMA sections.
• (b) Engaging with affected stakeholders in all key steps - ESRS 2 GOV-2, SBM-2, IRO-1, MDR-P and the topical standards, pointing to stakeholder engagement, risk management and the policy sections for climate, own workforce, value chain workers and business conduct.
• (c) Identifying and assessing adverse impacts - ESRS 2 IRO-1 and SBM-3, pointing to the DMA description and Annex 1.
• (d) Taking actions to address those adverse impacts - ESRS 2 MDR-A and the topical standards, pointing to the Climate Transition Plan, climate actions, own workforce actions, value chain actions and corruption prevention.
• (e) Tracking effectiveness and communicating - ESRS 2 MDR-M and MDR-T, pointing to the metrics and targets sections across all topics.

The narrative states that "Besi performs due diligence across its sites and its supply chain regarding various sustainability topics. The outcomes of our due diligence process inform us of our material impacts, risks and opportunities" (page 77).

Risk management and internal controls over sustainability reporting

Reference: page 79 (Annex 1 index, page 131).

The internal control and risk management function "operates under the responsibility of the Board of Management and is monitored on an ongoing basis", with Supervisory Board oversight and regular contact with the people fulfilling the function (page 79).

Besi's "sustainability reporting framework has been created to ensure that sustainability-related data is collected from our operations on a quarterly basis", with the Sustainability Team managing "data collection, validation, aggregation and reporting to the Board of Management and Management Team" (page 79). The report notes that controls vary by metric because multiple business units contribute, giving the example that "the definition of adequate wages may differ from country to country" (page 79).

Three controls are named as implemented to date (page 79):

• Gap assessment to identify policy, procedure and data gaps against regulatory reporting requirements.
• Annual review of the sustainability reporting framework.
• Quarterly sustainability data collection, review, aggregation and reporting.

Six routes are listed for identifying sustainability-related risks, including the climate risk assessment, the DMA and the Whistleblower and Grievance procedures (page 79). Besi notes separately that its systems "offer limited assurance that the" objectives will be achieved (page 166).

Strategy, business model and value chain

Reference: pages 58-61 (Annex 1 index, page 131).

Besi is "engaged in one line of business: the development, manufacturing, marketing, sales and service of semiconductor assembly equipment", across die attach, packaging, plating and services (page 58). Service and spares "together represented 15% of total revenue in 2025". Revenue was EUR 591.3 million, down from EUR 749.3 million in 2021 (page 94).

Headquarters are in Duiven, the Netherlands, with eight development and production facilities in Asia and Europe and 13 sales and service offices. Headcount at 31 December 2025 was 1,928 - 1,308 in Asia, 620 in Europe and North America (page 58).

The value chain has three blocks (page 57): upstream suppliers split into fabrication part, module outsource, vendor part and service suppliers; own operations covering R&D and product design, assembly, upgrades and post-sales support; and customers, primarily IDMs and foundries or subcontractors serving computing, mobile, automotive and industrial end markets.

Under the EU Taxonomy, "87% of turnover was eligible under Circular Economy ("CE") objectives, 85% of Capital Expenditures ("CapEx")... and 36% of Operating Expenses ("OpEx")" (page 58).

Phase-in used: SBM-1 paragraphs 40(b) and 40(c), the breakdown of revenue by significant ESRS sector, are omitted (pages 58, 131).

Interests and views of stakeholders

Reference: pages 65-67 (Annex 1 index, page 131; re-cited under S1 and S2).

Stakeholder mapping in 2023 produced "a list of 22 stakeholder groups", from which Besi "prioritized our employees, customers, suppliers, workers in the value chain, investors and nature" (page 69). Nature "is considered a silent stakeholder whose interests are taken into account when assessing our impact on the environment" (page 65).

A 2024 engagement roadshow validated the DMA through "moderated interviews with key stakeholders such as investors, customers, suppliers and employees (including representatives of Works Councils and Work Unions)" (page 65). Reported conclusions (pages 65-67):

• "There were no significant issues highlighted nor significant impacts, risks and opportunities not already considered material by the DMA."
• "There was consensus that Besi was not exposed to significant material risks involving severe negative financial effects", with increased regulatory exposure on environment and human rights.
• Stakeholders said Besi "could benefit from setting more ambitious long-term targets".

Outcomes "were presented to the Supervisory Board" and the material topic list approved; "Beyond approval of the DMA, no changes were made to our strategy and/or business model" (page 65). The 2025 employee survey had 91% participation and 88% engagement (page 67).

Material impacts, risks and opportunities

Reference: pages 70-73 (Annex 1 index, page 131; re-cited under E1, S1 and S2).

The material IRO table (pages 70-72) covers four standards only: ESRS E1 Climate change, ESRS S1 Own workforce, ESRS S2 Workers in the value chain and ESRS G1 Business conduct. Each row pairs a value chain position, a financial risk or opportunity, an impact description, an impact-type icon, a time horizon and the ESRS sub-topics covered.

Current financial effects are qualitative (page 72): social opportunities have "a positive impact on our revenue development"; environmental risks and opportunities "require capital investments in climate change mitigation activities"; OpEx rises from working environment, career development and supplier engagement. Besi then states: "it is not possible to separate costs and revenues to the granularity required to accurately quantify the financial effects".

Anticipated effects are equally qualitative, and "financial resources related to Besi's impacts, risks and opportunities are not considered significant" (page 72). Besi confirms no sustainability risks carry "a significant risk of material adjustment to the carrying amounts of assets and liabilities" next period (page 73).

Phase-in used: SBM-3 paragraph 48(e), anticipated financial effects, is omitted (pages 58, 131).

Process to identify and assess material IROs

Reference: pages 68-70 (Annex 1 index, page 132; re-cited under E1 and G1).

The DMA was conducted in 2023, validated with stakeholders in 2024 and reviewed in 2025. The 2025 review "included a peer analysis and interviews with the Management Team including the SVPs of the Product Groups... and the SVP Global Operations" and "concluded that the list of material topics identified in 2024 continues to address the material impacts, risks and opportunities that Besi is exposed to and that there have been no developments over the past year to suggest otherwise" (page 68). An external third party supported the original DMA.

The process has eight steps, ending in Board of Management approval, stakeholder validation and Supervisory Board approval (pages 68-70).

Thresholds are quantified (page 70). Impact materiality used 0-5 scales for scale, scope, likelihood and, for negative impacts, irremediability. Financial materiality rated magnitude 0-5 "using data of the 2022 financial year", with probability scored 0 to 1, and the threshold set at "a positive or negative impact on revenue greater than € 3.6 million and/or the impact on the cost of natural, human and financial resources being greater than € 2.1 million".

Time horizons are short-term under one year, medium-term one to five years, long-term over five years (page 68).

Disclosure requirements covered

Reference: pages 131-135, the "Annex 1 - Disclosure requirements in ESRS covered by Besi's Sustainability Statement" table.

Annex 1 is a genuine ESRS content index: each row gives the DR code, its description, the named section of the statement, page numbers, the Appendix B EU legislation cross-reference (SFDR, P3, BRR, EUCL) and a comments column carrying phase-in notes.

Covered: all ESRS 2 requirements (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2, MDR-P, MDR-A, MDR-M, MDR-T); ESRS E1 (E1-1 to E1-6, plus E1-9 flagged phase-in); ESRS S1 (S1-1 to S1-7, S1-9, S1-10, S1-12 to S1-14, S1-16, S1-17, plus S1-11 and S1-15 flagged phase-in); ESRS S2 (S2-1 to S2-5); and ESRS G1 (G1-1, G1-3, G1-4).

Absent from the index: E1-7, E1-8, S1-8, G1-2, G1-5, G1-6, and the whole of E2, E3, E4, E5, S3 and S4. E2 to E5 are explained by the DMA outcome on page 69; the others carry no explanation, which is permitted since IRO-2 asks only for what is covered.

Materiality of each row "was based on the Double Materiality Assessment conducted by Besi which included the use of impact and financial materiality thresholds" (page 131).

Transition plan for climate change mitigation

Reference: pages 81-86 (Annex 1 index, page 132).

The plan was "reviewed and updated" in 2025 and "approved by our Board of Management and the Supervisory Board" (page 80). Targets are net zero Scope 1 and 2 by 2030 and net zero across all scopes by 2050, with a 2026 interim target of a 75% cut against a 2021 baseline (pages 80-81).

Scope 1 and 2 levers are quantified against the 2021 baseline (pages 81-82): renewable energy purchase and production carries 97% of the potential reduction, energy efficiency and renewable heating/cooling 2%, electric vehicles 1%. Scope 3 levers are downstream renewable energy adoption by customers, supply chain renewable adoption, low-carbon procurement, low-carbon transportation and other measures (pages 83-87).

Locked-in emissions are addressed twice. In own operations, natural gas boilers in the Netherlands, Switzerland and China plus ICE vehicles are named, and "Besi's locked-in emissions in its own operations are not significant" (page 83). For products, "We do not expect significant locked-in GHG emissions from the use of our products on a long-term basis" (page 85).

Funding is not quantified: "we have not disclosed the specific monetary amount of current and future financial resources attributed to the implementation of Besi's Climate Transition Plan" (page 92). Besi is "not excluded from the EU Paris-aligned Benchmarks" (page 81).

Identification of climate-related risks and scenario analysis

Back-filled from the E1 "Climate-related risks and opportunities" subsection, disclosed in the FY2025 report at pages 86-90. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

When: "the climate scenario analysis which was performed in 2022" (page 86). It was not re-run in 2025; Besi plans "to further evaluate such risks... in a more comprehensive manner in future years" (page 90).

Scenarios (page 87): three IPCC RCPs with named temperature projections - Business-as-usual / RCP8.5, "expected to rise by 4.3 C (3.2 - 5.4 C) by the end of the 21st century"; Delayed transition / RCP6.0, 2.9 C (2.0 - 3.8 C); Net Zero / RCP2.6, 1.6 C (0.9 - 2.4 C). A high-emission scenario is present, but no 1.5 C-aligned scenario with no or limited overshoot is named - the most ambitious pathway is framed as "keeping global temperature growth below 2 C by 2100".

Methodology and scope (page 88): physical risk assessed for 12 countries, "including those where Besi and key suppliers have operations", using the Climate Impact Explorer across five indicators. Transition risk was assessed qualitatively against the four TCFD categories, each with a time horizon (page 89). Physical and transition risks are explicitly separated.

Results: the most critical gross physical risks sit at Leshan (China) and Malaysia (page 88).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 (page 73) and the E1 resilience subsection (pages 89-90). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Besi ran a resilience assessment as the third component of its 2022 scenario analysis, "by means of interviews with the Board of Management and Management Team", considering governance, the Sustainability policy and Climate Transition Plan, internal control, risk mitigation and the reporting framework (page 89).

Conclusion (page 90): "The assessment considered Besi's strategy and business model to be resilient against climate-related risks across all three climate scenarios. No material climate-related assumptions have been made in the Financial Statements."

Named weaknesses (page 89): Besi "could make further progress with respect to its climate-related goals by pursuing SBTi-certified targets, improving its energy and carbon emissions data tracking efforts and further integrating the Climate Transition Plan into our overall business strategy".

Adaptive capacity is evidenced at exposed sites: flood resilience measures in Malaysia, safeguarding Besi Leshan's electricity supply against heatwave blackouts, and flood defences at Besi Austria in 2024 (page 88). Uncertainty is acknowledged only through the promise of a fuller future evaluation (page 90).

Policies related to climate change mitigation and adaptation

Reference: pages 64, 81-86, 90 (Annex 1 index, page 133, listed as "IRO: E1-2").

Two instruments carry the climate policy. The Sustainability policy "outlines our climate ambitions and key strategic objectives", while the Climate Transition Plan "provides a more detailed GHG emissions action plan and the key levers to be used to achieve decarbonization in Besi's operations as well as its upstream and downstream value chains" (page 90).

The policy register (page 64) records the plan's scope as "Applies across Besi's operations and the Company's upstream and downstream value chain", and its availability as the Besi intranet - it is not published externally, unlike the Sustainability policy. Each policy "is reviewed and updated (if relevant) annually in the fourth quarter", and "The Supervisory Board approves each new policy" (page 62).

Two topics are covered (page 90). Climate change mitigation: net zero across operations and value chain, Scope 1 and 2 by 2030. Energy efficiency and renewable energy deployment, on five principles - increase efficiency, produce or use renewable energy where available, use market instruments for unavoidable emissions, apply sustainable design to products, engage suppliers.

Besi "aligns its Sustainability policy with the Paris Agreement". No separate adaptation policy is presented; adaptation runs through the scenario-analysis mitigation actions.

Actions and resources in relation to climate change policies

Reference: pages 91-92 (Annex 1 index, page 133, listed as "IRO: E1-3").

The action table (page 91) records one action plan, the Climate Transition Plan, with a time horizon of 2021-2050 and a year of completion of 2050, covering ten named actions. Resources are the Corporate Sustainability Team, Internal Audit and Control, operations teams and external consultants; financial resources are given only as "CapEx and OpEx allocated to Besi's Climate Transition Plan".

2025 progress in the table: supplier sustainability scorecard launched; sustainability performance ratings covering 65% of purchase volume; 97% reduction in Scope 1 and 2 emissions; heating efficiency projects at Besi Netherlands and Meco and renewable heating in Austria; EVs replacing ICE vehicles at Besi Leshan; "an action plan to reduce energy consumption in die attach platforms by 10% by 2027"; expanded Scope 3 reporting.

Named projects with figures (page 82):

• Besi Austria groundwater heat pump - generated 518 MWh of renewable heat and cut gas use 86% versus 2024 (25,754 m3, 49 tCO2eq); versus 2023, 42,437 m3 or 80 tCO2eq.
• Duiven AI heating and cooling - a further 7% cut in 2025, 42% versus 2023.
• Meco energy management - 42% cut in gas consumption versus 2024 and 20% overall energy reduction (54 MWh).

Investment amounts are not disclosed (page 92).

Targets related to climate change mitigation and adaptation

Reference: pages 92-93 (Annex 1 index, page 133).

Two strategic targets, "approved by our Board of Management and Supervisory Board": net zero Scope 1 and 2 by 2030 and net zero across all scopes by 2050 (page 92). Against a 2021 baseline (pages 92-93):

Two limitations are disclosed by Besi itself. The Scope 3 target covers only four categories - upstream and downstream transportation and distribution, business travel, and fuel- and energy-related activities - which "represent a minor percentage of Besi's total Scope 3 emissions" (page 93). And "The Scope 1 and 2 and Scope 3 emissions reduction targets have not been certified by the Science Based Targets initiative", although Besi considers the Scope 1 and 2 targets aligned with SBTi criteria and a 1.5 C trajectory (page 93).

"We will not use carbon credits nor offsets to meet our... targets", though carbon capture may cover residual Scope 3 emissions by 2050 (page 92).

Energy consumption and mix

Reference: page 96 (Annex 1 index, page 133; two rows, consumption and mix, and intensity).

Total energy consumption was 21,905 MWh in 2025, down from 22,172 MWh (page 96).

Coal, other fossil sources and renewable fuels including biomass are all zero.

Besi reports as a high climate impact sector undertaking, with intensity of 37 MWh per EUR million revenue (2024: 36), the rise attributed to a 2.7% revenue decline. Nuclear consumption "is counted based on energy grid mix of each country" and is excluded from the total "to avoid double counting".

Renewable electricity reached 99% of total electricity consumption, driven by RECs and GECs in China, Malaysia and Vietnam and 100% renewable use across Europe (page 94).

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 97, 94-95 (Annex 1 index, page 133; two rows, gross emissions and intensity).

Scope 3 by category (2025): purchased goods and services 93,555; use of sold products 148,081; business travel 2,397; employee commuting 2,481; upstream transportation 2,316; downstream transportation 2,139; waste 75; fuel and energy-related 41; end-of-life treatment 11 (page 97).

Category 2, capital goods, was excluded in 2025 "to avoid double counting given that part of capital goods is categorized in purchased goods and services" (page 127).

Intensity rose to 442 location-based and 425 market-based tCO2eq per EUR million revenue (2024: 417 and 400). Scope 3 is 99% of total emissions (page 83). Purchased goods and services use a spend-based Exiobase method covering 40% of total emissions; 64% of emissions came from primary data (page 128).

Policies related to own workforce

Reference: pages 104-105, 62-64 (Annex 1 index, page 133, listed as "IRO: S1-1").

Seven instruments apply: the Sustainability policy, Code of Conduct, Human Rights policy, Inclusion and Diversity policy, Anti-Corruption and Bribery policy, Grievance procedure and Whistleblower procedure, "all of which are available on our website" (page 104). Each is reviewed annually in the fourth quarter and approved by the Supervisory Board (page 62).

The Human Rights policy commits to the ILO Declaration, the UN Declaration of Human Rights, the UN Global Compact, the OECD Guidelines, the UN Women's Empowerment Principles, UNICEF's Children's Rights and Business Principles and the UN Convention on Migrant Workers, and "explicitly prohibits the use of forced, bonded or child labor" (pages 62, 105). It covers inclusion and diversity, non-discrimination, freedom of association, safe working conditions, anti-harassment, fair wages and work-life balance (page 105).

A gap is disclosed rather than glossed: "Although we do not have specific policy commitments for groups at particular risk of vulnerability such as disabled people, persons with long-term illnesses and other vulnerable groups, we seek to provide equal opportunities for all employees regardless of identity" (page 105).

"All employees are required to sign our Code of Conduct and undertake training upon hiring" (page 105).

Engaging with own workforce and workers' representatives

Reference: page 106 (Annex 1 index, page 133, listed as "IRO: S1-2").

Engagement runs directly and through representatives (page 106):

• Annual performance appraisals, where "employees and managers are encouraged to voice their concerns in a collegial exchange".
• "Employee interests are also communicated semi-annually in a more institutional way via representation by the local European Works Councils and Asian Work Unions. The results of these communications are used to create risk mitigation strategies."
• Quarterly Town Hall meetings for all employees.

"The Board of Management is the most senior body with operational responsibility for company-wide engagement initiatives such as the Employee Engagement survey", with operations managers responsible for location-specific initiatives.

Effectiveness is measured through the biennial Employee Engagement survey run by Willis Towers Watson. The 2025 survey reported 91% participation and 88% engagement, against 94% and 89% in 2023.

Vulnerable employees are specifically catered for: "Employees who may be particularly vulnerable to Besi's impacts can provide feedback in the survey by responding to open-ended questions". Findings drove follow-up, including collaboration workshops at Besi Switzerland and an annual physical and mental health assessment at Besi Netherlands.

Remediation and channels to raise concerns

Reference: pages 106, 123-125 (Annex 1 index, page 133, listed as "IRO: S1-3").

Two channels operate. The Whistleblower procedure covers "a suspicion of misconduct or a suspicion of infringement of EU law"; reports are handled by "experienced, trained and certified professionals", the whistleblower may require anonymity, and "Retaliation or discrimination for doing the right thing... is strictly forbidden" (page 63). Protections "comply and are in accordance with the Dutch Whistleblowers Act which transposes Directive (EU) 2019/1937" (page 124).

The Grievance procedure applies to "all Besi's employees, contractors, sub-contractors, consultants, interns and temporary workers" as well as suppliers' employees and other value chain workers. Besi "follows a 7-step process for providing, or contributing to, a remedy where it has caused or contributed to a material negative impact", running from submission through Ethics Committee conclusion, appeal and closure (pages 64, 119).

Confidentiality Counsellors were introduced in 2025 and are "available in each country of operation" (pages 107, 109).

Cases "are investigated immediately and overseen by the Board of Management and, if relevant, local management, who have responsibility for approving appropriate corrective measures and remedies" (page 105). All cases are recorded and a summary reaches the Board of Management and Supervisory Board (page 109).

Taking action on material impacts on own workforce

Reference: pages 106, 107-108 (Annex 1 index, page 134, listed as "IRO: S1-4").

The action table (page 107) sets out three policy-linked plans - Sustainability policy, Human Rights policy and Inclusion and Diversity policy - each covering all operations on a continuous basis with no defined completion year, reviewed annually.

2025 progress recorded: average training hours rose to 33 hours, up 27% on 2021; the biennial engagement survey was run; quarterly Town Halls held; "Seven out of eight Besi facilities are now ISO 45001 compliant"; mental health seminars introduced on stress, conflict and burnout; Confidentiality Counsellors introduced; Code of Conduct training covering human rights and diversity run on joining and repeated periodically.

Besi states it "was not involved in any actual negative impact for which remedial action was required based on the findings of the Double Materiality Assessment" (page 108).

A four-tier review rhythm is described for detecting negative impacts: weekly regional management meetings, Global Management Team meetings three times per week, monthly Management Team meetings with the Board of Management, and quarterly Supervisory Board and Audit Committee meetings (page 108).

Resources are not quantified: "such financial resources are not considered significant. As such, we have not disclosed the specific monetary amount" (page 108).

Targets related to own workforce

Reference: pages 110-111 (Annex 1 index, page 134, listed as "M: S1-5").

Five targets, all absolute, against a 2021 baseline (page 111):

US employees are excluded from the two diversity targets from 2025, though Besi states the reported figures would be unchanged if they were included (pages 57, 111).

Coverage gaps are declared plainly. "We have not yet set targets for additional sub-topics based on the Double Materiality Assessment conducted in 2024 and reviewed in 2025" (page 110). "Topics related to secure employment, working time, adequate wages and work-life balance are not yet covered by Besi's current targets" (page 110). On discrimination, "we have a zero-tolerance approach... As such, we have not set a specific target for this topic" (page 110). Data on work-life balance, family leave and social protection was first collected in 2024 and targets will be considered "over the medium-term" (page 110).

Employees were engaged in target setting, with performance communicated at quarterly Town Halls where employees can give feedback (page 110).

Characteristics of employees

Reference: pages 113-114 (Annex 1 index, page 134, listed as "M: S1-6").

At 31 December 2025 Besi had 1,928 employees by headcount (2024: 1,878), comprising 1,599 male and 329 female (83%/17%), none reported as other or not disclosed. The financial-reporting figure was 1,964 full-time equivalents (page 113).

By region: 1,308 in Asia (68%), 620 in Europe and the United States (32%).

By contract: 1,871 permanent, 56 temporary, 1 non-guaranteed hours; 97% permanent.

By country: Malaysia 479, China 389, Austria 314, Singapore 258, Netherlands 169, Switzerland 99, Taiwan 62, Vietnam 60, United States 38, South Korea 34, Philippines 15, Thailand 11.

By age (page 114): under 30, 199 (10%); 30-50, 1,296 (67%); over 50, 433 (23%).

Turnover and hiring: 172 leavers, a rate of 9% (2024: 155, 8%), and 218 new hires (2024: 228), a hiring rate of 11%. Turnover counts voluntary leavers, dismissals and retirements over total employees, across all contract types.

Besi explains the cyclicality: "In market upturns, headcount typically increases. Conversely, in downturns, headcount is typically reduced... particularly as it relates to temporary production personnel" (page 113).

Characteristics of non-employee workers

Reference: page 114 (Annex 1 index, page 134, listed as "M: S1-7").

Besi defines non-employees as "individuals working for Besi who are either self-employed individual contractors or individuals provided by third-party employment agencies primarily engaged in 'employment activities' as per NACE Code N78". Self-employed individuals include temporary workers and subcontractors supporting R&D; agency-provided individuals include employees of contracted companies such as office management services.

"As of December 31, 2025, non-employee workers aggregated 292 FTE (2024: 280) of whom 15 FTE (2024: 19) were self-employed people and 277 FTE (2024: 261) were provided by third-party employment agencies."

Non-employees are reported in full-time equivalents at period end, and "The calculation of non-employees is subject to the employment laws and regulations in each country of our operations".

Non-employees fall within scope of other disclosures: the health and safety incident and fatality metrics "cover Besi's employees and non-employees" (pages 112, 116); the Code of Conduct, Human Rights policy and Inclusion and Diversity policy all apply to them (pages 62-63); and so does the Grievance procedure (page 64).

The Annex 1 comment on this row flags a related phase-in for health and safety reporting on non-employees under S1-14 (page 134).

Diversity metrics

Reference: page 114 (Annex 1 index, page 134, listed as "M: S1-9").

"In 2025, female employees and female managers accounted for 17% and 19% of Besi's total employees and total managers, respectively" (page 114). Manager is defined as "an employee with a paygrade of M1 or higher and who has an employee directly reporting to them".

Top management: "The Board of Management consists of one male and is therefore 100% male. There are nine members in Besi's Management Team which includes one female and eight males which corresponds to a female/male ratio of 11%/89% at the management level" (page 114). Management is defined as the level below the Board of Management.

Age distribution: under 30, 199 (10%); 30-50, 1,296 (67%); over 50, 433 (23%).

The trend is disclosed candidly. Female managers rose from 18% in 2021 to 19% in 2025, with a dip in 2023 "due to the promotion of several male employees to management positions at Besi APac" (page 111). On the workforce measure: "There has been no increase in the percentage of female employees from 2019 until 2025", held at 17% throughout (page 111).

The Supervisory Board itself is 60%/40% male/female, in line with article 2:142b of the Dutch Civil Code (page 75).

Adequate wages

Reference: page 114 (Annex 1 index, page 134, listed as "M: S1-10").

"Besi compensates its employees fairly for their work with wages that meet at least the minimum legal standards in the geographies in which it operates... Similar to last year, Besi's employees receive adequate wages based on the assessment conducted versus applicable benchmarks in the countries of our operations. The adequate wage assessment was performed using employee payroll data" (page 114).

The company frames this as a positive assessment across its footprint: "an assessment was conducted across the countries in which Besi operates which found that Besi employees receive an adequate wage versus applicable local benchmarks" (page 56).

Pay scales are reviewed annually and "Given that Besi operates in three countries in Europe and 15 countries in Asia, the reviews are specific to the regional context of the labor market in each country of operation" (page 114). Inputs are annual performance reviews and labour market analytics.

Effectiveness is assessed "via our employee engagement survey" and direct feedback in performance reviews (pages 108, 114). Besi notes that controls over this metric are country-specific, since "the definition of adequate wages may differ from country to country" (page 79). No benchmark source, no percentage of employees paid at or above an adequate wage, and no country breakdown are given.

Persons with disabilities

Reference: page 115 (Annex 1 index, page 134, listed as "M: S1-12").

"As of December 31, 2025, we reported 10 employees (2024: 11) as persons with disabilities which represented 0.5% (2024: 0.6%) of total employees" (page 115).

The measurement basis is disclosed: "The percentage of employed persons with disabilities is reported across all our operations and is based on the definition of disability as per local regulations specific to each country where we operate". No breakdown by gender is given.

On accommodation, Besi states that "we implemented a set of policies and procedures as well as suitable accommodations to enable everyone with special needs, including workers with disabilities, to effectively perform their jobs" (page 115).

A policy gap is acknowledged rather than hidden: "Although we do not have specific policy commitments for groups at particular risk of vulnerability such as disabled people, persons with long-term illnesses and other vulnerable groups, we seek to provide equal opportunities for all employees regardless of identity" (page 105). The Inclusion and Diversity policy nonetheless covers disability among the grounds on which Besi "denounces all forms of discrimination" (page 63), and the diversity IRO names "employment and inclusion of persons with disabilities" as an ESRS sub-topic in scope (page 71).

Training and skills development metrics

Reference: page 115 (Annex 1 index, page 134, listed as "M: S1-13").

Performance and career development reviews (page 115):

"Our goal is to have annual performance and career development reviews for all employees. We aim to make progress towards this objective in the next few years" (page 115).

Average training hours (page 115):

"In 2025, a total of 64,125 training hours were recorded representing an average of 33 training hours per employee", calculated as total hours per gender divided by headcount per gender (page 115). Training hours are above the 2026 and 2030 target of at least 21 hours, up 10% on 2024 and 27% on 2021 (pages 111-112). The increase is attributed to the new Vietnam facility, an increased health and safety focus and supplementary technical training at Meco (page 112).

A methodology caveat is disclosed for the review metric: some entities run reviews twice a year and only the first round is counted, so "there is a possibility and minor uncertainty that some employees may have had a performance and career development review in the first round of reviews and not the second or vice versa" (page 115).

Health and safety metrics

Reference: page 116 (Annex 1 index, page 134, listed as "M: S1-14").

Coverage: facilities in Austria, China, Malaysia, Singapore, Switzerland and both Netherlands sites are ISO 45001 compliant, so "seven out of eight facilities are compliant in 2025 versus six in 2024". Vietnam is expected to certify in the medium term. "In total, 89% of our workforce was covered by a Health and Safety standard as of December 31, 2024, increasing to 94% as of December 31, 2025" (page 116).

That is "a 58% reduction versus 2021 and a 2% reduction versus 2024". No fatalities in 2024 or 2025, "not a work-related ill health case reported in 2025" and no related legal proceedings. These indicators "cover Besi's employees and non-employees" (pages 112, 116).

Days lost rose sharply: "The number of days lost due to incidents in the workplace was 56 versus two days in 2024". Both 2025 incidents were at the Malaysian facility and classified as major absences of more than four days; both employees returned to work (page 112).

Compensation metrics (pay gap and total compensation)

Reference: page 116 (Annex 1 index, page 134, listed as "M: S1-16", flagged SFDR and BRR).

Gender pay gap: 21% as of 31 October 2025, against 23% in 2024. The methodology is disclosed: it "is calculated as the difference between average male and female hourly salaries and is expressed as a percentage... we considered the gross hourly pay of all Besi employees across all levels and regions. Employees considered for this analysis were determined based on payroll data from October 2025 excluding interns and those who left Besi prior to such date", converted to euro at October month-end rates (page 116).

Besi attributes the gap "largely to an underrepresentation of female employees in the highest paid R&D and engineering positions of Besi and the semiconductor assembly equipment industry in general".

Annual total remuneration ratio: 138 in 2025, against 382 in 2024. It divides the highest-paid employee's annual remuneration by the median excluding that employee, for the period ending 31 October 2025, globally "in accordance with the ESRS requirements", counting base salary, benefits in cash and in kind, and short- and long-term incentives at fair value.

The fall is explained: "The 2024 remuneration of the CEO included equity compensation benefits for additional performance shares related to prior year".

Incidents, complaints and severe human rights impacts

Reference: pages 116-117 (Annex 1 index, page 134, listed as "M: S1-17", flagged SFDR and BRR).

"In 2024 and 2025, there were no reported incidents (0), or severe human rights impacts (0) related to discrimination on the grounds of gender, racial or ethnic origin, nationality, religion or belief, disability, age, sexual orientation or other relevant forms of discrimination. Such metrics include reports received via the Whistleblower procedure, Grievance procedure as well as complaints submitted to our HR managers" (page 116).

"There were four whistleblower cases reported in 2025. Zero cases were reported in 2024. The whistleblower cases reported in 2025 were not related to human rights nor working relationship topics. All whistleblower cases were investigated and the necessary corrective measures were implemented... In addition, there was one complaint related to a working relationship submitted via the Grievance procedure which was resolved through discussion with the parties involved. There were no fines or penalties associated with the reported complaints" (page 117).

Besi adds that it "was not involved in any actual negative impact for which remedial action was required" (page 108). The jump from zero to four whistleblower cases is disclosed without amounts or any further category breakdown.

Policies related to value chain workers

Reference: pages 117-118 (Annex 1 index, page 135).

Three instruments apply: "a Sustainability policy, a Supplier Code of Conduct (based on the code published by the Responsible Business Alliance ("RBA")), and a Human Rights policy". Besi also seeks "to align our operations and supply chain with the Restriction of Hazardous Substances ("RoHS") Directive" (page 117).

The Supplier Code of Conduct "has been created in accordance with RBA requirements since 2018" and sets standards for safe working conditions, respect and dignity, and ethical operations. "Besi expects that the supply chains of its suppliers comply with the same standards", and where the RBA Code and local law differ, "the RBA defines compliance as meeting the more strict requirements of the two" (page 118).

The Human Rights policy applies the UN Guiding Principles and the OECD Due Diligence Guidance for Responsible Business Conduct, in five steps: embed responsible conduct in policies, identify and assess issues, prevent or mitigate, track mitigation, communicate transparently (page 118).

"Our Supplier Code of Conduct and Human Rights policy explicitly address trafficking in human beings, forced labor or compulsory labor and child labor" (page 117).

Besi reports a nil return: "There have been no reported violations of Besi's Supplier Code of Conduct and Human Rights policy via our whistleblowing channels or supplier audits".

Engaging with value chain workers

Reference: pages 118-119 (Annex 1 index, page 135).

Engagement is indirect, running through suppliers rather than with workers or their representatives directly. Three channels are named (page 118): "Consultative stakeholder engagement interviews and meetings"; "annual sustainability briefing roadshows during Supplier Days"; and "Training sessions and the sharing of sustainability-related knowledge during audits".

Effectiveness is "measured through supplier audits to help verify compliance with our objectives and to reduce the risk of a negative impact".

Accountability is named: "Besi's Board of Management is responsible to ensure that supplier engagement occurs. The VP Strategic Supply Chain Management has day-to-day operational responsibility for value chain worker engagement."

Coverage in 2025: "Besi signed a General Work Agreement ("GWA") or General Procurement Contract ("GPC") with 79% of its Purchase Volume ("PV") in 2025 which includes alignment with the RBA Code of Conduct. In 2025, 70% of our total PV completed the self-assessment questionnaire and 65% of our total PV was audited."

Besi also discloses the limit of its RBA relationship: "Although Besi aligns its practices with the RBA, it is not a member of this organization. In 2024, Besi achieved silver status with the RBA which is externally audited and accredited. The new audit is planned for spring 2026".

Remediation and channels for value chain workers

Reference: pages 118-119 (Annex 1 index, page 135).

"As outlined in the Governance paragraph of this Sustainability Statement, we have Whistleblower and Grievance procedures available to any stakeholder interested in reporting any potential human rights violation" (page 118). The Grievance procedure "applies to our suppliers' employees and other workers in our value chain as well as to the other stakeholders who have business relationships with Besi" (page 64).

Awareness is pushed through the supply chain rather than assumed: Besi assists "our value chain worker representatives in effectively communicating the availability of such channels to their workforce", and engages suppliers and their employee representatives so that suppliers' employees "are aware of and trust our Grievance procedure" (pages 118, 125).

The seven-step remedy process is set out in full (page 119): submission; acknowledgement by the Ethics Counselor; assessment respecting anonymity and good faith; conclusion by the Ethics Committee; appeal; action with a timeline and responsible parties; and closure.

"We commit to provide appropriate forms of remediation in cases where Besi has directly caused or contributed to a negative impact on workers in the value chain" (pages 118-119). The Grievance procedure "was introduced in 2024" (page 121). No value chain worker cases are reported for 2025.

Taking action on material impacts on value chain workers

Reference: pages 119-120 (Annex 1 index, page 135).

The preventative action table (page 120) pairs three material impacts - human rights, working conditions and health and safety, all concentrated in Asian suppliers - with named controls: GWAs and GPCs referencing the RBA Code of Conduct; the Conflict Free Sourcing Initiative; supplier training; the three governing policies; self-assessments and audits; and the Whistleblower and Grievance procedures.

Besi sets out its exposure candidly: Asian personnel were 68% of headcount and Asian customers about 76% of revenue in 2025, and "we operate in countries that, according to international human rights and corruption indices, are perceived to be of higher risk" (page 119). It also names who is most exposed: workers "involved in the creation of fabricated parts have a higher exposure to health and safety-related negative impacts", and "certain geographies such as Singapore rely on migrant workers" (page 117).

2025 actions: reviews and audits reached 65% of total PV, up one point; the QBR scorecard carries a 10% sustainability weighting across six performance categories, with suppliers in the lowest category for three consecutive quarters formally reviewed (page 121); an IT Risk Survey drew 131 supplier responses (page 121).

Resources are not quantified: "we have not disclosed the specific monetary amount" (page 119).

Targets related to value chain workers

Reference: pages 121-123 (Annex 1 index, page 135).

Besi explains why its targets are entity-specific: "The ESRS S2 'Workers in the value chain' standard does not set any specific metrics to be measured as part of ESRS compliance. As such, we have set entity specific targets measuring the commitment of our suppliers to follow best international practices" (page 121).

Four absolute targets against a 2021 baseline, all as a share of purchase volume (pages 122-123):

Each improved by one to two points on 2024, and all four sit below the 2026 milestone.

Two limitations are disclosed. Coverage is incomplete by design: "we realize that it is unlikely that 100% of our PV will align with all the initiatives above", so Besi "will develop an engagement plan for any PV not aligned" (page 122). And the set is not complete: Besi "intend[s] to set other targets addressing our material impacts, risks and opportunities over the next two years" (page 122).

Business conduct policies and corporate culture

Reference: pages 123-125 (Annex 1 index, page 135).

Besi lists seven website-published instruments - the Sustainability policy, Code of Ethics for Senior Financial Officers, Inclusion and Diversity policy, Code of Conduct, Anti-Corruption and Bribery policy, Whistleblower procedure and Grievance procedure - plus two internal ones, the No-Gift and Limited Entertainment policy and the Conflict of Interest policy (page 123).

Culture and training: "all new employees are required to sign the Code of Conduct and all employees undertake training on an annual basis. The training includes key topics included in Besi's Code of Conduct, Whistleblower procedure, Grievance procedure, No-Gift and Limited Entertainment policy and Conflict of Interest policy".

Political contributions: "Besi commits to not making any contributions or donations to candidates or political parties in any of the countries in which it operates" (page 124).

Whistleblower protection complies with "the Dutch Whistleblowers Act which transposes Directive (EU) 2019/1937"; anonymity may be required and privacy respected during and after the process (page 124).

Governance: the Supervisory Board oversees business conduct policy, the Board of Management sets and executes the framework, and day-to-day oversight sits with SVPs and facility management (page 123).

Prevention and detection of corruption and bribery

Reference: pages 125-126 (Annex 1 index, page 135).

"Besi has a zero-tolerance approach to any form of bribery and corruption... Besi requires that all third parties acting on its behalf adhere to the principles of this policy. We consider sales and purchasing positions to be of highest risk in the countries ranking highest on international corruption indices" (page 125).

Five mechanisms are set out (page 125):

• Record keeping of all transactions and expenses with supporting documentation.
• Whistleblower and Grievance procedures to raise concerns.
• Anti-corruption and bribery training for all employees, ensuring "all 'functions-at-risk' participate".
• Reporting cadence: "The Board of Management is updated on a quarterly basis of any violations... The Supervisory Board is informed twice a year."
• Investigator independence: "Investigators into potential corruption and bribery issues are always separate from the chain of management involved in the matter."

Detection goes beyond reporting channels: "we also use data fraud analytics tools to find potential corruption and bribery cases", managed by Internal Audit and Control and reported to both boards (page 125).

Supervisory Board members "reviewed and approved the Anti-Corruption and Bribery policy and Besi's internal Anti-Corruption and Bribery Framework" (page 125). No training completion rate is given.

Targets related to business conduct

Back-filled from the business conduct "Metrics and targets" section (page 126), which the Annex 1 index reaches through the MDR-T row (page 132). G1-3 became a standalone numbered DR only in the 2025/2026 ESRS.

Besi discloses no measurable business conduct targets. The section headed "Metrics and targets" (page 126) contains metrics and no targets, and no numeric goal for training completion or incident reduction appears in the G1 chapter.

Consistent with MDR-T's second limb, effectiveness is tracked in the absence of targets:

• "all new employees are required to sign the Code of Conduct and all employees undertake training on an annual basis" (page 123).
• "Regular internal audits which form part of the internal audit plan are conducted to monitor adherence to this policy" (page 125).
• "The Board of Management is updated on a quarterly basis of any violations... The Supervisory Board is informed twice a year", and "we also use data fraud analytics tools to find potential corruption and bribery cases" (page 125).
• Material findings reach the Audit Committee "on a quarterly or semi-annual basis including the status of systems, procedures and activities to monitor and evaluate risks from fraud, bribery or corruption" (page 126).

One business-conduct objective sits in the CEO's short-term incentive: "Further enhance Besi as responsible business including ethics and compliance" (page 77).

Incidents of corruption or bribery

Reference: page 126 (Annex 1 index, page 135, flagged SFDR).

A complete nil return for both years: "In 2024 and 2025, there were no reported incidents of corruption, no convictions or fines for violation of anti-corruption and anti-bribery laws and no actual violations or penalties" (page 126).

On competition: "There were no legal proceedings associated with anti-competitive behavior during the last five years".

The scope of the metric is defined, and it is narrower than the full value chain: "We take into account incidents involving actors in the value chain only where Besi or its employees are directly involved when assessing legal proceedings, incidents of corruption and convictions or fines for violation of anti-corruption and anti-bribery laws".

The nil return is qualified by Besi itself: "Although we have implemented policies and procedures designed to help ensure compliance with all applicable rules and regulations, there can be no assurance that our employees, partners and other persons with whom we do business will not take actions in violation of our policies or such rules and regulations".

Related figures give context: four whistleblower cases were reported in 2025 against zero in 2024, none "related to human rights nor working relationship topics" (page 117). No functions-at-risk breakdown and no training completion rate is disclosed.