Beijer Ref

Governance roles

Reference: pages 51-52; business-conduct governance page 89. The ESRS index points GOV-1 to "Board of Directors p. 51, Group Management p. 51, Responsibilities of the Board of Directors and Management (GOV-1 G1) p. 51" (page 91).

The Board "has overall responsibility for Beijer Ref's sustainability work and is the decision-making body for the Group's strategies, policies and goals in the area of sustainability" (page 51). The Audit Committee "is responsible for fulfilling the Board's monitoring responsibilities regarding the company's sustainability reporting". Material IROs are prepared by the Audit Committee and approved annually by the Board.

Board composition (page 51): eight members, four of them women; seven (88 percent) independent of the company and its management; four (50 percent), including the Chair, have dependencies to the largest owner or their own shareholding. "Trade union employee representatives are not represented at Board level."

Management (page 51): the CEO & President is ultimately responsible. Day-to-day responsibility sits with the Group Sustainability Manager, who took up the post in January 2025 and is part of the extended management team. Group management, including the extended team, has 10 members, 20 percent women.

All Board members and management received PwC training on the CSRD in 2024, followed up in 2025; further training is planned for 2026 (page 51).

Information provided to and sustainability matters addressed by the bodies

Reference: page 52.

"The Board and Group Management receive regular updates on Beijer Ref's work with sustainability and due diligence, normally on a quarterly basis or as needed." Corruption incidents and whistleblower reports are the stated exception, handled by the General Counsel and presented separately to management and the Board.

Board. Nine regular Board meetings were held in 2025 and "sustainability topics were specifically addressed at all Board meetings". Topics included GHG emissions against the SBTi-validated targets, approval of the GHG-reduction outcome under the long-term incentive programme, annual revision of sustainability policies, approval of the revised double materiality assessment, and HR topics such as diversity and employee well-being. Risk reviews are conducted by the Board at least once a year and twice by the Audit Committee, "with sustainability-related risks constituting a significant part". The Audit Committee discusses reporting status and IRO deviations four times a year. The 2025 DMA was approved at the October 2025 Board meeting.

Group Management met 11 times in 2025 with sustainability a standing agenda item, the Sustainability Manager acting as rapporteur; DMA results are reviewed in workshop format and decided annually.

Integration of sustainability-related performance in incentive schemes

Reference: page 52 and page 65 ("Integration of sustainability into incentive systems (E1 GOV-3)").

"There is no incentive programme for the Board of Directors" (page 52).

Long-term programme, approved by the Board and implemented in 2025: "Ten percent of the programme's outcome is linked to a reduction in the Group's Scope 3 emissions, with the criterion that a reduction of at least 6-9 percent must be achieved by 2027 compared with 2024. This target is based on the average annual Scope 3 reduction Beijer Ref needs to achieve to meet its 2030 climate targets." It applies to all participants at levels A-E, level A being the CEO. For 2025, "the reduction in Beijer Ref's carbon dioxide emissions is in line with the long-term incentive programme's target" (page 65).

Short-term programme: management team members have 5-10 percent of variable salary linked to OEM sales of products for refrigerants with a GWP below 150 rising by at least 5 percent in the year. It is a minimum threshold: if it is missed, "the other sustainability-related targets in the short-term programme for the year will be dropped, even if they have been achieved". HR managers and the CEO also carry diversity targets (page 52).

Statement on due diligence

Reference: page 53 ("Due diligence in the area of sustainability" and the due diligence index).

Beijer Ref describes due diligence as the process by which it "identifies, prevents, limits and reports both the actual and potential negative consequences of its operations on the environment and people", applied on major changes to strategy, business model, activities and business relationships, and on acquisitions and divestments (page 53).

The report carries the ESRS 2 due diligence index mapping the five core elements to sections of the statement (page 53):

• (a) embedding in governance, strategy and business model - pages 52 and 57
• (b) engaging with stakeholders - page 56
• (c) identifying and assessing adverse impacts - page 57
• (d) taking action on those impacts - pages 57 and 60
• (e) tracking effectiveness and communicating - pages 57 and 56

Risk assessment focuses on "the sustainability areas that are most relevant to the business, primarily issues related to climate change, our own employees and business ethics". Acquisitions are evaluated under the law of the country of operation, and "where relevant, the due diligence process includes a life cycle assessment (LCA) of the overall environmental impact of the business" (page 53).

Risk management and internal controls over sustainability reporting

Reference: page 53.

Internal control covers all Group companies, and "the ambition is to further develop the internal control process in 2026", integrating self-assessment into the overall internal control carried out by Finance HQ, with on-site controls at subsidiaries and online self-assessments, starting with a limited number of subsidiaries.

Risk is monitored by the Risk Committee within the Enterprise Risk Management process. The company states its main reporting risk plainly: "One of the biggest risks to the accuracy of the report is a systemically dispersed and, in some cases, untraceable internal reporting." All material sustainability data is now reported through the Group-wide financial reporting system, with Scope 1 and 2 emissions the exception, reported through an external system (pages 50 and 53). Note the system is named IBM Controller on page 50 and Cognos on page 53.

For 2025 the control performed was "mainly ... a plausibility check of the reported data from a risk perspective", covering E1, S1 and G1. Scope 1 and 2 checks are performed with external partner Schneider Electric, S1 checks by Group HR, G1 incidents by the Compliance Office. E1 and S1 deviations were reported to management in Q1 2026.

Strategy, business model and value chain

Reference: pages 54-56.

Beijer Ref is "a global distributor of commercial and industrial refrigeration, heating and air conditioning systems and related products and services", and also manufactures refrigeration systems and industrial heat pumps using natural refrigerants with low GWP (page 54). The organisation is decentralised: more than 7,000 employees, 500+ branches, operations in 45 countries on four continents and around 150 subsidiaries (pages 54-55).

2025 sales split (page 54): HVAC 62 percent (60), commercial and industrial refrigeration 31 percent (32), own manufacturing (OEM) 8 percent (8). Acquisitions in 2025 were in Australia, Estonia, Hungary, Latvia, Lithuania, India, Singapore and the United States.

Value chain (pages 55-56). Upstream: finished products from suppliers "such as Toshiba, Mitsubishi Heavy Industries and Gree", plus copper, steel, refrigerants, processors and control units mainly from China. Own operations: sales, warehousing, administration, OEM assembly (about 10 percent of the portfolio), R&D, acquisitions. Downstream: "approximately 200,000 customers in over 70 countries", end users including grocery stores, hotels, ice rinks, the offshore industry and residential property.

Strategy is built on decarbonisation, with four focus areas: lower-GWP refrigerants and reduced leakage, technology leadership, skills development, and monitoring F-gas and energy-efficiency legislation (page 54).

Interests and views of stakeholders

Reference: pages 56-57; S1-specific engagement page 83.

Key stakeholder groups, updated in the 2025 DMA, are shareholders and investors, suppliers, personnel (with management and the Board called out as "particularly strategic players"), customers and end customers, and "neighbours of production facilities and warehouses ... another stakeholder group that may experience negative consequences of being located close to a business with production and incoming and outgoing transport" (page 56).

The report tabulates channels and results per group (page 57). For investors, "an MSCI ESG Rating of A, approved climate targets according to SBTi, and targets for working conditions, health and safety, and ethical business practices are often a prerequisite" for meeting expectations. For customers, "approved climate targets according to SBTi are a requirement from many customers, especially in Northern Europe, which in turn is driven by end customers' ambition to reduce their own Scope 2 emissions". Beijer Ref notes it "does not have direct dialogue with end customers; this takes place via installers".

Major recurring forums are named: MCE Milan, Chillventa Nuremberg, AHR Expo and ARBS. The company states dialogue "has had a significant impact on the formulation of goals, policies and measures", with insights shared with Group Management continuously and the Board annually (pages 56-57).

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

Reference: pages 57-59; topic tables pages 62-63, 80 and 87.

"The material issues for 2025 fall within three different subject areas: Climate change mitigation (E1) ... Our own workforce (S1) ... Business ethics (G1)" (page 57), and "no significant changes have been made in relation to the materiality assessment for 2024".

The overview table (pages 58-59) lists eight impacts, one risk and two opportunities:

• E1: energy use and mix; GHG emissions within Scope 1, 2 and 3; decreased GHG emissions from end customers (the sole positive impact)
• S1: work environment and health and safety; fair and equal working conditions; employees' working conditions and human rights
• G1: preventive work against and detection of corruption and bribery; protection for whistleblowers
• Risk: confirmed cases of corruption and bribery ("unethical business conduct could lead to substantial fines and damage to reputation")
• E1 opportunities: a rising share of natural refrigerants in sales; rising temperatures driving demand for cooling

"In 2025, no significant effects have yet been noted in the financial reports that are linked to significant impacts, risks or opportunities in the area of sustainability" (page 59).

Note: the page 59 risk table is headed "Significant impact in the area Own employees (S1)" above a row that is plainly a G1 risk; page 87 heads it correctly.

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

Reference: pages 60-61; climate-specific process pages 62-63 and 70-72.

The DMA is reviewed annually, "led by the Sustainability Manager and carried out by a CSRD working group", presented to Group Management, reviewed by the Audit Committee and "finally approved by the Board of Directors" (page 60). "More external stakeholders than previously have been involved in the 2025 version, including customers and suppliers."

Process steps (page 60): value chain mapping; identification of topics and IROs; final assessment; validation and reporting. Topics were identified "through work meetings, workshops, external analysis and established tools such as SASB Materiality Finder".

Method (pages 60-61). Negative impacts are weighted on Scope, Reach, Irreversibility and Probability; positive impacts on Scope, Reach and Probability. Financial materiality is weighted on size (including EBIT ranges under the Enterprise Risk Management criteria) and probability. Horizons are short (under a year), medium (one to five years) and long (over five years). "Levels four and five on the five-point scale are considered significant" for impact; "levels three and four on the four-point scale are assessed as material risk or opportunity" financially. "The current materiality threshold has been defined and established through a Board decision, both for impact and financial effects."

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

Reference: pages 91-92 (ESRS index) and pages 93-94 (data points derived from other EU legislation, ESRS 2 Appendix B).

Beijer Ref prints a full ESRS content index headed "ESRS-index", listing each disclosure requirement against the section and page in the report (pages 91-92). It covers ESRS 2 (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), E1 (GOV-3, SBM-3, IRO-1, E1-1 to E1-6 and E1-9), S1 (SBM-2, SBM-3, IRO-1, S1-1 to S1-10, S1-14, S1-16, S1-17) and G1 (GOV-1, IRO-1, G1-1, G1-3, G1-4).

Requirements absent from the index are E1-7, E1-8, the whole of E2 to E5, S1-11, S1-12, S1-13, S1-15, all of S2, S3 and S4, and G1-2, G1-5 and G1-6. The Appendix B data-point table (pages 93-94) corroborates the environmental and social omissions, marking E1-7, E2-4, E3-1, E3-4, the E4 IRO-1 points, E5-5, and the S2, S3 and S4 data points as "Not material", "Not significant" or "Not relevant".

The statement is the Group's statutory sustainability report under the Swedish Annual Accounts Act, and "2025 is the first year in which the sustainability report is fully reported in accordance with ESRS ... and the Taxonomy Regulation" (page 50). It covers 1 January to 31 December 2025 and the whole Group, on the same scope as the financial statements.

Transition plan for climate change mitigation

Reference: pages 65-67 (transition plan, disclosed as E1-1, E1-3 and MDR-A); EU Taxonomy page 73.

The plan "supports the strategy and business model in the effort to limit global warming to well-below 2 degrees Celsius and is in accordance with the Greenhouse Gas Protocol", and "focuses on reducing carbon dioxide emissions in Scope 3, as these account for more than 99 percent of the business's total emissions" (page 65).

Approval and financing. The plan "is integrated into Beijer Ref's overall strategy and prioritised activities are financed through the annual budget process, which means that it is approved annually by Group Management and the Board of Directors". It was "adopted by company management and the Board of Directors in September 2025. As the plan is in its first year, progress relative to the plan will be reported for the first time in the 2026 report."

Seven levers (pages 66-67): low-GWP portfolio shift; OEM sales of low-GWP products (70 percent by 2030, 56 percent in 2025); reduced refrigerant leakage (no target); employee and customer training (no targets); supplier partnerships; and reducing fossil energy and fuels in own operations.

Costs are not quantified: capital and operating costs "cannot be separated as isolated sustainability initiatives", and for Scope 1 and 2 "expected emission reductions and investments through 2030 need to be quantified".

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 climate DMA section (pages 62-63, 70-72). This DR did not exist under the 2023 ESRS the report was prepared against.

Risk types (page 70). The report separates "Physical risks: Event-driven (acute) or long-term changes (chronic) in climate patterns" from "Transition risks" (political and legal, technological, market, brand). Beijer Ref's "operations are not exposed to significant physical climate-related risks in the short and medium term" (page 63).

Methodology (page 70). Physical risk assessment "was conducted by AON plc in an initial round in 2024 and focuses more on the exposure of the business's current assets, and less on the exposure of the value chain"; because own operations sit in the same regions as strategic suppliers, it doubles as a supply-chain proxy. Physical risks are also evaluated through property insurance work.

Scenarios (page 71). "Greenhouse World", a disorderly transition on SSP 3-7.0, and "Low-carbon economy", an orderly one on SSP 1-2.6. Beijer Ref "has not chosen a distinct 1.5-degree scenario, as leading researchers already consider such a scenario to be outdated", and preferred SSP 3-7.0 over SSP 5-8.5 "justified by caution, as the business in principle benefits from temperature increases". Projections: over 3 degrees by 2100 under SSP 3-7.0 and 1.3-2 degrees under SSP 1-2.6, with 2030 carbon prices of USD 65 and USD 100.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the E1 "Strategy and resilience" section (pages 62-63, 70, 72). This DR did not exist under the 2023 ESRS the report used.

The company's "resilience analysis ... is conducted annually as part of the company's strategic planning" (page 62) and is "linked to the annual materiality assessment" (page 70). It "covers the company's operations and customers' use of the company's solutions in all countries where the company operates, with a focus on the markets with the highest sales and/or markets with high greenhouse gas emissions" (page 63).

Results. The analysis "shows how Beijer Ref can increase its competitiveness and growth by offering cooling and heating solutions with a low GWP value" (page 70). The climate impact "is therefore not expected to have a negative impact on Beijer Ref's financial position in the short, medium and long term; instead, ongoing climate change presents financial opportunities" (page 63).

Uncertainties. "There is uncertainty surrounding political decisions on regulations, particularly in North America but also in Europe" (page 63). On page 72, current development "is closer to a scenario of a 'disorderly' transition", "the potential vulnerability of the supply chain to extreme weather and temperature increases may need to be further mapped and assessed", and insurance costs "can be expected to increase". No quantified capacity-to-adapt assessment is given.

Policies related to climate change mitigation and adaptation

Reference: page 64 ("Policy for limiting and adapting to climate change (E1-2, MDR-P)").

One policy is disclosed against E1: the Group Sustainability policy.

Content. "Beijer Ref is committed to conducting its business in a socially responsible and environmentally sustainable manner." The company "prioritises the development and sale of sustainable and energy-efficient products and solutions through wholesale and distribution operations as well as OEM products based on natural refrigerants", including "providing customers with information and tools to make environmentally responsible choices." On emissions: "Beijer Ref has set targets to reduce both its own greenhouse gas emissions and emissions from the entire value chain." It "addresses activities and identified impacts, risks and opportunities related to climate, energy efficiency, and renewable energy".

Scope: "The entire value chain: own operations, upstream supply chain and downstream customer use."

Accountability: "The Board of Directors has adopted the policy, and operational management at the group and local level is responsible for implementation and monitoring compliance. The policy owner is the Head of Sustainability."

Standards: an SBTi-confirmed science-based target since 2023 and the UN Global Compact's ten principles. The policy is on the intranet and the website.

Actions and resources in relation to climate change policies

Reference: pages 65-67 (transition plan table, disclosed as E1-1, E1-3 and MDR-A).

Critical Scope 3 areas sit downstream, with three headline measures: "increasing sales of refrigerants with low global warming potential (GWP) ...; reducing refrigerant leakage; reduce emissions from energy use during the product's lifetime" (page 65).

Actions and 2025 progress (pages 66-67):

• Low-GWP portfolio shift to R744, R600a and R290, and in HVAC from R-410A to R-454B and R-32. "In 2025, Scope 3 decreased by 12% vs 2024, mainly due to the shift to products with low GWP."
• OEM sales of low-GWP products: "Sales have increased steadily since 2021 and reached 56% of total OEM sales in 2025" against a 70 percent by 2030 target.
• Reduced refrigerant leakage, including Refbuster, "which streamlines the recycling, refilling, and handling of refrigerants". Targets "have not yet been set".
• Beijer Ref Academy training for employees and customers; it "is currently available in 7 countries"; targets "not yet set".
• Fossil energy and fuel reduction, plus supplier partnerships; a playbook "will be launched internally in Q2 2026".

Resources. Capex and Opex are not separated for the product levers, the Academy "is not of sufficient financial size to be categorised as Opex and Capex", and most subsidiaries rent premises where "the choice of energy is controlled by the property owner".

Targets related to climate change mitigation and adaptation

Reference: page 64 ("Climate targets (MDR-T, E1-4)"); progress charted on pages 65 and 68.

Targets were "adopted by the Board in 2023 and have been verified by the Science Based Targets initiative (SBTi), in line with the Paris Agreement's target of a maximum of 1.5 degrees Celsius of global warming for Scope 1 and 2. For Scope 3, the target is well-below 2 degrees for global society" (page 64). Validation was in November 2023, with the mandatory five-year review of targets and base year due in 2028 (page 65).

The report states the Scope 1 and 2 reduction as "42% by 2030 compared with the base year 2021, with 11,794 tCO2e" (page 67), and the annual targets in the emissions table as -5 percent for Scope 1 and Scope 2 and -3 percent for Scope 3 (page 68).

The company is explicit about proportions: "Scope 3 accounts for more than 99% of Beijer Ref's total GHG emissions" and "Scope 1 and 2 account for 0.2% of Beijer Ref's total GHG emissions" (page 64). No adaptation target is disclosed, and no removals or carbon credits are relied upon.

Energy consumption and mix

Reference: page 70 ("Energy use in own operations (E1-5)"), with accounting principles on the same page.

"The total number of MWh has increased slightly in 2025 compared to 2024, which can be explained by the Group's growth and thus an increase in operational scope. However, the share of fossil sources has decreased by 1 percent, and the share of fossil-free sources, as in renewable energy and nuclear power, has altogether increased by 2 percent."

Accounting principles: consumption comes from supplier invoices or meter readings and includes leased and rented sales offices and small local warehouses. No energy intensity per net revenue is given.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: page 68 (emissions), page 69 (intensity).

Intensity fell from 1,418 tCO2e per MSEK net revenue in 2021 to 655 in 2024 and 557 in 2025.

Restatements (page 67). "The new base year value for 2021 is 23 968 322 tCO2e and the revised value for 2024 is 23 382 328 tCO2e", after corrections at five subsidiaries and, for 2024, Australia. Categories 2, 4, 8, 10 and 13-15 are omitted.

Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Reference: the ESRS index points E1-9 to "Financial consequences p. 72" (page 91); that section itself sits on page 59, with the scenario summary on page 72.

What is disclosed (page 59). "In 2025, no significant effects have yet been noted in the financial reports that are linked to significant impacts, risks or opportunities in the area of sustainability." On impacts and risks: these "are not expected to have any significant financial effect on the company's financial position, earnings or cash flows in the short, medium or long term. This also applies with regard to planned investments, divestments and sources of financing linked to the strategy." On opportunities: "it is difficult to assess with any degree of certainty the expected financial impact."

Qualitative exposure (page 72). The highest physical risk geographies for own operations are "North America, the Caribbean and Australia, Africa and certain countries in Asia, as well as Mediterranean countries", with drought, extreme heat, rain and forest fires increasing "particularly in the longer term (2045)".

Not quantified. The Appendix B table marks the E1-9 portfolio-exposure, acute/chronic monetary breakdown and property energy-efficiency data points as "Not material", mapping only paragraph 66 c to page 72 and paragraph 69 to page 54 (page 93).

Policies related to own workforce

Reference: page 81 (S1-1 and MDR-P).

Three Group policies are tabled against S1:

• Sustainability policy - "Beijer Ref is committed to providing a safe and inclusive work environment that promotes the health and well-being of our employees, and the policy addresses the identified material issue of employee health and safety." Scope: "Supply chain, own operations, including all employees and temporary staff." Owner: Head of Sustainability, aligned to the UN Global Compact and the OECD Guidelines.
• Code of Conduct - "The company does not tolerate any form of discrimination or harassment of employees; all employees are entitled to fair and equal treatment", and it "respects freedom of association and the right to collective bargaining". Owner: EVP HR and Communications.
• Diversity and inclusion policy - covers "gender identity, age, ethnicity, nationality, language, religion, culture, health, education, sexual orientation, parental status, trade union membership, and disability", extending to contractors and job applicants. In 2026 "skin colour, social origin, and political opinion will be added to the policy as prohibited grounds for discrimination."

All are Board-adopted, on the intranet and "distributed annually to all local company CEOs via the global e-learning system". The Supplier Code of Conduct covers "child and forced labour, trafficking, migrant workers, working hours, leave and wages".

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

Reference: page 83 ("Procedures for remedying negative impacts and channels for employee dialogue (S1-2 and S1-3)").

"In accordance with Beijer Ref's decentralised organisation, the main responsibility for employee dialogue at the individual level ... lies with the local company and its management, in accordance with the Group's policies and guidelines." Group-level monitoring is through global employee surveys.

Channels:

• Employee surveys, "conducted annually in the Group, and more frequently in certain countries, such as the Netherlands, the United Kingdom and Croatia"
• Development discussions between managers and employees, held annually across the Group
• Workplace meetings held regularly throughout the business
• "Trade union cooperation takes place in countries where collective agreements are in place, such as France, Italy, the United Kingdom, Sweden and the Netherlands"
• Continuous training initiatives, locally and at Group level

"The results of both performance reviews and employee surveys are used to identify areas for improvement and continued work towards achieving jointly set goals for the units in question. These channels also enable any problems at work to be identified at an early stage."

One Group Management meeting a year is dedicated to the survey results (page 52). No individual is named as accountable for engagement at Group level.

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

Reference: page 83; whistleblower mechanism also pages 80, 88 and 90.

"Beijer Ref ... follows up on reported accidents once a year to understand the type of accident that occurred and assess the measures taken to prevent similar accidents in the future, as well as the local measures taken to get affected employees back to work. These procedures will be further developed in 2026." Discrimination cases "are investigated and analysed in a similar manner ... once a year" (page 83).

Whistleblower channel. "The most important channel for employees to report suspected irregularities, Beijer Ref's whistleblower system ... is available on the intranet and via QR codes posted around the local companies" (page 83). It is run by external provider SpeakUp and "conducted in accordance with EU Directive 2019/1937 and relevant legislation" (page 80). Reports go to the Compliance Office, "which is responsible for receiving, investigating, responding and, if necessary, taking initial action. A prohibition on reprisals against reporters applies", and the channel "is not available to external persons" (page 90).

Intended use covers "discrimination, bullying and harassment; illegal activities; financial fraud; bribery or corruption". "All company CEOs have also certified in writing that they have read the Group's whistleblower policy" (page 83).

Taking action on material impacts on own workforce

Reference: page 82 ("Measures and resources (MDR-A)") and pages 83-84 (S1-4).

Actions in 2025 (page 82):

• Health and safety training: "In 2025, local companies have implemented and will continue to implement safety training as part of the induction programme for all new staff. The zero-accident vision has been more clearly specified in the strategy." In 2026, "procedures for the Group's handling of serious accidents will be further developed."
• Discrimination and equal working conditions: e-learning "covering the prevention of discrimination and harassment, and equal rights - a general version for all employees and an extended version for employees with personnel responsibility". Also, "surveys of adequate salary conditions have been conducted".

Employee survey findings (page 83). "The three highest-rated areas were: relationship with manager, safety, and meaningfulness and participation." "The three lowest-rated areas were feedback, autonomy, and workload ... with the lowest being 3.5 on a 5-point scale."

Diversity actions (page 84): a recruitment recommendation that "female candidates should always be presented whenever possible"; an internal women's network since 2023; and an HR toolbox including "unconscious bias" training for managers.

Resources. "Costs for the above measures for our own personnel are not classified as Capex or Opex at this level" (page 84).

Targets related to own workforce

Reference: page 82 ("Measures for follow-up (MDR-M) and targets (S1-5 and MDR-T)"). The targets "have been approved by the Group's Board of Directors".

The company is candid about the limits: "In the area of Health & safety ... more clearly quantified targets will be set in the coming years. For some of the issues reported concerning our own workforce, there are still challenges in obtaining relevant metrics and data points." "The metrics below have not been verified by an external party", and companies acquired in Q4 2025 (Alpine India, Airwave gruppen, Dennis Supply, Key Refrigeration) are excluded.

Note: the accident count of 73 here differs from the 64 work-related accidents reported for 2025 on page 86.

Characteristics of the undertaking's employees

Reference: page 84. "The accounting principles are that the number of employees is reported in terms of headcount (HC), defined as the total number of people with employment contracts."

Countries with at least 50 employees representing at least 10 percent of the total: United States 1,148, Australia 825, South Africa 757.

"A total of 1 149 employees left Beijer Ref in 2025 and staff turnover during the period was 17 percent (15). Staff turnover is based solely on full-time employees (FTE)."

Note: the 6,755 headcount does not reconcile with the 7,017 total in the FTE-based gender table on page 85 or with "more than 7,000 employees" on page 54.

Characteristics of non-employee workers

Reference: the ESRS index lists "S1-7 Information about non-employee members of the company's workforce" against "Information about non-employee contributors to the workforce p. 84" (page 92).

What page 84 actually contains. Page 84 carries only the section headed "Information about the company's employees (S1-6)". There is no separate S1-7 heading and no separate metric for non-employee workers such as self-employed people or workers supplied by employment agencies. The workforce tables at that reference disclose 214 temporary employees and 76 on-call employees within the 6,755 total headcount (page 84), all of them under employment contracts by the report's own accounting principle.

Scope statements elsewhere. The S1 chapter consistently defines its scope as "all employees and temporary staff" (page 80), and the S1 IRO table records the relevant value chain as "own operations and own and temporary staff" for each material impact (page 80). The health-and-safety accounting principle states that "the reporting includes all Beijer Ref's full-time and part-time contract partners" (page 86).

The disclosure is therefore marked reported on the authority of the company's own ESRS index, with the caveat that no distinct non-employee workforce figure is published.

Collective bargaining coverage and social dialogue

Reference: page 85 ("Collective bargaining coverage and social dialogue (S1-8)"), with accounting principles in the footnote on the same page.

"Beijer Ref's policy entails freedom of association, i.e. trade unions are permitted and so is the right to collective agreements. In China, however, certain restrictions on freedom of association apply by law" (page 85).

Coverage. "In the Beijer Ref Group, 24 percent of employees are covered by collective agreements. The number of employees working at sites with employee representatives is 8 percent, i.e. social dialogue coverage." The stated calculation is 1,639 employees covered by collective agreements divided by 6,755 employees for the first figure, and 559 employees at sites with employee representatives divided by 6,755 for the second (page 85).

Banded disclosure. "The regions with >50 employees and >10 percent of the total number of employees are all located outside the EEA and have collective agreement coverage of 0-19 percent" - namely the USA, Australia and South Africa. The EEA and workplace-representative columns of the banded table are empty, since no single EEA country meets the >50 employees and >10 percent threshold (page 85).

"There is no agreement for Beijer Ref regarding representation in a European Works Council" (page 85). Union cooperation is described in France, Italy, the United Kingdom, Sweden and the Netherlands (page 83).

Diversity metrics

Reference: page 85 ("Diversity indicators (S1-9)"). Management figures cover full-time equivalents, where "company management ... comprises of employees who report directly to the respective company Managing Director".

Age-band comparatives for 2024 are marked N/A. "The Board of Directors consists of four different nationalities ... and Group management is represented by four different nationalities. Beyond this, Beijer Ref currently only measures gender distribution among possible diversity aspects."

Female representation fell in both company management (20 to 16 percent) and Group management (14 to 12.5 percent); the report does not comment on the decline.

Adequate wages

Reference: page 85 ("Adequate wages (S1-10)").

The disclosure is a nil return, given in full: "The company has no employees whose wages fall below an adequate wage level in any country of operation. An adequate wage level is a wage that enables a reasonable and dignified life for the employee, based on local conditions" (page 85).

No benchmark, reference wage source or country-level breakdown is given, and no percentage of employees paid below an adequate wage is quantified beyond the statement that there are none. Supporting context sits elsewhere in the S1 chapter: the Code of Conduct addresses "the identified material issues of equal and fair working conditions, including fair and adequate wages" (page 81); the Supplier Code of Conduct carries wage requirements for suppliers' own workforces (page 81); and under actions, "surveys of adequate salary conditions have been conducted" during 2025, alongside a pilot survey of pay differences between women and men (page 82). Beijer Ref also states that it "works to ensure that all local organisations have reasonable salary levels, guarantee equal pay for equal work" (page 83).

Health and safety metrics

Reference: pages 85-86 ("Work-related accidents (S1-14)", with accounting principles and the outcomes table on page 86).

Accounting principles (page 86): "Work-related injuries are measured as the number of injuries resulting in absence from work exceeding one day per million working hours. The reporting includes all Beijer Ref's full-time and part-time contract partners." Long-term sick leave is "more than 14 consecutive days".

"Beijer Ref has a long-term zero vision for workplace accidents ... In connection with every workplace-related accident, a basic analysis of the underlying factors is conducted" (page 85).

Note: the accident count here (64 for 2025) does not agree with the target table on page 82, which reports "73 (64)" accidents against the same frequency of 5.5 (5.8). The two tables appear offset by a year in that column.

Compensation metrics (pay gap and total compensation)

Reference: page 86 ("Salary differences (S1-16)"). The Appendix B table maps "ESRS S1-16 Unadjusted gender pay gap point 97 a" and "Excessively high CEO salary point 97 b" to this page (page 94).

Gender pay gap. "For 2025, pilot work has begun on compiling figures on pay differences, initially based on average salaries for men and women. The results for 2025 are based on total compensation, base salary, and bonuses. This shows that in 2025, men have 19 percent higher compensation on average." No 2024 comparative is given, and the basis is average rather than median pay.

CEO pay ratio withheld. "The compensation ratio for the highest paid in the organisation in relation to the median value for total compensation will not be reported by Beijer Ref for 2025, as the reliability of the measure is not yet sufficient." The stated reason is data reliability, not confidentiality or a phase-in provision.

Regulatory context. "Beijer Ref's companies within the EU with more than 100 employees comply with the EU directive on transparency regarding salaries. Employers with 250 or more employees must report annually ... The report must show pay differences between women and men performing the same or equivalent work." Under actions, a pilot survey of pay differences "has been initiated and is currently being developed" (page 82).

Incidents, complaints and severe human rights impacts

Reference: page 86 ("Discrimination or failure to respect human rights (S1-17)").

The ten discrimination cases are the first year of this metric: the target table records the 2024 comparative as N/A and notes that "the follow-up was implemented in 2025, taking into account the UN Global Compact's guiding principles for business and human rights" (page 82).

"If cases of discrimination arise, they are investigated in accordance with Beijer Ref's investigation process, with the aim of clarifying the background and considering measures to prevent similar cases from recurring, such as modified or expanded training either locally or for a specific target group." "Reports via the whistleblower channel that are not considered to be actual whistleblower cases are generally referred back for local handling and resolution, unless a new report is received" (page 86).

Business conduct policies and corporate culture

Reference: pages 87-89 (G1-1 and MDR-P).

"Beijer Ref has a clear stance on ethics: zero tolerance for corruption and other unethical conduct. The primary way to combat corruption is to continuously create a corporate culture where each individual acts with integrity in line with Beijer Ref's values and policies", covering "all types of corruption, including bribery and extortion, nepotism, patronage and embezzlement" (page 87).

Policies tabled (page 88):

• Code of Conduct - covers "employees' personal conduct; anti-bribery and anti-corruption; compliance with competition laws; relationships with business partners; workplace standards and conditions; corporate responsibility". Owner: EVP HR and Communications.
• Anti-bribery and anti-corruption policy - owner: General Counsel. It "sets out minimum rules and guidelines; if stricter rules and/or regulations apply locally, they should be followed."
• Competition policy and Whistleblower policy - owner: General Counsel; the whistleblower process is "handled by an external independent party".
• Code of Conduct for Suppliers - owner: Global Purchasing Director.

All are Board-adopted and "reviewed annually and as needed", with effectiveness "monitored and assessed in relation to significant issues related to business ethics".

Culture assessment: "the corporate culture is evaluated on a regular basis through regular global employee surveys".

Prevention and detection of corruption and bribery

Reference: page 90 (G1-3), risk analysis page 87, governance page 89.

Risk analysis (page 87). "The professional groups within the organisation that are most exposed to corruption and bribery risks are purchasing managers, sales staff and managers at various levels, as well as, to some extent, the finance function. The starting point for the risk analysis is the areas identified in the Code of Conduct and the Anti-Bribery and Anti-Corruption Policy", reviewed "with relevant internal stakeholders such as the CEO & President, CFO, COO, and purchasing manager".

Training (page 90). "Over 90 percent (90) of the Group's employees have undergone training in the Code of Conduct and business ethics over the past three years." It "is to be repeated every two years using the Group's e-learning tool" and covers "how all employees - including management and the most exposed groups - should behave and act towards colleagues and business partners".

Reporting (pages 89-90). "Violations of the Anti-Bribery & Anti-Corruption Policy are reported via the Group's reporting system IBM Controller." The Compliance Office (EVP HR and General Counsel) "follows up, verifies the circumstances and discusses measures". There is "a process ... which ensures that an objective investigation is conducted by an independent party", and "the Board of Directors is informed of any cases at each meeting of the Audit Committee".

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are disclosed under MDR-T rather than as a numbered DR. G1-3 became a standalone targets DR only in the 2025/2026 ESRS; the report's own "G1-3" is the 2023 corruption-prevention requirement.

Reference: page 90 ("Measures for follow-up (MDR-M) and targets (MDR-T) for business ethics").

Beijer Ref does state measurable business conduct targets, tabled per material topic:

The aim is "that all operations shall be conducted in a fair and lawful manner ... These targets are based on Beijer Ref's Code of Conduct and Anti-Corruption Policy and are adapted to national and international guidelines and laws."

The 90 percent level "reflects the ambition to continuously cover new employees and employees in acquired companies, but, as a rule, there is a certain delay in completing the training. The outcome for 2025 is in line with the target." "The target has not been verified by an external party."

Incidents of corruption or bribery

Reference: page 90 ("Confirmed cases of corruption and bribery (G1-4)").

"Beijer Ref has not had any confirmed cases of, or fines caused by, bribery or violations of anti-corruption laws in 2025 (0 cases of bribery in 2024). In the event that cases arise, these are presented to the Board alongside the measures taken."

"In 2025, no reports (0) via the whistleblower channel qualified as whistleblower cases. All reports received via this channel are evaluated by the Compliance Office and, if necessary, by the management team as a second instance."

The S1-17 incident table on page 86 gives the same nil figure for whistleblower cases and records zero fines, penalties or compensation. The target table on page 90 confirms the outcome against the zero-tolerance target as "0 cases (0)", noting that "in the event of a confirmed case, this is presented to management and the board alongside the measures taken".

The Appendix B table maps "ESRS G1-4 Fines for violations of laws against corruption and bribery, section 24 a" and "Standards for combating corruption and bribery, point 24 b" to page 90 (page 94). No convictions, fines or amounts are reported for either year.