Betsson Ab

The role of the administrative, management and supervisory bodies

Reference: pages 47-48.

Betsson's ESG Policy is formally adopted by the Board of Directors. Oversight of sustainability is embedded in the Board's Rules of Procedure and the Audit Committee's Terms of Reference. The Board receives an annual update on sustainability covering material IROs, due-diligence implementation and the effectiveness of policies, actions, metrics and targets; the Audit Committee receives a yearly briefing and holds delegated responsibility from the Board.

A management-level Sustainability Forum, chaired by the VP Communications and Investor Relations, meets twice annually and includes the President and CEO and the Operational CEO. A Sustainability Working Group, led by the Head of ESG, coordinates day-to-day work and reports to the Forum.

Board composition: seven members, one executive and six non-executive. Gender diversity ratio (female to male) is 0.75; four members (57%) are independent. Employees are not represented on the Board. Sustainability is not a standalone risk category; it is embedded across the Group's Risk Management Policy and enterprise risk register.

In 2025 the Board completed tailored CSRD training delivered by an external provider.

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

Reference: page 49.

The Board receives an annual update on sustainability; the Audit Committee is briefed regularly on progress, risks and opportunities, covering KPI performance, due-diligence implementation and policy effectiveness. The Sustainability Forum meets twice a year; the Sustainability Working Group reports to it with detail on material IROs from the enterprise risk assessment and the double materiality assessment (DMA).

Matters addressed during the reporting period: Responsible gaming, Ethics and business compliance, Employee impact, Social impact and Climate impact, as well as CSRD readiness and progress, stakeholder dialogue and the DMA process and outcome.

Governance bodies consider these matters when overseeing strategy, major transactions and risk management, assessing how identified IROs may affect regulatory compliance, customer trust, operational resilience, workforce capability and long-term value creation. Responsibilities are formally embedded in the Board's Rules of Procedure and the Audit Committee's Terms of Reference.

Integration of sustainability-related performance in incentive schemes

Reference: pages 49-50.

Betsson's long-term incentive programme includes a sustainability-related performance criterion for selected members of the management team, linked to the Group maintaining an AA or higher ESG rating from MSCI at the end of each yearly performance period.

"If this ESG target is achieved, the payout related to the ESG component corresponds to 10 percent of the participant's base salary." This represents approximately 4.4 percent of the individual's total annual remuneration opportunity under the Performance Share Plan.

The ESG component is assessed against MSCI's independent, sector-specific ESG ratings rather than directly against Betsson's own GHG reduction targets; those targets are instead monitored under ESRS E1 through internal governance and do not currently constitute a remuneration performance indicator. The programme applies to the CEO, Group Management and the Operational Management team, is updated by the Board and approved yearly by the AGM.

Statement on due diligence

Reference: page 49.

Betsson maps the core elements of due diligence under ESRS 1, chapter 4, to where each is addressed in the statement:

This overview explains how the Group-wide due diligence process is integrated into governance, strategy and operational activities, and is presented as a signposting table rather than a narrative due-diligence statement.

Risk management and internal controls over sustainability reporting

Reference: pages 49-50.

Internal controls cover all sustainability-related disclosures (environmental, social, governance and value-chain data), addressing completeness, accuracy, timeliness, consistency and traceability. Each data point has an assigned owner and documented source; the Head of ESG reviews all entries before senior-management sign-off ahead of publication.

Key risks identified: data completeness risk, estimation/modelling risk for climate and GHG calculations, system/process risk (manual-entry errors, inconsistent definitions) and timing risk.

Mitigation controls: automated validation checks within the third-party platform Position Green, review by a third-party advisor, cross-functional checkpoints, documented methodologies, audit-trail requirements and corrective-action follow-up. Sustainability-related risks are mapped into the Group's annual Enterprise Risk Assessment by the GRC team using the standard risk-scoring methodology. Significant findings escalate to the bi-yearly Sustainability Forum, senior management and, where relevant, the Board.

Strategy, business model and value chain

Reference: pages 50-52.

Betsson AB is a holding company investing in fast-growing, profitable companies in the online gaming industry (casino and sportsbook, B2C and B2B), listed on Nasdaq Stockholm Large Cap. During 2025 the Group received new licences in Brazil, Paraguay, Poland and Italy, reaching 24 countries. Revenue split: CEECA 40%, Latin America 27%, Western Europe 19%, Nordics 12%, Rest of World 2%. Revenue is classified under the ESRS sector "Gambling and Betting Activities".

Value chain: upstream games providers, media/marketing agencies, server and cloud providers, affiliates and consultants; own operations centred on Betsson's proprietary technology platform with the operational headquarters in Malta; downstream B2C players and B2B operator customers. At period end Betsson employed approximately 2,899 people.

The Group does not operate in the fossil fuel sector and derives no revenue from coal, oil or gas activities. The global sustainability framework has five focus areas: Responsible Gaming, Ethics and Business Compliance, Employee Impact, Social Impact and Climate Impact, each with goals, KPIs and governing policies.

Interests and views of stakeholders

Reference: pages 53-54.

Key stakeholder groups: investors and analysts, customers, employees, legislators/regulators, and suppliers. A stakeholder assessment based on interest and influence is reviewed every two years, feeding the Sustainability Forum, Audit Committee and Board.

Highly prioritised topics from stakeholder dialogue: responsible gaming, anti-corruption, ethics/compliance, customer privacy and information security, AML, gender equality and diversity. Prioritised topics: climate impact, competence development, community involvement, tax transparency, work-life balance, responsible marketing.

Engagement channels vary by group: investors through AGMs, quarterly reports and press releases; customers through commercial material, 24/7 customer service and surveys; employees through internal channels, development discussions (at least twice yearly), a yearly survey and quarterly All Hands meetings, plus elected employee representatives in Malta; suppliers through the Supplier Portal and a Contract Lifecycle Management system. Outcomes are shared with the Board, committees and management teams at scheduled meetings.

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

Reference: pages 55-57.

The DMA identifies material matters under ESRS E1 (Climate change), S1 (Own workforce), S4 (Consumers and end-users) and G1 (Business conduct). Environmental impacts arise mainly from indirect energy use in offices and third-party data centres; workforce impacts from working conditions, wellbeing, equal treatment and skills; downstream impacts on consumers from data protection, cybersecurity, responsible gaming and marketing; governance impacts from anti-corruption, AML, tax transparency and whistleblowing.

"Betsson does not anticipate any major financial risks or significant investments arising from its material sustainability matters in the near term; associated costs are expected to remain within normal operational budgets."

The full IRO table (30 individually typed rows across E1, S1, S4 and G1) is presented on pages 56-57 with value-chain location, actual/potential status, positive/negative direction and classification as impact, risk or opportunity. The assessment process currently focuses mainly on risks and in some cases also impacts; it "will be further developed in 2026." Strategic resilience is assessed via the enterprise risk assessment (reviewed quarterly/yearly by the Board) and the climate scenario analysis (see E1).

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

Reference: pages 58-59.

The DMA methodology is adapted from the KPMG approach, supplemented by PwC's 2024 review and revisited in 2025, covering impact and financial materiality across the full value chain. Topics were identified via ESRS topical standards, sector-specific considerations for online gaming, regulatory expectations and internal workshops/expert interviews, validated against Betsson's full scope of activities.

Climate-specific process: GHG emission sources mapped across Scopes 1-3 using the GHG Protocol and the operational-control boundary; most material climate impacts sit upstream in cloud infrastructure and within own operations (electricity, business travel). Meter readers were installed at the Malta office in 2025 to improve data granularity.

Impact materiality: scale, scope, irremediability and likelihood, with negative and positive impacts assessed separately. Financial materiality: likelihood and magnitude of effects on performance, cash flow, cost of capital and access to finance, with defined thresholds. Sustainability risks are embedded in the Group's ERM framework rather than treated as a standalone category, using risk scoring matrices, workshops and specialist input (Responsible Gaming, Compliance, Information Security).

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

Reference: page 59; table and non-materiality statement page 81.

"Betsson reports only on material ESRS 'shall' requirements and has not included voluntary disclosures, except where they help contextualise required information. Phase-in provisions have been applied where relevant and permitted by the standards."

The Appendix table of Disclosure Requirements lists, by ESRS standard, page references: ESRS 2 (BP-1, BP-2, SBM-1 to 3, IRO-1, IRO-2, GOV-1, GOV-2) pages 47-59; E1 (E1-1 to E1-8) pages 60-66, 89-90; S1 (S1-1 to S1-6, S1-8 to S1-10, S1-14 to S1-17) pages 66-71, 91-92; S4 (S4-1 to S4-5) pages 71-76; G1 (G1-1 to G1-5) pages 76-80. "Phase in applied for S1-8."

"The topics assessed as non-material are ESRS E2 to E5... as well as ESRS S2 on workers in the value chain, ESRS S3 on affected communities, and ESRS G1-6 on payment practices," reflecting Betsson's digital, office-based model, its limited physical asset base and the absence of manufacturing/extractive activities (page 81).

Transition plan for climate change mitigation

Reference: page 61.

"Betsson does not currently have a climate transition plan as defined in ESRS E1-1." The Group instead has science-based targets, a climate strategy and roadmap to reduce emissions, and ongoing mitigation actions. "A full transition plan will be developed in 2027 following the mid-term SBTi review."

Betsson has committed to SBTi-validated (2021) targets: -55% Scope 1 and 2 GHG emissions and -15% Scope 3 emissions by 2030, from a 2019 base year. The baseline was updated in 2025 to reflect the Group's current composition; the mid-term SBTi review will incorporate it in 2026. As a digital, low-emission online gaming operator, Betsson frames the absence of a formal E1-1 transition plan as a data point in itself rather than a gap requiring remedy: the targets, strategy and mitigation actions described under E1-2 to E1-4 substitute for it pending the 2027 transition plan.

Identification of climate-related risks and scenario analysis

Back-filled from the ESRS E1 Climate Change Strategy/SBM-3 subsection, where this content is disclosed in the FY2025 report (pages 60-61). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Betsson's material climate IROs are classified by type in the IRO table (page 56-57): physical risks are not treated as a material standalone risk given the digital, office-based model's low sensitivity; transition risks (regulatory change, carbon pricing, stakeholder scrutiny) are material.

Scenario analysis: a Paris-aligned 1.5°C pathway and a high-emissions pathway exceeding 3°C (aligned with IPCC SSP3-7.0 or NGFS "Hot House World"), assessed qualitatively across short, medium and long-term horizons using expert judgement, DMA insights, public regional climate data and cloud-provider disclosures rather than quantitative modelling. "The scenario analysis does not introduce any new material IROs but rather confirms the time horizons... of the existing climate-related IROs identified through the DMA." Exposure/sensitivity indicators: office-location geography, cloud-provider dependence and energy-cost exposure.

Resilience in relation to climate change

Back-filled from the ESRS E1 "Climate resilience analysis" subsection, disclosed in the FY2025 report (pages 60-61). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"The resilience analysis was carried out in 2025 as part of Betsson's annual Group-wide Enterprise Risk Assessment cycle," drawing on the qualitative scenario analysis. Under both the 1.5°C and >3°C scenarios, "Betsson's business model remains resilient": the digital nature of operations, geographic office spread and reliance on cloud providers with established resilience programmes limit physical-risk exposure; transition-risk exposure is "modest."

Adaptive capacity: short term - flexible offices and cloud infrastructure enable adjustments to energy management, travel policy and supplier engagement; medium term - tightening cloud-procurement requirements and renewable sourcing; long term - continued technology/skills transition, with good access to financing since Betsson holds no carbon-intensive, stranding-exposed assets.

Uncertainty flagged: the analysis is qualitative only - "there is potential to further deepen the analysis... for example by increasing the level of detail in regional risk projections, asset-level hazard quantification, developing probability-weighted outcomes."No part of the business model was identified as incompatible with a climate-neutral economy.

Policies related to climate change mitigation and adaptation

Reference: pages 61-62.

Betsson's ESG Policy sets climate mitigation and responsible energy use as long-term strategic priorities, committing to emissions reductions in line with the science-based targets and to managing climate IROs per the DMA. No standalone adaptation policy exists; adaptation is integrated into the ERM framework and business-continuity planning.

Scope covers offices, data-centre arrangements and business travel. Upstream impacts are addressed via the Supplier Code of Conduct; downstream customer electricity use is monitored and climate-compensated, though offsets do not count toward target achievement. In 2025 Betsson obtained ISO 14001 (Environmental Management) and ISO 50001 (Energy Management) certifications and an ISO 26000 attestation for Azzuri Ltd, covering the Malta headquarters. Only ~1.13% REGOs were acquired for renewable electricity in 2025; no other renewable-electricity instruments were purchased. Governance sits with the Board (adoption) and the Sustainability Forum (implementation), with annual policy review.

Actions and resources in relation to climate change policies

Reference: pages 62-63.

Actions target specific material IROs: office/cloud energy-efficiency measures address Energy use - environmental impact and cost exposure; cloud optimisation and renewable-provider prioritisation address Climate change mitigation - mitigation actions; a new centralised travel-booking system (introduced August 2025) addresses Climate change mitigation - transition risk, since business travel is one of the most material Scope 3 sources.

Concrete 2025 actions: electrical meter readers installed at the largest (Malta) office; retrofitted energy-efficient lighting/HVAC; electricity-use emissions in offices fell to 761 tCO2e (from 1,273 tCO2e in the 2019 baseline); continued migration to cloud infrastructure and server decommissioning; community tree-planting/clean-up initiatives (no material emissions contribution).

"No significant capital or operational expenditure was required for the actions listed above, apart from the travel booking system." Expected reduction effects of 10-30% from travel measures are anticipated between 2026 and 2030 as procedures mature.

Targets related to climate change mitigation and adaptation

Reference: pages 63-64.

Science-Based GHG Emissions Reduction Targets, absolute, from a 2019 base year (Scope 1: 39 tCO2e; Scope 2 market-based: 1,836 tCO2e; Scope 3 SBTi baseline excl. Cat.11: 5,217 tCO2e; total 7,092 tCO2e). Target: -55% Scope 1+2 and -15% Scope 3 by 2030. Scope 3 categories covered: 1, 2, 3, 5, 6, 7, 11; categories 4, 8, 9, 10, 13, 14, 15 excluded as immaterial/zero.

GHGs covered: CO2, CH4, N2O, HFCs, PFCs, SF6, NF3. Offsets are explicitly excluded from progress measurement and used only for the separate climate-neutrality claim (E1-7). Methodology: GHG Protocol Corporate/Scope 2/Value Chain standards; organisational boundary: operational control.

Progress versus 2019 baseline: Scope 1 and 2 down 53% (Scope 1: 82 tCO2e; Scope 2 market-based: 808 tCO2e in 2025). Scope 3 rose 3.2% versus 2019, "partly driven by supplier methodology updates" (AWS's inclusion of upstream Scope 3). Targets validated by SBTi in 2021; mandatory SBTi review due in 2026.

Energy consumption and mix

Reference: page 64, quantitative table page 89.

Total energy consumption 2025: 2,706.93 MWh. Mix: 76.64% fossil (entirely purchased electricity/heat/cooling from fossil-based generation), 7.55% nuclear, 15.81% renewable (428 MWh, entirely purchased renewable electricity; no self-generation). Betsson uses no coal, crude oil, petroleum products, natural gas or bio-based fuels, and neither produces renewable nor non-renewable energy on site.

The energy-intensity-per-net-revenue disclosure applies only to high climate-impact sectors; Betsson does not fall within these sectors, so this metric and its net-revenue reconciliation are not applicable.

Betsson states it "continues to focus on increasing the share of renewable energy within its energy mix, in line with its climate objectives and its obligations under the CSRD and ESRS E1."

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 64-65, quantitative table page 89.

Organisational boundary: operational control. Methodology: GHG Protocol, with DEFRA (2024), EXIOBASE (2019), AIB (2024), IEA (2024), NTM (2018) and supplier-specific factors.

Scope 1: 82 tCO2e (mobile combustion and fugitive emissions only; no stationary combustion or process emissions; 2.66 tCO2e biogenic CO2). Scope 2: 808 tCO2e market-based / 718 tCO2e location-based (no renewable-electricity contractual instruments purchased in 2025). Scope 3: 5,899 tCO2e (incl. use of sold products), dominated by business travel (2,310.20 tCO2e), employee commuting (1,277.86 tCO2e) and purchased goods and services (1,273.61 tCO2e); categories 4, 8-10, 13-15 excluded as immaterial.

Contractual instruments covered 1.13% of electricity consumption (REGOs only; no RECs, GOs or I-RECs). AWS's 2025 methodology update (including upstream Scope 3) increased reported emissions. GHG intensity per net revenue is disclosed on both location- and market-based bases.

GHG removals and GHG mitigation projects financed through carbon credits

Reference: pages 65-66.

Betsson has purchased voluntary carbon credits annually since 2017 through South Pole, certified under Verra and Gold Standard. For 2025 Betsson will cancel credits equal to 100% of total reported Scope 1-3 emissions (including customer electricity use) plus a ~10% buffer.

"Carbon credits... do not contribute to the achievement of Betsson's science-based targets and do not reduce reported gross emissions." Betsson does not finance GHG removals and makes no Article 6 corresponding-adjustment claims (0% of credits so adjusted). Reversal risk is managed via Verra/Gold Standard permanence mechanisms and is "not considered material" given annual compensation with no long-term storage claims.

2024 reference year: 8,047 tCO2e cancelled (0% from EU projects); 17% removal / 83% emission-reduction projects; quality standard 32% Verra VCS CCBS, 68% Verra VCS. The 2025 project split had not yet been finalised at time of reporting.

Internal carbon pricing

Reference: page 66.

"Betsson does not currently apply an internal carbon price as part of its climate-related decision-making or investment processes."

The Group states it "continuously monitors best practices and regulatory developments and will evaluate the introduction of internal carbon pricing as part of future climate strategy reviews." This is a complete nil disclosure under E1-8 rather than an omission: the requirement is to disclose whether an internal carbon price is applied, and Betsson answers that it is not.

Policies related to own workforce

Reference: page 67.

Betsson's workforce policies are grounded in the Code of Conduct, based in part on the UN Global Compact's ten principles, plus global and local HR policies. Coverage includes working conditions, job security, working time, hybrid work, wellbeing, mental health, and non-discrimination, with local HR support for reasonable adjustments for employees with disabilities.

Health and safety: formal workplace accident-prevention policies across major locations - in Malta (largest site) a Health & Safety Policy covers mandatory incident reporting, risk assessments, emergency procedures and first-aid/fire-warden structures; in Sweden a Work Environment Policy covers physical and psychosocial risk assessments and safety rounds.

Data protection within employment is governed by the Data Protection and Privacy Policy (GDPR-aligned). Remedy runs through grievance procedures and a global whistleblowing channel. Oversight sits with the Chief Human Resources Officer, supported by global/local HR, Compliance, Legal and GRC; policies apply globally and, where relevant, to non-employees under Betsson's supervision, and are reviewed annually.

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

Reference: pages 67-69.

Betsson engages its workforce through open access to managers and HR, quarterly All Hands meetings, development discussions (at least twice yearly), team meetings, employee surveys, engagement forums and a digital suggestion channel. Elected employee representatives in Malta supplement these processes through consultation.

These channels surface workforce priorities - fair and secure working conditions, wellbeing, manageable workloads, equal opportunities, skills development and inclusion - that align with the IROs identified in the DMA. Feedback is fed into annual HR planning and informs wellbeing initiatives, hybrid-work practices, workload management and career-progression decisions.

A global, external whistleblowing channel, with a supporting policy and framework, allows employees and external stakeholders to report concerns anonymously. The Board, relevant committees, Group and Operational Management teams and the Sustainability Forum are kept updated on engagement outcomes at scheduled meetings.

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

Reference: page 69.

Workforce complaints relating to discrimination, harassment and other concerns are handled locally by HR under the Code of Conduct, local people policies and applicable legislation. Cases requiring independent handling, or raising integrity concerns, can be escalated through Betsson's confidential whistleblowing channel, administered by the Governance, Risk and Compliance function with safeguards for confidentiality and protection against retaliation; access to case details is limited to those who need it.

Information on workforce-related complaints is maintained locally, with only formally escalated matters reported to Group HR. Where a substantiated case arises, remediation may include corrective or disciplinary action, training, mediation or adjustments to working arrangements, applied under internal procedures and local law.

"No escalations of discrimination, harassment or other human-rights-related complaints were received at Group level during the reporting period."

Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions

Reference: page 69.

Workforce-related impacts, risks and opportunities directly shape Betsson's strategic priorities: secure employment, fair working conditions and balanced workloads underpin operational stability; the hybrid working model and structured scheduling support recruitment and retention of skilled technology, compliance and responsible-gaming staff. Expansion into new licensed markets increases regulatory/competence demands, reinforcing training and compliance-culture investment.

Positive impacts arise through inclusive culture, secure employment and wellbeing policies; principal negative impacts/risks relate to high work intensity, uneven gender representation in certain functions, and compliance risk from fast-changing regulation. Dependencies include skilled technical/compliance staff and responsible-gaming teams.

No particularly vulnerable workforce groups were identified in the DMA. Actions flow through investments in wellbeing, training, diversity/inclusion, recruitment and responsible working-environment practices, overseen via HR, the Sustainability Forum and the enterprise risk assessment.

Targets related to own workforce

Reference: page 69; targets detailed at S1-6, S1-8 and S1-9.

Betsson maintains named workforce targets: Target 1 (Employer of Choice) - at least 90% of employees recommending Betsson to friends and family; Target 2 (Employee Retention) - voluntary turnover at or below 30% (2025 outcome: 21%); Target 3 (Competence and Career Development) - 100% of new hires completing the 3-day induction course (2025 outcome: 99%, "very close to target").

These targets "strengthen employee engagement and the corporate brand" and support talent retention in competitive labour markets, mitigating risks related to loss of skilled technical and compliance staff. Targets are set through Betsson's annual HR/sustainability planning, informed by the DMA, and reviewed against outcomes annually; baselines are "not applicable" as they are absolute annual targets rather than multi-year trajectories.

Characteristics of the undertaking's employees

Reference: page 70, quantitative table page 91.

Total employees: 2,709 (Male 1,895; Female 814; Other 0; not disclosed 0). Employment type: 2,617 permanent, 92 temporary, 0 non-guaranteed-hours; 2,684 full-time, 25 part-time. Employee turnover rate: 21.08% (571 employees left during the period), "well below the Group's target of under 30%." Malta is the largest location (1,523 employees), with the remainder spread across Betsson's other offices (see also financial-statement Note 7).

A small number of employees in the recently consolidated Betsson France and Bukmacherska Ltd are excluded from the compilation due to HR-system limitations. Data is compiled from Betsson's central HR information system and validated by local HR teams before Group consolidation, using definitions that distinguish employees, non-employees and full-time contractors under Betsson's direct supervision.

Collective bargaining coverage and social dialogue

Reference: pages 70-71.

"Only a smaller share of Betsson's workforce is covered by collective bargaining agreements; the remainder are governed by Group-wide people policies that ensure consistent working conditions across all locations." Employees are entitled to benefits ranging from health insurance to parental leave and wellness allowances.

"Quantitative disclosures under ESRS S1-8 are subject to phase-in and are therefore not reported for the current reporting period," consistent with the index's note that "Phase in applied for S1-8" (page 81). The qualitative description of bargaining coverage and social-dialogue structure is nonetheless disclosed, satisfying the DR's narrative limb while the quantitative coverage-percentage datapoint is deferred under the ESRS 1 Appendix C phase-in relief.

Diversity metrics

Reference: page 70, quantitative table page 91.

Gender distribution in Executive Management (Group Management + Operational Management, 15 members): 4 women (26.67%), 11 men (73.33%), 0 other/not disclosed. Age distribution (Group-wide): under 30 - 733 employees (27.06%); 30-50 - 1,877 (69.29%); over 50 - 99 (3.65%).

"The gaming industry has traditionally been male-dominated... During the reporting year, more than 70 nationalities were represented in the organisation" and the workforce is "relatively young, with a significant proportion of employees under the age of 30." Diversity metrics are derived from the HR information system, with gender/age collected at onboarding via voluntary self-identification and maintained under applicable data-protection rules; management categories follow Betsson's internal job architecture.

Adequate wages

Reference: page 71.

"Betsson ensures adequate pay through established, market-based benchmarks and clear, gender-neutral principles for salary setting." Remuneration is reviewed regularly as part of HR governance to ensure it is fair, competitive and supports employees' long-term security and development.

This is disclosed as a qualitative confirmation rather than a quantified adequacy gap analysis; no named statutory minimum-wage comparator or percentage of employees below an adequate-wage threshold is given in the statement.

Health and safety metrics

Reference: the company's own ESRS content index lists S1-14 within its covered range ("S1-1 to S1-6, S1-8 to S1-10, S1-14 to S1-17," pages 66-71, 91-92), but no dedicated S1-14 heading, and no fatality count, accident rate or lost-days figure, could be located anywhere in that page range.

The only related content is qualitative, under S1-1 (page 67): "Workplace health and safety, including psychosocial wellbeing, is a core part of the employee experience at Betsson... strong emphasis is placed on preventive measures related to stress, workload and mental health." Malta (largest site) has a Health & Safety Policy covering "mandatory incident reporting, risk assessments, emergency procedures, and first-aid and fire-warden structures"; Sweden has a Work Environment Policy covering "physical and psychosocial risk assessments, safety rounds."

*Flag: the Appendix B legislative cross-reference table cites ESRS S1-14 paragraph 88(b), (c) and (e) (fatalities, accident rate, days lost) but the figures themselves are not printed in the statement we reviewed. This is worth checking against the filed PDF directly - it is possible the figures sit in a table our extraction could not capture.

Work-life balance metrics

Reference: page 71, quantitative table page 92.

Family-related leave (2025): 100% of employees entitled; of those, 3.91% took family-related leave (women 6.88%, men 2.64%, other gender identities 0%, not disclosed 0%).

"All employees are entitled to family-related leave in accordance with applicable national legislation... Findings from employee surveys and local follow-ups indicate that opportunities for hybrid working, flexible working arrangements, wellness benefits, and access to parental and family-related leave are appreciated by employees." Indicators are compiled from the HR information system, based on local statutory definitions and reported on a headcount basis, validated by local HR teams before Group consolidation.

Remuneration metrics

Reference: page 71, quantitative table page 92.

Aggregated (unadjusted) gender pay gap: 14.29%, calculated on base salary converted to full-time equivalents across all countries, functions and job levels. Annual total remuneration ratio: 59.47, compiled from the Group's HR Information System (base salary, short- and long-term incentives, and benefits, standardised and converted to euro).

"Any deviations are explained by competence- and experience-related factors." Betsson benchmarks pay using external data from Mercer, segmented by industry, region, country and job level, complemented by leaver data and recruitment salary expectations. The Appendix B legislative datapoint table marks the excessive CEO pay ratio datapoint (ESRS S1-16, para 97(b)) separately; the main index applies the ESRS 1 phase-in for that item.

Incidents, complaints and severe human rights impacts

Reference: page 71.

"No escalations of discrimination, harassment or other human-rights-related complaints were received at Group level during the reporting period." "No severe human rights incidents - including forced labour, child labour or human trafficking - were identified or reported within Betsson's workforce during the reporting period."

"Betsson received zero material complaints through its whistleblowing channel, zero complaints were filed with National Contact Points, and the Group incurred zero euros in fines or monetary sanctions; accordingly, no reconciliation or remediation information is required." Complaints are handled locally by HR per the Code of Conduct and applicable legislation, with escalation available through the confidential whistleblowing channel administered by GRC, and monetary fines/penalties are monitored through financial control and compliance processes.

Policies related to consumers and end-users

Reference: page 72.

Three named group-wide policies: Responsible Gaming Policy (minimise gambling-related harm via predictive analytics/AI detection, escalation protocols, mandatory training, monitored by G4/eCOGRA audits and reported to the COO/Board); Data Protection and Privacy Framework (privacy-by-design, vendor due diligence, breach notification, ISO27001-certified ISMS); Global Marketing Policy (prohibits targeting minors/vulnerable individuals, responsible-gambling messaging, affiliate monitoring via automated compliance tools).

Policies extend contractually to suppliers, affiliates and third-party vendors. Employees complete mandatory annual training on responsible gaming, data privacy and anti-corruption. Betsson is a UN Global Compact signatory; while its policies do not explicitly reference the UNGPs, they are "broadly aligned with their core expectations." Board-level policies are re-adopted annually; all are reviewed annually against audits, regulatory change and the enterprise risk assessment.

Processes for engaging with consumers and end-users about impacts

Reference: pages 72-73.

24/7 customer service via chat, email and phone, with all interactions logged, categorised and analysed for trends. Proactive outreach through regular satisfaction surveys and focus groups; direct, trained-staff engagement with customers identified as at-risk of gambling harm, including case-based assessments.

Insights feed into operational reports reviewed weekly/monthly by the COO and Head of Responsible Gaming, with major issues escalated to Operational Management and, where relevant, the Board. Customer service processes are audited by regulators and certification bodies such as G4 and eCOGRA, with results shared with the Board, COO, General Counsel and Head of Compliance. Customer service has received "multiple industry awards" recognising these standards.

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

Reference: pages 73-74.

Channels: brand websites, terms of use, privacy notices, 24/7 customer service (phone/chat/email), and the Data Protection Officer's published contact details. Customer Service handles approximately 500,000 queries per month; team leaders review issues daily, escalating unresolved cases to the Head/Director of Customer Service and the Complaints team, which works with Compliance and Legal and reports daily to the COO; major issues escalate to Operational Management and, if necessary, the Board.

Remedies include account adjustments, restrictions/suspension, responsible-gaming support or corrective data-protection measures, assessed through follow-up and case review. "Consumers are not subject to adverse treatment for using complaint, grievance or whistleblowing channels." Complaint handling is audited by regulators and by G4 and eCOGRA.

Taking action on material impacts on consumers and end-users

Reference: pages 74-75.

Dedicated teams in Customer Service, Responsible Gaming, Data Privacy and Marketing run ongoing behaviour monitoring, early at-risk outreach, privacy-by-design practices, supplier/affiliate checks and compliant marketing review, financed through operating expenditure plus external audits (G4, eCOGRA) and monitoring tools.

Remedies are impact-specific: safer-gambling issues via account restrictions, self-exclusion support and referral; data-protection issues via corrective technical/organisational measures and notification; marketing issues via content correction/withdrawal. Litigation disclosed: in a judgment dated 1 July 2025, the Supreme Court ordered BML Group Ltd to repay approximately EUR 500,000 to a Swedish player for services provided 2009-2014 (pre-dating the 2019 Swedish Gaming Act); Betsson "considers that the case relates to specific circumstances" with no broader expected financial implications.

Effectiveness is assessed via responsible-gaming indicators, satisfaction/complaint data and independent audits, reviewed through regular reporting cycles to senior management and the Board.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities (consumers and end-users)

Reference: pages 75-76.

Customer service targets: chat response ≤1 min (2025: 24 seconds); satisfaction ≥90% (2025: 92%); first-contact resolution ≥80% (2025: 85%).

Responsible gaming targets: all customers informed of RG tools (2025: 100%); at-risk customers actively engaged. 2025 performance: 86.8% of active customers have RG tools activated; 32.1% use deposit limits; 61,878 customers manually analysed for risk; 2.5% self-excluded for more than 6 months.

Targets are set through annual sustainability/operational planning informed by the DMA and customer feedback; no fixed base year is used, as monitoring is continuous. Progress is reviewed via QA scorecards, AI-supported sentiment/compliance checks, and independent audits (G4, eCOGRA).

Business conduct policies and corporate culture

Reference: pages 76-77.

Corporate culture rests on three core values - One Betsson, Passion and Fair Play - developed with employees and embedded via the Code of Conduct. Culture is assessed through the annual employee survey, All Hands feedback, the leadership index and performance reviews, alongside turnover trends, whistleblowing data, training completion and ISO audit outcomes; HR, Compliance and the Sustainability Forum escalate material themes to Management and the Board.

Policy framework: Code of Conduct, Corporate Governance Policy, Risk Management Policy, Anti-Corruption Policy, Whistleblowing Policy, Supplier Code of Conduct, Procurement Policy, Global Tax Policy and ESG Policy - Group-wide, aligned with the UN Global Compact, UDHR, UNGPs, OECD Guidelines and ILO conventions, developed by cross-functional HR/Compliance/Procurement/GRC experts and updated through the annual Internal Rules process.

Whistleblowing: a global, independent channel managed by the VP GRC and Chief Legal Officer, with Board oversight by two independent board members; reports acknowledged within seven days. Functions with higher corruption exposure (Commercial, Customer Service, Procurement) receive enhanced training.

Management of relationships with suppliers

Reference: page 77.

Supplier relationships are governed by the Procurement Policy, Code of Conduct and Supplier Code of Conduct, setting expectations for ethical conduct, legal compliance, human rights and environmental responsibility, aligned with the UDHR, UN Global Compact, UNGPs, OECD Guidelines and ILO Conventions. The Supplier Code of Conduct sets out engagement processes, contact routes and grievance mechanisms, including access to the confidential whistleblowing channel.

Betsson conducts supplier due diligence at onboarding covering legal compliance, data protection and information security, guided by responsible-business-conduct principles in the Code of Conduct. Payment practices form part of general supplier-relationship governance but "have not been assessed as material under ESRS G1-6." Betsson does not operate programmes specifically targeted at vulnerable suppliers; supplier risk is assessed within the broader enterprise risk framework.

Prevention and detection of corruption and bribery

Reference: pages 77-78.

Betsson maintains a zero-tolerance approach under its Anti-Corruption Policy and Framework, applying to own activities, suppliers, vendors, consultants and business partners. All employees, including management and internal Board members, complete annual online anti-corruption/bribery training; induction covers the Code of Conduct and anti-corruption principles for all new hires.

Detection mechanisms: the Procurement Business Process as primary detection route, supplier/partner due diligence with contractual anti-corruption clauses and periodic reassessment, a gifts register, budget-approval controls and internal cost control. Concerns route through the Global Whistleblowing Channel, investigated by the VP GRC (independent, reports directly to the Board) and the Chief Legal Officer, supported by Lead Counsels M&A and Corporate, with escalation to Group Management and, if necessary, the Board.

Policy implementation is managed by the VP GRC, reviewed annually through the Internal Rules process.

Targets related to business conduct

Reference: page 79 (part of MDR-T/GDR-T disclosures; the FY2025 report is prepared under the 2023 ESRS, which has no standalone G1 targets DR).

"Betsson has not set quantitative targets for the material G1 topics during the reporting period." In the absence of a formal target, the report describes how effectiveness is tracked - the other MDR-T limb: "Betsson's approach is based on continuous compliance, clear policies, adherence to regulatory requirements, and qualitative indicators such as training completion, whistleblowing procedures and supplier due diligence."

Follow-up includes the annual review of completed mandatory business-ethics trainings, supplier-audit results, confirmed corruption/bribery cases, whistleblowing case volumes and processing times, and internal-control/compliance-review outcomes, reported to Management and the Board. "As the indicators are qualitative... no formal baseline year has been established." Betsson states it "will continue to monitor developments in ESRS requirements and sector practice and will evaluate... whether formalised quantitative G1 targets are appropriate."

Confirmed incidents of corruption or bribery

Reference: page 79.

"For the reporting year 2025, Betsson recorded no (0) confirmed incidents of corruption or bribery across its operations or within upstream and downstream business relationships." No legal proceedings, fines or settlements related to corruption or bribery occurred during the period, and as no breaches of anti-corruption or anti-bribery procedures were identified, no additional remedial actions were required.

Political influence and lobbying activities

Reference: page 79.

"Betsson... does not make political donations and only engages in public affairs through its defined Public Affairs strategy or via recognized industry organizations that operate exclusively through legal and transparent means." Key associations: European Gaming and Betting Association (EGBA), International Betting Integrity Association (IBIA) and the Swedish Trade Association for Online Gambling (BOS); all lobbying positions are agreed at the industry-association level for consistency and legal compliance.

Betsson is registered in the EU Transparency Register (REG number 537657797802-81). Political engagement standards are set out in the Anti-Corruption Policy, and associations are used to advocate for responsible gaming, fair regulation and consumer protection.