BEWI

The role of the administrative, management and supervisory bodies

Reference: pages 32-33 (incorporated by reference, p. 47; listed at p. 59).

BEWI ASA is "a Norwegian public limited liability company listed on the Euronext Oslo Børs" applying the Norwegian Code of Practice for Corporate Governance "adopted on 28 August 2025" (p. 30). Bodies: general meeting, board, and a CEO and executive management team, with an audit committee and a remuneration committee, each of two members in 2025, "one female and one male" (p. 33).

Composition (p. 33): six directors in 2025, "three female and three male, in line with the requirements of the Norwegian Public Limited Companies Act (NPLCA) section 6-11 a"; a seventh, male, was elected on 22 December 2025, giving 43 per cent female at year end (p. 98). "Four of seven of the directors are independent of the owners, five of seven are independent of executive management." No employee-elected directors, "as there are less than 30 employees in the parent company".

Sustainability competence (p. 33): the competency summary includes "Environment and climate", and the board "through the audit committee among others, have at least quarterly meetings with sustainability experts in the company, such as the Chief Sustainability Officer".

Activity (pp. 32-33): 20 board meetings in 2025, all directors attending all; audit committee six, remuneration committee four.

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

Reference: pages 32-33 (incorporated by reference, p. 47; listed at p. 59).

Cadence to the board (p. 32):

• Monthly - "Monthly management reports are made available to the board. The reports include financial and non-financial metrics."
• Quarterly - the board "reviews the group's progress on KPI's related to material topics".
• Annually - the board reviews and approves "(i) procedures for the board, sub-committees of the board and the CEO, (ii) key policies and procedures (May), (iii) the group's annual report (March), (iv) the annual double materiality assessment (DMA), (v) risk management system and risk assessment".

The board "is responsible for the group's adherence to governance principles, including internal control, audit matters, double materiality assessment, and risk management systems" (p. 32).

Sustainability reaches the board through the audit committee, which holds "at least quarterly meetings with sustainability experts in the company, such as the Chief Sustainability Officer, to discuss and review the company's material impacts, risks and opportunities (IROs)" (p. 33).

Integration of sustainability-related performance in incentive schemes

Reference: page 47 (listed at p. 59 under both ESRS 2 and E1.GOV-3).

"To secure alignment between the group strategy and executive incentives, climate-related KPIs are embedded in the executive remuneration framework, linking variable pay to performance against greenhouse gas reduction targets across scope 1, 2 and relevant scope 3 categories, in line with the group's climate transition plan" (p. 47).

"The board oversees the design and application of sustainability-linked incentive mechanisms, ensuring that performance conditions are aligned with BEWI's long-term objectives" (p. 47). Detail is referred to the separate Remuneration report.

Circular-economy performance is also tied to pay: progress on the resource-use targets "is monitored monthly at the business-segment level and reported quarterly to the executive management team and the board. Progress is also integrated into remuneration schemes, aligning incentives with objectives" (p. 83). In 2025 the remuneration committee "reviewed a proposed amendment to the composition of the performance indicators for the short-term incentive scheme for the management of the company" (p. 33).

Not disclosed: no percentage of variable remuneration linked to sustainability or climate targets, and no split between the individual KPIs.

Statement on due diligence

Reference: pages 48-49 (listed at p. 59).

"BEWI's due diligence framework follows a risk-based approach, focusing on identifying, preventing, and mitigating potential adverse impacts on people, the environment, and ethical business conduct" (p. 48).

"The board has the overall responsibility for the due diligence framework. The framework is approved by the executive management team and implemented and monitored by the sustainability and compliance teams, ensuring that due diligence remains a continuous process integrated into corporate strategy, decision-making, and daily operations" (p. 48).

Page 49 carries "a mapping of how BEWI applies the core elements of due diligence processes and where they are presented in the sustainability statement", covering all five elements:

• (a) embedding in governance, strategy and business model - GOV-1, GOV-2, GOV-3, SBM-3 (pp. 32-36, 47, 66-67)
• (b) engaging with affected stakeholders - SBM-2, S1-2, S1-3, S2-2, S2-3 (pp. 50, 94, 97, 103-104)
• (c) identifying and assessing adverse impacts - IRO-1, SBM-3 and topical policies (pp. 56-58, 66, 77, 81, 94, 102, 108)
• (d) taking actions - MDR-A and topical actions (pp. 65, 68, 77-78, 94, 105-106, 109)
• (e) tracking effectiveness and communicating - MDR-T and MDR-M (pp. 68-69, 72-74, 78-79, 82-84, 94-100, 106)

Norwegian subsidiaries additionally "publish an annual report of its compliance with the Norwegian Transparency Act", issued separately (p. 30).

Risk management and internal controls over sustainability reporting

Reference: page 47 (listed at p. 59).

"The board is responsible for overseeing BEWI's internal control framework and monitoring its effectiveness... The audit committee assist the board with addressing and preparing issues concerning the group's internal control - and risk management systems, and the financial and non-financial/ sustainability reporting" (p. 47).

Method and risks named (p. 47): "BEWI applies a structured risk-assessment methodology that evaluates data completeness, accuracy, reliability and compliance across business units. Risks include inconsistent or incomplete site-level data, limited data availability in parts of the value chain and manual data-handling processes that may increase the risk of errors."

Data sources (p. 47): the group sustainability reporting system, plus the ERP system, supplier due diligence, the BEWI Partner platform, BEWI Learn and the whistleblower channel.

Controls (p. 47): "Internal controls are performed monthly, quarterly and annually by the local business units and the group sustainability controller... Identified risks and findings are reported to the audit committee through quarterly updates and the annual audit cycle."

"The sustainability statements have been approved by the board. BEWI's external auditor, PwC, has performed a limited assurance of the sustainability statements" (p. 47).

Strategy, business model and value chain

Reference: page 13 and pages 20-22 (incorporated by reference, p. 47; listed at p. 59 as "p. 13, 20-22").

"BEWI operates through the two downstream segments Insulation & Construction and Packaging & Components, where end goods are manufactured, and the Circular segment, where used material is collected and recycled. In addition, the group has a 49 per cent ownership in the EPS raw materials producer BEWI RAW" (p. 13).

Value chain (p. 13): upstream is "sourcing of raw materials and energy sources required to produce heat/ steam for the production (used to expand polystyrene). While fossil-based feedstock remains the primary input for polymers, an increasing share of the raw materials is recycled feedstock sourced from the Circular segment." Output is "mainly supplied to the building and construction-, food-, automotive-, and HVAC industries in Europe".

Scale (2025): group net sales EUR 796.2 million (p. 27); Insulation & Construction EUR 420.9 million (p. 18); Packaging & Components EUR 339.1 million, up 10.0 per cent (p. 20); Circular runs "5 circular facilities, 1 jointly owned facility" with 146 FTEs (p. 21). Year-end headcount 3,028 (p. 99).

The Circular segment "produces recycled general purpose polystyrene (rGPPS), which is used as raw material in the production of solutions based on extruded polystyrene (XPS) and new EPS materials" (p. 21).

Interests and views of stakeholders

Reference: page 50 (listed at p. 59).

"The Chief Sustainability Officer is responsible for consolidating this information and ensuring that stakeholder views and interests are reflected in the DMA. These insights are then communicated to the executive management team and the board to guide strategic decision-making" (p. 50).

The page 50 table sets out, for seven stakeholder groups, how BEWI engages, the purpose, topics raised and BEWI's response:

• Owners and capital markets - reports, investor calls, ESG ratings; topics include climate targets and transition plan, CSRD, EU Taxonomy
• Employees - surveys, training, development dialogues, grievance channels; topics include health and safety, learning and development
• Customers - support, periodic reviews, partner due diligence; topics include product quality, microplastics, climate data and EPDs
• Suppliers - due diligence, on-site assessments; topics include workers' rights, health and safety
• Authorities - public hearings and regulatory processes; topics include the Circular Economy Act, Packaging Waste Directive, Construction Products Regulation
• Civil society - dialogue, partnerships, research; topics microplastics, circular economy
• The industry - association membership, joint initiatives

Six of the seven rows record that engagement "Informs DMA and strategic priorities".

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

Reference: pages 51-55 (listed at p. 59).

The DMA found material matters under climate change (E1), pollution (E2), resource use and circular economy (E5), own workforce (S1), workers in the value chain (S2) and business conduct (G1) (p. 51).

"A total of 16 IROs have been assessed as material, with 3 assessed as material from both an impact and financial perspective" (p. 51). Pages 52-54 describe each with its ESRS reference, value chain position and time horizon; page 55 maps each to metrics, baseline year, target and policies.

Counts in the chapters: E1 "four material impacts, one financial risk, and one financial opportunity" (p. 66); E2 "three material topics" (p. 77); E5 "three material impacts and one financial opportunity" (p. 81); S1 three (pp. 94, 97); S2 one (p. 102); G1 "two material impacts" (p. 108).

Revision of scope (p. 51): "The DMA were updated in 2025 to reflect BEWI's revised operational structure and scope of consolidation following the reduction of ownership in BEWI RAW to 49 per cent and the divestment of the traded food packaging business. As a result, topics previously assessed as material, including substances of concern and pollution to air and water (E2), are no longer considered material."

"Material IROs did not have a material impact on BEWI's financial position, performance or cash flows" (p. 51).

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

Reference: pages 56-58 (listed at p. 59).

The DMA has four steps: identification, "Assessment and scoring", "Calibration and validation" and "Management review and approval" (p. 56). Risks and opportunities were "supplemented by existing assessments, including enterprise risk, climate (TCFD), nature (TNFD) and salient human rights risks".

Scoring (p. 56): impact materiality uses scale, scope and irremediable character plus likelihood; the human rights threshold "was lowered based on ESRS 1 (45) requirements". For financial materiality, "the potential magnitude of financial effect (EBITDA, CAPEX, OPEX) constituted 50 per cent of the score, while the remaining half was based on the likelihood of occurrence". The threshold "was set at high".

Calibration (p. 56): a workshop with executive management and business segments did the final scoring "focusing on IROs scored as borderline"; results went "to the audit committee and the board for review and approval". and "Material IROs are incorporated into the Enterprise Risk Management (ERM) framework".

Topic processes (pp. 56-58): E1 - GHG Protocol and LCAs, physical risk per "the EU Taxonomy Climate Delegated Act (Appendix A), using geospatial data", transition risk per TCFD. E2 - "the LEAP approach, in line with EFRAG implementation guidance". E3 - ISO 14001 and the WWF Water Risk Filter. E4 - LEAP with ENCORE.

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

Reference: pages 59-61, with the EU-legislation datapoint table at pages 62-63.

The statement carries a full "ESRS disclosure requirements" table at pages 59-61, tagged "ESRS 2, IRO-2", listing each covered requirement against a page reference: all twelve ESRS 2 requirements, plus the topical requirements for E1, E2, E5, S1, S2 and G1 and the topic-specific IRO-1 entries for E1, E2, E3, E4, E5 and G1.

Phase-ins (p. 47): "BEWI has applied the phase-in provisions permitted under ESRS and has omitted certain disclosures in accordance with these transitional provisions. An overview of the applied phase-ins and omitted disclosures is presented in the ESRS Disclosure requirements table." Four are marked "Phase in": E1-9 (p. 59), E2-6, S1-13 and E5-6 (p. 60).

Incorporated by reference (p. 47): GOV-1 (pp. 31-33), GOV-2 (pp. 33-36), SBM-1 (pp. 13, 16-22), SBM-3 (pp. 14-15) and net revenue (p. 116).

Datapoints from other EU legislation (pp. 62-63): marks the E3, E4, S3, S4 and G1-4 entries "Not material", the E2-4 E-PRTR and SBM-1 40(d) entries "Not applicable", and the E1-9 66(a), 66(c) and 67(c) datapoints "Phase in".

Gaps: the Governance block (p. 61) lists only G1.GOV-1, G1.IRO-1 and G1-1, omitting G1-2 even though page 102 is tagged "MDR-P; S2-1; G1-2". The table prints E1-4 as "E-4".

Transition plan for climate change mitigation

Reference: pages 65-66 (listed at p. 59).

"BEWI's climate transition plan is aligned with a 1.5 degrees C pathway... For scope 3, the targets include category 1 and category 12 (end-of-life of sold products)" (p. 65). The 2030 targets "were validated in February 2026, using 2023 as the base year" (p. 68).

Locked-in emissions (p. 65): "A share of BEWI's future emissions is considered locked-in, primarily related to energy use and process emissions from existing manufacturing assets that cannot be fully decarbonised in the medium term." Qualitative only; no tonnage.

Levers (p. 65): "improving energy efficiency and optimising production processes, increasing the share of renewable electricity through sourcing and power purchase agreements (PPAs), expanding the use of recycled and renewable raw materials, and scaling the collection and recycling of post-consumer materials". The page 65 charts split the scope 1-2 path into energy efficiency (-12%) and renewable energy (-32%).

Dependencies (pp. 65-66): scope 3.1 reductions are "dependent to a large degree on the pace of decarbonisation among key upstream raw-material suppliers"; category 12 depends on "downstream waste-management and recycling infrastructure".

Capital allocation (p. 66): "At present, no material CAPEX is expected to be required to execute the transition plan." The plan "is approved by the board" and performance "is monitored monthly".

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 (pages 56-57) and the E1 SBM-3 / IRO-1 subsection (pages 66-67), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Methodology and exposure (pp. 56, 66): "Physical climate risks are assessed for all production facilities in line with the EU Taxonomy Climate Delegated Act (Appendix A), using geospatial data to evaluate site-level exposure to acute and chronic climate-related hazards. The assessment also considers exposure at critical supplier locations." "Results indicate limited exposure... The most relevant risks identified were storm surges, river flooding, and cold waves, affecting a small number of production sites." Page 67 rates each hazard Low, Medium or not relevant.

Scenarios (p. 67): the analysis "draws on recognised external reference scenarios, including the IEA Stated Policies Scenario (STEPS)", NGFS scenarios "and the IPCC SSP5-8.5 pathway". Three were applied: "an orderly transition aligned with a 1.5-degree pathway and net zero by 2050; a disorderly transition reflecting a delayed transition towards a 2-degree outcome by 2030; and a worst-case scenario representing a 3-4-degree 'hot house world' by 2080".

Not disclosed: when the analysis was carried out, or the key assumptions per scenario.

Resilience in relation to climate change

Back-filled from the ESRS 2 SBM-3 subsection "Resilience of strategy and business model" (pages 66-67), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

BEWI "has adapted the Task Force on Climate-related Financial Disclosures (TCFD) framework to structure its assessment and management of climate-related IROs. The results of these assessments inform the annual DMA and are integrated into the groups strategic planning and operations" (p. 66).

Implications for strategy (pp. 66-67): "BEWI is well positioned to benefit from a global shift towards a 1.5 degrees C pathway. Demand for energy-efficient insulation and circular packaging are set to grow." The insulation IRO "is embedded in the group strategy supporting the ambition to achieve 70 per cent taxonomy-aligned revenue"; aligned turnover was 57 per cent (pp. 66, 85).

Uncertainties (pp. 66-67): growth "depends on regulatory enforcement and customers' willingness to adopt low-carbon and circular alternatives... Weak policy frameworks could limit BEWI's ability to meet its strategic targets." BEWI also "plans to further enhance its physical risk methodology".

Capacity to adapt (p. 66): "Further assessments are ongoing... to develop resilience measures for facilities located in higher-risk areas." No quantified resilience analysis is presented.

Policies related to climate change mitigation and adaptation

Reference: page 68, tagged "MDR-P, E1-2" (listed at p. 59).

"BEWI's management of climate-related IRO's is embedded in its strategy and governance framework, rather than set out in a stand-alone climate policy. Climate change mitigation is central to the group's commitment to align its scope 1, 2, and 3 emissions with the 1.5 degrees C pathway by 2030" (p. 68).

"The transition plan defines BEWI's decarbonisation pathway and is implemented through measurable targets and metrics addressing key levers such as energy efficiency, renewable-energy sourcing, and use of recycled materials. Climate considerations are integrated into the ERM process, investment planning, and EU Taxonomy-aligned CAPEX reporting" (p. 68).

Instruments that do exist (p. 68): "BEWI's environmental policy formalises the group's commitment to climate mitigation and adaptation, while the Supplier Code of Conduct extends these principles throughout the value chain."

Accountability (p. 68): "The Chief Sustainability Officer oversees implementation and annual policy review to maintain alignment with the DMA and approval by the executive management or the board."

Page 55 lists the policies attached to the climate matters as "Corporate strategy", "Environment policy" and "Climate transition plan".

Not disclosed: policy scope by activity, value chain step and geography is not set out in MDR-P form.

Actions and resources in relation to climate change policies

Reference: page 68, tagged "MDR-A; E1-3" (listed at p. 59).

Own operations (p. 68): scope 1 and 2 "accounted for 12 per cent and 2 per cent respectively of the group's total greenhouse gas emissions".

• Energy efficiency - "In 2025, BEWI continued implementing its energy-mapping programme across production facilities to benchmark performance and identify efficiency opportunities."
• Renewable energy - BEWI "is actively pursuing, power purchase agreements (PPAs), and renewable-energy procurement in regions where such sources are available and commercially viable." Purchased renewable electricity rose 77 per cent (p. 70).

Value chain (p. 68): "Scope 3 emissions account for 86 per cent of BEWI's total greenhouse gas emissions. Purchased goods and services represent the largest share at 55 per cent, while end-of-life treatment of sold products accounts for 29 per cent."

• Closed-loop systems - "strengthened systems for collection and recycling of used EPS and XPS... diverting waste from incineration and landfill".
• Supplier engagement - "encouraging the adoption of science-based targets, improving climate transparency, and collecting supplier-specific Environmental Product Declarations (EPDs)".

These "emissions arise outside BEWI's direct operational control", so reductions "depend on effective collaboration across the value chain" (p. 68). No CapEx or OpEx figures are attached.

Targets related to climate change mitigation and adaptation

Reference: pages 65, 68-69 and 72, tagged "MDR-T; MDR-M; E1-4" (the index prints the code "E-4", p. 59).

"In 2025, BEWI submitted its 2030 near-term targets to the SBTi for validation. The targets were developed in accordance with SBTi criteria and the Greenhouse Gas Protocol and were validated in February 2026, using 2023 as the base year" (p. 68).

Scope 3 boundary (p. 68): "Other Scope 3 categories are currently excluded due to limited emission relevance and/or limited reduction leverage but are monitored and reassessed over time."

Progress (pp. 69, 72): scope 1 and 2 market-based emissions for continued operations fell from 128,546 tCO2e at base year to 103,492 tCO2e in 2025, 19 per cent below base year and 13 per cent below 2024, "driven by an increased share of renewable electricity following additional power purchase agreements (PPAs), resulting in a 57 per cent reduction in Scope 2 (market-based) emissions". The scope 3.1 and 3.12 intensity ratio moved from 3.13 kg CO2/kg at base year to 3.01 in 2025, 4 per cent below base year.

Not disclosed: no milestone years between 2025 and 2030, and no separate adaptation target.

Energy consumption and mix

Reference: pages 70-71, basis page 75 (listed at p. 59).

Continued operations (MWh, p. 71):

Discontinued operations added 50,298 MWh, giving total operations of 711,245 MWh, up 1 per cent.

Intensity (p. 71): 0.00083 MWh per EUR of net revenue from high climate impact sectors, up 5 per cent; entity-specific 13.99 MJ/kg raw materials, up 4 per cent, against a 2030 target of 12.02.

Narrative (p. 70): "the ramp-up of the new circular facility in Nörrkoping, together with growth in automotive and EPP raw materials (which are more energy-intensive per kilogram of raw material) contributed to higher energy intensity."

Basis (p. 75): "Data are based exclusively on metered records and supplier invoices resulting in low uncertainty."

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 73-75, basis pages 75-76 (listed at p. 59).

Continued operations (tCO2e, p. 73):

Scope 1 from regulated emission trading schemes: 0 per cent.

Scope 3 by category, 2025 (p. 73): 1 purchased goods and services 358,957; 2 capital goods 917; 3 fuel and energy-related 23,751; 4 upstream transport 60,936; 5 waste 312; 6 business travel 708; 7 commuting 2,032; 9 downstream transport 1,244; 10 processing of sold products 4,427; 12 end-of-life treatment 190,189; 15 investments 10,216. Categories 8, 11, 13 and 14 are nil (p. 76). Discontinued operations are reported separately at 302,924 tCO2e market-based (p. 74).

Intensity (p. 75): market-based 0.00095 tCO2e per EUR of net revenue, unchanged.

Restatements (p. 76): scope 1 and 2 reduced by 887 tCO2; category 4 moved to a spend-based method, raising the comparative 44 per cent; "the reported 2024 emissions under scope 3.12 have been significantly revised, leading to an increase of 101 501 tonnes of CO2".

Policies related to pollution

Reference: page 77, tagged "MDR-P; E2-1" (listed at p. 60).

"BEWI's environmental policy requires all production facilities to identify, control, and monitor potential sources of pollution in line with ISO 14001 and the Operation Clean Sweep (OCS) programme. The policy focuses on pollution prevention, incident avoidance, and continuous improvement in environmental performance" (p. 77).

Value chain reach (p. 77): "Environmental expectations extend across BEWI's value chain through the Supplier Code of Conduct, which sets requirements for pollution management, and environmental due diligence among suppliers and business partners."

Governance (p. 77): "Governance and oversight of environmental policies are integrated in BEWI's sustainability and risk management framework, as described in the section about sustainability due diligence." The Chief Sustainability Officer oversees implementation and annual review (p. 68).

Page 55 lists the environment policy against all three pollution matters, with "Operation clean sweep" and "ISO 14001" as the associated actions. Substances of concern are managed without a reduction policy: "BEWI has not set a quantitative target" for them (p. 79).

Not disclosed: policy scope by geography, the most senior level accountable, and whether it addresses soil pollution or substances of very high concern.

Actions and resources related to pollution

Reference: pages 77-78, "MDR-A; E2-2" (listed at p. 60).

Emissions to water and air (p. 77): "BEWI RAW has thermal treatment of off gases that removes styrene and pentane emitted during the production. All RAW's production facilities have wastewater treatment systems to remove VOCs before the water discharges." Group-wide, "All BEWI's production facilities operate management systems" for "monitoring, control and mitigation of pollution-related impacts".

Substances of concern (p. 77): actions "include defined operational controls, safe-handling procedures, employee training and compliance with REACH and national permitting requirements."

Microplastics (pp. 77-78): BEWI "has signed the Operation Clean Sweep (OCS) pledge... based on five core principles: conducting systematic risk assessments, identifying and analysing root causes of pellet loss, implementing preventive and corrective measures, and ensuring regular performance monitoring." "In 2025, the new EU regulation on preventing pellet loss entered into force... BEWI is certifying its facilities in accordance with the OCS certification scheme", and "is implementing the bow-tie methodology to quantify and track potential microplastic leakages".

Value chain (p. 78): suppliers and transport partners are encouraged to adopt OCS principles, "followed up through the BEWI Partner supplier evaluation platform". No CapEx is attached.

Targets related to pollution

Reference: pages 78-79, tagged "MDR-T; MDR-M; E2-3" (listed at p. 60).

Pollution to air and water (p. 78): "Targets for emissions to air and water are defined through site-specific environmental permits issued by competent authorities for each production facility. These permits set legally binding emission limit values and monitoring requirements."

Substances of concern (p. 79): "BEWI has not set a quantitative target for reducing the use of substances of concern. Instead, the management of such substances is addressed through site-level controls and continuous improvement processes." Page 55 records "No target" against both the substances of concern and the air and water matters.

Microplastics (p. 79): "BEWI has a target to achieve certification for all production facilities under the OCS programme by the end of 2026... Implementation of OCS supports compliance with regulatory requirements on microplastics, including the EU restriction on intentionally released microplastics."

Progress (p. 79): "As of the end of 2025, 40 per cent of BEWI's production facilities were OCS certified, compared with 5 per cent in 2024. Progress is reported annually to the executive management and board."

The OCS target is the only measurable outcome-oriented pollution target; permit limits are compliance thresholds set by authorities rather than targets BEWI sets itself.

Pollution of air, water and soil

Reference: page 78, basis for calculation page 80 (listed at p. 60).

Pollution to air, continued operations (tonnes, p. 78): pentane 0.9 (2024: 0.9), styrene 0.0, total 0.9 tonnes, 0 per cent change. Pollution to water: styrene, formic acid and isocyanate all 0.0.

The table also reports prevented pollution and the efficiency of burning units. For discontinued operations, the BEWI RAW business deconsolidated in July 2025, pollution to air fell 55 per cent to 161.1 tonnes and prevented pollution totalled 783.7 tonnes, with burning-unit efficiency of 76 per cent in total (p. 78).

Why own-operations figures are near nil (p. 77): "Potential impacts from emissions to air and water were historically linked to the BEWI RAW operations. As a result of the reduced ownership in RAW to 49 per cent, these emissions no longer form part of BEWI's pollution footprint in own operations."

Basis (p. 80): calculations "follow the methods prescribed in site permits and EU legislation, including Directive 2010/75/EU on industrial emissions and the associated BAT Conclusions". "One production site uses formic acid and isocyanate for PIR-board manufacturing. Emissions to air and soil are regulated under Lithuanian National Ambient Air Pollution Legislation and monitored through five-yearly measurements."

The E-PRTR datapoint (paragraph 28) is marked "Not applicable" (p. 62). No soil pollution figures are reported.

Substances of concern and substances of very high concern

Reference: page 79, basis page 80 (listed at p. 60).

BEWI presents a quantified "E2-5: Substances of concern" table in tonnes, split between continued and discontinued operations. It addresses both limbs of ESRS E2 paragraph 34 through four line items: total use in products, total integrated in procured materials, total amount that leave production facilities as emissions, and total integrated in sold products.

Each is broken down by the four substances BEWI identifies, and the sold-products block prints the hazard classes: "Pentane (H225, H304, H336, H411)", "Styrene (H226, H332, H315, H319, H361d, H372, H304, H412)", "Formic acid (H226, H290, H302, H314, H318, H331)" and Isocyanate (nine H-codes) (p. 79).

Where the impact sits (p. 79): "Following reduced ownership in the RAW operation, BEWI's activities do not involve the use of substances of concern. Consequently, material impacts are located upstream in the value chain. During the reporting period, no material changes were identified."

Basis (p. 80): "BEWI identifies substances of concern using the criteria defined in the PlastChem State of the Science on Plastic Chemicals report." Uncertainty "is considered low".

Gap against paragraph 35: "substances of very high concern" appears in the report only in the index title (p. 60). No separate presentation of substances of very high concern is given.

Policies related to resource use and circular economy

Reference: page 81, tagged "MDR-P; E5-1" (listed at p. 60).

"BEWI's strategy, supported by its environmental policy, governs the management of resource use and circular economy across its operations. The policy is built on four key principles: designing recyclable and reusable products, increasing resource efficiency and the use of recycled and renewable materials, facilitating the recycling of waste and end-of-life products to close material loops, and ensuring the safe handling and disposal of hazardous waste to protect people and the environment" (p. 81).

Value chain reach (p. 81): "These principles are embedded throughout the value chain through BEWI's Supplier Code of Conduct, which requires suppliers to apply resource-efficient production practices, minimise waste, and support sustainable consumption in line with circular-economy objectives."

The circular economy is positioned as strategy rather than compliance: "The transition to a circular economy is defined as a strategic driver of growth in BEWI's downstream operations" (p. 81). Page 55 lists the associated policies as "Use of recycled raw materials", "Design for recycling", "Material efficiency" and "Collection and recycling".

Not disclosed: policy scope by geography and value chain step, and the most senior level accountable, are not set out in MDR-P form.

Actions and resources related to resource use and circular economy

Reference: pages 81-82, tagged "MDR-A; E5-2" (listed at p. 60). "Actions are grouped into resource inflows and outflows" (p. 81).

Resource inflows (p. 81):

• Recyclability - "Engineering and R&D teams work closely with customers and recyclers to select mono-material solutions, avoid additives that hinder recycling, and maintain compatibility with established mechanical recycling systems." Transparency comes "through RecyClass certification... and REDcert certification at multiple sites".
• Resource efficiency - "Production teams systematically adjust product density and moulding parameters to reduce raw material use."

Resource outflows (pp. 81-82):

• Waste management - "BEWI aims to eliminate landfill disposal and achieve 80 per cent recycling of operational waste... a waste management programme has been implemented across production sites."
• Collection and recycling - "BEWI collects and recycles post-consumer waste, primarily EPS, reducing reliance on virgin materials and lowering lifecycle emissions."

Resources: investments have gone into "circular capabilities in its Circular segment... recycling capacity and infrastructure", tracked as EU Taxonomy-aligned CAPEX (p. 66). The segment runs "5 circular facilities, 1 jointly owned facility" with 146 FTEs (p. 21). No CapEx figure is attributed to the E5 actions themselves.

Targets related to resource use and circular economy

Reference: pages 83-84, tagged "MDR-T; MDR-M; E5-3" (listed at p. 60).

"BEWI has established voluntary targets and KPIs to measure progress in the transition toward a circular and resource-efficient business model. These targets are closely linked to the group's climate transition plan, addressing emissions associated with raw material production and end-of-life treatment of sold products" (p. 83).

Targets and progress (p. 83):

The waste target is a 2030 split of 80 per cent recycling, 20 per cent incineration and 0 per cent landfill, against 48 / 48 / 4 per cent in 2025 (p. 83). Page 55 gives the baseline year as 2023.

Governance (p. 83): "Performance is monitored monthly at the business-segment level and reported quarterly to the executive management team and the board. Progress is also integrated into remuneration schemes."

Two of the three targets are ahead of or at plan; the waste-to-recycling target moved backwards in 2025, and BEWI discloses the reason rather than restating the target.

Resource inflows

Reference: page 82, basis page 84 (listed at p. 60).

Inflows "consist of raw materials, packaging, water and energy used in own operations", reported "by material type, distinguishing between virgin and recycled materials, renewable and non-renewable resources" (p. 82).

Continued operations (tonnes unless stated, p. 82):

Discontinued operations: 67,179 tonnes (2024: 201,663).

Materials named (pp. 53, 81): "styrene", "polystyrene and polypropylene".

Basis (p. 84): inflows "include raw materials that represent more than 1 per cent of total consumption". "Recycled raw materials refers to post-consumer materials reintroduced into production after completing a previous lifecycle." Restatement: certain raw materials "were reclassified from fossil-based to non-fossil sources", restating 2024 by "an increase of 21 561 tonnes of renewable materials".

Resource outflows

Reference: pages 82-83, basis page 84 (listed at p. 60).

Outflows "comprise finished products and non-product outputs, including hazardous and non-hazardous waste", managed through "product design, material selection and process efficiency to reduce material intensity, increase recyclability, increase the share of recycled content and extend product lifetimes" (p. 82).

Recyclability (p. 82): "Depending on product application and collection conditions, recyclability rates reach up to 100 per cent. Clean post-consumer materials can be mechanically recycled multiples times without losing material properties."

Durability (p. 82): "Insulation products used in construction typically have service lives of 30-50 years."

By-products and wastewater (p. 82): "BEWI does not generate by-products or wastewater streams beyond those regulated through local permits, and these are not material within the ESRS E5 scope." This is a nil return, not an omission.

Circular offtake: used EPS and XPS collected reached 38,444 tonnes, up 16 per cent (p. 82), against a 2030 target of 60,000 tonnes (p. 83).

Basis (p. 84): "BEWI assesses recyclability based on material composition and the technical recyclability of EPS, XPS and EPP under standard industry conditions." "All products are fully recyclable, however, actual recyclability depends on how they are used, collected and treated in the market." Waste volumes appear under E5-5 Waste (p. 83).

Waste

Reference: page 83 ("E5-5: Waste", tonnes), basis for calculation page 84.

Continued operations (tonnes, p. 83):

Treatment profile against the 2030 target (p. 83): recycling 4,547 t / 48% (2024: 4,832 t / 56%) against 80%; incineration 4,609 t / 48% (3,234 t / 37%) against 20%; landfill 371 t / 4% (561 t / 7%) against 0%.

Composition (p. 82): waste "consist mainly of polymer residues, process scrap, packaging waste and limited amounts of hazardous waste".

Progress (p. 84): "The share of waste directed to recycling decreased compared with 2024, primarily reflecting changes in waste composition and operational volumes."

Basis (p. 84): "Waste data is collected from reports provided by waste handling companies... categorised into 18 distinct waste fractions." Page 76 describes the scope 3 waste calculation as using "17 waste categories"; the two counts do not agree.

Policies related to own workforce

Reference: pages 94, 97, tagged "MDR-P, S1-1" (listed at p. 60).

Health and safety (p. 94): "BEWI's Code of Conduct and health and safety policy outlines the commitment to ensuring safe and healthy working conditions. The policies apply to all employees, including part-time, non-permanent, and temporary staff." "The Chief Human Resource Officer oversees the overall compliance and effectiveness, while the executive management team reviews and approves the policies annually."

Equal treatment (p. 97): "BEWI's Code of Conduct and human resource policy define the group's commitment to human rights, equal opportunities, diversity and inclusion. These policies apply to all employees and are aligned with the UN guiding principles of business and human rights, the OECD guidelines for multinational enterprises and relevant ILO conventions." They "prohibit harassment, discrimination, and unfair treatment, while ensuring freedom of association, protection against child and forced labour, and fair compensation".

Scope extends beyond employees: the health and safety impact reaches "other workers operating under BEWI's direct or indirect control, including... agency staff and contractors" (p. 94). The EU-legislation table records paragraph 20 at p. 97 and paragraph 23 at pp. 94 and 97, while paragraph 21 (ILO Conventions 1 to 8) is "Not material" (p. 63).

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

Reference: pages 94 and 97, tagged "S1-2" in both subsections (listed at p. 60).

Health and safety engagement (p. 94): "Each production site has safety representatives who participate in local health and safety committees and collaborate with management to identify hazards, review incident reports, and propose corrective actions." "Feedback from employees is gathered through regular toolbox talks, safety walks, and annual engagement surveys."

Survey (p. 97): "BEWI's annual employer survey, BE-Heard... index, measured on a scale from 0 to 100, is built on four pillars: employee engagement, leadership, organisational capabilities and goals and strategy. The index increased from 62 in 2024 to 64 in 2025."

Formal representation (p. 97): "Employee engagements are further supported through formal structures such as work councils and social dialogue. In total, 61 per cent of BEWI's employees were covered by a collective agreement, and 75 per cent in a system with a social dialogue or local works council."

A health and safety committee "chaired by the Chief Human Resources Officer and comprising representatives from operations and local business units, meets quarterly" (p. 94).

Not disclosed: no single senior role with operational responsibility for workforce engagement is named, and effectiveness is not assessed beyond the survey index movement.

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

Reference: page 97, tagged "S1-3" (listed at p. 60).

Channels (p. 97): "BEWI encourages employees to raise concerns through direct dialogue with their line manager or local HR teams. In addition, BEWI maintains an independent whistleblowing channel managed by a third party, providing a secure and anonymous platform to report potential breaches of company policy, discrimination, or unethical behaviour without fear of retaliation."

Oversight (p. 97): "All reports are handled confidentially and reviewed by the Chief Legal Officer and Chief Human Resources Officer, with oversight from the chair of the audit committee."

Remediation in 2025 (p. 97): "In 2025, no cases of negative impacts on employees were identified through BEWI's grievance and whistleblowing mechanisms. Consequently, no remediating actions were required or implemented." This sits awkwardly against S1-17, which records three discrimination incidents and two complaints in the same year (pp. 97-98); the statement does not reconcile the two.

Limitations disclosed (p. 109): "Although no formal training on the whistleblowing system has yet been conducted", and "At present, BEWI does not have additional formal grievance mechanisms beyond the whistleblowing system." Awareness relies on "biannual internal communications distributed to all staff with a company email address".

Taking action on material impacts on own workforce

Reference: pages 94 and 98, tagged "MDR-A, S1-4" in both subsections (listed at p. 60).

Health and safety (p. 94): the management system "is built on due diligence and supported by ISO 9001, ISO 14001 and ISO 45001 certifications". "All injuries and near-misses are investigated to determine root causes." "Introduction training is mandatory for all new employees and contractors before they start working." "In 2025, BEWI carried out quarterly health and safety campaigns."

Equal treatment and development (p. 98): the 2025 BE Heard survey added "a section regarding discrimination... to increase awareness regarding DEI"; "In 2026, workshops and training activities are planned for managers within the area of unconscious bias". "All employees participate in an annual Performance and Development Dialogue (PDD)", feeding the talent review. BEWI Business School comprises "The Growth Programme, a nine-month learning initiative", the "Senior Leadership Programme" and "BEWI Learn". "BEWI conducts an annual salient human rights assessment, which includes the evaluation of DEI practices, fair treatment, and workplace equality."

Response to the 2025 safety deterioration (p. 95): "The Chief Operating Officer function in BEWI has been strengthened and will during 2026 increase focus on health and safety." No CapEx or OpEx amounts are attached.

Targets related to own workforce

Reference: pages 94-96 and 98, tagged "MDR-T, S1-5" in both subsections (listed at p. 60).

Health and safety (p. 94): "BEWI has a 2030 target to reduce the frequency of workplace accidents to 5-6 per 1 million working hours and to lower the severity rate to below 65 per million working hours. To achieve this, the group has established interim objectives aimed at the continuous reduction of both accident frequency and severity rates through 2030." The metrics table prints the 2030 targets as 6 for frequency and <64 for severity (p. 95).

Equal treatment (p. 98): "Target: 30 per cent women in management positions by 2030"; "Target: employee learning and development index score of 80 by 2030, measured through the annual employee survey."

Page 55 gives a 2024 baseline year for all four: severity 65, frequency 6, internal engagement index 80 per cent, share of female leaders 30 per cent.

Progress (pp. 95-96, 99): the frequency rate moved the wrong way, to 15.1 from 11.2, and severity to 178 from 121. Women in management rose from 19 to 22 per cent. The learning and development index "reached 67 in 2025, up from 66 the previous year and from 62 the baseline year 2023", which sits against the 2024 baseline in the page 55 table.

Not disclosed: whether workers or their representatives were involved in setting the targets.

Characteristics of the undertaking's employees

Reference: pages 99-100, basis page 101 (listed at p. 60).

Headcount by gender (p. 99): male 2,299 (2024: 2,471), female 729 (768), other and not disclosed 0, total 3,028 (3,239).

By contract type (p. 99): permanent 2,768 (2024: 2,990), temporary 260 (249), non-guaranteed hours 0 (0). In 2025: male 2,117 permanent and 182 temporary; female 651 permanent and 78 temporary.

By country (p. 99): Germany 500 (2024: 567), Netherlands 442 (621), Norway 367 (403), Poland 322 (310), Other 1,397 (1,338).

By region (p. 99): East 469, Nordic 1,041, West 1,518. "Region Nordic includes Norway, Denmark, Sweden, and Finland. Region West includes the Netherlands, United Kingdom, Germany, Spain, and Portugal."

Turnover (p. 100): "The number of employees was 6.5 per cent lower at the end of 2025 compared to 2024, due to organisational adjustments, and targeted redundancy programmes. During the year, 524 employees left the company, corresponding to 16 per cent of own workforce. In 2024, 548 employees left the company which equals to 16 per cent."

Basis (p. 101): "Headcount and FTE figures are based on the December reporting period." Restatement: "The 2024 headcount figures reflect all employees recorded as of December 2024; accordingly, both BEWI RAW and BEWI Food are included in the 2024 totals", which accounts for part of the fall.

Characteristics of non-employee workers

Reference: page 100, definitions page 101 (listed at p. 60 as "p. 99-100", titled "Characteristics of non-employees in the undertaking's own workforce").

"The number of non-employees totalled 258, comprising 66 women and 191 men, primarily consisting of self-employed individuals or workers engaged through employment agencies. In 2024 the total number of non-employees totalled 280, comprising 71 woman and 209 men" (p. 100).

The 2025 total does not equal the sum of the gender breakdown given (66 + 191 = 257); the 2024 figure reconciles.

Definition (p. 101): "Workers who are not employed directly by the company, such as agency workers and self-employed individuals, are referred to as non-employees."

Coverage by the S1 policies: the material health and safety impact extends to "other workers operating under BEWI's direct or indirect control, including permanent and temporary employees, agency staff and contractors" (p. 94); the policies "apply to all employees, including part-time, non-permanent, and temporary staff"; and introduction training "is mandatory for all new employees and contractors before they start working" (p. 94). The health and safety table reports "Number of fatalities... of other workers working on BEWI's sites" as zero (p. 95).

Not disclosed: the headcount is not split between self-employed and agency workers, and no methodology or uncertainty note is given for it.

Collective bargaining coverage and social dialogue

Reference: pages 97, 100 (listed at p. 60).

"In total, 61 per cent of BEWI's employees were covered by a collective agreement, and 75 per cent in a system with a social dialogue or local works council" (p. 97).

Page 100 presents the breakdown as an "S1-8: Collective bargaining coverage and social dialogue" table with coverage-rate bands of 0-19, 20-39, 40-59, 60-79 and 80-100 per cent, across three rows: "Employees - EEA (for countries with >50 empl. representing >10% total empl.)", "Employees - Non-EEA (estimate for regions with >50 empl...)" and "Workplace representation (EEA only)". The country codes placed in the bands are PL, DE, NL, SE and NO.

Comparatives (p. 100): "As S1 8 is subject to a phase in under Appendix C, and 2025 constitutes the first year of mandatory application, comparative information is not required in accordance with ESRS 1 paragraph 136." The requirement itself is reported for 2025, so this is not an omission; only the prior-year comparison is withheld, on a stated basis.

Definition (p. 101): coverage is "The proportion of employees whose working conditions (such as wages, hours, and benefits) are governed by a collective bargaining agreement negotiated between employers and workers' representatives or unions."

Note: the banded table's published layout does not make the country-to-band assignment unambiguous in extracted text, so the per-country bands are not restated here.

Diversity metrics

Reference: page 99, narrative pages 98-99 (listed at p. 60).

Employees by age (p. 99): under 30: 421 (2024: 472); 30 to 50: 1,437 (1,520); over 50: 1,170 (1,247); total 3,028 (3,239).

Gender distribution (pp. 98-99): "At the end of 2025, BEWI's workforce comprised of 76 per cent men and 24 per cent women. Among management positions, 78 per cent were held by men and 22 per cent by women. Overall, the gender mix in BEWI were stable compared to 2024... while women in management positions increased from 19 per cent to 22 per cent."

Top management (p. 98): "During 2025, BEWI's executive management team comprised of two women and four men, corresponding to a 33 per cent share of women which is the same as in 2024." Top management is "members of BEWI's executive management team" (p. 101).

Board (p. 98): "For the majority of the year, the board consisted of three women and three men. On 22 December 2025, a new male member was appointed... thus the composition was 43 per cent female and 57 per cent male at the end of the year."

Against the 2030 target of 30 per cent women in management (p. 98), the 22 per cent reached leaves an eight-point gap, narrowed by three points in the year, attributed to "targeted recruitment, leadership development programmes, and structured succession planning" (p. 99).

Not disclosed: age is not cross-tabulated with management level.

Health and safety metrics

Reference: pages 94-96 ("S1-14: Healt and safety", p. 95; basis p. 96); listed at p. 60.

Narrative (p. 95): "The most frequent category of accidents was related to slip, trip and fall accidents (38), equipment accidents (19) and struck by or caught in between objects (14)."

The deterioration is stated plainly (p. 95): "In 2025, BEWI had a negative development of accidents in a few business units... The Chief Operating Officer function in BEWI has been strengthened and will during 2026 increase focus on health and safety."

Basis and restatement (p. 96): frequency is "the number of workplace accidents per 1 000 000 working hours"; "In the 2024 sustainability statements, the frequency and severity were multiplied by 200 000. Due to the size of BEWI, this multiplicator is corrected to 1 000 000."

The share covered by a health and safety management system fell from 87 to 83 per cent, unexplained.

Compensation metrics (pay gap and total compensation)

Reference: page 100, basis page 101 (listed at p. 60 as "Remuneration metrics (pay gap and total remuneration)").

"The gender pay gap in BEWI was 13 per cent in 2025, down from 15 per cent in 2024, while the annual total remuneration ratio was 8 per cent, in line with 2024" (p. 100).

Basis for calculation (p. 101):

• "Gender pay gap is calculated as ((average gross male monthly pay - average gross female monthly pay)/average gross male monthly pay) x 100)."
• "Annual total remuneration ratio of the highest paid individual divided by the median annual total remuneration for all employees (excluding the highest-paid individual). The basis for calculation is monthly salaries for all employees employed at year-end. Employees with hourly salaries has been recalculated to monthly salaries based on country specific monthly working hours."

The EU-legislation table records paragraph 97(a) (unadjusted gender pay gap) at p. 100 and paragraph 97(b) (excessive CEO pay ratio) at pp. 121-123 (p. 63).

Context: the pay gap narrowed two points while the workforce gender mix stayed flat at 76 per cent men and 24 per cent women, and women in management rose from 19 to 22 per cent (pp. 98-99).

Note: the remuneration ratio is reported as a percentage ("8 per cent") rather than as the multiple ESRS S1-16 paragraph 97(b) contemplates, with no explanation of the difference or the year-on-year movement.

Incidents, complaints and severe human rights impacts

Reference: pages 97-98 (listed at p. 60).

Incidents and complaints (p. 97): "For 2025, BEWI recorded three incidents of discrimination, including cases of harassment compared to two in 2024. The number of complaints filed through channels for own employees to raise concerns or to the National Contact Points for OECD Multinational Enterprises was two (WB). In 2024 BEWI had zero cases through the whistleblower channel. The total amount of fines, penalties, and compensation for damages as a result of the incidents and complaints disclosed above were zero."

Severe human rights impacts (pp. 97-98): "BEWI registered no severe human rights incidents connected to its own workforce in 2025 or 2024, and no cases of non-respect of the UN Guiding Principles or OECD Guidelines."

Definition (p. 101): discrimination covers incidents "on the grounds of gender, racial or ethnic origin, nationality, religion or belief, disability, age, sexual orientation" and includes harassment.

The EU-legislation table records paragraph 103(a) at pp. 97-98 and 104(a) at pp. 97 and 102-103 (p. 63).

Tension with S1-3: page 97 also states that "no cases of negative impacts on employees were identified through BEWI's grievance and whistleblowing mechanisms. Consequently, no remediating actions were required", which the statement does not reconcile with the three incidents. No outcome or breakdown by ground is given.

Policies related to value chain workers

Reference: pages 102-103 (listed at p. 61).

The "Supplier Code of Conduct sets out mandatory requirements for all suppliers and contractual partners and is grounded in internationally recognised standards, including the OECD Guidelines for multinational Enterprises, the UN Guiding Principles on Business and Human Rights (UNGPs), and the ILO Core Conventions" (p. 102).

Content (p. 102): suppliers "must respect internationally recognised human rights and safe, fair and equitable working conditions"; they "are required to conduct human rights and labour-rights due diligence across their own operations, supply chains and subcontractors"; business ethics covers "anti-corruption, data protection, fair competition, conflicts of interest, import/export controls and economic sanctions"; and they "must maintain accessible and trusted grievances mechanism for workers... aligned with OECD and UNGP effectiveness criteria".

Enforcement (pp. 102-103): "Non-compliance... may lead to contract termination." "BEWI requires all suppliers to formally acknowledge and accept the Supplier Code of Conduct, being embedded in supplier contracts and purchase documents." It "is reviewed annually"; "The procurement department oversees... implementation of due diligence procedures."

Scope (p. 102): "BEWI's scope extends beyond direct suppliers to include lower tiers, as well as on-site workers not directly employed by BEWI."

Processes for engaging with value chain workers about impacts

Reference: pages 103-104 (listed at p. 61).

BEWI "has established a due diligence process to engage with business partners and suppliers to identify potential human rights violations" (p. 103).

Salient human rights assessment, five steps (p. 103): Data collection - "from internal audits, supplier self-assessments, industry initiatives, and stakeholder reports". Evaluation - "Internal experts assess each issue based on severity (scale, scope, and irremediable nature of potential impacts) and likelihood." Prioritisation - "focusing on the most significant risks to people". Action planning - "tailored action plans... Key performance indicators (KPIs) are established to monitor progress."

Supplier due diligence (pp. 103-104): an "Annual desktop assessment" of direct suppliers "based on spend, sector, country, and the group's salient human rights issues"; "Supplier screening" registering medium and high-risk suppliers in BEWI Partner for a self-assessment questionnaire, which also determines "whether tier 2 suppliers require additional screening"; and on-site assessment of high-risk suppliers.

Limitation stated (p. 106): "BEWI has not directly involved workers in the value chain, primarily due to the absence of established mechanisms for engaging workers across different tiers of the supply chain." Engagement is with suppliers about their workers, not with the workers themselves.

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

Reference: page 105, tagged "S2-3" (listed at p. 61).

"BEWI addresses concerns and grievances within its value chain through a framework grounded in transparency, trust and effective remediations. The responses are proportionate and tailored to the specific grievance raised" (p. 105).

Whistleblowing channel (p. 105): "BEWI provides a whistleblowing channel accessible at the group's website and supplier platform. The channel is monitored by an independent third party to maintain impartiality and confidentiality in handling reports." It "is open to both internal and external stakeholders" (p. 109).

Remediation framework (p. 105): "BEWI uses a structured remediation framework designed to promptly investigate and resolve grievances. When adverse impact is identified, the group collaborates with stakeholders to provide or facilitate appropriate remedies."

Outcomes in 2025 (p. 106): "There were no reported incidents of non-compliance with the UN Guiding Principles, ILO Conventions, or OECD Guidelines in BEWI's upstream or downstream value chain during 2025 and 2024. No supplier terminations or material human-rights remediation cases were recorded."

Not disclosed: whether value chain workers are aware of or trust the channel, and no number of grievances received from them.

Taking action on material impacts on value chain workers

Reference: pages 105-106 (listed at p. 61).

Monitoring (p. 105): BEWI "monitors progress on material social impacts through monthly and annual reporting, including tracking the number of suppliers assessed, audited, and followed up".

Facilities for drivers (p. 105): "A mapping of all BEWI sites was conducted in 2024 to assess... on-site facilities for drivers... This work continued in 2025 to close remaining gaps." That answers the material impact directly: "The risk of poor working conditions is high in the logistics sector... Issues such as inadequate rest periods, insufficient overtime pay, and limited access to proper facilities are prevalent" (p. 102).

Supplier risk assessment (p. 105): "In 2025, 85 per cent of suppliers classified as medium- and high-risk were assessed. Ten suppliers were identified as high risk... no suppliers were disqualified due to high-risk findings."

Supplier engagement (p. 106): "three supplier visits were conducted, comprising two internal on-site visits and one external audit. The findings primarily related to documentation gaps."

Resources (p. 106): "No capital expenditure (CAPEX) or operational expenditure (OPEX) were identified for addressing material impacts during 2025."

Against "more than 7 700 suppliers" (p. 102), three visits is a small sample; BEWI notes that "visibility into tier 2 and tier 3 suppliers remains limited".

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

Reference: page 106 (listed at p. 61).

"the group has established a set of key performance indicators with voluntary targets to monitor the implementation and effectiveness of its supplier due-diligence processes" (p. 106).

"BEWI aims for all suppliers classified as medium or high risk are registered, screened and periodically reassessed through BEWI Partner... by 2030... in line with the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights" (p. 106). "All suppliers identified as high risk are to undergo on-site assessments by 2030."

Progress (p. 106): "During the year, ten suppliers were classified as high risk, all of which were registered and screened through BEWI Partner, in line with the 2030 target. Screening coverage of medium-risk suppliers increased to 85 per cent."

Worker involvement (p. 106): "When setting targets, BEWI has not directly involved workers in the value chain." The targets measure BEWI's own process coverage rather than outcomes for workers.

Business conduct policies and corporate culture

Reference: pages 108-109 (listed at p. 61).

Material matters (p. 108): "BEWI has identified two material impacts related to business conduct" - corporate culture and whistleblower protection; "failure to uphold ethical standards could expose the group to legal, financial, or reputational risks".

Policies (p. 108): "The board has adopted a set of core policies... the Code of Conduct, anti-corruption policy, sanctions policy, and privacy policy. The executive management has implemented additional supporting policies - such as the gifts and events policy and the competition law compliance policy."

Accessibility (p. 109): "Other business conduct policies are currently available in English, with plans to translate the anti-corruption policy into relevant local languages."

Whistleblower protection (p. 109): the system "is administered by an external third party, allowing for anonymous submissions". But "no formal training on the whistleblowing system has yet been conducted", and "At present, BEWI does not have additional formal grievance mechanisms beyond the whistleblowing system."

Training (p. 109): mandatory online training covers "Code of Conduct, anti-corruption policy, competition law compliance policy, human rights due diligence, and GDPR requirements", repeated "annually or bi-annually, depending on role and risk exposure". No completion rate is published.

Management of relationships with suppliers

Reference: pages 102-103, tagged in the report "MDR-P; S2-1; G1-2" (p. 102).

Caveat on this classification: the Governance block of BEWI's "ESRS disclosure requirements" table (p. 61) lists only G1.GOV-1, G1.IRO-1 and G1-1, so G1-2 does not appear in the company's own content index. The classification rests on the printed "G1-2" tag on page 102. The same table prints E1-4 as "E-4" and mislabels two topical blocks, so it is demonstrably incomplete in places.

Supplier base (p. 102): "In 2025, the total number of suppliers decreased by 26 per cent... BEWI collaborates with more than 7 700 suppliers, with 87 per cent of total procurement spend concentrated among 452 suppliers, primarily within raw materials, transport and energy."

Approach (pp. 102-103): the Supplier Code of Conduct "sets out mandatory requirements for all suppliers and contractual partners" and is "reviewed annually". "Non-compliance... may lead to contract termination. However, BEWI always seeks to collaborate with its suppliers to improve their performance through dialogue and knowledge sharing." Screening runs through an annual desktop assessment and BEWI Partner, with 85 per cent of medium- and high-risk suppliers screened against a 100 per cent 2030 target (p. 106).

Not disclosed: whether social or environmental criteria are weighted in supplier selection, and no payment-practice information (see G1-6).

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed under the MDR-T/MDR-M heading rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

Reference: page 109, tagged "MDR-T; MDR-M".

BEWI sets no quantitative business conduct targets and says so plainly (p. 109): "Currently, BEWI has no overarching quantitative targets related to corporate culture or whistleblower protection. However, the group evaluates qualitative indicators and governance metrics - such as the number of reported cases, employee awareness levels, and training participation rates - to identify opportunities for improvement."

Page 55 confirms it, recording "No target" against both G1 matters.

Consistent with MDR-T's alternative limb, effectiveness is tracked in the absence of targets (p. 109): "each business unit within the group monitors and reports on concerns or suspected misconduct raised through internal channels monthly"; "Training completion rates are monitored and reported to executive management"; and the audit committee chair "is informed of all whistleblowing cases".

The tracking is described but not quantified: no number of reported cases, awareness level or training completion rate is published for 2025. BEWI also notes that "no formal training on the whistleblowing system has yet been conducted" (p. 109).