BICO Group

Governance roles

Reference: page 41. Listed in the Appendix 2 content index (page 65). Composition datapoints are incorporated by reference: "ESRS 2 GOV 1 Governance Structure: Paragraph 21 a) to e) described on page 129 - 134 in the Governance report" (page 40).

"BICO's sustainability governance is anchored in a structured, groupwide model approved by the Board of Directors. The Board is the ultimate decisionmaking body for sustainability matters" and approves the Corporate Sustainability Strategy, the Corporate Sustainability Policy, the Sustainability Governance Model and the Annual Sustainability Report (page 41).

Allocation of responsibility (page 41):

• The Board has seven members, "of whom 57% are women".
• "The Audit Committee serves as the designated 'governing body' for sustainability oversight within the Board structure."
• The President and CEO is "responsible for executing the sustainability strategy", with the Executive Management Team "accountable for the operational execution of sustainability priorities".
• A Sustainability Council, "chaired by the Head of Global QA/RA and Sustainability", meets quarterly and reports to the EMT.

Information flows to the governance bodies

Reference: pages 41-42. Listed in the Appendix 2 content index at page 41 (page 65).

"Sustainability information is produced on a quarterly basis through BICO's internal reporting system and includes KPI trends, reconciliations to targets, and comparative figures. This enables timely review by the EMT and, as appropriate, escalation to the Audit Committee and Board" (page 41).

"At least annually, the Board receives an in depth sustainability report that includes the CEO's commentary and covers CO2 emissions, gender equality and diversity, health and safety, sustainability investments, policy compliance, value chain incidents, and analysis of financial effects. The Board is also updated annually on the status and outcomes of internal controls over non financial reporting" (page 41).

The Sustainability Council "provides structured quarterly inputs to management on: KPI analyses; compliance with sustainability policies and due diligence processes; Paris Agreement alignment; and prioritized actions. These inputs inform management's decisions and, where relevant, Board oversight" (pages 41-42).

A governance diagram on page 41 splits duties across Board (definition of strategy and targets, monitoring of target achievements), Executive Management and Audit Committee (regulatory monitoring, deploying and monitoring the strategy, reporting) and the three business areas (implementing sustainable business models).

Sustainability in incentive schemes

Reference: page 43. Listed in the Appendix 2 content index at page 43 (page 65), and separately as "ESRS 2 GOV-3-E1" at page 43 (page 65).

BICO reports a nil position, and states it as a settled intention rather than a gap to be closed:

"Climate-related or other sustainability considerations are not currently factored into the renumeration of members of our administrative and supervisory bodies, and it is not the plan to have this in the future." (page 43)

No share of variable remuneration is therefore linked to sustainability or climate performance, and no Executive Management or Board member bonus metric is tied to the SBTi-validated reduction targets set out under E1-4 (pages 53-54). The statement gives no further detail on whether sustainability performance features in incentive schemes below Board and Executive Management level.

This sits alongside the remuneration disclosures in the Management Report, where the share-based incentive programmes for the Board, Executive Management and key personnel are described without any sustainability-linked performance condition (page 45 of the Management Report section).

Statement on due diligence

Reference: page 43, with the mapping table in Appendix 1 at page 64. Listed in the Appendix 2 content index at page 43 (page 65).

The disclosure is made by incorporation by reference: "Please refer to Appendix 1 on page 64 of the Management Report for the table mapping information in the sustainability statement to the due diligence process" (page 43).

Appendix 1 mapping (page 64):

• a) Embedding due diligence in governance, strategy and business model - pages 38, 44-45
• b) Engaging with affected stakeholders in all key steps of the due diligence - pages 39-43
• c) Identifying and assessing adverse impacts - pages 38, 43, 44, 45, 48
• d) Taking actions to address those adverse impacts - pages 39, 41, 48, 52, 58, 60, 62
• e) Tracking effectiveness of these efforts and communicating - pages 52, 58, 62

"BICO's governance model assigns responsibilities across the Board, CEO/EMT, local management, and Group support functions (Finance, Legal/HR, IT, Investor Relations, Operations) to implement sustainability strategy and controls, including due diligence on material impacts across the value chain. The Sustainability Council agenda explicitly includes sustainability due diligence compliance" (page 43). Future steps include "developing a structured due diligence framework and a supplier engagement program" (page 39).

Risk management and internal controls over sustainability reporting

Reference: page 43. Listed in the Appendix 2 content index (page 65).

"BICO applies an internal control framework to sustainability reporting with the same integrity expectations as for financial reporting." The five components disclosed are (page 43):

• Control environment - "clear organizational structures, decision pathways, responsibilities, and authorisations, communicated through Board approved policies and instructions".
• Risk/impact assessment - "annual DMA at group and entity level to identify material impacts and related control needs".
• Control activities - "procedure and reconciliation based controls performed at multiple levels; quarterly performance monitoring via internal reporting with target reconciliations and trend analysis".
• Monitoring - "at least annual governance model review by the Group Head of Group Accounting & Financial Reporting; compilation of an annual self assessment from subsidiaries on key internal control topics".

On assurance: "BICO's consolidated sustainability statements are subject to limited assurance in accordance with Rev 19" (page 43). No specific risk of material misstatement is named or ranked.

Strategy, business model and value chain

Reference: page 44, with the market and business model description at page 12. Listed in the Appendix 2 content index (page 65).

"BICO's strategy is built on advancing 'bio convergence,' - the integrating of biology with advanced technology (AI, robotics, data orchestration and digital workflow platforms) to transform how life science laboratories operate." The model "focuses on enabling end-to-end automated, reproducible and resource-efficient scientific workflows" (page 44).

The ecosystem (page 44): hardware ("high-precision liquid handlers, single cell dispensers and bioprinters"), software ("The GBG suite enables hardware-agnostic orchestration"), and consumables ("Biomaterials, bioinks and other workflow-specific consumables").

Value chain (page 44). Upstream: "specialized electronic components and precison assemblies from global suppliers", with impacts "from energy-intensive industries such as semiconductor fabrication and transport". Own operations: "The operational footprint is relatively small due to the strategic use of outsourcing" and "Internal impacts relate primarily to business travel". Downstream: pharma and biopharma, biotech, academia and research institutes.

A value chain diagram runs source of origin, 2nd/3rd tier supplier, 1st tier supplier, inbound transport, own operations, outbound transport, waste, distribution, customers. Total net revenue is SEK 1,497,200,000 (page 55).

Interests and views of stakeholders

Reference: page 45. Listed in the Appendix 2 content index, and separately as SBM-2-S2, SBM-2-S3 and SBM-2-S4 (pages 65-66).

"The company conducts a double materiality assessment that includes systematic stakeholder engagement... Information is collected from sources such as surveys, interviews, focus groups, media analysis, peer benchmarking, and expert opinions" (page 45).

Stakeholder table (page 45), five groups:

• Customers - emails, online meetings, visits; outcome is public commitment through EcoVadis, CDP, UN Global Compact and SBTi.
• Employees - leadership communication, training, performance and development reviews; outcome an employee survey.
• Suppliers - email, online meetings, in person visits; outcome "Signing BICO Code of Con-duct".

"A thorough analysis stakeholder analysis was carried out in 2024. In 2025 the analysis was confirmed to be valid" (page 45). Worth noting against this: the DMA methodology states that "Consultation with affected external stakeholders was not conducted during this phase of the assessment" (page 46), so the engagement described is with customers, employees, investors, suppliers and regulators rather than with affected rightsholders.

Material impacts, risks and opportunities

Reference: pages 44-48, with the material IRO table at page 46 and topic-level SBM-3 sections at pages 50-52 (E1), 58 (E3), 60 (E5) and 62 (G1). Listed in the Appendix 2 content index, and separately as SBM-3-E1, E3, E5, S2, S3, S4 and G1 (pages 65-66).

Material topics (page 46): E1 Climate Change, E3 Water, E5 Circular, S2 Workers in the value chain, S3 Affected Communities, S4 Consumers and End-Users, G1 Business Conduct - 23 IRO rows with value chain location and short, medium and long term markers.

"As part of the DMA, BICO applied a 1.5 Celsius Paris-aligned transition scenario" (page 44), and "All the risks identified are considered to be translational risks" (page 48).

S2, S3 and S4 are handled differently: their IROs "are all reported in ESRS 2, BP-2 Disclosures in relation to specific circumstances on a high level" (page 45). S1 Own Workforce is presented as "IMPORTANT BUT NOT MATERIAL TOPIC" (page 48).

Process to identify and assess material IROs

Reference: pages 45-48. Listed in the Appendix 2 content index, and separately as IRO-1-E1, IRO-1-E5 and IRO-1-G1 (pages 65-66).

"During 2024, BICO carried out a Double Materiality Assessment (DMA)... supported by the Position Green platform, which provided a structured and ESRS-aligned methodology for evaluating materiality across the value chain. In 2025, BICO conducted a limited update of the double materiality assessment (DMA) to align the process with the latest guidance issued by EFRAG. A comprehensive review is planned for a future reporting cycle" (page 45).

Five-step methodology (pages 46-47): a gross list built from ESRS 1; stakeholder and process review; impact materiality; financial materiality; and mapping, with "The final DMA was approved by the Board".

Thresholds (pages 47-48): "Impact Score = Severity x Likelihood", severity for negative impacts being "scale + scope + remediability", plotted on "a 5x5 severity-likelihood matrix. A materiality threshold curve was applied, with a lower threshold for human rights-related impacts". Financial magnitude is scored on EBITDA bands from "Minor (+/1-2.5%)" to "Major (+/- <20%)".

Two limitations are stated plainly: "Consultation with affected external stakeholders was not conducted during this phase of the assessment" (page 46), and the risk process "was conducted independently, although the internal ERM framework was taken into account" (page 48).

Disclosure requirements covered

Reference: page 40, with Appendix 2 at pages 65-66 and Appendix 3 at pages 67-70.

BICO prints a real ESRS content index. Page 40 signposts it: "ESRS 2 IRO-2 List of ESRS Disclosure Requirements complied with in preparing the sustainability statement page - 65" and "List of datapoints that derive from other EU legislation... page 67".

Appendix 2, "Disclosures Requirements in ESRS Covered in BICO Group - ESRS reporting's Sustainability Statement / List of material DRs" (pages 65-66) lists ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2), E1 (E1-1 to E1-8), E3 (E3-1 to E3-3), E5 (E5-1 to E5-5), S2, S3 and S4 (each labelled "(phase in)", covering only SBM-2, SBM-3 and the topic's policies DR) and G1 (G1-1 to G1-5), each with a page reference.

Three points follow from the index itself. E1-9, E3-4, E3-5, E5-6 and G1-6 do not appear in it. S1 Own Workforce appears nowhere in it, consistent with page 48. And its page references are unreliable: IRO-2 is given as page 44 though Appendix 2 sits at page 65, and E1-2 Policies as page 42 though that section is at page 53.

Transition plan for climate change mitigation

Reference: page 49. Listed in the Appendix 2 content index (page 65).

The disclosure opens with a nil return, which is the finding:

"Currently no transition plan exists. The transition plan will be initiated in 2026, in which there is currently no climate-related Capex allocations or investments. All impacts identified in the assessment is transitional and the transition plan is based on this." (page 49)

What is disclosed instead is the framework the plan will sit in. "The BICO Group has established 2024 as the baseline year for its greenhouse gas (GHG) inventory." Targets "are designed to be aligned with a 1.5 Celsius pathway... To support this, BICO has formally pursued and achieved alignment with the Science Based Targets initiative (SBTi)" (page 49).

Emissions profile driving the plan (page 49): "Scope 1 and 2 account for around 9% of emissions, with remaining 91% of the emissions sitting within scope 3", the largest Scope 3 categories being transport and business travel.

Locked-in emissions (page 49): "BICO is not operating energy-intensive production processes. Any locked-in GHG emissions... would arise from the long-lived instruments. As estimated under Scope 3 category 11 use of sold products this is however assessed to be negligible."

The plan "is approved by management" (page 49).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 SBM-3 and IRO-1, where this content is disclosed in the FY2025 report (pages 44-48). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification (page 48): "All the risks identified are considered to be translational risks" - BICO reports no material physical climate risk, only transition risk. The E1 IRO summary at page 49 bears this out: six negative impacts (purchased goods emissions, upstream shipments, business travel, in-house energy, instrument electricity, downstream shipment energy) and two opportunities.

Scenario used (pages 44, 48): "As part of the DMA, BICO applied a 1.5 Celsius Paris-aligned transition scenario to assess climate-related risks and opportunities. The scenario draws on scientific resources... The scenario uses short- (1 year), mid- (2-5 years) and longterm horizons to reflect BICO's operational and product lifecycle realities." And: "A double materiality assessment was conducted for the three value chains, electronic equipment, Biomaterials and Consumables using a 1.5 degree scenario."

What is absent. No high-emission physical scenario, no scenario identified by published reference (no SSP, RCP or IEA pathway), no temperature projection, and no key assumptions on policy, macroeconomics, energy mix or technology.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3, where this content is disclosed in the FY2025 report under the heading "Resilience Analysis" (page 48). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

BICO does report a resilience conclusion, and reports it as a positive:

"The risks and opportunities assessed in the double materiality assessment correlate well with the existing business models and are monitored on a continuous basis preparing to act when needed. No changes in the way to do business are needed." (page 48)

Worked through one risk (page 48): "The risk of Change in technology adaptation and mindset among customers minimizing the consumption of single used products was assessed, and it will not impact the BICO business financially short term. By offering refurbished instruments BICO can reduce the CO2 footprint and increase sales revenue... Customers might underutilize the purchased instruments/equipment and may benefit from a leasing model instead of owning the assets."

What is absent. No areas of uncertainty are identified, and no capacity to adjust or adapt over short, medium and long term is discussed - no financial flexibility, no asset redeployment, no effect of planned investments, consistent with there being "no climate-related Capex allocations or investments" (page 49).

Policies related to climate change mitigation and adaptation

Reference: page 53, with the group policy architecture at page 42. Listed in the Appendix 2 content index at page 42 (page 65).

"BICO's Environmental policies that describe the ambitions within the climate change area are best expressed through the public commitments made by the company. We have commited to Paris agreement reduction target: The Group has formally committed to aligning its climate pathway with a 1.5 Celsius scenario and have validated target under the Science Based Targets initiative (SBTi) for net zero and GHG emission reduction for category 1,2 and 3 in near and long term" (page 53).

Two further instruments are named (page 53): a Sustainable procurement policy that "is being developed: Climate performance and emissions transparency are being integrated into supplier selection, onboarding, and renewal processes"; and an Energy and facilities policy - "The Group's operations follow a low carbon operational policy, prioritizing renewable electricity procurement and reduction of the office space footprint where feasible."

One scope exclusion is stated outright: "Energy efficiency is not one of the levers for the area and is for that reason not part of the policy" (page 53).

No accountable role is named for the climate policy, and adaptation policy content is not separately addressed.

Actions and resources in relation to climate change policies

Reference: page 53. Listed in the Appendix 2 content index at page 52 (page 65).

Two ongoing and planned actions are disclosed, both preparatory (page 53):

1. Supply Chain Decarbonization

• "Engaging with 1st tier suppliers in their relative geographical location to improve emissions data quality and transparency."
• "Introducing supplier climate questionnaires and requesting emissions disclosures aligned with GHG Protocol standards."
• "Initiating joint reduction activities (e.g., material substitutions, more efficient logistics flows, lowercarbon transport modes)."

2. Emissions Data and Monitoring Improvements

• "Strengthening internal systems to ensure consistent Scope 1, 2, and 3 data collection, verification, and comparability from the 2024 baseline onward."
• "Enhancing collaboration with transport partners to obtain more granular logistics emissions data."

Both carry the same caveat: "Milestones and KPI's will be established once the project is kicked off in 2026. The plan is currently under development and no capex or opex has been defined at this stage."

The same action set carries the E3 and G1 mitigation load (pages 58, 62). No completed 2025 action, no expected GHG reduction per action and no CapEx or OpEx figure is disclosed. Business travel reduction, named as a lever at page 49, is not carried into the action list.

Targets related to climate change mitigation and adaptation

Reference: pages 53-54. Listed in the Appendix 2 content index at page 52 (page 65).

The three stated commitments (page 54):

• "commits to increase active annual sourcing of renewable electricity from 61.0% in 2024 to 100.0% by 2030."
• "commits to reduce absolute scope 1 and 2 GHG emissions 100.0% by 2045 from a 2024 base year."
• "committing to a carbon intensity measure of reducing scope 3 GHG emissions from purchased goods and services, upstream transportation and distribution and business travel by 51.6% per unit of value created by 2030."

"The targets have been validated by SBTi" and were "calculated using the SBTi Corporate Net Zero Standard... Target coverage is Company-wide for scope 1,2 and 3 target" (page 54). A pathway table (page 53) gives glide paths for 2025-2045 from the 2024 baseline (Scope 1 37.24 tCO2e, Scope 2 market-based 1,731.90, Scope 3 23,184.07).

"Targets were finally agreed late 2025 and no reportable progress towards the target has been made at this point" (page 54).

Three figures do not hold together and should be checked. The 2025 Scope 3 category 1 and 4 reduction targets are printed as 94.31% and 126.50%, above the 97% end-state for 2045. The renewable electricity row shows 58.15% for 2024 and 46.57% for 2025, against a narrative baseline of 61.0%. And the Scope 3 2024 baseline does not match the 23,119.07 tCO2e in the E1-6 retrospective table (page 57).

Energy consumption and mix

Reference: pages 54-55. Listed in the Appendix 2 content index at page 54 (page 65).

Reported figures for 2025 (page 55), MWh:

Coal, crude oil and petroleum products, natural gas, other fossil sources, renewable fuels including biomass and self-generated non-fuel renewable energy are all reported as 0.00 MWh. "Share of renewable sources in total energy consumption (%) 46.57". Energy produced is 8.50 MWh, all non-renewable. Energy per net revenue in high climate impact sectors is "0.00149" MWh per thousand SEK.

Two internal inconsistencies are worth checking before the figures are reused. The fossil subtotal of 854.31 MWh is labelled "calculated as the sum of lines 1 to 5", but the five fossil lines as printed sum to 260.95 MWh, leaving 593.36 MWh unaccounted for. And the printed "Share of fossil sources in total energy consumption (%) 15.17" equals 338.72 / 2,232.68, the nuclear ratio, rather than either fossil figure; the nuclear share is separately printed as 15.7.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 56-57, methodology at pages 54-55. Listed in the Appendix 2 content index at page 56 (page 65).

2025 against 2024 (page 57), tCO2e:

Scope 3 by category, 2025 (page 57): purchased goods and services 723.28; capital goods 1,231.72; fuel and energy-related activities 155.97; upstream transport 694.11; waste generated in operations 673.31; business travel 1,827.91; employee commuting 223.58; upstream leased assets 8.07; downstream transport 1,334.26; use of sold products 571.39; end-of-life treatment 15.53; downstream leased assets 86.12. Processing of sold products, franchises and investments are nil.

Intensity is 0.005527 tCO2e per thousand SEK market-based (page 56). Biogenic emissions are 0.00 across all scopes; Scope 1 under emission trading schemes is 0.00%.

Two caveats the company states itself: "No third-party verification of the reported emissions has been carried out" (page 55), and the fall in purchased goods "is primarily attributable to recent divestments, a lower volume of large procurement orders, and related changes in our operational footprint" (page 53), not to abatement.

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 54. Listed in the Appendix 2 content index at page 54 (page 65).

A nil return, stated completely (page 54):

"BICO group AB has not acquired any carbon credits in 2025 nor in previous years."

"In December 2025 BICO group AB set net zero targets using the SBTi Corporate Net-Zero Standard. These targets have been validated by SBTi."

"We do not plan to mitigate emissions beyond our value chain within the next five years as BICO wants to prioritize climate action within our own value chain first."

No GHG removals or storage in own operations or the upstream and downstream value chain are reported, and no carbon credits are cancelled or planned to be cancelled. This is consistent with the targets under E1-4, which are absolute and intensity reduction targets with no stated reliance on removals or offsets (page 54), and with the biogenic emissions figures of 0.00 tCO2e across all scopes (page 56).

Internal carbon pricing

Reference: page 54. Listed in the Appendix 2 content index at page 54 (page 65).

A nil return, stated in one sentence:

"BICO group AB has not applied an internal carbon pricing scheme." (page 54)

No shadow price, internal fee or implicit price is therefore disclosed, and no carbon price is applied in capital allocation or investment decisions. That sits consistently with the rest of the climate chapter: the transition plan does not yet exist and carries "no climate-related Capex allocations or investments" (page 49), no capex or opex has been defined for either climate action (page 53), and "Percentage of Scope 1 GHG emissions from regulated emission trading schemes (%) 0.00" (page 57), so BICO faces no compliance carbon cost that an internal price would shadow.

The Corporate Environmental Policy does commit to "Integration of climate considerations into M&A, investments, and business decisions" (page 42), but no pricing mechanism is described as giving effect to that.

Anticipated financial effects from climate-related risks and opportunities

Reference: pages 50-52. The section heading prints the code: "SBM-3, E1.SBM-3, E1-9 / MATERIAL IROS AND THEIR INTERACTION WITH STRATEGY AND THE BUSINESS MODEL" (page 50).

Each of the eight climate IROs carries a "Financial impact" paragraph, and in every case the effect is unquantified. "The financial impact has not been quantified" is repeated for purchased goods emissions, upstream shipments, business travel, in-house energy and instrument energy consumption (pages 50-51). Representative reasons:

• Purchased goods: "Given the low activity level, it is however not expected to have a significant financial impact."
• Downstream shipment energy: "Products are normally sold ex-works and any change in the downstream transports will for that reason not have an impact on the company."

No monetary amounts, no acute/chronic physical risk split and no location of assets at material physical risk are given, which follows from page 48: "All the risks identified are considered to be translational risks."

Two index points qualify this. E1-9 is absent from the Appendix 2 list of material DRs, and Appendix 3 marks the four E1-9 benchmark-portfolio datapoints "Not material / N/A" (page 68) - those apply to financial undertakings. The code is nonetheless printed over the disclosure and the requirement addressed qualitatively, which is why this is recorded as reported.

Policies related to water and marine resources

Reference: page 58. Listed in the Appendix 2 content index at page 58 (page 65).

"Policies on the water and marine resources topics: Freshwater is a scarce commodity and essential for sustaining life... We appreciate that through our business decisions we have a minor impact in regions where our value chain Partners are active and where freshwater or clean water is a scarce commodity. In our own operations, we are not a material user of freshwater" (page 58).

Two positions are stated (page 58): "BICO continuously assesses the Partners in the value chain towards minimizing the risk for water stress and the use of marine resources in a sustainable way"; and "BICO strives to base water and marine resources related business decisions on science- based data, models and scenarios."

The group Corporate Environmental Policy adds that "BICO recognises minimal direct water use but imposes due diligence where value chain exposure exists", that "Industries with water related risks (e.g., chemicals, mining, pharma) are identified for enhanced assessment",.

Appendix 3 marks the E3-1 water and marine resources and dedicated policy datapoints as "Material", page 59, while "Sustainable oceans and seas paragraph 14" is "Not material / N/A" (page 68). No commitment on withdrawal or consumption reduction in areas of water stress is quantified, and no accountable role is named.

Actions and resources related to water and marine resources

Reference: page 59. Listed in the Appendix 2 content index at page 59 (page 65).

A nil return with a stated reason:

"Given BICO's low overall water consumption and the absence of any indications that our upstream partners are generating negative water related impacts, no specific mitigation actions are currently planned. The focus instead lies on continued data collection and mapping to further substantiate the materiality assessment and determine whether additional measures may be needed in the future." (page 59)

The only mitigation BICO points to for the single material water IRO is carried by the climate action set: on the upstream water use impact, "Actions taken to minimize the effects are described under Supply Chain decarbonization action" (page 58). That action covers engagement with first tier suppliers on emissions data, supplier climate questionnaires and joint reduction activities, and has no water-specific limb; its "Milestones and KPI's will be established once the project is kicked off in 2026" and "no capex or opex has been defined at this stage" (page 53).

No resources are allocated to water, and no action addressing the named upstream sectors (semiconductor fabrication, pulp and paper, mining) is described.

Targets related to water and marine resources

Reference: page 59. Listed in the Appendix 2 content index at page 59 (page 65).

A nil return with a stated reason and an explicit trade-off:

"No targets have been set for this topic, as BICO's impact in this area is assessed to be minimal. For that reason, the company has chosen to focus its target setting efforts on emission reduction objectives that have been validated by the Science Based Targets initiative (SBTi), where the potential for meaningful climate impact is significantly greater." (page 59)

This is consistent with the statement-wide position that "No time-bound targets have been set for any topic" where phase-in provisions are applied (page 46), and with the single material water IRO sitting upstream only: the DMA identified "Upstream water use" as the lone E3 row, and "The double materiality analysis did not identify any risks or opportunities related to the topic" (page 58).

No target is therefore set for water withdrawal, consumption or discharge, in areas of water stress or otherwise, and no baseline year or milestone is disclosed. BICO's stated forward step is data collection rather than target setting: "The focus instead lies on continued data collection and mapping to further substantiate the materiality assessment" (page 59).

Policies related to resource use and circular economy

Reference: page 60. Listed in the Appendix 2 content index, where E5-1 is the one entry printed without a page number (page 66).

"The policy objective is for the BICO Group companies to move to a more circular economy approach from design of products to purchasing and manufacturing. This will drive a life cycle assessment of the product wich will introduce a waste hierachy where reuse will be prioritized over waste treatment and this will drive a reduction in the use of virgin materials whereever feasible. The implementation of a LCA will help meet the circular economy regulations. Head of Sustainability is accountable for implementing the policy" (page 60).

This is one of the few policies in the statement with a named accountable role.

The group Corporate Environmental Policy adds that "BICO expects subsidiaries and partners to embed circularity in design, procurement, manufacturing, sales, and end of life processes", "Encourages reuse, reduce, recycle approaches, durable product design, leasing solutions, and take back schemes", and "Requires compliance with REACH, RoHS, and group wide design guidelines" (page 42).

The policy has to be read against the constraint BICO reports under its material IRO: "Only virgin materials are permitted in our product categories, meaning recycled plastics or reused inputs cannot be used due to regulatory and performance requirements" (page 60). No commitment is quantified.

Actions and resources related to resource use and circular economy

Reference: page 60. Listed in the Appendix 2 content index at page 60 (page 66).

"During the reporting year, BICO advanced circularity and waste reduction by reusing inbound shippers for outbound shipping, donating unused equipment and materials to local universities and strengthening waste segregation systems. The near-term plan is to implement a circular economy model as part of the development of new products" (page 60).

This is one of the few places in the statement where a completed 2025 action is reported rather than a plan for 2026. Three actions are named - shipper reuse, donation of unused equipment and materials, and waste segregation - but none is quantified, no tonnage reused or diverted is given, and no resources, CapEx or OpEx are attached.

The fourth action is forward-looking and carries into the target: "Target for 2026 is that 100% of initiated product development projects will use the circular economy model" (page 61).

Elsewhere the report treats the refurbished instrument route as a resilience response rather than an E5 action: "By offering refurbished instruments BICO can reduce the CO2 footprint and increase sales revenue. The share of refurbished instruments is estimated to be on the same level as for the previous reporting period" (page 48). No leasing or take-back scheme is reported as implemented, although the policy encourages both (page 42).

Targets related to resource use and circular economy

Reference: page 61. Listed in the Appendix 2 content index at page 61 (page 66).

One target is set, and the company flags its own incompleteness:

"Target for 2026 is that 100% of initiated product development projects will use the circular economy model. It is expected that this will drive a reduction of use of virgin materials. Because the target is under development an actual number for this has not been established. Work will be initiated to establish a baseline to be able to set a target." (page 61)

So the target is an activity coverage target for 2026 - the share of new product development projects applying the circular economy model - rather than an outcome target on resource inflows, outflows or waste. No baseline year, no interim milestone and no quantified reduction in virgin material use is attached,.

This is the only numeric target anywhere in the statement outside E1-4, and it sits against the statement-wide position that "No time-bound targets have been set for any topic" where phase-in provisions are applied (page 46). The constraint on what it can achieve is reported under the material IRO: "Only virgin materials are permitted in our product categories", so "opportunities for circularity - such as using recycled content or closed loop systems - are limited" (page 60).

Resource inflows

Reference: page 61, under the combined heading "E5-4, E5-5 / RESOURCE INFLOW AND RESOURCE OUTFLOW". Listed in the Appendix 2 content index at page 61 (page 66).

BICO states what it measures but publishes no figures:

"Reporting in this area is under development. For resource inflows, we measure total materials used to manufacture our products and services, the proportion of recycled and renewable inputs, and the rate of recyclable content in our equipment." (page 61)

No quantitative resource inflow data is disclosed - no total weight of technical and biological materials used, no share of biological materials, no share of secondary reused or recycled components. "Where exact data was unavailable, we have applied phase in provisions under ESRS 1 and used conservative estimates based on available site-level waste reporting" (page 61). BICO names the gaps itself: "expanding material-composition transparency from suppliers, and enhancing the accuracy of recycled and recyclable content measurements" (page 61).

The underlying position is qualitative: "BICO relies on a moderate to high share of virgin materials - including metals, polymers, minerals, and biomass based inputs - across its operations and supply chain" (page 60), with no figure attached. E5-4 is recorded as reported because the company's own content index lists it; the substance is a statement of method with no data behind it.

Resource outflows

Reference: page 61, under the combined heading "E5-4, E5-5 / RESOURCE INFLOW AND RESOURCE OUTFLOW". Listed in the Appendix 2 content index at page 61 (page 66).

BICO states what it monitors but publishes no figures:

"For resource outflows, we monitor waste volumes by waste stream, including hazardous and non-hazardous fractions, and track the share of recycled content, or otherwise sent to recovery in our own operations." (page 61)

No quantitative resource outflow data is disclosed. There is no information on products and materials designed along circular principles, no expected durability, reparability or recyclability rate, and no recycled content figure. "Reporting in this area is under development" (page 61). Appendix 3 lists the two E5-5 datapoints derived from other EU legislation - non-recycled waste (paragraph 37(d)) and hazardous and radioactive waste (paragraph 39) - without a page reference (pages 68-69).

The closest quantified proxy in the report is an emissions figure, not an outflow one: Scope 3 category 5, waste generated in operations, is 673.31 tCO2e for 2025 against 45.39 tCO2e for 2024 (page 57). E5-5 is recorded as reported because the company's own content index lists it; the substance is a statement of method with no data behind it.

Waste

Reference: page 61, disclosed within the combined "E5-4, E5-5 / RESOURCE INFLOW AND RESOURCE OUTFLOW" section listed in the Appendix 2 content index at page 61 (page 66).

Waste is addressed as part of the resource outflow disclosure, qualitatively only:

"For resource outflows, we monitor waste volumes by waste stream, including hazardous and non-hazardous fractions, and track the share of recycled content, or otherwise sent to recovery in our own operations." (page 61)

No waste tonnages are reported. There is no total waste generated, no hazardous and non-hazardous split, no breakdown by treatment route, no non-recycled waste figure and no radioactive waste figure. "Reporting in this area is under development", and "Where exact data was unavailable, we have applied phase in provisions under ESRS 1" (page 61). BICO names the gap itself: "improving the completeness and consistency of waste-stream data across all sites" (page 61).

Waste actions are reported without measurement: during 2025 BICO "advanced circularity and waste reduction by reusing inbound shippers for outbound shipping, donating unused equipment and materials to local universities and strengthening waste segregation systems" (page 60).

The only quantified waste-related figure is an emissions one: Scope 3 category 5, waste generated in operations, is 673.31 tCO2e for 2025 against 45.39 tCO2e for 2024 (page 57). The rise is not explained and is worth asking about.

Policies related to value chain workers

Reference: page 42, with the topic-specific high-level disclosure at page 39. Listed in the Appendix 2 content index at page 41, under the heading "S2- Workers in the value chain (phase in)" (page 66).

The policy sits in the group Social and Human Rights Policy, which "establishes BICO's commitment to international frameworks including: UN Guiding Principles on Business & Human Rights. OECD Guidelines for Multinational Enterprises. Children's Rights & Business Principles. ILO Core Conventions. It applies across investments, operations, and the entire value chain" (page 42).

For value chain workers specifically, "BICO requires value chain partners to: Implement human rights and labour rights policies. Conduct human rights due diligence. Undergo controversy screening and align with BICO's expectations (e.g., preventing forced labour, ensuring fair recruitment)" (page 42).

The high-level S2 disclosure reports implementation candidly (page 39): "no indications have been found that these suppliers operate in ways that conflict with BICO's Code of Conduct... Future steps include developing a structured due diligence framework and a supplier engagement program." On measurement: "Data is not collected systematically... Metric: 100 % of 1st tier suppliers signed CoC. Result 2025: 100 % signed."

The material S2 IROs are upstream diversity, a harsh working environment and work-life balance (page 46).

Policies related to affected communities

Reference: page 42, with the topic-specific high-level disclosure at page 39. Listed in the Appendix 2 content index at page 42, under the heading "S3- Affected communities (phase in)" (page 66).

The policy sits in the group Social and Human Rights Policy, which commits BICO to the "UN Guiding Principles on Business & Human Rights", the "OECD Guidelines for Multinational Enterprises", the "Children's Rights & Business Principles" and the "ILO Core Conventions", and "applies across investments, operations, and the entire value chain" (page 42).

For affected communities specifically, "BICO commits to: Engage affected communities proactively. Avoid involuntary resettlement; when unavoidable, ensure fair compensation. Require free, prior and informed consent (FPIC) for land/natural resource acquisition relating to indigenous peoples or customary rights holders" (page 42).

The high-level S3 disclosure sets out the position and its limits (page 39): "We have no indications that communities in the regions where our upstream partners operate are experiencing any of the issues identified at a broader geopolitical level... For major suppliers, we also conduct onsite visits."

The material S3 IROs are all upstream and all negative: water and sanitation, free, prior and informed consent, cultural rights, freedom of expression and human rights defenders (page 46).

Policies related to consumers and end-users

Reference: page 42, with the topic-specific high-level disclosure at pages 39-40. Listed in the Appendix 2 content index at page 42, under the heading "S4- Consumers and End-users (phase in)" (page 66).

The policy sits in the group Social and Human Rights Policy (page 42), which commits BICO to the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, the Children's Rights and Business Principles and the ILO Core Conventions.

For consumers and end-users specifically, and with a scope caveat: "While not consumer centric, BICO's commitments include: Ethical product development. Avoiding adverse impacts from product use. Ensuring health & safety across product lifetime, aligned with sector expectations" (page 42).

The material S4 IROs are positive and downstream - "Using BICO Products", "Enabling health and wellbeing" and "Access to products" (page 46) - and pages 39-40 set out what BICO claims they deliver: "Better prediction of clinical outcomes in early drug discovery using in-vitro human tissue models", "Faster and more reliable diagnostics, leading to earlier patient treatment and societal health benefits", and "More accurate, animal free safety testing using human tissue models".

On measurement, BICO reports none: "No metrics are in place, but customer feedback is used as part of continuous im-provements" (page 40).

Business conduct policies and corporate culture

Reference: page 62. Listed in the Appendix 2 content index at page 62 (page 66).

"BICO maintains a zero tolerance stance on bribery and corruption and requires ethical conduct across all operations and business relationships. This commitment is embedded in the Corporate Sustainability Policy, the Social & Human Rights Policy, and the Group governance model approved by the Board. These documents set the tone at the top, mandate compliance with applicable laws and international frameworks (UN Global Compact, OECD Guidelines), and apply globally to all subsidiaries and Group partners" (page 62).

On training: "Due dilligence: An annual training in the Code of Conduct is carried out" (page 62). No completion rate, coverage by function or at-risk-role targeting is reported.

Policies "are reviewed annually and subsequently approved by the board. All internal policies are available on the intraweb and external in the Code of Conduct" (page 42). Appendix 3 marks the G1-1 UN Convention against Corruption and whistleblower protection datapoints as material, page 63 (page 70).

Corporate culture is addressed thinly: the statement does not describe how the culture is developed, evaluated or promoted beyond the annual Code of Conduct training and the policy architecture.

Management of relationships with suppliers

Reference: page 63, with supplier metrics at page 39. Listed in the Appendix 2 content index at page 63 (page 66).

"BICO requires suppliers and other value chain partners to comply with BICO's Code of Conduct for Suppliers and the Social & Human Rights Policy. These include expectations on human rights due diligence, labor practices, and responsible business conduct. The policies are global in scope and apply to all Group partners and subsidiaries" (page 63).

The one measured outcome sits in the BP-2 high-level S2 disclosure: "Data is not collected systematically. First step has been to identify 1st tier suppliers and commit them to BICO's code of conduct... Metric: 100 % of 1st tier suppliers signed CoC. Result 2025: 100 % signed" (page 39). SBM-1 confirms it: "All first tiers suppliers have commited to BICO's Supplier Code of Conduct, covering human rights, anti-corruption, environmental expectations and labor standards" (page 44).

Supplier selection is a work in progress: a "Sustainable procurement policy is being developed: Climate performance and emissions transparency are being integrated into supplier selection, onboarding, and renewal processes" (page 53).

Two things a reader should note. Nothing is disclosed on payment practices, on vulnerable suppliers, or on screening criteria beyond Code of Conduct signature; and the due diligence framework is still to be built (page 39).

Prevention and detection of corruption and bribery

Reference: page 63. Listed in the Appendix 2 content index at page 63 (page 66).

"BICO's internal control framework for non financial reporting applies to business conduct and includes: Control environment (clear structures, authorities, policies); Risk/impact assessment (annual DMA and topic specific assessments); Control activities (procedure/reconciliation controls, quarterly monitoring); Monitoring (annual model review, self assessments in subsidiaries); Information & communication (Group instructions, policy access, Board updates" (page 63).

On the reporting channel and its handling (page 63):

"A Group whistleblowing channel (digital, external) is available for reporting suspected misconduct, including bribery / corruption. BICO cooperates with judicial and non judicial mechanisms if cases are brought forward. Findings are addressed through management action, engagement with stakeholders, and remediation where relevant."

Training is covered under G1-1: "An annual training in the Code of Conduct is carried out" (page 62).

Several elements of the requirement are not addressed. There is no description of the procedures to investigate business conduct incidents separately from the whistleblowing channel; no statement on the independence of investigators from the chain of management involved; and no training figures - no coverage of functions at risk, no delivery format, no completion rate.

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS; under the 2023 ESRS this report was prepared against, G1-3 is "Prevention and detection of corruption and bribery".

BICO sets no business conduct target. The statement-wide position is recorded under the material IRO table: "No time-bound targets have been set for any topic" where phase-in provisions are applied (page 46). For the one material G1 matter, animal welfare, the company says so directly: "No specific metrics have been established for animal welfare, as BICO's products are designed to support and improve animal welfare, however BICO will explore whether reliable data and meaningful metrics can be developed" (page 63).

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

• "An annual training in the Code of Conduct is carried out" (page 62).
• The control framework runs annual DMA and topic specific assessments, "procedure/reconciliation controls, quarterly monitoring" and "annual model review, self assessments in subsidiaries" (page 63).
• "A Group whistleblowing channel (digital, external) is available", with findings "addressed through management action, engagement with stakeholders, and remediation where relevant" (page 63).

Incidents of corruption or bribery

Reference: page 63. Listed in the Appendix 2 content index at page 64 (page 66).

A nil return, stated in one sentence:

"No confirmed reports of corruption or bribery has been reported during the reporting period." (page 63)

No convictions and no fines for violation of anti-corruption and anti-bribery laws are reported, and no incident is disclosed as having been investigated without confirmation. The detection machinery behind the nil return is described under G1-3: a digital, external Group whistleblowing channel for suspected misconduct "including bribery / corruption", cooperation "with judicial and non judicial mechanisms if cases are brought forward", and findings "addressed through management action, engagement with stakeholders, and remediation where relevant" (page 63).

What the nil return does not cover: incidents relating to contracts with business partners, incidents leading to dismissal or disciplinary action, and public legal cases regarding corruption or bribery are not separately addressed. There is no figure for reports received through the whistleblowing channel, so a reader cannot see the denominator behind "no confirmed reports".

Political influence and lobbying activities

Reference: page 63. Listed in the Appendix 2 content index at page 63 (page 66).

A nil return, stated for every limb of the requirement:

"BICO did not engage in political lobbying, did not provide financial or in-kind political donations, and did not participate in political activities in any jurisdiction during the reporting year." (page 63)

The framing around it (page 63): "BICO aligns with international frameworks that require transparent, lawful business conduct and compliance with applicable regulations in all jurisdictions. Engagement with policymakers, trade associations, or standard setting bodies is conducted in accordance with law and Group policies; BICO does not tolerate corrupt influence, improper payments, or facilitation of unlawful political activities."

So no financial or in-kind political contributions are reported by country, no principal topics of lobbying are disclosed, and no EU Transparency Register entry is named. That follows from the nil position rather than being an omission on top of it.

No representative responsible for overseeing political engagement is named. Engagement with regulators is limited to monitoring: "We follow the updates from regulators and other relevant public authorities" (page 45).