Bilia

Governance roles

Reference: page 49. Composition, expertise and independence datapoints (20(a), 21(b), (d), (e)) are incorporated by reference to the Corporate Governance Statement (page 48 table).

Bilia "is governed by the Board of Directors, the Audit Committee, the Remuneration Committee and Group Management" (page 49).

Responsibilities (pages 49-50):

• The Board "has a collective and overall responsibility for ensuring that Bilia's annual report complies with the requirements of the CSRD", approves the sustainability statement and monitors IROs.
• The Audit Committee reviews the DMA results and IROs "before the Board receives information or makes decisions".
• The CEO "has ultimate responsibility for the Group's sustainability work, including policies, targets and action plans"; the Sustainability function "operates on behalf of Group Management and reports to the CFO".
• Delivery is delegated to "the Managing Director of each subsidiary", supported by HR, Property, and Environment & Occupational Safety.

Expertise: "The Board has completed training on the CSRD legislation", and "Going forward, the Nominating Committee will include sustainability expertise as a parameter when selecting future Board members" (page 49). "No members of Bilia's Board of Directors hold executive positions"; "All members of Bilia's Group Management hold executive positions" (pages 49-50). Board gender split 3 women / 6 men, 33% / 67% (page 107).

Information provided to and matters addressed by the bodies

Reference: page 50.

"Sustainability matters are discussed regularly by Bilia's Board of Directors, the Audit Committee and Group Management to ensure that the management of impacts, risks and opportunities is integrated into the business" (page 50).

Cadence (page 50):

• The Board "meets six to ten times per year, and sustainability is a standing item on the agenda at every Board meeting"; it also features in Board strategy meetings, "held approximately every three years".
• Group Management "meets five to eight times per year and holds a three-day workshop once a year. Sustainability matters are included as a standing item on the agenda."
• "Bilia's Head of Sustainability will annually present updated information on material impacts, risks and opportunities, as well as the development of policies, actions and progress towards established targets."
• "In connection with the CSRD, the Board has received continuous updates on the process and on the results of identifying impacts, risks and opportunities."

Trade-offs: "During the year, no compromises related to sustainability-related impacts, risks or opportunities have been considered" (page 50).

The CFO "has overall responsibility for sustainability matters"; Group Management approves the Supplier Code of Conduct, Environmental Policy and Purchasing Policy (page 50).

Sustainability performance in incentive schemes

Reference: page 51.

The AGMs in 2023, 2024 and 2025 resolved on long-term share savings programmes, "offered annually to approximately 60 executives and other key employees within Bilia". Participation required buying Bilia AB shares; per savings share participants "may receive four and a half or five performance shares free of charge", subject to Board-set targets (page 51).

The sustainability-linked target: "Among the performance targets set by the Board for the long-term incentive programmes, one target was linked to Bilia's sustainability target: the proportion of women in the sales organisation. This target relates to the negative actual impact on Bilia's own workforce due to gender imbalance"; it "corresponded to a maximum allocation of one performance share" (page 51).

Explicit exclusion: "The incentive programmes do not include targets related to the reduction of greenhouse gas emissions" (page 51). No percentage of variable remuneration tied to sustainability is quantified.

Short-term programmes are prepared by the Remuneration Committee and decided by the AGM; long-term ones by the Committee and the Board, decided by the AGM, under AGM-adopted remuneration guidelines (page 51). Full detail is in Note 8, page 129.

Statement on due diligence

Reference: page 51.

"Bilia applies due diligence processes relating to people and the environment." The statement is a table mapping the five core elements to where each is addressed (page 51):

Every row routes the value chain element to ESRS 2 BP-2 §17, reflecting the phase-in applied to the whole of ESRS S2 (pages 47, 109). The GOV-4 due-diligence datapoint (paragraph 30) is indexed to page 51 in the list of datapoints derived from other EU legislation (page 69).

Risk management and internal controls over sustainability reporting

Reference: page 52.

The Sustainability function, with the corporate functions contributing to ESRS reporting, "define, implement, monitor and assess the controls that need to be applied. The sustainability reporting processes have been documented, and Bilia will continue to formalise and strengthen its internal control of sustainability reporting going forward" (page 52).

Controls (page 52): "analytical controls have been performed, including reasonableness assessments of deviations compared with previous periods"; "The four-eyes principle is applied throughout the data flows"; and "third-party support is used to identify potential discrepancies in the climate calculations".

Risk process: "Bilia has a partially integrated process for managing sustainability risks alongside other risk assessments within the Group", based on "qualitative risk assessments of the reliability, transparency and relevance of the sustainability information" (page 52). IRO-1 instead says the process is "integrated" (page 66).

Main reporting risk: "sustainability data being handled in several systems. There is a risk that national legislation determines which data are available in the systems and that these cannot always be directly translated into specific data points or metrics" (page 52).

Strategy, business model and value chain

Reference: pages 53-54.

Bilia is a full-service automotive retailer and service provider in Sweden, Norway, Belgium and Luxembourg, with three business areas: the Car Business, the Service Business and the Fuel Business (fuel and car wash through Tanka in Sweden) (pages 53, 60). Customers are "corporate customers (60 per cent) and private customers (40 per cent)". Net revenue was SEK 40,413m and the workforce 5,106 FTE (pages 81, 106).

"Bilia's business model is based on its circular business model and its internal strategy and strategy for sustainable growth" (page 53). Circularity comes from "car rental, used-car sales, service, repairs and dismantling"; Bilia runs five dismantling facilities, three in Sweden and two in Norway (pages 53, 91).

Value chain (page 54): upstream runs from raw material extraction through several supplier tiers, with car manufacturers as the main suppliers - "Bilia's ability and possibility to influence the upstream value chain is limited". Downstream ends with dismantlers recycling "in accordance with the EU End-of-Life Vehicles Directive".

Dependency stated plainly: "Bilia's material impacts across sustainability matters are largely influenced by the car brands with which Bilia collaborates. These manufacturers control the design and production of the cars, which affects all material sustainability matters for Bilia" (page 53).

Interests and views of stakeholders

Reference: page 55.

Bilia "maintains an ongoing dialogue, both formal and informal, with internal and external stakeholders". Six groups are tabulated with channels, key issues and responses: shareholders and investors, customers, own workforce, suppliers and partners, authorities, and the planet (page 55).

Examples (page 55):

• Customers "value professional customer service and that agreements are honoured, that we provide reliable products and services, and that we take responsibility for climate impact, pollution, human rights, gender equality and sound business ethics."
• Own workforce "values a safe workplace with secure employment and good working conditions", engaged via collaboration meetings, surveys, one-on-one meetings and the employee survey.
• Value chain workers: "managed through Bilia's Supplier Code of Conduct and through dialogue between Bilia's purchasing function and suppliers. Feedback from workers in the value chain may also be received through the whistleblowing system."

Effect on strategy, stated explicitly: "Insights from our stakeholder dialogues have contributed to our double materiality assessment... The stakeholders' views have not resulted in any changes to Bilia's strategy or business model" (page 55). The Board, Audit Committee and Group Management "receive information about stakeholder views through presentations in relevant forums".

Material impacts, risks and opportunities

Reference: pages 56-64.

The master IRO table runs pages 56-59, giving topic, sub-topic, type, whether people or environment are affected, description, value-chain position and time horizon. 17 material IROs are listed: E1 six (four negative actual impacts also labelled climate-related physical risk, one transition risk, one transition opportunity), E2 one, E5 two, S1 four, S2 three, G1 one.

Topic-level conclusion (page 56): "All identified impacts, risks and opportunities are managed on an ongoing basis within the operations. No changes to the strategy or business model have been deemed necessary. The identified impacts, risks and opportunities have also not influenced decision-making."

Resilience: "Bilia has not yet conducted a structured resilience analysis of its strategy and business model, or of its ability to manage material environmental impacts, risks and opportunities" (page 56) - against the E1 sub-section, which states "The resilience analysis conducted in 2025 is based on the transition risks identified in the climate scenario analysis and the physical climate risks" (page 61). See E1-3.

Climate-specific risk identification and scenario analysis is also presented under E1-2, and resilience under E1-3 (2025 ESRS numbering).

Process to identify and assess material IROs

Reference: pages 65-68.

The DMA was carried out for the first time for FY2025 and is described as iterative (pages 65-66).

Method (pages 65-66): prior work was used as input, including "the assessment of environmental aspects according to ISO 14001 as well as the evaluation of group-wide risks and opportunities"; thresholds and methodology were set with external experts. Stakeholders were mapped "according to the ISO 9001 framework"; value chains "were mapped from raw material extraction to end-of-life handling", then "aggregated into an overarching value chain applicable to all of Bilia". Workshops with Group Management, interviews, a Group-wide employee survey and customer surveys in Sweden and Norway fed the result.

Scoring: severity (scale, scope, irremediability) on a five-point scale, averaged then combined with likelihood against a threshold; financial risks and opportunities on a three-point scale benchmarked to "Bilia's operating profit" (page 66).

Internal control, stated candidly: "As the double materiality assessment was carried out for the first time and continuously adjusted, no predefined internal control process for the assessment was in place" (page 66). Results were validated in workshops, reviewed by the Audit Committee and Board, and approved by Group Management and the Board.

Disclosure requirements covered

Reference: pages 69-76.

Bilia publishes a real ESRS content index headed "Disclosure Requirements in ESRS covered by the undertaking's sustainability statements" (pages 75-76).

Scope statement (page 75): "The selection of disclosure requirements and associated data points has been determined based on the company's double materiality assessment. Only the disclosure requirements assessed as material have been included, based on a systematic evaluation of the materiality of the data points, including a gap analysis."

Listed with page references: ESRS 2 BP-1, BP-2, GOV-1 to GOV-5, SBM-1, SBM-2, SBM-3, IRO-1, IRO-2; MDR-P, MDR-A, MDR-M and MDR-T each mapped across E1, E2, E5, S1, S2 and G1; E1-1 to E1-6; E2-1 to E2-4; E5-1, E5-2, E5-3, E5-5; S1-1 to S1-6, S1-9, S1-13, S1-14, S1-16, S1-17; for S2 a single row, "ESRS 2 BP-2 §17 Application of phase-in provisions... through the Omnibus 'quick fix'" (page 109); and G1-1, G1-2, G1-6.

Not listed: E1-7 to E1-9, E2-5, E2-6, all E3, all E4, E5-4, E5-6, S1-7, S1-8, S1-10 to S1-12, S1-15, all S3, all S4, G1-3, G1-4, G1-5. The datapoint table marks E1-7, E3, E4, S1-16 CEO pay ratio, S3, S4 and both G1-4 datapoints "Non material", and E1-9 and S2-1/S2-4 "Phase-in" (pages 70-74).

One inconsistency: an E5-4 Resource inflows section is printed on page 93 and E5-3 sets a "Target for resource inflows" (page 92), yet E5-4 is absent from the index.

Transition plan for climate change mitigation

Reference: pages 77-78, with the strategic narrative at pages 60-62.

Bilia discloses that it has no ESRS-compliant transition plan, and says why. "The time lag in the Car Business and the climate impact from the Fuel Business mean that scope 3 emissions... are estimated to decrease by 23 per cent by 2030 and by 40 per cent by 2035 compared with 2023... In this scenario, Bilia would not contribute to reducing greenhouse gas emissions to an extent consistent with limiting global warming to 1.5°C in line with the Paris Agreement, and will therefore not adopt a transition plan that meets the requirements of ESRS E1-1-17" (page 77).

Reasoning (pages 77-78): under the land-transport sector standard, a car manufacturer's Scope 3 target "must, under a 1.5°C ambition, cover 100 per cent of use-phase emissions in category 3.11". Bilia argues restricting itself to zero-emission cars would merely shift emissions "to other actors in the industry".

Locked-in emissions (page 78): Fuel Business Scope 1 and 2 locked-in emissions to 2030 are "negligible"; on 2024 data "total emissions of 12.5 tonnes CO2e up to 2030", and in the reporting year "locked-in greenhouse gas emissions from the direct use phase amounted to 4,2 tCO2e".

Reassessment: "the earliest point at which Bilia may reassess the conditions for developing and adopting a transition plan would be 2035" (page 78).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the ESRS 2 SBM-3 climate sub-section, where this content is disclosed in the FY2025 report (pages 60-62, 66-67). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification (pages 56-57, 61-62). Pages 61-62 tabulate climate risks under two headings, TRANSITION RISKS (politics and law, technology, market) and PHYSICAL RISKS (water, solid mass, wind; chronic and acute), each with value-chain position, risk level and time horizon.

Methodology (pages 66-67). Physical risks used the WWF Risk Filter, Bilia "also considered, at an overall level, the geographic locations of production facilities based on publicly available information from the car manufacturers", so own operations and upstream are both covered.

Scenarios (pages 66-67). Physical: "a pessimistic scenario for 2030 and 2050, corresponding to a 4-degree scenario with high warming and limited climate action (RCP6.0/RCP8.5)". Transition: variables from "the International Energy Agency (IEA) and S&P Global", plus EU policy "to keep the global temperature increase well below 2 °C and to pursue efforts to limit it to 1.5 °C".

Gap: no named 1.5°C-aligned scenario and no per-scenario temperature projection beyond the 4-degree physical case.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3, where this content is disclosed in the FY2025 report (pages 56, 60-62). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The report says two different things, and both are quoted here. At topic level: "Bilia has not yet conducted a structured resilience analysis of its strategy and business model" (page 56). In the E1 sub-section: "The resilience analysis conducted in 2025 is based on the transition risks identified in the climate scenario analysis and the physical climate risks" (page 61).

Results (pages 61-62). Each risk carries an "Adaptation for resilience" column: All transition risks are rated low or very low; the physical risks rated high are upstream ones affecting car manufacturers, where Bilia states "We do not assess that this will affect Bilia's business."

Conclusion (page 60): "The company considers itself to have strong prerequisites and good resilience for climate change and the industry transition ahead, regardless of time horizon."

Uncertainty (page 60): "There is uncertainty in current internal and external forecasts for the number of zero-emission cars sold", and the December 2025 EU proposal to ease the 2035 rule to a 90 per cent reduction "has not been reflected in our transition plan". Financial flexibility is asserted, not quantified (page 56).

Policies related to climate change mitigation and adaptation

Reference: page 78.

"The material impacts and the identified transition opportunity are primarily governed by Bilia's Environmental Policy and Bilia's Supplier Code of Conduct" (page 78).

Scope limits, stated explicitly: "Bilia has no IRO related to climate change adaptation and therefore no policy addressing this area. The transition risk is not governed by policy but is managed through operational planning and associated action plans" (page 78).

Environmental Policy (page 78): it "states that we work to limit our own climate impact by improving energy efficiency, using renewable energy sources and phasing out fossil fuels. Bilia also aims to offer products and services that can reduce our customers' environmental impact. We do this by working with car brands that have strong climate ambitions and by supporting our customers in making climate-conscious choices." Group Management adopted it and the CEO holds ultimate responsibility (page 87).

Supplier Code of Conduct (page 78): it "includes precautionary principles for the climate and the 1.5-degree goal of the Paris Agreement, which Bilia expects our suppliers to consider and respect. This includes limiting climate change by reducing emissions from their own operations and value chains through energy efficiency measures and the use and development of renewable energy."

Actions and resources in relation to climate change policies

Reference: page 79.

Resourcing, stated plainly: "All measures are managed as part of normal business operations... and no additional resources are expected to be required." The 2025 measures, bar one, "have been executed and financed through Bilia's operating cash flow and are included in the Taxonomy disclosures on page 99"; the 2026-2030 measures "will be financed by the respective property owners" (page 79), reflecting that Bilia leases most facilities.

1. Fossil-fuel phase-out in buildings, led by the Swedish and Norwegian property functions with landlords: "Bilia estimates that these measures could result in a gross reduction of Scope 1 emissions of 22 per cent... The net reduction will be somewhat lower, as Scope 2 emissions are expected to increase." For own transport vehicles, "a gross reduction of two per cent".
2. Energy efficiency and renewables: insulation, heat-recovering ventilation, lighting;
3. Upstream: "An action plan for updating Bilia's supplier self-assessment questionnaire will be developed... in 2026."

Quantified 2025 outcomes: Luxembourg solar −23 tCO2e against −9 expected; a mobile charging station and lighting adjustment each −211 MWh against −48 expected. Planned 2026-2030: Sweden oil boiler to electric boiler −33 tCO2e, to district heating −120 tCO2e, −289 MWh from building work.

Targets related to climate change mitigation and adaptation

Reference: pages 80-81.

Bilia states its targets are not science-based: they "do not meet the requirements regarding emission coverage or the percentage reduction thresholds needed for Scope 1 and 2 targets to be considered science based and aligned with limiting global warming to 1.5°C". Bilia has "chosen not to define its Scope 1 and Scope 2 greenhouse gas reduction targets in terms of absolute reductions or intensity metrics" (page 80).

Scope 3 excluded: targets "do not cover climate impacts from the upstream value chain... nor... downstream impacts during the use phase or end of life treatment. Consequently, Bilia has no Scope 3 reduction targets". Four entity-specific targets and 2025 outcomes (pages 80-81):

• Internal transport vehicles on fossil-free fuels "no later than 2028": outcome rose 86 → 132 tCO2e (+45); "Half of the increase can be attributed to the acquisition of new companies."
• "No consumption of fossil energy sources for heating (including paint booths) by 2030": 1,158 → 1,257 tCO2e (+99), "primarily attributable to the acquisition of new companies".
• Electricity and district heating per m² to fall annually "10 per cent in Norway, and 5 per cent in Sweden": Norway 159 → 158 (−1%), Sweden 105 → 96 (−9%).
• Self-generated renewable electricity to reach "20% of total electricity consumption in Norway no later than 2030": 6.7% → 6.5%.

Energy consumption and mix

Reference: page 81.

High climate impact sectors: "Bilia's three business areas are classified as high climate impact sectors in accordance with NACE Rev. 2, Annex 1: Division E - Water supply; sewerage, waste management and remediation activities (the Service Business) and Division G - Wholesale and retail trade; repair of motor vehicles and motorcycles", so the full paragraph 38 fossil breakdown is given (page 81).

MWh, 2025 vs 2024 (page 81):

*Four values are printed with a trailing comma in the source table and are reproduced as printed; check them against the PDF.

Intensity: 3.45 MWh/MSEK (2024: 3.36), up 2.7%, on SEK 40,297m of high-climate-impact net revenue out of SEK 40,413m total.

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 82-86.

No comparatives: "as we have further developed the methodology and calculations... we have chosen to consider 2025 as the first complete reporting year for the company. Therefore, comparative figures are not presented" (page 84).

2025, tCO2e (page 84): Scope 1 5,667; Scope 2 location-based 2,571, market-based 2,062; total Scope 3 2,112,050 - 3.1 purchased goods and services 752,958; 3.3 fuel and energy-related 2,482; 3.4 upstream transport 1,020; 3.5 waste 2,712; 3.11 use of sold products 1,291,503; 3.12 end-of-life 17,900; 3.15 investments 43,475. Totals 2,120,288 (location-based) and 2,119,780 (market-based), so Scope 3 is 99.6%. Intensity 52.61 and 52.62 tCO2e per SEK m (page 86).

Method (pages 82-83): Scope 1 and 2 factors from the CEMAsys tool; "All of Bilia's calculations are activity based." "Of the 73,042 MWh of electricity purchased by the Group under Scope 2, 96 per cent originated from certified renewable electricity." Categories 3.1 and 3.11 use an internal method on GreenNCAP lifecycle fact sheets assuming a 240,000 km lifetime; end-of-life uses "a brand independent average value... of 0.5 tCO2e per vehicle".

Data quality: "three per cent" of category 3.1 was supplier-specific primary data, and 3.11 used "WLTP values for 75 per cent of the vehicles" (pages 83-84).

Policies related to pollution

Reference: page 87.

"The identified material impact is primarily governed by Bilia's Environmental Policy" (page 87). The single material E2 impact is "Vehicle and spare-part washing results in water pollution", in own operations.

Coverage (page 87): "With regard to pollution, the Environmental Policy governs water pollution and chemical use. The policy highlights that product selection, controls, preventive measures and regular water testing are essential for Bilia to prevent and reduce emissions of pollutants to water... The substances addressed... include oil commonly found in cars, metals such as copper and zinc (which account for the largest share), and lead in lower concentrations."

Chemicals (page 87): Bilia complies with "Regulation (EC) No 1907/2006... (REACH) and Regulation (EC) No 1272/2008... (CLP), as well as by applying the substitution principle. Bilia actively works to reduce the number of chemicals used, eliminate the use of substances of very high concern, and limit emissions of volatile organic compounds."

Incidents and training (page 87): procedures exist for reporting, documenting and following up spills, including containment and clean-up and the equipment required. "All employees in workshops, spare parts, rental cars and sales must complete spill-response training upon employment. This training is repeated every two years for relevant employees."

Actions and resources related to pollution

Reference: page 88.

Measures follow national legislation in each country and the Environmental Policy. Resourcing: "The resources required are managed as part of normal operations." Sampling frequency is not Bilia's choice: "The water samples taken are mandated by authorities... and the sampling intervals are not determined by Bilia" (page 88).

Candour about limits: "Water pollution cannot be completely avoided. The pollutants may originate from the car itself, from the dirt accumulated on the car, and from the chemicals used in the washing process. Bilia's focus is to remain within the limits set by authorities by working preventively and using treatment equipment" (page 88).

Equipment (page 88): "All facilities that wash cars are equipped with oil separators... emptied at regular intervals, and the waste is handled as hazardous waste."

2025 actions, quantified: "In 2025, a new oil separator was installed at one of the facilities in Belgium... In Sweden, four new oil separators were installed at four facilities, and one oil separator was replaced at another facility" (page 88).

Escalation: in Norway chemical suppliers visit affected facilities; in Sweden "Bilia follows an action ladder" covering routine compliance, functional checks and equipment upgrades, applied also in Belgium and Luxembourg (page 88).

Targets related to pollution

Reference: page 89.

"In 2025, Group Management decided to adopt an entity-specific target related to water pollution, which is group-wide and covers Bilia's installations that wash cars and car parts and are subject to regulatory requirements for water sampling" (page 89).

The target: "All installations shall have approved water values by 2030." "Having approved water values means that Bilia remains within the regionally regulated limit values for each facility... Most often, the sampled parameters are oil index and heavy metals such as zinc, lead, cadmium, copper, chromium and nickel" (page 89).

Boundary, stated: "These substances are present in such low concentrations that they have been assessed as non-material in the DMA", and "The target is not directly linked to air or soil pollution" (page 89).

Outcome (page 89): approved water samples 70% in 2024 → 80% in 2025, a 10-point change. "During 2025, 137 water samples were taken at a total of 66 facilities, of which 110 water samples were approved and 27 not approved."

Measurement caveat, disclosed: "In Sweden, the sampling period was from November to March, and outcomes and analysis cannot be presented until the sampling period is completed. The figures were therefore estimated based on 2024 data" (page 89). Norway samples twice a year; Belgium and Luxembourg have no fixed intervals.

Pollution of air, water and soil

Reference: page 89.

Bilia discloses the E-PRTR test as a reasoned nil return rather than a pollutant table. "To verify that Bilia's discharges do not exceed the threshold values set out in Annex II to Regulation (EC) No 166/2006, Bilia has performed standardised calculations" (page 89).

Method (page 89): "The calculations are based on the highest measured discharges from the water samples and the highest number of car washes, and have been extrapolated to an annual level. Bilia has assumed that if the facility with the highest discharge level is below the threshold values in the Annex, then the other facilities with lower discharges are also below these thresholds."

Conclusion: "The outcome shows that the water pollution occurring within Bilia is far below the threshold values listed in the Annex" (page 89).

Sub-topic scope. The only material E2 sub-topic is pollution of water (pages 57, 65, 87); the E2-3 target "is not directly linked to air or soil pollution" (page 89), and the sampled substances "have been assessed as non-material in the DMA" (page 89).

The E2-4 datapoint "Amount of each pollutant listed in Annex II of the E-PRTR Regulation... paragraph 28" is indexed to page 89 (page 71), and E2-4 is listed in the content index at page 89 (page 76). No absolute tonnages per pollutant are given, only the conclusion that the Annex II thresholds are not reached.

Policies related to resource use and circular economy

Reference: page 90.

"The identified material impacts are primarily governed by Bilia's Environmental Policy" (page 90). The two material E5 impacts are "The manufacturing of cars and car parts requires finite natural resources" (upstream, own operations, downstream) and "Waste in own operations".

Environmental Policy (page 90): it "provides overarching guidance for Bilia's waste management and sustainable resource use. The policy states that Bilia shall work to reduce waste in accordance with the waste hierarchy (minimise, reuse, recycle, recover energy and dispose). The Environmental Policy also describes Bilia's dismantling operations as part of the company's circular-economy efforts."

Supplier Code of Conduct (page 90): "Suppliers who have signed the Code are expected to strive for circularity, the efficient and sustainable use of resources, and, as far as possible, to choose renewable energy sources and minimise waste."

Why it matters to the business model (page 90): "Bilia's retail and service operations depend on the functioning flow of raw materials, spare parts and cars throughout the entire value chain... recover used spare parts during the dismantling process, which are then used in our Service business, primarily in the damage repair segment. The service operations generate a significant amount of waste, including hazardous waste, across several waste fractions."

Actions and resources related to resource use and circular economy

Reference: page 91.

"The resources required for measures within the circular economy are managed as part of normal operations unless otherwise stated" (page 91).

Dismantling as the main lever (page 91): "As Bilia is a non-producing company, we work to reduce the need for new resources, partly through our dismantling operations... Today, we operate five dismantling facilities, three in Sweden and two in Norway. As a result, Bilia holds a leading position in our industry in terms of capacity to supply the market with used spare parts."

2025 actions: "In 2025, we introduced improved monitoring of the use of used parts in damage repair workshops in Sweden. During the year, Bilia also strengthened its routines in Sweden, meaning that certain types of used parts must always be ordered in damage repair cases when available." On waste, Bilia and a waste contractor "initiated a project during the year to review the sorting rate and the potential to increase it" (page 91).

Constraints disclosed plainly (page 91): "Dismantlers depend on insurance companies writing off cars for dismantling... Availability is also restricted when end-of-life cars are exported abroad for higher profitability. When a vehicle is delivered to a dismantler, the entire vehicle is classified as hazardous waste."

Targets related to resource use and circular economy

Reference: page 92.

"The circular business model has two targets. Both targets are voluntarily adopted... The targets apply solely to Bilia's own operations, and in setting the targets, Bilia has not consulted with stakeholders" (page 92).

Target 1 - resource inflows: "12 per cent share of used spare parts for repair jobs in Sweden by 2028." "The target is linked to the negative impact in resource inflows and applies only to Sweden. A target will be established for Bilia's Norwegian operations once statistics are available" (page 92).

"To simplify the follow-up at facility level, a reporting portal has been launched... One factor influencing the target is the general availability of used spare parts on the market; another is that certain car brands do not allow the use of used spare parts" (page 92).

Target 2 - waste: "At least 85 per cent of waste shall be re-used or recycled by 2028... measured by weight and diverted from disposal". Outcome 83.9% (2024) → 83.8% (2025), "0.1 percentage points lower than the previous year". The target "was new for 2025 and will be followed up for the first time in 2026", with 2025 as its baseline. Data comes from "the waste contractors' compilations of delivered waste".

Resource inflows

Reference: page 93.

Caveat on status. An "E5-4 Resource inflows" section is printed on page 93, and E5-3 sets a "Target for resource inflows: 12 per cent share of used spare parts for repair jobs in Sweden by 2028", explicitly "linked to the negative impact in resource inflows" (page 92). But E5-4 is absent from Bilia's ESRS content index (pages 75-76), whose E5 rows are only E5-1, E5-2, E5-3 and E5-5,. The disclosure therefore reads as voluntary narrative rather than a claimed material DR, and it carries no weights, no tonnages and no recycled-content percentages.

What is disclosed (page 93): "Bilia's material resource inflows consist primarily of purchased new and used cars as well as spare parts. New agreements with car manufacturers are entered into only after a strategic decision that includes a separate due diligence process and requires approval from the Board of Directors."

Materials named: "The main materials used in the upstream value chain... are steel, iron, aluminium, thermoplastics and elastomers. The cars may also contain critical raw materials such as lithium, cobalt, nickel, manganese and rare earth elements" (page 93).

Measurement basis for the one quantified element: "Used spare parts are sourced from an internal report based on the cost distribution between used and new spare parts" (page 93) - a cost-share proxy, not a mass measure.

Resource outflows

Reference: page 93. E5-5 "Resource outflows" is listed in the content index at page 93 (page 76).

Products and materials (page 93): "End-of-life vehicles, spare parts and tyres constitute Bilia's main waste streams, which largely consist of materials such as steel, iron, aluminium, thermoplastics and elastomers. They may also contain critical raw materials such as lithium, cobalt, nickel, manganese and rare earth elements."

Durability and reuse: recovered parts re-enter the Service Business "primarily in the damage repair segment" (page 90), and "Dismantlers play an important role, as they can identify and return parts in good condition to the market during the dismantling process. This means that parts from end-of-life cars, which would otherwise have been discarded, are reclassified and can be reused" (page 91). The share of used spare parts in Swedish repair jobs reached 8.6% against a 12% by 2028 target (page 92).

Quantified outflows, tonnes (page 93): total waste 16,086 t, of which 16,024 t diverted from disposal (recycling 13,483 t; other recovery 2,541 t; preparation for reuse nil) and 62 t directed to disposal (incineration 43 t, landfill 18 t). Hazardous 4,711 t, non-hazardous 11,375 t. Non-recycled waste 16%.

No recycled-content or recyclability rates are given for the products Bilia sells, and no expected durability figures are disclosed.

Waste

Reference: page 93. The report's own section heading is "E5-5 Waste".

Approach (page 93): "Bilia's strategy is to ensure that all waste is sorted correctly to enable proper end-of-life treatment. This increases the possibility for waste to be materially recycled... Correct sorting is governed by established procedures and collaboration with Bilia's waste contractors."

Composition (page 93): "End-of-life vehicles, spare parts and tyres constitute Bilia's main waste streams... In addition, hazardous waste occurs, such as waste oil and sludge from oil separator installations, as well as other chemical residues."

Outcome 2025, tonnes (page 93):

Data basis (page 93): "Waste data is provided through the waste contractors' compilations of delivered waste... Assumptions regarding treatment codes may be made when necessary." No radioactive waste is reported. Against the 85%-by-2028 target the 2025 outcome was 83.8% (page 92).

Policies related to own workforce

Reference: pages 101-102.

The four material S1 impacts are high workload affecting employee well-being, accidents resulting in serious injury, employees' balance between demands and the conditions to meet them, and gender imbalance - all in own operations (page 101).

Work Environment Policy (pages 101-102): it ensures "work environment efforts are systematic and integrated into decision-making", in cooperation "with employees and the trade unions". It "applies to everyone working at Bilia or on behalf of the Group, including board members, employees, interns and contractors". The HR Director is accountable; it "is revised annually through a structured review in Bilia's Swedish Work Environment Council, where the safety organisation and all trade unions within Bilia in Sweden are represented".

Code of Conduct (page 102): "Bilia's work is based on the UN Universal Declaration of Human Rights, the ILO core conventions, the UN Guiding Principles on Business and Human Rights, and the OECD Guidelines for Multinational Enterprises. Bilia has also joined the UN Global Compact."

Enhanced Recruitment Policy (page 102): "women with the right qualifications must always be invited to an interview... at least one final candidate must be a woman. In cases of equal qualifications, the woman should be selected."

"The Pay Transparency Directive will apply to Bilia from June 2026" (page 102).

Processes for engaging with own workforce and workers' representatives

Reference: page 103.

"Bilia has established procedures for dialogue with its own workforce and employee representatives through regular communication channels, cooperation forums and structured meetings" (page 103).

Channels (page 103):

• "Bilia conducts an annual employee survey in Belgium and Luxembourg. In Sweden and Norway, pulse surveys are carried out every four weeks using the digital tool 'BiliaPulsen', which enables anonymous feedback."
• "Pulse measurements related to the perspectives of female employees are therefore conducted continuously throughout the year, as the results can be filtered by gender."
• "quarterly safety inspections, led by local managers and involving employees and safety representatives"; quarterly local safety committee meetings; and "At least once a year, the Work Environment Council in Sweden convenes".

Scope limitation, stated: "This process applies only to permanent employees" (page 103).

Accountability (page 103): "The HR Director has ultimate responsibility... The HR and work environment functions are responsible for contacts with trade unions. Bilia is not covered by any global framework agreement on human rights for its own workforce; however, Bilia is bound by collective agreements."

Processes to remediate negative impacts and channels to raise concerns

Reference: page 103.

Ownership (page 103): responsibility "lies primarily with the immediate manager. If the immediate manager is involved in the misconduct... the responsibility is transferred to the next-level manager or HR. Managers who suspect or receive information about potential misconduct are obliged to discreetly investigate."

Remediation by impact area (page 103):

• Discrimination or harassment: "Bilia initiates informal discussions as a first step. If these discussions do not lead to improvement, a more formal investigation is launched... to ensure that the discrimination or harassment ceases."
• Gender imbalance, disclosed as a gap: "Bilia does not have formalised procedures for regular evaluation or remediation in cases of negative impacts related to gender imbalance in sales."

Channels (page 103): reporting to the immediate manager, or anonymously "through the employee survey, 'BiliaPulsen', or the whistleblowing tool. The whistleblowing tool is available to both Bilia's employees and external parties such as contracted labour."

Effectiveness, disclosed as a gap: "Bilia does not have a process for monitoring awareness of the whistleblowing channel, whether the workforce trusts the channel, or how effectively it functions" (page 103).

Taking action on material impacts on own workforce

Reference: pages 104-105.

Resourcing (page 104): "Resources allocated to manage material impact areas primarily consist of personnel resources, but also include financial resources used for, among other things, digital tools and training". Actions "continue without a predetermined end date unless otherwise explicitly stated".

Work environment (page 104): "For all 1,600 employees in Sweden, Bilia's work environment function has carried out fit-testing to ensure individual adaptation of respiratory masks in accordance with new Swedish legislation introduced in January 2025." "Bilia introduced a digital self-inspection system in all Swedish workshops in 2025... related to car lifts. Since 2025, third-party inspections of lifts have also been carried out annually."

Gender imbalance (pages 104-105): "targeted initiatives to offer internships to young women"; recruitment-policy compliance "monitored and evaluated through a survey that must be completed by the recruiting manager", with follow-up "being revised and... expected to be in place during 2026"; gender distribution monitored monthly; "annual pay equity analyses, excluding newly acquired companies", carried out in all countries, with salary corrections initiated by HR. Context: "only 8 per cent of employees in the motor industry are women" (2023).

Targets related to own workforce

Reference: page 105.

1. High workload and stress. "In 2025, targets were established for Bilia's Swedish and Norwegian operations related to working conditions, specifically addressing high workload and stress... The target is to achieve better results than the industry index." Outcome: "7.6 for Sweden and 7.7 for Norway", against an "industry index of 7.4"

2. Serious accidents. "In 2025, Bilia adopted an entity-specific Group-wide target of zero serious accidents within its own operations... adopted in cooperation with safety and union representatives". Measurement is reported serious accidents "based on whether the employee required medical attention and/or sick leave". Outcome: "In 2025, 36 serious accidents occurred, of which 29 took place in Sweden."

3. Gender balance. An entity-specific target introduced in 2022 that the "share of women should exceed 30 per cent" in sales operations, "measured against the baseline of 12 per cent women in 2021", "Group-wide, absolute, and... monitored and reported to all managers on a monthly basis in Sweden". The 2025 outcome was 18 per cent (page 107).

Skills development - no target: "At present, Bilia does not have a Group-wide target for skills development within the own workforce. In 2026, Bilia will explore the possibility of identifying an appropriate method for monitoring the number of training hours" (page 105).

Characteristics of the undertaking's employees

Reference: page 106. Employees by gender and country (paragraph 50(a), (b), (d), (e)) is partially incorporated by reference to Note 8, page 128 (page 48).

"Bilia had, in accordance with the financial report, 5,106 employees during the 2025 financial year and operated in four markets in Europe" - the asterisk clarifying this "Refers to full-time equivalents (FTE)... calculated as a monthly and annual average" (page 106).

By contract type (average headcount, page 106):

"Gender as stated by the employees themselves."

By gender (FTE): women 803, men 4,303, total 5,106. By country (FTE, at least 50 employees): Sweden 3,443, Norway 1,244, Luxembourg 247, Belgium 171.

Turnover: 484 left in 2025, a rate of 9 per cent, "lower than last year's outcome of 11 per cent". The numerator covers those who "voluntarily left the company, as well as those who have been dismissed, retired or passed away", against a denominator of "head count, not full-time equivalents" (page 106).

Note S1-14 uses a different basis - "5,663 as of 31 December 2025" (page 108) - so headcount, FTE and year-end figures are not interchangeable.

Diversity metrics

Reference: page 107.

Gender balance in sales, against the entity-specific target: "The outcome related to Bilia's entity-specific target of exceeding 30 per cent women in the sales operations was 18 per cent for 2025 (the result for 2024 was 16 per cent), an increase of two percentage points" (page 107).

Method and its limits, stated: "The method used to measure the outcome is based on dividing the number of women in car sales by the total number of employees in car sales. This target does not cover the entirety of Bilia's identified negative impact related to gender imbalance in its core operations" (page 107).

Governance bodies (page 107):

*"excluding employee representatives."

Age distribution of employees (page 107): under 30 29%, 30-50 44%, over 50 27%.

Basis: figures are "sourced from Bilia's HR system and are based on the number of employees in head count as of 31 December 2025" (page 107), a different basis from the S1-6 averages and FTE figures.

This is the one sustainability measure linked to executive pay: "one target was linked to Bilia's sustainability target: the proportion of women in the sales organisation" (GOV-3, page 51).

Training and skills development metrics

Reference: page 107.

Reviews and training hours (page 107):

Exclusions from the review population, stated: reviews are offered annually to all employees "with the exception of employees who started after 1 December, those on long-term sick leave, leave of absence or parental leave, hourly-paid employees, as well as one subsidiary in Luxembourg and recently acquired companies in Sweden".

Data limitations, disclosed (page 107): "For Sweden, the training hours reported this year do not include white-collar employees. For one of the companies in Luxembourg, the reported training hours only cover external training provided by general agents... data collection routines vary between countries."

Explanation of the 3 versus 24 hour gap: "The higher average number of training hours for men is mainly attributable to the larger proportion of men in workshop operations, where the company's most significant risks are found and where environmental and occupational safety-related training is mandatory" (page 107).

Delivery model: "possibilities are being explored to obtain follow-up data for training provided by general agents" (page 107). There is no Group-wide skills-development target (page 105).

Health and safety metrics

Reference: page 108.

Coverage: "All employees in Bilia's own workforce are covered by the company's health and safety management system. The number of employees amounted to 5,663 as of 31 December 2025" (page 108).

Outcome 2025 (page 108): employees covered by the health and safety management system 100%; fatalities nil; recordable work-related injuries 48; rate of recordable work-related injuries 6; cases of work-related ill health 57; days lost 280.

Method, with a caveat worth noting (page 108): "worked hours have been calculated based on payroll data reflecting days worked during 2025, taking into account vacation and sick leave, but excluding leave of absence. The rate... has been calculated by dividing the total number of accidents by the total number of worked hours and multiplying the result by a factor of 1,000,000. This enables the reporting of the number of work-related accidents per 500 full-time employees." The stated normalisation basis does not follow from a per-million-hours multiplier, so the rate of 6 should be read with care.

Scope: "All data presented in the table refer to Bilia's own employees" (page 108), excluding contracted labour, which is inside the S1 boundary (page 63). Separately, S1-5 reports 36 serious accidents, 29 in Sweden, against a target of zero (page 105).

Compensation metrics (pay gap and total compensation)

Reference: page 108.

Gender pay gap: 7.6 per cent for employees (page 108).

Method, stated: "The gender pay gap between men's and women's average gross pay in 2025 is expressed as a percentage. The pay gap is calculated by dividing the difference between men's and women's average gross pay by men's average gross pay. The outcome shows that a pay difference exists between women and men, with men on average earning more than women" (page 108).

Market detail: "The pay gap amounts to 4.9 per cent in Bilia's largest market (Sweden)" (page 108).

The total-compensation ratio is not given. The list of datapoints derived from other EU legislation marks "ESRS S1-16 / Excessive CEO pay ratio paragraph 97(b)" as "Non material", while the unadjusted gender pay gap (97(a)) is indexed to page 108 (page 72).

Related actions (pages 102, 104): "Bilia's HR function conducts annual pay equity analyses to ensure equal pay regardless of gender... Measures in the form of salary corrections are initiated by the HR function based on the results... Pay equity analyses are carried out in all countries where Bilia operates." And: "The Pay Transparency Directive will apply to Bilia from June 2026... the HR function has allocated resources to ensure equal pay for work of equal value and to develop relevant governance and potential targets."

Incidents, complaints and severe human rights impacts

Reference: page 108.

Human rights: "No work-related human rights incidents involving Bilia's own workforce were reported in 2025, including cases of non-compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines for Multinational Enterprises. No severe human rights impacts affecting employees were reported during the same period" (page 108).

Incidents and complaints: "A total of 32 reports were submitted in 2025 through channels available for employees to raise concerns and report misconduct. Fifteen discrimination cases were registered, six of which have been confirmed" (page 108).

Source: "The information has been collected from Bilia's whistleblowing system and from central and local HR functions" (page 108).

Bilia also discloses that it "does not have a process for monitoring awareness of the whistleblowing channel, whether the workforce trusts the channel, or how effectively it functions" (page 103), which bears on how the 32-report figure should be read.

Business conduct policies and corporate culture

Reference: pages 112-113.

The single material G1 impact is "Difficulties in following up on suppliers", upstream (page 112). "The Board of Directors is responsible for the oversight of responsible business conduct at an overall level, while Group Management and delegated managers in the subsidiaries handle day-to-day operations".

Reporting duty (page 112): "All individuals representing Bilia are... required to take responsibility and report suspected incidents, deviations, and breaches of law or Bilia's policies." Investigators "must be independent".

Code of Conduct (page 113): "Training on the Code of Conduct is provided as a mandatory e-learning course for all new employees... Training on anti-corruption and bribery is conducted in connection with the mandatory Code of Conduct training. Employees working in service and sales functions have been identified as particularly exposed to corruption-related risks."

Whistleblowing (page 113): an external, encrypted, password-protected tool open to "all stakeholders in Bilia's value chain", with reports assessed by a Whistleblowing Committee of the Deputy CEO, CFO and HR Director; "Bilia complies with whistleblower protection legislation, which protects the reporting person from retaliation and guarantees full anonymity."

Management of relationships with suppliers

Reference: page 114.

The material G1 impact addressed here is "Difficulties in monitoring business partners": "Larger suppliers may have more knowledge and data on sustainability issues but offer less transparency. Smaller suppliers, in turn, have fewer resources and less capacity for continuous monitoring and data collection... This sometimes makes it difficult for Bilia to make well-informed choices of suppliers or to terminate partnerships due to a lack of information" (page 59).

Approach (page 114): "To ensure that all contracted suppliers meet the Group's ethical and environmental standards, including commitments related to human rights, they approve and sign Bilia's Supplier Code of Conduct. This requirement is considered fundamental for reducing negative impacts in the follow-up and monitoring of Bilia's suppliers." The Code "is based on the Ten Principles of the UN Global Compact... which include internationally recognised human rights as well as the ILO's fundamental principles and rights at work."

Direction of travel noted: "Bilia is a partner to the car manufacturers... Our partnership is governed by the manufacturers' Code of Conduct for business partners or similar principles" (page 114), consistent with SBM-1's statement that Bilia's upstream influence "is limited" (page 54).

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. In Bilia's ESRS content index, MDR-T "Tracking effectiveness of policies and actions through targets" is mapped for G1 Business conduct to page 114 (page 76).

Bilia discloses no numerical business conduct target. Page 114 provides MDR-T's other limb, how effectiveness is tracked. On supplier monitoring, the material G1 impact: signing the Supplier Code of Conduct "is considered fundamental for reducing negative impacts in the follow-up and monitoring of Bilia's suppliers". On payment practices, four principles: "Clear payment terms... Automated invoice processing... Regular follow-up... Transparency and communication."

The quantified commitments sit under S2, page 111, and are entity-specific rather than ESRS targets: agreements in place with all suppliers above SEK 25,000 of annual purchase value "no later than 2028" (held since 2018), and an annually-tracked requirement that all centrally contracted suppliers sign the Code - 88 per cent signed in 2025, a further 8 per cent held an equivalent code, so 96 per cent in total.

Corporate-culture effectiveness is not measured: no Code of Conduct training completion rate and no culture metric is disclosed (pages 112-113).

Payment practices

Reference: page 114.

Standard terms and actual performance: "The company's standard terms for suppliers are payment against invoice within 30 days. The average actual payment period is approximately 30 days and is based on a selection of small and medium-sized suppliers, defined as suppliers with fewer than 250 employees, and has been calculated using data from Bilia's paid invoices during 2025" (page 114).

Sector carve-out, disclosed: "For certain purchases, primarily vehicles, payment is made in accordance with industry practice, which is usually 30 days or no later than upon delivery of the vehicle to the end customer" (page 114).

Legal proceedings: "At the time of publication of the sustainability report, the company has no outstanding legal proceedings related to late payments" (page 114).

Policy and procedure (page 114): "the company seeks to avoid late payments, particularly to small and medium-sized enterprises." The payment function "follows a procedure that ensures payments are made on time, regardless of the supplier's size. The procedure requires correctly issued invoices"

Reading the figures. The average payment period is given as approximately 30 days rather than exactly, and is measured on a selection of SME suppliers rather than all invoices. Bilia does not report the percentage of payments aligned with standard terms.