BillerudKorsnas

The role of the administrative, management and supervisory bodies

Reference: page 56; pages 56-57.

"Billerud's Board of Directors consists of seven members and two employee representatives", representing the Swedish Paper Workers Union and PTK. Excluding them, "all seven (100%) Board members are non-executives and independent of the Company and management. Six of seven (86%) Board members are independent of the Company's major shareholders." "Three of seven Board members (43%) are women, and four members are men (57%)", so "the Board's gender diversity ratio... is 75%" (page 56).

The Group Management Team "consists of nine executive representatives", including an EVP Sustainability & Public Affairs. "There are no workers' representatives in the Group Management Team. Two (22%) of the nine members are women and seven (78%) members are men" (page 56).

"Billerud's Board of Directors is the highest body overseeing sustainability at Billerud" and is responsible for ensuring the annual report follows the Swedish implementation of CSRD and the ESRS. It approves the strategy, Group policies, incentive programmes and sustainability-linked remuneration targets, and "normally dedicates at least one meeting per year to a deeper dive on relevant sustainability topics" (page 57). A separate Audit Committee is "responsible for the oversight of the financial and sustainability reporting" (page 57).

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

Reference: page 58.

"The Board of Directors typically has around seven ordinary Board meetings each year. The CEO provides a business and strategy update at every Board meeting, including where relevant on sustainability matters. In addition, the Board typically conducts an in-depth review of sustainability matters once a year."

"In 2025, the Board was informed about sustainability-related impacts, risks and opportunities connected to climate change, water, biodiversity, resource use and circular economy, own workforce, safety and business conduct. Furthermore, the Audit Committee received information on regulatory updates connected to relevant sustainability reporting frameworks."

"The Board approves all Group policies... and reviews them annually. This does not include the Supplier Code of Conduct, which is approved when needed by the Group Management Team. In addition, the approval of the Operations, Quality and Procurement Policy is delegated to the CEO."

"The Group Management Team meets once or twice each month, and sustainability topics are considered regularly. Performance and targets are monitored monthly. During 2025, the Group Management Team was informed about the same impacts, risks and opportunities as described for the Board" (page 58).

Integration of sustainability-related performance in incentive schemes

Reference: page 58.

"Billerud has integrated sustainability matters in its incentive programs and remuneration policies."

Long-term share programme. The LTIP "has a term of three years. There are currently three LTIP ongoing: 2023, 2024 and 2025. The 2025 incentive program is structured to promote both financial performance conditions and a sustainability-related performance condition connected to our scope 1 and 2 science-based targets to 2030." "For LTIP 2025, the performance conditions are weighted so that 85% of the share award will be based on the fulfillment of the financial performance condition and 15% of the allotment of the sustainability performance condition." "The CO2e emission reduction is calculated based on the information presented in Billerud's sustainability statement."

Variable compensation. The scheme covers "all Billerud employees within Europe and a majority of the employees in North America", including the Group Management Team, and "is linked to Billerud's yearly target on either lost time injury frequency rate (LTIFR) or total recordable injury frequency rate (TRIFR) depending on the contract. The targets include both own workforce and workers in the value chain." Safety-linked variable pay "accounts for maximum 20% of the total variable compensation for the CEO" and between 10% and 20% for others (page 58).

Statement on due diligence

Reference: page 58; page 137.

"The table in the Sustainability note 2 (Sn2) on page 137 provides a detailed mapping of the information presented in this sustainability statement concerning Billerud's due diligence process" (page 58).

Sn2 (page 137) maps the five core elements to paragraphs and pages:

• a) Embedding due diligence in governance, strategy and business model - GOV 2 page 58; SBM-3 page 65; IRO-1 page 68; topic IRO-1 pages 69 (E1), 83 (E2), 88 (E3), 90 (E4), 97 (E5), 127 (G1)
• b) Engaging with affected stakeholders - SBM-2 page 63; MDR-P page 58 and in topical standards pages 75, 84, 88, 92, 98, 103, 112, 116, 121, 124, 128
• c) Identifying and assessing negative impacts on people and the environment - IRO-1 page 68; SBM-3 page 65 and topic SBM-3 pages 71 (E1), 91 (E4), 102 and 111 (S1), 116 (S2), 120 (S3), 124 (S4)
• d) Taking action to address negative impacts - MDR-A pages 76, 84, 89, 93, 98, 106, 113, 118, 123, 125
• e) Tracking the effectiveness of these efforts - MDR-M pages 79, 86, 89, 96, 100, 108, 115, 119, 123, 126, 135; MDR-T pages 78, 86, 89, 95, 99, 108, 115, 119, 123, 126, 131-132

Risk management and internal controls over sustainability reporting

Reference: page 59.

"The Sustainability & Public Affairs function is responsible for the Group's consolidated sustainability reporting and for ensuring that risks related to sustainability reporting are assessed and managed through the internal control framework."

"During 2025, Billerud continued the process of formalizing its internal control framework for sustainability reporting on a consolidated level. The framework is built on a risk assessment of the quantitative disclosures presented in the sustainability statement. The risks have been prioritized according to likelihood and impact in similarity to our Enterprise Risk Management (ERM) framework."

"The four-eyes principle is applied at multiple points in our data flow structures, for example for environmental data at our mills and in consolidation procedures."

Four named risk drivers, which "remain consistent with those identified in 2024": the discrepancy between reporting processes, KPIs and methodologies in Region Europe and Region North America; differing legal frameworks affecting data accessibility; "the manual processing of data"; and "the formalization and documentation of processes and responsibilities to ensure continuity and reduce risk of personal dependencies".

Reporting risks reach the Board through the Audit Committee "from the annual limited assurance on the sustainability statement" (page 59).

Strategy, business model and value chain

Reference: pages 59-62.

"Billerud makes high-performance packaging materials for a low carbon society. Billerud's products are manufactured in ten production facilities in Sweden, Finland and the US." "All facilities, except the Wisconsin Rapids converting facility and the Pietarsaari mill, are integrated mills that produce paper, board and pulp." "On 31 December 2025, Billerud had 5,626 employees located in 17 markets" (page 59).

"In Europe, our main products include liquid packaging board, containerboard, carton board, kraft paper and sack paper. In North America, our main products include graphic paper, label paper and market pulp." "Billerud has no products and services that are banned in certain markets. Billerud is not active in fossil fuel (coal, oil or gas) sectors" (page 59, the paragraph 40(d)(i) datapoint). Chemical production, controversial weapons and tobacco are marked "Not material" in the index (page 137).

"Billerud's Way Forward strategy aims to create value and achieve financial, sustainability and safety targets", with initiatives including "the execution of the Evolution program, driving cost-efficiency, building a winning value proposition, securing cost-competitive fiber and improving mill efficiency" (page 59).

The value chain diagram (page 62) maps material topics per stage: upstream E1, E4, E5, S2, S3, G1; own activities E1-E5, S1, S2, S3, G1; downstream E1, E4, E5, S2, S4.

Interests and views of stakeholders

Reference: pages 63-64.

"Billerud continuously engages in formal and informal dialogue with internal and external stakeholders... Learnings from the stakeholder engagement feeds into our double materiality assessment, strategy and business model development" (page 63).

Channels by group (pages 63-64). Investors: AGM, investor and analyst meetings, Capital Markets Day. Customers and brand owners: meetings, fairs, customer surveys, audits. Employees: workplace meetings and safety rounds, the annual employee survey, incident registration, performance management conversations. Contractors: a contractor contact point, trainings, "annual contractor survey (North America)", audits. Affected communities: information meetings and events; for indigenous peoples, "Consultation meetings, conversations as part of supplier relations, yearly management reviews, certifications procedures / forums (FSC, PEFC, SFI)".

"Billerud does not engage directly with end-users or consumers. Our primary interactions to address any product issues are with our customers." Indigenous peoples' views "are included in our double materiality assessment via representatives from our Wood Supply operations... However, indigenous peoples are not directly involved in Billerud's strategy development process" (page 63).

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

Reference: pages 65-67.

"During the double materiality assessment, Billerud identified material sustainability-related impacts on people and the environment in our operations and value chain." "Note that when an impact has already occurred, it is labelled 'actual impact'. All other impacts are deemed to be potential" (page 65).

The overview table lists 44 rows across ten topics,, type shown only as icons:

• E1 Climate change (13 rows) - adaptation risks (operational disruptions, decreased wood supply); mitigation impacts (scope 1 and 2, biogenic and scope 3 emissions; "Providing a substitute to fossil-based packaging materials"); risks and opportunities (not achieving climate targets, wood raw material competition); energy (fossil fuels in the mix, district heating from excess energy, electricity and certificate prices)
• E2 Pollution (6)
• E3 Water (1), E4 Biodiversity (6), E5 Resource use (6), S1 Own workforce (5), S2 Value chain workers (1), S3 Affected communities (1), S4 Consumers and end-users (1), G1 Business conduct (4)

"Changes to material impacts, risks and opportunities from the previous reporting period are disclosed in BP-2 on page 55": E2-5 was excluded after the annual DMA review, and two previously separate G1 and S2 impacts were consolidated into one impact under G1 (page 55).

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

Reference: page 68.

"Billerud's double materiality assessment is the basis for our 2025 sustainability statement. The process... involved collaboration with a wide range of stakeholders as well as interviews and desktop research."

Scope and sources. "The double materiality assessment covered Billerud's own operations and value chain. Workers within forestry and at our mills as well as direct suppliers were the primary focus of our value chain assessment." "No external stakeholders were directly involved in the double materiality assessment, as their views were deemed to be properly represented by the involved internal stakeholders."

Thresholds. "Impacts were assessed by severity (scale, scope and irremediability) and likelihood. A threshold was established that gave precedence to severity over likelihood. Adjustments were made for human rights-related impacts by applying a lower threshold."

Approval and review. "The result of the double materiality assessment was calibrated together with Billerud's Group Management Team in 2024, and thereafter approved. Billerud's Audit Committee and Board of Directors also accepted the results in 2024." "However, the full double materiality assessment is not subject for approval every year." "During 2025, Billerud defined a process to review its double materiality assessment annually to ensure relevance" (page 68).

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

Reference: page 68; pages 137-140.

"The disclosure requirement is presented in Sustainability note 3 (Sn3) on page 137" (page 68). Sn3 is a four-page ESRS content index: "The content index demonstrates a list of disclosure requirements presented in the sustainability statement" (page 137).

Listed with a page reference: ESRS 2 BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2 (page 137); E1 IRO-1, E1 SBM-3, E1-1 to E1-6; E2 IRO-1, E2-1 to E2-4; E3 IRO-1, E3-1 to E3-4 (page 138); E4 IRO-1, E4 SBM-3, E4-1 to E4-5; E5 IRO-1, E5-1 to E5-5; S1 SBM-3, S1-1 to S1-6, S1-9, S1-13, S1-14, S1-17 (page 139); S2 SBM-3, S2-1 to S2-5; S3 SBM-3, S3-1 to S3-5; S4 SBM-3, S4-1 to S4-5; G1 IRO-1, G1-1 to G1-6 (page 140).

Marked "Not material": E1-7 paragraph 56; both S1-16 datapoints; SBM-1 paragraph 40(d) ii-iv; E3-1 paragraphs 13 and 14; E4-2 paragraphs 24(b) and (c); E5-5 paragraph 39; S4-1 paragraph 17; S4-4 paragraph 35. Marked "Transitional provision": all five E1-9 datapoints and S1-14 paragraph 88(e).

Absent from the index: E1-8, E2-5, E2-6, E3-5, E4-6, E5-6, S1-7, S1-8, S1-10, S1-11, S1-12, S1-15.

Transition plan for climate change mitigation

Reference: pages 74-75.

"Billerud's transition plan is based on strategic decisions, operational efficiency improvements and effective investments. Our strategic direction is supported through activities and plans to phase out fossil fuels, increase energy efficiency, and optimize the use of raw materials in production facilities. The transition plan for our own operations has been approved by Billerud's Group Management Team. The transition plan was approved during 2024 and covers both our European and North American operations" (page 74).

Scope. "Scope 3 decarbonization levers and activities are not part of the current transition plan. Upstream and downstream value chain emissions are planned to be reduced through a roadmap that will be developed in collaboration with, for example, suppliers, logistics partners and other partners" (page 74).

Financial plan. "Future Capex required to implement the scope 1+2 action plan for Billerud's European and North American operations is estimated at SEK 115-165 million" (page 74). No EU Taxonomy KPI mapping or capex plan has been produced (page 75)..

Net zero. "Billerud has not yet established a transition plan for the net-zero target, and therefore no drivers, key actions, or investments have been defined. Billerud has not yet defined a date of adoption of a transition plan" (page 75).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 and E1 IRO-1 and E1 SBM-3, where this content is disclosed in the FY2025 report (pages 69-73). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 69-70; pages 71-73.

Classification. Risks are split explicitly into physical and transition: "Billerud has considered its resilience against different types of climate-related risks and has identified both physical and transition risks" (page 71).

Methodology. "Climate-related hazards were considered for the identification of gross physical risks, both stemming from Billerud's own operations as well as for its value chain, using IPCCs high-emissions scenario RCP 8.5."

Scenarios. "The scenario analysis includes IPCCs Representative Concentration Pathway (RCP) 2.6 scenario in line with the Paris Agreement to keep temperatures well below 2 degrees, and the RCP 8.5 four-degree scenario 'business as usual'" (page 69). "The RCP 2.6 does not align with limiting global warming to 1.5 degrees C but was considered the most relevant scenario during the time the assessment took place. Billerud has not yet updated its climate scenario analysis to align with the 1.5 degrees C target" (page 70). "Billerud updated its climate-related scenario analysis in 2023" (page 71), so no refresh was carried out in 2025.

Resilience in relation to climate change

Back-filled from E1 SBM-3, where this content is disclosed in the FY2025 report (pages 71-74). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: page 71; pages 72-74.

Process. "By using the input from Billerud's climate scenario analysis, Billerud has considered its resilience against different types of climate-related risks and has identified both physical and transition risks."

Uncertainty. "The areas of uncertainty of the analysis include which global emissions pathway will materialize. Future climate and energy policies are also difficult to predict, as are market trends and consumer behaviour. The availability and price of wood raw material, energy prices and electricity market dynamics are subject to volatility. Dependencies on external actors throughout the value chain add further uncertainty" (page 71).

Capacity to adapt. A "Resilience" paragraph accompanies each risk. For physical risks: "Within own operations, Billerud increasingly takes on climate adaptation measures to reduce physical climate risks in the forest areas that we manage by, for example, cooperating with contractors to minimize rutting damage".

Policies related to climate change mitigation and adaptation

Reference: pages 75-76.

"Billerud's climate change endeavors are governed by our Sustainability Policy and the subordinate Environmental Directive and Energy Directive" (page 75).

Sustainability Policy. "The major impacts, risks and opportunities covered are negative material impacts related to scope 1 and 2 emissions, biogenic emissions and scope 3 emissions as well as the positive impact of providing a substitute to fossil fuel-based packaging." Named commitments include "the Rio Declaration on Environment and Development, the UN Global Compact, the UN Global Goals, the Science Based Targets initiative (SBTi) and the Paris Agreement" (pages 75-76).

Environmental Directive. It "includes water emissions, emissions to air, chemicals, waste, greenhouse gas (GHG) emissions, and products and solutions... It addresses climate change mitigation, but not climate change adaptation activities." It "spans the entire Billerud value chain, for example, managing scope 3 emissions". Owner: the Director Global Environment & Quality (page 76).

Energy Directive. It "covers climate mitigation activities, including energy efficiency measures, but does not cover climate adaptation measures", and "covers the negative impacts of fossil fuels in the energy mix as well as the positive impact concerning the recovery of excess energy" (page 76).

Actions and resources in relation to climate change policies

Reference: pages 76-77.

"Billerud's key actions under the approved transition plan cover its own operations in Europe and North America."

2025 actions, expected versus achieved (ktons CO2e, page 77): increased purchased biomass -30 expected, 0 achieved ("The project was not carried out as planned and therefore did not result in the expected CO2e outcomes"); rail ties project -30 expected, -31 achieved, "completed in 2025 in one of our North American mills"; woodyard project at Escanaba N/A expected, -25 achieved,; one-way sootblowing N/A expected, -6.6 achieved; biofuel power and recovery boiler at Gruvön -10 expected, 0 achieved ("the switch to bio-oils have not been made yet and the outcome is so far zero"); electrical boiler -0.4 expected, 0 achieved. Total -70.4 expected against -62.6 achieved.

Planned 2026-2030 (ktons CO2e): landfill project -47, increase purchased biomass -65, biofuel in biofuel boiler -10, total -122. "Billerud is revising its CO2e reduction plan in response to the current market conditions and developments related to the ETS. An updated plan will be finalized in 2026" (page 77).

Financing. "During the reporting period, Capex of SEK 35 (36) million was invested... Future Capex is estimated to amount to SEK 115-165 million between 2026-2030. No future Opex has been calculated for the duration of the action plan."

Targets related to climate change mitigation and adaptation

Reference: pages 78-79.

"Billerud's near-term and long-term climate change mitigation targets are approved and verified by the Science Based Targets initiative (SBTi)... The near-term 2030 target includes scope 1 and 2 reductions of 42% and a 25% reduction of scope 3 emissions. The long-term 2050 target includes a reduction of scope 1-3 emissions by 90%" (page 78).

Baseline. Base year 2022. "Scope 1 & 2 emissions equals 1,030 ktons CO2e... and scope 3 covers 2,685 ktons CO2e. Both targets use the market-based method for scope 2 emissions. The baseline value for scope 2 and 3 emissions has been restated."

"Decarbonization levers in the value chain have not yet been individually quantified and formulated into an action and transition plan" (page 78).

Progress (page 79). "Scope 1 emissions have increased with approximately 5% compared with 2024... However... scope 1 emissions have decreased with approximately 18% since 2022. Market-based scope 2 emissions decreased with approximately 17% compared with last year." "Total scope 3 emissions have increased slightly with approximately 1% compared with 2024." "Between 2022 and 2025, Billerud has reduced emissions in scope 1, scope 2, as well as total scope 3 emissions with 1,019 ktons CO2e." "Scope 1 and scope 2 accounts for 70% (78%) of the total reductions needed to meet our scope 1 and 2 near-term targets."

Energy consumption and mix

Reference: page 79.

Total energy consumption fell from 25,137 GWh in 2024 to 24,784 GWh in 2025 (page 79). The mix:

• Total fossil energy consumption 2,244 to 2,444 GWh, a 9% to 10% share. Within that, coal and coal products 26 to 0 GWh; crude oil and petroleum products 341 to 322 GWh; natural gas 1,865 to 2,112 GWh; purchased electricity, heat, steam and cooling from fossil sources 12 to 9 GWh; other fossil sources nil in both years. Nuclear sources accounted for 2,665 then 2,441 GWh (11% then 10%).

• Total renewable energy consumption 20,228 to 19,899 GWh, an 80% share in both years. Within that, fuel from renewable sources including biomass 19,987 to 19,654 GWh and purchased renewable electricity, heat, steam and cooling 241 to 246 GWh.

"Total energy consumption from activities in high climate impact sectors per net revenue" rose from 0.58 to 0.61 GWh/SEKm, up 6% (page 79).

"Billerud primarily uses bioenergy in its processes, with most of the biofuel coming from internal streams such as black liquor and bark. In 2025, Billerud significantly reduced its use of coal in line with the planned phase-out of remaining stored volumes, while increased production in North America led to higher natural gas consumption" (page 79).

An entity-specific metric reports sold energy converted to houses heated: 65,000 in 2024 and 64,900 in 2025, covering district heating from the Gävle mill (including Bomhus Energi), Frövi, Gruvön and Skärblacka (page 79).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 80-81.

Base year 2022, comparative 2024, then 2025 (ktons CO2e, page 80):

• Gross scope 1 883, 687, 720 (up 5% year on year); 2030 milestone 562, 2050 milestone 88
• Gross location-based scope 2 293, 254, 182 (down 29%)
• Gross market-based scope 2 147, 7, 6 (down 17%)
• Total gross scope 3 3,698, 2,964, 2,984 (up 1%); 2030 milestone 2,611, 2050 milestone 349
• Total GHG (location-based) 4,873, 3,905, 3,885 (down 1%)
• Total GHG (market-based) 4,728, 3,658, 3,709 (up 1%); 2030 milestone 3,209
• Total gross biogenic emissions 7,856, 7,521, 7,412 ktons CO2 (down 1%)

Largest 2025 scope 3 categories: purchased goods and services 1,130; upstream transportation and distribution 476; processing of sold products 465; fuel and energy-related activities 295; end-of-life treatment of sold products 281; downstream transportation 218; capital goods 110.

GHG intensity per net revenue rose from 0.09 to 0.1 ktons CO2e/SEKm location-based and 0.08 to 0.09 market-based (page 81).

Methodology. GHG Protocol, operational control, IPCC AR6 GWP factors; emission factors "with a majority originating from DEFRA, EPA (Sweden and the US) and EcoInvent (v3.10)". "26% of scope 3 emissions are calculated using primary activity data from suppliers and other value chain partners." Scope 2 figures for 2022-2024, scope 3 category 1 and biogenic emissions were all restated (page 81).

Policies related to pollution

Reference: page 84.

"The material impacts and the risk presented on the previous page are governed by Billerud's Environmental Directive. Billerud's Environmental Directive outlines Billerud's commitment to environmental sustainability and focuses particularly on minimizing the environmental impact of Billerud's production units. For the European operations, the directive states compliance with the EU Industrial Emissions Directive (IED)" (page 84).

Scope. "The directive is mainly focused on impacts from Billerud's own operations, especially focusing on the production units, but it also includes impacts in the value chain." "The directive covers all emissions that occur due to Billerud's activities, including all pollutants covered in Annex II of Regulation (EC) No 166/2006."

Limits and disturbances. "For Region Europe, the production units shall limit the emissions to water and air to be within the span for the best available techniques associated emission level (BAT-AEL)." The directive "highlights Billerud's ambition to minimize its impact on the surrounding communities by monitoring and following up on potential operational disturbances such as noise and odor", and sets "a long-term goal... for all production units to have the third-party certified environmental management system ISO 14001". Owner: the Director Global Environment & Quality (page 84).

Actions and resources related to pollution

Reference: pages 84-85.

"The key actions related to emission reductions at Billerud's mills include technological upgrades and process improvements, focused on ensuring that pollution permits are maintained." (page 84).

Air (page 84). At Frövi, "optimization measures have been implemented on the new recovery boiler to reduce nitrogen oxide (NOx) emissions", which now "fall below or are in line with the lower BAT-AEL levels". "A new electric steam boiler has been installed and taken into operation in Rockhammar".

Water (page 85). "The Frövi mill has installed an effluent treatment plant to treat the discharge from the woodyard", and "From 2025 onwards, Billerud have a water investment fund, called the Water Fund, for the European mills with the funds dedicated to projects that will reduce effluent discharge." "In 2025, Billerud reached our water target and the action that have had the largest contribution to this was the installation of a cooling system for parts of the board machine in The Gruvön mill."

Resources. "The capital expenditures for environmental investments during the reporting period amounted to SEK 110 (134) million." "Future investments are estimated to amount to SEK 20 million per year for projects in the water fund. In 2025, capital expenditure connected to the water fund accounted to SEK 3 million" (page 85).

Targets related to pollution

Reference: page 86.

"Billerud has set a target to reduce process effluent, the wastewater flow to the effluent treatment plant, as it will enhance the effluent treatment plant's function and decrease water pollution. The target is to reduce wastewater flow to the effluent treatment plant by 10% by 2030."

Methodology. "The target was set in 2023 with 2020 as the baseline year. The baseline value for the wastewater flow is 316,000 m3/day and the target for 2030 is to reduce the flow to 285,000 m3/day, which equals a reduction of 10%. It is an absolute reduction target. To reach the target we have set a yearly reduction on 3,160 m3/day, which equals a reducation on 1%. The target is not based on conclusive scientific evidence."

Outcome. "The short-term target for 2025, equal to a 3,160 m3/day (1%) reduction, was reached. The outcome in 2025 equals a reduction of 4,790 m3/day (1,620 m3/day). This equals to a reduction of around 1.5% (0.51%)." Cumulatively, Billerud "has reduced process effluents by 9.4% (7.9%) in relation to the 2020 base year by the end of 2025" (page 86).

No air or disturbance targets. "Billerud does not have any targets related to emissions to air. The reason is that emissions to air are subject to production permits, which we aim to comply with. Billerud does not have any targets on disturbances and related grievances" (page 86).

Pollution of air, water and soil

Reference: pages 86-87.

"The table presents the accumulated emissions from each production unit with emissions above the threshold in Annex II of Regulation (EC) No 166/2006" (page 87).

Emissions to water (tons), 2024 then 2025. Total 27,887 to 28,984. Chlorides (as total Cl) 15,078 to 17,602; total organic carbon 12,136 to 10,792; total nitrogen 328 to 278; halogenated organic compounds (as AOX) 251 to 235; total phosphorus 80 to 68; zinc 12 to 9;.

Emissions to air (tons), 2024 then 2025. Total 22,462 to 23,070. Carbon monoxide 7,070 to 7,597; methane 6,298 to 6,194; nitrogen oxides 5,114 to 5,486; non-methane VOC 2,328 to 2,398; particulate matter PM10 818 to 726; ammonia 475 to 355; sulphur oxides 185 to 155;.

Outcome. "As chlorides stands for a large part of the total emissions, and the majority of such emissions occur in Region North America, the production increase in Region North America drives the increase in both chlorides and total emissions to water. Emissions to air show no significant change between 2025 and 2024" (page 87). "The reported TOC outcome for 2024 has been restated due to a human error in last year's reporting. The total TOC was overreported by 13%" (page 87).

Entity-specific grievance metric. Smell grievances 26 to 39 and noise grievances 19 to 13 (page 87).

Policies related to water and marine resources

Reference: page 88.

"The Environmental Directive describes Billerud's management of material impact related to water withdrawals and discharge and Billerud's dependency on water for its operations. It states that Billerud is committed to using surface water in its production and to returning most of it to the local body of water, acknowledging that some of the water is consumed as water vapor. The directive focuses mainly on impacts from Billerud's own operations, especially the production units. However, it also includes impacts that occur within the value chain" (page 88).

"The directive states that Billerud should monitor water stress in the areas of our operations and handle potential risks. It also states Billerud's ambition to limit water emissions according to the operating licenses."

Limits of the policy. "The directive does not address areas of high-water stress or risk, as Billerud does not have pulp and paper mills in areas of high-water stress" (page 88). The content index correspondingly marks the ESRS E3-1 paragraph 13 dedicated policy datapoint and the paragraph 14 sustainable oceans and seas datapoint as "Not material", while E3-1 itself and the paragraph 9 datapoint are reported on page 88 (page 138). The single material E3 IRO is "Water usage in operations", a negative actual impact with no associated risk or opportunity (pages 66, 88).

Actions and resources related to water and marine resources

Reference: page 89.

"We are committed to minimizing the impact of our water use and our impact on water quality. Surface water is mainly withdrawn for our production processes and returned to waterways" (page 89). Sedimentation basins and biological and chemical treatment remove contaminants before discharge.

"During 2025, around 5% of the withdrawn water was not released back to the source. This is primarily attributable to evaporation and the retained water content of our finished products."

Water risk. "Our annual water risk assessment identified that our converting facility, Wisconsin Rapids, is located in an area of high water stress. Other production units (pulp and paper mills) are located in areas rated as low or low-medium water risk. Based on the outcome of the water risk assessment, no related impact has been assessed as significant for Billerud." "For this reporting, we have applied the WRI's Aqueduct Global Water Tool."

Site-level actions. "In Quinnesec, a water conservation team is focused on implementing further ways to reduce water usage by changing behaviors and exploring technical solutions." "During the reporting year, Billerud has not taken any key actions to provide support to the provision of remedy for impacted environment, as there have been no occurences of harm" (page 89). The action plan behind the effluent target is described in E2-2 on page 84.

Targets related to water and marine resources

Reference: page 89; page 86.

"Billerud has a voluntary target to reduce the wastewater flow to the wastewater treatment in our Swedish and Finnish production units by 10% to 2030. To reach the target we have set a yearly reduction on 3,160 m3/day, which equals a reducation on 1%. In 2025, we achieved a reduction of 4,790 m3/ day (1,620 m3/day), which means that the short-term target was reached. This corresponds to a percentage reduction of approximately 1.5% (0.51%)" (page 89).

"The target will result in a positive impact on the function of the treatment plant, with potential to further reduce emissions of organic matter and nutrients. Over the coming years we plan to review and integrate our mills in North American the target. The target is interlinked with reducing water pollution and is not based on conclusive scientific evidence. Outcome and methodology are described in detail in E2-3 on page 86" (page 89).

The underlying figures from E2-3 are a 2020 baseline of 316,000 m3/day and a 2030 target of 285,000 m3/day, with cumulative progress of "9.4% (7.9%) in relation to the 2020 base year by the end of 2025" (page 86). Progress is tracked monthly (page 86). Billerud discloses no separate withdrawal or consumption target and none relating to marine resources.

Water consumption

Reference: page 89.

Metrics (page 89). Total water consumption rose from 11,000,000 m3 in 2024 to 13,400,000 m3 in 2025, with values "rounded to the nearest hundred thousand". "Total water consumption in areas at water risk, including areas of high-water stress" is reported as nil in both years, footnoted: "Based on the outcome of the water risk assessment, no related impact has been deemed significant for Billerud." Water intensity, the paragraph 29 datapoint, rose from 252 to 331 m3 per SEKm of net revenue.

"Total water recycled and reused", the paragraph 28(c) datapoint, is reported as a dash with the footnote: "Billerud recycle and reuse water within the production units, but Billerud is unable to measure or estimate the amount of water that is recycled or reused for this reporting" (page 89).

Methodology. "Billerud's metrics for water consumption are based on a study for Nordic pulp and paper mills that was conducted by IVL Swedish Environmental Research Institute. The water consumption includes water retention in products and water leaving the production units as steam. "

Outcome. "The increase compared to 2025 is mainly due to the Escanaba mill having changed its method for calculating water consumption. During 2025, we have updated our reporting unit of the intensity metric below from million m3/SEKm to m3/SEKm" (page 89).

Transition plan on biodiversity and ecosystems

Reference: page 92.

"Billerud does not have a communicated biodiversity transition plan but is aligning its actions within biodiversity with relevant local, national, and global goals for biodiversity. During the reporting period, no assessment to map alignment with the Kunming-Montreal Global Biodiversity Framework and the EU Biodiversity Strategy for 2030 has been conducted. However, a TNFD gap assessment was condcuted in 2025 to evaluate alignment with the framework" (page 92).

What the report gives instead is a resilience and risk discussion for the single material E4 risk. "The transition risk concerning increased regulations and restrictions on wood supply for biodiversity purposes... is considered to be prevalent in Billerud's own operations (forestry management activities) but is assessed to be larger in regard to sourced wood raw material. No resilience analysis has been conducted, but Billerud performs an annual risk assessment within our Enterprise Risk Management (ERM) framework, where this risk is included."

"As wood raw material and pulp account for a third of Billerud's operating costs, a price increase in this segment is considered a significant risk."

Policies related to biodiversity and ecosystems

Reference: pages 92-93.

"Wood Supply Directive. It "outlines Billerud's commitment to ensure traceability of sourced wood raw material". It "adheres to third-party forest certification standards, including third-party certified chain of custody standards set by the Forest Stewardship Council (FSC), and standards endorsed by the Programme for the Endorsement of Forest Certification (PEFC), as well as the Sustainable Forestry Initiative (SFI) in North America", and "complies with the EUTR, EUDR and US Lacey Act timber legislations".

Sustainable Forestry Directive. It "establishes Billerud's approach to responsible forestry, focusing on practices that support long-term timber yield, biodiversity, water quality, cultural preservation, and recreational opportunities", and "applies only to Billerud's European operations and purchases" (page 92).

Deforestation and gaps. "Both directives specifically address deforestation and state Billerud's No Deforestation commitment" (page 93), the paragraph 24(d) datapoint. "Billerud does not have any sustainable land or agricultural policy, nor any sustainable ocean or sea practices policy, as this is not relevant for Billerud" (page 92), and the index marks paragraphs 24(b) and 24(c) "Not material" (page 139).

Actions and resources related to biodiversity and ecosystems

Reference: pages 93-94.

"Sourcing. "During 2025, 99.7% (99.2%) of the wood material that was delivered to the European mills (including pulp wood, chips and pulp) was sourced from European forests, with 70.6% (66.6%) coming from Swedish forests, 13.0% (12.2%) from Finnish forests, 11.3% (9.7%) from Norwegian forests and 4.4% (10.0%) from the Baltic countries." "In total, Billerud purchased 13.8 (14.6) million cubic meters of wood raw material (solid under bark) in 2025" (page 93).

Forestry practices in own operations (page 94): "When felling, all the dead trees are left, and high stumps are created to resupply dead wood in the forest"; "buffer zones are created and retained where necessary"; "In FSC certified forestry, at least 10% of the productive forest land area is set aside for conservation or social purposes"; "Conservation burning is carried out to promote fire-dependent biodiversity".

Species protection. "By engaging with the Swedish Society for Nature Conservation, Billerud supports the protection of the white-backed woodpecker and the pool frog", and collaborates "with Upplandsstiftelsen, to preserve over 200 red-listed species listed in the Vällen lake, northeast of Uppsala" (page 94).

"Billerud does not use biodiversity offsets within its own forestry operations or upstream wood supply" (page 94).

Targets related to biodiversity and ecosystems

Reference: page 95.

"Billerud has two targets related to biodiversity and ecosystem services: the proportion of domestic wood supply and the Group-certified forest owners in Billerud's Group certificate for FSC and PEFC" (page 95).

Proportion of domestic wood supply. "The base year is 2023 with the baseline value of 99.5% for Europe and 100% for North America." "The target for 2025 and 2026 is 96%. There are no interim targets. The outcome for 2025 was 100% (100%) for Europe and 100% (100%) for North America. This means that Billerud managed to reach the 2025 target of 96% (96%) for both regions."

Group-certified forest owners. "The baseline year 2013 and the baseline value is 71. The target for 2025 was 314 (320)." "During the reporting period, Billerud achieved the target of certifying 35 new forest owners. At the same time, the total number of forest owners in Billerud's group certificate decreased during the year, which resulted in a total outcome of 309. This meant that we did not reach the overall target of 314 Group-certified forest owners."

Limits. "The two targets are not set based on conclusive scientific evidence and no external stakeholders were involved in setting the targets." "The targets have not been informed or aligned with the Kunming-Montreal Biodiversity Framework, EU Biodiversity Strategy for 2030, or other biodiversity and ecosystem-related national policies and legislation" (page 95).

Impact metrics related to biodiversity and ecosystems change

Reference: page 96; page 145.

Sites in or near protected or key biodiversity areas. "Sites owned, leased, or managed in or near protected or key biodiversity areas" fell from 3,469 sites covering 28,641 hectares in 2024 to 2,924 sites covering 26,937 hectares in 2025. "The decrease in the outcome compared with the previous year is mainly due to change in market conditions in Europe" (page 96). The site mapping by designation type (Natura 2000, UNESCO World Heritage Sites, Key Biodiversity Areas, other protected areas) is given in Sn5 on page 145.

"Entity-specific biodiversity indicators from follow-up at 120 sample sites in Sweden, 2024 then 2025 (page 96): consideration for social values 91% to 94%; sites without major or moderate rutting 87% to 93%; acceptable buffer zones 97% to 94%; acceptable handling of sensitive habitats 98% to 83%; correct handling of high stumps 77% to 83%; average high stumps per hectare 4.4 to 4.3; green, living and preservation trees 90% to 93%; open areas 98% to 100%; cultural relics 77% to 88%; ancient relics 75% to 100%.

"For the follow-up of sensitive habitats, the assessment criteria were changed in 2025, which resulted in more sites being rated as not accepted despite minor deviations."

Policies related to resource use and circular economy

Reference: page 98.

"The identified material impacts and opportunities are governed by Billerud's Environmental Directive... The directive includes objectives to promote the cascading principle regarding byproducts and waste hierarchy for generated waste. It does not explicitly address transitioning away from using fresh fiber and primary resources, nor increasing the use of secondary (recycled) resources in Billerud's own operations" (page 98).

That last sentence is the disclosed gap against ESRS E5-1, and the company states it plainly rather than claiming coverage.

"In addition to the Environmental Directive, resource inflows and circular economy matters are also governed by the overarching Sustainability Policy. The policy centers around taking responsibility at every stage, from selecting raw materials to recycling, as well as in developing business solutions and innovations. The policy states that resources should be used as efficiently as possible" (page 98).

"Securing responsible wood raw material is central for Billerud's operations. For more information on our wood procurement practices and responsible forestry see E4-2 on page 92" (page 98), which covers the Wood Supply Directive and the Sustainable Forestry Directive.

Actions and resources related to resource use and circular economy

Reference: pages 98-99.

"Key actions for resource use and circular economy are based on mapping of value retainment and capture in Billerud's current operations regarding input chemicals, waste, byproducts and energy potential. Another key action is monitoring the regulatory development regarding the Packaging and Packaging Waste Directive (PPWR)" (page 98).

Named 2025 actions. Resource outflows: "In 2025, wastewater treatment residuals were reused at the Quinnesec mill through safe land application on farms and in mine reclamation, reducing landfill disposal and supporting circular resource use. In addition, starting in November 2025, Quinnesec's woodyard sweepings were redirected to land application, cutting the amount of material sent to landfill each year" (page 98).

Resources and gaps. "Financial resources allocated to resource use and circular economy are mainly for maintenance and renewal of current operational investments. No significant CapEx or OpEx related to actions was taken during the reporting period. Financial resources related to future key actions have not been evaluated at this stage." "No action plan has been formalized during the reporting year. In addition, no actions have been formulated for non-operational units" (page 99).

Targets related to resource use and circular economy

Reference: pages 99-100.

"Billerud's target is that 100% of paper packaging material put on the market should be recyclable. Billerud's Region Europe has reached its target of 100% recyclable paper packaging material through testning according to the Papiertechnische Stiftung (PTS) method" (page 99). "The target's baseline value is 100% and the base year is 2023. "

Outcome (page 100). Region Europe: target 100% and outcome 100% for 2024 and 2025, with a 100% target to 2030. Region North America: target 66% for 2025 and 33% for 2026, outcome reported as a dash for every year. "As shown in the table on the next page, the North American product portfolio was not tested in 2025. However, since the portfolio mirrors the European product range, it is also expected to be 100% recyclable" (page 99).

Scope and limits. "The target is limited to Billerud's operations before being further processed by customers downstream in the value chain." "The target is set on a voluntary basis and is not mandated by legislation." "Billerud's European paper packaging material recyclability target relates to recycling in the waste hierarchy, but it does not relate to Billerud's own waste management" (page 100).

No other targets. "Billerud currently has no other time-bound outcome-oriented targets for any of the other material impacts and opportunities" (page 99).

Resource inflows

Reference: page 100.

"Material resource inflows are primarily wood, woodchips, pulp, water, electricity, energy feedstocks, chemicals, parts for repair, maintenance of technical equipment and new technical equipment" (page 100). Technical materials cover "all chemicals (both synthetic and bio-based) as well as non-renewable energy sources"; products "only include packaging materials within this category due to data constraints".

Metrics, 2024 then 2025 (ktons). Products 33 to 28; technical material 3,715 to 3,770; biological material 14,058 to 13,438, "of which for non-energy purposes and sustainably sourced" 12,984 (73%) to 12,387 (72%); total resources used 17,807 to 17,236; of which reused 0 in both years; of which secondary intermediary products 2,820 to 2,783 (16% in both years); of which secondary materials 47 to 42.

"Billerud reintroduces secondary intermediary products (recovered chemicals) of 2,783 (2,820) ktons for its global operations. Reintroduction of recovered chemicals constitutes over 77% (79%) of total weights of all technical material used in production for non-energy related purposes" (page 100).

Methodology. "Double counting was avoided by excluding intra group flows and only including externally procured materials." "The changes in the outcome between 2024 and 2025 are explained by shifts in production volumes" (page 100).

Resource outflows

Reference: page 101.

"Billerud makes fiber-based, high performing packaging materials. Our board and paper products are made from 100% recyclable materials using only responsibly sourced fibers, enabling circularity for our customers. Furthermore, 100% of our product packaging is also recyclable" (page 101).

Recyclability is evidenced by testing rather than assertion: "All relevant paper packaging material in Region Europe has been tested as recyclable according to the Papiertechnische Stiftung (PTS) method in previous reporting periods. Region North America's product range is expected to be recyclable too, due to similiarites with the European products" (page 97), and in 2025 "Billerud has tested all new products for the Region Europe according to the CEPI method" (page 98).

Byproduct outflows. "Between 30% and 50% of purchased wood raw material can not be used for board and paper production. Bark and black liquor are used for chemical recovery and to generate steam and electricity for the production processes." Soap is refined on site into crude tall oil and terpenes into turpentine, both sold externally (page 98).

Billerud notes a constraint on recycled input: "Billerud faces a challenge regarding the use of recycled fibers due to strict requirements for purity in paper packaging material and to minimize the risk of contamination" (page 97). The waste breakdown is reported separately (page 101).

Waste

Reference: page 101.

Total waste generated was 276,163 tons in 2025 against 272,049 tons in 2024, split 647 tons hazardous and 275,516 tons non-hazardous in 2025 (page 101).

Diverted from disposal fell from 117,336 to 108,697 tons: preparation for reuse 55,583 to 55,626 tons; recycling 35,755 to 45,181 tons; other recovery 25,998 to 7,890 tons.

To disposal rose from 154,713 to 167,466 tons: incineration 34,149 to 16,976 tons; landfill 120,216 to 138,851 tons; other disposal operations 348 to 11,639 tons.

Percent of non-recycled waste rose from 57% to 61%, the ESRS E5-5 paragraph 37(d) datapoint (page 101). The paragraph 39 hazardous and radioactive waste datapoint is shown as "Page 101, Not material" in the content index (page 139).

"" "Not all waste streams of hazardous waste for Region North America has been reported in accordance with European legislation, due to legislative differences in definition of waste. However, these waste streams has been included in the consolidated metric, but based on definitions according to U.S. legislation."

"The variations between 2024 and 2025 are due to normal fluctuations, production changes, and the reclassification of hazardous waste described in the methodology. The reclassification accounts for the largest shifts, particularly in other recovery, incineration, and other disposal" (page 101).

Policies related to own workforce

Reference: pages 103-104; page 112.

"People Policy. It "covers all Billerud's identified impacts within this standard on a high level". "The People Policy explicitly recognizes that all forms of forced, involuntary or child labor is unacceptable... Complementary policies... such as the Responsible Business Policy, explicitly addresses modern slavery. The term 'trafficking' is not explicitly stated" (page 104), the paragraph 22 datapoint.

Diversity & Inclusion Directive. It "commits to zero tolerance for discrimination and sexual harassment" and identifies protected grounds as "gender, transgender identity or expression, ethnicity, religion or other belief, disability, sexual orientation, and age". "No other grounds for discrimination are explicitly mentioned in the directive" (page 104).

Human rights. "Policy provisions related to such impacts are regulated in the Health & Safety Policy, People Policy, Diversity & Inclusion Directive, and Rehabilitation Directive... However, such provisions are not explicitly committed to human rights-relevant instruments." The People Policy refers to the Sustainability Policy, which commits to the ILO's eight core conventions, the UN Guiding Principles and the OECD Guidelines, but "processes and mechanisms to monitor compliance with UN, ILO and OECD principles are not stipulated in these policy provisions" (page 104).

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

Reference: page 105; page 112.

"Billerud conducts annual Performance Management Conversations, which include questions on safety, workplace environment, reasonable workloads and inclusive workplaces. .

"Billerud's annual employee survey helps the company to identify relevant measures for continuous improvement and track the effectiveness of our engagement... This process is applicable to employees only; non-employees do not take part in the survey. The results of the survey are discussed within each department and on a company-wide level and action plans are created based on the survey results."

Accountability. "The CEO is ultimately responsible for Billerud's engagement with employees. The EVP HR & Communications is responsible for ensuring union-related engagement" (page 105).

Health and safety (page 112). "Billerud has established processes for the consultation, collaboration and participation of workers and workers' safety delegates at all applicable levels and functions." "Board employee representatives are also included in defining and tracking targets."

Transition engagement. "Billerud has not had any engagement with people in its workforce on potential impacts, that may arise from reducing carbon emissions and transitioning to climate neutral operations, as no such potential impacts have been identified" (page 105).

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

Reference: page 105; page 113.

"All managers must ensure a safe and secure workplace, and any violations require quick and effective corrective measures. The responsibility for investigating, addressing, and following up on any violations lies with the immediate supervisor. "

"Remedial measures related to high workload concern rehabilitation... The Group process comprises initiation planning measures (such as health interviews), implementation measures (follow-up meetings) and conclusion measures" (page 105).

Channels. "Billerud's employees are expected to report violations to the immediate manager. Complaints can also be reported anonymously through Billerud's whistleblowing channel", the Speak-Up Line, described in G1-1 (pages 105, 128-131), the paragraph 32(c) grievance mechanism datapoint.

Health and safety remediation (page 113). "Billerud has a specific routine for escalating significant safety events. An incident investigation procedure is initiated if the accident has or had potential to cause or contribute to a negative impact related to health and safety. Mitigating actions are assigned a closing date and a responsible manager for each incident." "These systems, as well as the whistleblowing system, ensure non-retaliation."

Taking action on material impacts on own workforce

Reference: pages 106-107; pages 113-114.

"No Opex or Capex above significant thresholds is dedicated to activities below" for diversity, health and competence (page 106). "Capital expenditures with safety as the primary objective amounted to SEK 143 million in 2025" (page 113)..

Diversity and anti-discrimination (page 106). Named actions: adapted work environment; "Recruiting beyond traditional networks", including "applying diversity targets when recruiting summer workers in Region Europe"; mandatory onboarding training on "diversity, inclusion and belonging"; local D&I committees with trained ambassadors meeting quarterly in Sweden; a Women in Business Taskforce in North America;.

Health and competence (page 107). "In 2025, approximately 60 (50) leaders in Europe and 60 (50) leaders in North America completed the program, and 120 (99) leaders globally completed the corresponding e-learning course."

Safety (pages 113-114). Actions include health and safety training, risk assessments, audits and certification - "during 2025 our mills in Gävle, Gruvön and Frövi were audited and certified to the standard" ISO 45001 - safety rounds, safety walks and Key Safety Performance Audits, occupational health services, and the Safety Roadmaps 2024-2028, which "define workstreams and annual deliveries of objectives and targets up until 2028".

Targets related to own workforce

Reference: page 108; page 115.

Diversity targets (page 108). "Billerud's long-term ambition is to reach a 60-40 ratio among male and female employees and managers at all locations and functions." Proportion of female employees: 2023 baseline outcome 21.7%, 2024 target 22.0% with outcome 21.8%, 2025 target 22.0% with outcome 21.5%. Proportion of female managers: 2023 outcome 25.0%, 2024 target 25.5% with outcome 26.4%, 2025 target 26.5% with outcome 25.9%, and a 2035 target of 33.0%.

"Targets were missed "mainly derived to the cost-saving program in 2025" and "seniority rules defined by collective agreements" (page 108).

No training or workload target. "Billerud has no target on training or high workload impacting well-being. However, the defined ambition is to improve skills and professional growth and reduce the level of sick leave. Training targets are set individually for employees" (page 108).

Safety targets (page 115). "Our lagging Group KPIs during 2025 were the total recordable injury frequency rate (TRIFR) and lost time injury frequency rate (LTIFR)." TRIFR: baseline 7.7, 2024 outcome 8.6, 2025 target 5.8 or lower with outcome 7.4, 2028 target 3.0 or lower. LTIFR: baseline 4.9, 2024 outcome 5.7, 2025 target 3.7 or lower with outcome 3.7, 2028 target 1.5 or lower. "Billerud has achieved its 2025 LTIFR interim target but remains behind on its TRIFR target."

Characteristics of the undertaking's employees

Reference: pages 108-109.

"All metrics below are reported by head count per the 31 December 2025" (page 108).

Headcount, 2024 then 2025. Total employees 5,822 to 5,626. By gender: male 4,526 to 4,385; female 1,296 to 1,240; other 0 in both years; not reported 0 to 1. By country: Sweden 3,944 to 3,778; the US 1,651 to 1,638; other 227 to 210 (page 109).

By contract type, 2025. Permanent 5,455 (female 1,174, male 4,281); temporary 168 (female 63, male 104); non-guaranteed hours 3; full-time 5,548; part-time 78.

By region, 2025. Europe 3,972 (3,806 permanent, 163 temporary); North America 1,638 (1,634 permanent, 4 temporary); Asia 16 (page 109).

Turnover. "Total employees who ended their employment" 454 in 2024 and 475 in 2025, a turnover rate of 8.1% then 8.7%. "The turnover rate is calculated by the total number of leavers divided by the total number of permanent employees during the year" (pages 108-109).

Context for the fall in headcount. "Reductions in total employees from 2024 to 2025 reflects Billerud's initated cost-saving program, targeting staff reductions of up to 650 positions. By 31 December 2025, all affected employees had not yet left the company" (page 108). The programme was introduced in September 2025 and targets "Region Europe and Group functions" (page 102).

"

Diversity metrics

Reference: page 109.

"Top level management is defined as our Group Management Team (GMT), which is the highest executive management team."

Gender, 2025. "In 2025, the Board of Directors, excluding employee representatives, consisted of 3 women (43%) and 4 men (57%). The Group Management Team consisted of 2 women (22%) and 7 men (78%), and the employees consisted of 1,240 women (22%) and 4,385 men (78%). The only notable change compared with the previous reporting period is that the proportion of women on the Board has increased from 33% in 2024 to 43% in 2025."

Managers are 25.9% female and 74.1% male (page 103).

Age, 2025. "In 2025, the Board of Directors, excluding employee representatives, consisted of 1 person aged 30-50 years (14%) and 6 people over 50 years of age (86%). The GMT consisted of 4 people aged 30-50 years (44%) and 5 people over 50 years (56%). There were no individuals under 30 years of age in either the Board or the GMT. Among the employees, 695 people (12%) were under 30 years, 2,610 people (46%) were between 30 and 50 years, and 2,321 people (41%) were over 50 years, with no noticeable relative change from the year prior" (pages 109-110).

"Metrics for the Board and GMT contain all consolidated companies except subsidiary Scandfibre Logistics AB, the joint arrangement Bomhus Energi AB, and the associate Trätåg AB."

Training and skills development metrics

Reference: page 110.

Metrics, 2025 (page 110). "Employees that participated in regular performance and career development reviews" 75% overall, 78% of women and 74% of men. "Average training hours per employee" 11.6 overall, 8.6 for women, 12.5 for men, and 7.8 for the not-disclosed category. "Comparative information is presented from 2026", so no 2024 figures are shown.

Why the review figure is 75%. " The reason why only 75% have participated in the reviews is that completing both reviews require that the employee in question had started their employment at a certain date and not ended their employment before a certain date. Looking at only the performance conversation, 99% of employees completed their review" (page 110).

Scope limits. "The percentage of employees that participated in regular performance and career development reviews includes all Billerud employees. However, blue collar workers in Region North America are not included in the metric, as those reviews are not registered in a system." "The average training hours per employee is based on a summary of training hours completed in our global people system, LinkedIn learning, as well as additional training hours performed across mills. Such hours include digital industry safety trainings. For the additional training hours in Region North America, a gender allocation key is applied based on the general gender distribution."

Health and safety metrics

Reference: page 115.

"Metrics, 2024 then 2025 (page 115). Percentage of own workers covered by the health and safety management system: 100% in both years. Percentage covered by a system internally audited or externally audited or certified: 100% in both years. Number of fatalities as a result of work-related injuries and work-related ill health: 0 in both years. Number of recordable work-related accidents excluding fatalities: 127 to 105. Rate of recordable work-related accidents: 8.6 to 7.4.

"Definitions. "The LTI includes work-related injury and illness that leads to sick leave. From 2027, it will also include work-related ill-health. The LTIFR is the number of lost time injuries per one million worked hours. The TRIFR also includes work-related injuries and illness that leads to restricted work and medical treatment beyond first aid. The targets and outcomes include fatalaties" (page 115).

Restatement. "Two cases have been added to 2024 values after the previous reporting peiod, due to the fact that the two cases were investigated after the reporting period. No other changes are conducted" (page 115).

Days lost to injuries, accidents, fatalities or illness, the paragraph 88(e) datapoint, is marked "Transitional provision" in the content index (page 139).

Incidents, complaints and severe human rights impacts

Reference: page 110.

Discrimination and harassment, 2024 then 2025 (page 110). Total number of incidents of discrimination, including harassment: 20 to 7, of which reported through the Speak-Up Line 5 to 0 and through human resources procedures 15 to 7.

"The total amount of fines, penalties and compensation for such damages equals 0, and as such, is not reflected in financial statements" (page 110), the paragraph 103(a) datapoint.

Severe human rights incidents. Zero, with zero related fines, penalties and compensation (page 110), the paragraph 104(a) non-respect of UNGP and OECD guidelines datapoint.

Stated completeness limits. "There is a risk related to completeness of discrimination cases, as cases which have not been reported through either Speak-Up Line, HR or the responsible manager will not be reflected in metrics. However, since November 2025, European discrimination cases could also be registered directly by employees within our incident reporting system, ensuring improved traceability and data quality." For human rights, "The metrics reported are based on what is reported by a limited group (to higher and top management) in the organization. In addition, the survey excludes insignificant violations. Each reporting person determines what constitutes an insignificant violation" (page 110).

Policies related to value chain workers

Reference: pages 116-117.

Operations, Quality & Procurement Policy. "Our Operations, Quality & Procurement Policy states that we expect that our suppliers, and their suppliers, operate in compliance with all applicable laws and regulations and adopt the requirements described in Billerud's Supplier Code of Conduct." It covers working conditions for value chain workers, while contractor health and safety sits under the Health & Safety Policy (page 116).

Supplier Code of Conduct. It "covers the impact of working conditions for suppliers and contractors, including health and safety for suppliers". "The Supplier Code of Conduct explicitly addresses health and safety, as well as labor rights, human rights, forced labor and child labor. Human trafficking is included within forced labor provisions but not explicitly recognized" (page 117).

Stated gaps. "General processes and mechanisms to monitor compliance with UN, ILO and OECD principles are not stipulated in these policy provisions." "Remedy is highlighted through enforcement of the Supplier Code of Conduct, stating that a breach of the Code, including a human rights breach, can lead to corrective measures, including the termination of contracts. No further remedial measures for the value chain workers are explicitly recognized in the Code" (page 117).

Processes for engaging with value chain workers about impacts

Reference: page 117.

Contractors at the mills. "There are specific routines for contractors working at the mills. Each contractor has a contact person at Billerud. " "Each contractor must complete one or multiple safety training sessions, depending on the type of work. "

"We assess the effectiveness of our engagement with contractors at the mills through closing dialogues after the work is finalized, where the contractor can highlight improvements, risks and opportunities regarding health and safety. In Region North America, all contractors also receive an annual contractor survey focused on safety."

Forestry contractors. "All European forestry contractors conduct a web-based training program for forest contractors, which include health and safety. We have regular contact directly with the workers and conduct annual site audits focused on safety and working conditions where we engage with the contractors. Ten percent of the contractors are being site audited each year. The Vice President Wood Supply Europe holds the operational responsibility."

Latvia. "We conduct several engagement activities to gain insights related to the particularly vulnerable group of forestry workers and forestry sub-contractors within our Latvian Wood Supply operations. For example, we conduct continuous follow-ups, training and announced and unannounced audits where engagement with workers is included" (page 117).

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

Reference: page 118.

""In the case of a safety incident involving a contractor, Billerud has a specific routine for escalation of significant safety events. Billerud begins an investigation procedure if it has caused or contributed to a negative impact. Mitigating actions, a closing date and a responsible manager are attributed to each incident."

Channels. "External stakeholders are encouraged to report suspect behavior relating to Billerud's business operations in our whistleblowing channel, the Speak-Up Line. Information about our Speak-Up Line is found in our supplier agreements, in trainings for contractors and via channels at the mills such as posters." "As included in the Supplier Code of Conduct, Billerud requires suppliers to make similar channels available for their personnel to raise concerns without fear of retaliation. Contractors can also raise concerns with their contact person at Billerud."

Stated limits. "We do not assess contractors' awareness of and trust in the Speak-Up Line." "However, we do not monitor the effectiveness of the Speak-Up Line for contractors, this follow-up is conducted primarily for our employees, for example through the annual employee survey."

Taking action on material impacts on value chain workers

Reference: page 118.

""

Named actions (page 118). Safety rules for contractors at mills: "Billerud has common safety rules for employees and for contractors within Region Europe... It is applicable to all contractors at Swedish mills. The effectiveness of actions is measured through the effect on TRIFR." Training activities: "During 2025, the Wood Supply operations has implemented personal protective equipment (PPE) requirements, in all contractors' agreements, for all harvesting contractors in Sweden... No LTIs were reported among our contractors during 2025, which is a strong indication that our ambition and commitment are having a positive impact." Evaluations and audits: "During 2025, Billerud's Wood Supply operations conducted unannounced controls related to working conditions and health and safety. Such controls were applied to our upstream forestry management operations in Latvia, where occupational health and safety risks are assessed to be higher than in other markets."

Remedy and incidents. "No particular action to provide or enable remediation in relation to material impacts was conducted in 2025 for value chain workers. No whistleblowing cases regarding health and safety were filed." Zero human rights issues and incidents connected to the value chain were reported during 2025" (page 118), the paragraph 36 datapoint.

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

Reference: page 119.

Supplier Code of Conduct coverage. "Our target is to have the Supplier Code of Conduct signed by 95% of our suppliers, by spend, over applicable threshold values, by the end of 2025. " "The baseline value from 2023 is 82%, and the 2025 target is 95%, with a 2024 interim target of 85%" (page 119).

"In 2025, 94% of Billerud's suppliers had signed the Supplier Code of Conduct, which meant that we came close to achieving the target of 95%. This represents an improvement of 2% compared to 2024. No specific reasons for not reaching the target have been identified. No target has been established for 2030. Future targets will be reviewed during 2026" (page 119).

Scope. "The target covers all relevant operations in all Billerud markets, such as wood supply, sourcing, logistics and supply chain. European suppliers with a purchased value under SEK 1 million/year are excluded in the KPI. In Region North America, this threshold is USD 500 thousand/year."

Safety targets. "Contractors are included in Billerud's health and safety targets. Read more in S1-5 on page 115."

Worker involvement. "Workers in the value chain have not been involved in setting the targets or in tracking performance or identifying improvements in relation to targets." "Contractors have not participated in setting the safety targets" (page 119).

Policies related to affected communities

Reference: page 121.

Sustainability Policy. It "describes the overarching ambition for Billerud's environmental, social and economic responsibility and direction" and "includes, but is not restricted to, social matters, including a provision to contribute to making a positive impact on local communities where Billerud engages in production. The policy stipulates Billerud's commitment to respecting and promoting international human rights" (page 121), the paragraph 16 human rights policy commitment datapoint.

Stated gaps. "However, specific consideration for the interests of indigenous peoples or other specific communities is not included in any policy provisions or in the setting of the policy."

"Policy provisions do not cover engagement with affected communities in relation to human rights" (page 121).

Wood Supply Directive. "The directive relates to the negative material impact regarding potential sourcing without consultation of indigenous peoples." To address and prevent the identified impact the directive stipulates that Billerud should not source wood raw material from activities where the spirit of the UNDRIP is not met. As such, the directive covers specific affected communities, and not only affected communities in general." "However, processes and mechanisms to monitor compliance with other UN, ILO and OECD principles are not stipulated in the directive" (page 121).

Processes for engaging with affected communities about impacts

Reference: page 122.

"Billerud always consults with indigenous groups when the legal or customary rights of the Sami populations are affected by our forestry management in Sweden. Information from consultations is logged, whereafter Billerud takes actions such as, for example, stopping or restricting felling activities" (page 122).

"Form of consultation. "In Region Europe, the form of collaboration/consultation needed depends on whether the landowner is certified or not, the forest owner's total area, the area of measure, the type of reindeer grazing land affected, and factors regulated in the 1992 settlement agreement. Such characteristics also define the type and frequency of consultations, which can be annual or on a case-by-case basis."

North America. "the Native American Menominee tribe constitutes one of the enterprises that we purchase wood raw material from. We engage with representatives directly through cyclical and case-by-case conversations, as we do for all suppliers."

Accountability and effectiveness. In Europe the Senior Director Forestry & Field Purchase, in North America the Fiber Supply Director. "Billerud assesses the effectiveness of our engagement by following up on metrics, as presented in S3-5 on page 123" and through "the yearly management reviews". "No steps have been taken to gain insights on specific vulnerable sub-segments of the affected communities" (page 122).

Processes to remediate negative impacts and channels for affected communities to raise concerns

Reference: page 122.

"Billerud does not have a standardized process for providing or assessing remedy if we were to cause a material negative impact on affected communities. Instead, it is context and case-based. As such, the approach of considering customs, traditions, rules and legal systems in the design of remedy measures also vary based on case" (page 122).

Channels. "Affected communities can raise concerns and have them addressed through several channels. One of these channels is our whistleblowing channel, the Speak-Up Line. " In Region North America, SFI hosts a hotline for any type of inconsistent practice. This is communicated through SFI channels and mail sent to all suppliers. It is also communicated in all logger training. Similarily, FSC provides regional complaints websites both in Region Europe and Region North America."

"A formal complaints mechanism regarding wood supply and certifications is available via our website. "

Stated gaps. "Indigenous people are not part of ensuring the effectiveness of either this channel or channels presented in this section." "We do not use specific processes to assess if indigenous peoples are aware of channels or if a remedy is effective. Billerud appreciates that the objectivity of the third-party channel administrator creates trust amongst affected communities" (page 122).

Taking action on material impacts on affected communities

Reference: page 123.

"National laws and regulations for forestry, such as the Swedish Forestry Act, EUTR, and US timber legislation, the Lacey Act, set the minimum standard for Billerud's activities." Billerud is "third-party certified to chain of custody standards set by the Forest Stewardship Council (FSC), PEFC, and in North America, SFI". Certification criteria "mandate forest owners and managers to respect and uphold indigenous rights to land ownership, land use, and resource access"" (page 123).

""

Named actions. Forestry management and sourcing: "Billerud engages in collaboration, consultations and joint planning activities with indigenous people in our own operations related to forestry management services and in our sourcing activities for certain small forest owners in Sweden." Stakeholder forums: "a Billerud representative is the chair of a regional SFI committee in Region North America responsible for improving regional opportunities and managing risks, including matters related to indigenous peoples. No additional improvement measures are planned at this stage."

"Metrics, presented under S3-5 on this page, measure compliance with policy objectives rather than effectiveness of actions, as activities are implemented on a case-by-case basis" (page 123), and zero human rights incidents are reported (paragraph 36 datapoint).

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

Reference: page 123.

"There is currently no target related to free, prior and informed consent. However, Billerud tracks the effectiveness of actions to prevent and mitigate the occurrence of such impact, by measuring and following up on entity-specific metrics presented below. Billerud is evaluating the potential benefit for indigenous groups from defining a target related to the identified impact but has not defined a specific timeframe for doing so." (page 123).

This is an MDR-T effectiveness-tracking disclosure in the absence of a target, which the company states explicitly rather than leaving silent.

Entity-specific metrics, 2024 then 2025 (page 123). "Number of consultations carried out regarding the land managed by Billerud" 11 to 21. "Number of incidents concerning violations of the rights of indigenous peoples" 0 in both years.

"The increase in 2025 is due to a higher number of buyers within the sites and clarifications made in our internal reporting routines."

"" "Hence, indigenous groups have not been engaged in either target setting, performance tracking or improvement identification in relation to targets" (page 123).

Policies related to consumers and end-users

Reference: page 124.

""Billerud's Food Safety & Product Safety Directive describes procedures and principles to ensure food and product safety for packaging materials that may come into direct or indirect contact with food and medical products. It applies globally across all Billerud operations and requires compliance with relevant legislation, continuous risk assessment, and improvement practices. It addresses any impact that could potentially affect consumers, without focusing on any specific group" (page 124), which is the paragraph 16 datapoint.

"The Food Safety & Product Safety Directive ensures delivery of safe products to consumers by operating according to the third-party standard FSSC 22000. Billerud's ambition is to certify all production units according to FSSC 22000 where applicable."

Monitoring and ownership. "Compliance with the directive is monitored through annual reviews, controls and third-party external audits and is reviewed at least annually... any deviations are reported in internal deviation systems where they are managed and followed up. The most senior level at Billerud accountable for the implementation of the Food Safety & Product Safety Directive is the Director Global Environment and Quality."

The paragraph 17 datapoint on non-respect of the UN Guiding Principles and OECD Guidelines is marked "Not material" in the content index (page 140).

Processes for engaging with consumers and end-users about impacts

Reference: page 125; page 63.

"Billerud does not directly engage with consumers. We primarily interact with customers, brand owners, and converters to address any product issues. If a product fails to meet standards, customers inform Billerud, which can initiate an incident management process to address potential harm. In cases of severe impact, Billerud's crisis management team has remediation processes for affected consumers" (page 125).

This is consistent with SBM-2, which states for the consumers and end-users stakeholder group: "Billerud does not engage directly with end-users or consumers. Our primary interactions to address any product issues are with our customers" (page 63).

The engagement channels with customers are listed in SBM-2 as "Meetings, regular business contacts, networking and collaborations, fairs, seminars, customer surveys, audits, customer questionnaires", with sustainability topics including "traceability of our products... quality, reusability and recyclability, working conditions, product and food safety" (page 63).

Under S4 SBM-3 the company explains why no vulnerable group is identified: "No particular vulnerable end-users have been identified because Billerud does not control the end-product, and therefore lacks knowledge of the end-users" (page 124).

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

Reference: page 125.

Remedy. "Billerud has a system for recalling faulty products that enables us to track and identify all products that have been impacted. No remedy has been provided during the reporting year, as no recalls have been reported. If the impact already occurred, Billerud has a central crisis management team, that is alerted and in charge of providing remedies for any affected consumers or end-users. Billerud has no system or process in place to measure the effectiveness of such a remedy" (page 125).

Channels. "Billerud relies on actors at the end of the value chain to have processes in place to address and remediate any negative impacts. Consumers can report product related concerns via our whistleblowing channel. However, if an issue arises, it would typically be identified at Billerud's customers."

"Billerud customers can raise concerns in case of potential or suspected incidents to the appointed key account manager at Billerud. Customer queries are logged in a system that is jointly managed with Technical Service representatives and applicable production units. Customer expectations, queries and claims are managed daily and are reviewed according to a formalized procedure on an annual basis. We do not track the effectiveness of the the system beyond the functionalities on a day-to-day basis" (page 125).

Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions

Reference: pages 125-126.

" that Billerud's production units, where applicable, are certified according to the Food Safety System Certification, FSSC 22000" (page 125).

"Region North America. "The Escanaba mill completed its certification process, according to the Food Safety Certification Standrad, FSSC 22000, in 2025 and obtain certification approval at the beginning of 2026. It was decided during the reporting year that the converting facility in Wisconsin Rapids would not continue its certification process due to business changes. Today, Billerud's products produced in North America are not for food or medical use" (page 125).

Region Europe. "Region Europe reached its target of FSSC 22000 certification for all mills already in 2019 and has consecutively reached it since then. In Europe, maintaining certifications is Billerud's key action... Our customers also audit the effectiveness of Billerud's actions within food and product safety on-site, on a regular basis" (pages 125-126).

The paragraph 35 human rights issues and incidents datapoint is marked "Not material" (page 140).

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

Reference: page 126.

Target and outcomes (page 126). "Proportion of production units certified according to food safety standards, %". Region North America: 2019 baseline outcome 0%, 2024 target 33% with outcome 0%, 2025 target 66% with outcome 0%, 2026 target 33% and 2030 target 66%.

"The Escanaba mill completed its certification process in 2025, but did not obtain certification approval until early 2026. As a result, the goal of having Escanaba certified in 2025 was not achieved. Due to business changes, Wisconsin Rapids has decided not to pursue the certification process in 2025, which means that the target for 2025 was not reached. As a result, the 2026 target for Region North America has been set at 33%, with a focus on maintaining certification for Escanaba. The 2030 target has been adjusted from 100% to 66% for Region North America. The rationale for this change is linked to the above mentioned business changes" (page 126).

Basis.

"The target-setting process is managed by Billerud's food safety network Center of Excellence... The targets have been approved by the Global Environment & Quality function... However, stakeholders have not been directly involved in the target-setting process" (page 126).

Business conduct policies and corporate culture

Reference: pages 128-131.

"Billerud has several governing policies and directives aimed at managing business conduct and corporate culture impacts, risk and opportunities. The Code of Conduct is the Group's overarching governing document" (page 128).

Code of Conduct. It "establishes, for example, that we shall always place safety first, respect human rights, have zero tolerance for corruption, and take responsibility for reducing our environmental impact." It applies to employees, non-employees and the Board, is "ultimately adopted by Billerud's Board of Directors", and the CEO is accountable for implementation (page 128).

Other instruments (pages 128-129): the Responsible Business Policy, which "builds on third-party standards and initiatives, such as the OECD Guidelines for Multinational Enterprises... However, the guidelines are not directly referenced in the policy"; the Anti-Corruption Directive; the Supplier Code of Conduct; and the Public Affairs Directive.

Compliance programme. "Billerud's responsible business compliance program focuses on five areas: anti-money laundering, anti-corruption, compliance with competition rules, compliance with international sanctions, and respect for human rights", structured as a ten-step wheel (page 130).

Whistleblowing. The Speak-Up Line is "supplied by a third-party service supplier but operated by Billerud and reporting can be done anonymously".

Management of relationships with suppliers

Reference: pages 131-132.

"The four main stages of engagement are the selection of suppliers, including signing the Supplier Code of Conduct, our EcoVadis supplier assessments, our Billerud specific logistics and supply chain assessments and audits of suppliers" (page 131).

Selection. "The supplier qualification process includes due diligence procedures related to the supplier's financial, operational and sustainability performance, covering working conditions and health and safety for value chain workers. " A stated gap: "Region North America does not yet have a process in place to screen suppliers based on the same sustainability criteria as for Europe."

EcoVadis. "Since 2019, we have been using third-party solution EcoVadis to assess supplier performance. Assessments are conducted annually, and we receive an evaluation focusing on four main categories: environment, labor and human rights, ethics, and sustainable procurement."

Audits. "During 2025, a limited number of audits were conducted, supported by a structured questionnaire assessing compliance with the Supplier Code of Conduct... focusing on the European upstream value chain."

Metric. "During 2025, 86% (88%) of suppliers were covered by supplier assessment. Billerud achieved the target", which was 85% for 2025 from a 2014 baseline of 40% (page 132). The target "does not cover Region North America".

Prevention and detection of corruption and bribery

Reference: page 133.

"Business partner due diligence. "Billerud has implemented a business partner due diligence program, according to which business partners are subject to due diligence depending on the risk in the geographical location. Business partners need to disclose Know Your Client information and are screened for sanctions and corporate crimes using a reputable international screening service. They must also agree to anti-corruption compliance obligations, and in some cases to Billerud's Supplier Code of Conduct."

Training. "All Billerud employees go through the Code of Conduct training, which covers anti-corruption. White-collar workers are considered to be exposed to increased risk for corruption and must therefore also take a dedicated online anti-corruption and anti-bribery training. This group includes key management positions, such as the Group Management Team."

"The total number of employees receiving training in anti-corruption and anti-bribery during 2025 was 1,260 (535) employees. The increase between 2024 and 2025 is mainly because the training was launched in the end of 2024. Functions-at-risk covered by the training program, being all white-collar workers, was 100% (100%) during 2025" (page 133).

Targets related to business conduct

(part of MDR-T/GDR-T disclosures)

Reference: page 131; pages 132-135.

The statement was prepared under the 2023 ESRS, where business conduct targets fell under MDR-T rather than a numbered G1-3. Billerud discloses both limbs: a stated target, and effectiveness tracking where no target exists.

Stated target. "Our target for 2025, defined in 2024, was that 95% of employees should have completed the training. The baseline year is 2023 and equals 95%. The outcome for 2025 demonstrates that 97% (96%) had completed the training by the end of 2025. The target was approved by the Group Management Team. No target has been established for 2030. Future targets will be reviewed in 2026" (page 131).

Effectiveness tracking where no target exists. For corruption: "There is currently no Group target related to incidents of corruption and bribery. However, Billerud tracks the effectiveness of actions to prevent and mitigate the occurrence of such impact, by measuring and following up metrics that support our ability to ensure adherence to policy provisions, rather than progress towards policy objectives. Due to this, the base year for metrics is not relevant" (page 133). For payment practices: "There is currently no Group target related to payment practices. However, Billerud tracks the effectiveness of actions... by measuring and following up metrics that support our ability to ensure adherence to payment terms instructions" (page 135).

Incidents of corruption or bribery

Reference: page 133.

"2025 actions. "A compliance risk assessment was finalized with key focus on sales and the purchasing department to identify risks and assess internal awareness." "The Business Partner Due Diligence directive was reviewed and updated." "During the year, we addressed an ethical violation of our internal rules/Code of Conduct that ultimately led to the company and the employee parting ways." "CapEx and OpEx connected to this are considered not relevant."

Metrics (page 133). "In 2025, a total of 20 whistleblowing cases globally were reported through the Speak-Up Line. No comparative figure is presented, as this is an entity-specific metric that was not included in the sustainability statement in 2024." "There were 0 (0) violations of anti-corruption and anti-bribery laws during 2025" and "There were 0 (0) (SEK) fines for violation of anti-corruption and anti-bribery laws during 2025", the paragraph 24(a) and 24(b) datapoints.

Sources and stated limits. "The number of violations of anti-corruption and anti-bribery laws are brought to Billerud's attention through reports to the Speak-Up Line and through quarterly Litigation Reports. In addition, the metrics are gathered through an annual compliance survey with top management." "None of the metrics below have been validated by an external body other than the assurance provider" (page 133).

Political influence and lobbying activities

Reference: page 134.

"Billerud's Sustainability & Public Affairs function is responsible for the high-level management and monitoring of political and legislative developments... The function engages in dialogue with decision-makers on a national and European level, often in coordination with industry associations such as the Swedish Forest Industries Federation and Brussels-based associations such as FBCA and CEPI" (page 134).

Contributions. "Billerud is politically neutral and does not accept political donations." "

Memberships (page 134): the Swedish Forest Industries Federation, FBCA, Cepi ContainerBoard, CEPI Eurokraft, the Michigan Manufacturers Association and the American Forest and Paper Association.

Main positions in 2025. The Packaging and Packaging Waste Regulation, where "Billerud participates in the work at European Committee for Standardization (CEN)"; the Nature Restoration Regulation; the EU Deforestation Regulation; the EU ETS, where "Billerud has advocated that the 95% rule... is negative for combating climate change and discriminates forerunners"; and the BioEconomy strategy.

"Billerud is registered in the EU Transparency Register with the identification number 761211137543-91." "No person within Billerud's administrative, management and supervisory bodies have held a comparable position in public administration in the two years preceding the 2025 reporting period" (page 134).

Payment practices

Reference: page 135.

"In Region Europe, Billerud works together with some small suppliers, that potentially could be affected by late payments. This is particularly the case for Billerud's forestry contractors within Sweden and Latvia.

Region Europe. "Region Europe's average time to pay an invoice from the date when the contractual or statutory term of payment starts to be calculated was 44 (46) days in 2025. Region Europe's standard payment terms are 75 (75) days for direct suppliers and 60 (60) days for indirect and maintenance suppliers. During 2025, the proportion of payments per supplier category that were aligned with the payment terms was 98% (62%) for direct suppliers, 99% (56%) for indirect suppliers, and 99% (58%) for maintenance suppliers."

Wood Supply operations. "Wood Supply operations' average time to pay an invoice... was 14 days in 2025. Within our Wood Supply operations, industry practice is followed for payment terms, which are 15 days. During 2025, the proportion of payments per supplier category that were aligned with the payment terms was 100% for forestry contractors. There were no legal proceedings currently outstanding for late payments at year-end."

Legal proceedings. "There was 1 (1) legal proceeding currently outstanding for late payments at year-end." The improvement "is due to payment files in 2025 being expanded to be sent once per day."