Boliden

Reference: page 52.

The 2025 AGM elected 9 non-executive Board members; one resigned in autumn 2025, leaving 8 non-executive members and one vacancy. Group management had 5 executive members at the start of the year, expanded to 6 during the year. The Board also had 3 employee representative members and 3 deputy members.

Board gender ratio (AGM-elected): 44/56, moving to 50/50 after the resignation. Group management gender ratio: 20/80 at the start of the year, 33/67 after expansion. 100% of AGM-elected non-executive members were independent of major shareholders, the company and management.

Sustainability oversight: the Executive Vice President People and Sustainability sits on Group management and is supported by Group functions including Climate and Sustainability Control, HR, Ethics and Compliance, and Environment and Quality. Boliden has a Climate Committee and councils for HR, Ethics and Compliance, Communications, Security and Environment. For business conduct, the Group Ethics and Compliance function reports on anti-bribery, sanctions, human rights and anti-money laundering, and the Board "reviews and approves Boliden's Code of Conduct and Anti-Corruption Policy annually."

Reference: page 53.

"Sustainability and ESG reporting are standing items" reported monthly to the Board as part of the President and CEO's overall performance report, and presented quarterly in depth. Annually the Board receives a sustainability progress update from the EVP People and Sustainability, a strategy presentation, and reviews the Annual and Sustainability Report.

Group management holds monthly meetings with a sustainability update, with a more extensive quarterly presentation. Material IROs addressed by the Board, management and councils are listed at the start of every topical chapter under IRO-1/SBM-3.

Boliden's Code of Conduct and Business Partner Code of Conduct "define the overall ethical principles and standards" for the company and its partners; nearly every material topic has a policy or commitment, reviewed annually as part of the BMS management system, with approval from the Board, CEO or Group management depending on the policy.

Reference: page 55.

The CEO's short-term incentive is based on Group Return on Equity, progress toward climate targets, and the Lost Time Injury Frequency (LTIF) trend; other Group management members add personal/financial targets. Within the annual short-term incentive, "5 percentage points is linked to the progress toward Boliden's greenhouse gas emission reduction targets" and "5 percentage points is linked to the Lost Time Injury Frequency trend."

Three long-term share-savings programs are running (LTIP 2023/2026, 2024/2027, 2025/2028); in each, "20% of overall performance criteria concern progress toward Boliden's greenhouse gas emission reduction targets."

Incentive schemes are developed by the Board's Remuneration Committee and approved annually by the Board and shareholder meeting, which adopts the remuneration report. Further detail is in Note 5 of the Financial statement (p.137).

Reference: page 55.

Boliden discloses a table mapping the five core elements of due diligence to pages of the sustainability statement:

Reference: page 55.

Boliden's management system (BMS) "includes the ICMM Mining Principles as well as the quality, environmental, occupational health and safety, and energy management systems." Health, safety and environmental data are collected monthly from business units and consolidated at Group level; other sustainability data is collected quarterly or annually. A single risk matrix evaluates probability and consequence across all sustainability topics.

Identified risks include "data inaccuracies, non-compliance with reporting standards and potential cybersecurity threats," mitigated through BMS-documented processes, a four-eyes review culture and standardized templates. In 2025 a pilot brought sustainability metrics (consolidated GHG, Scope 1-2 and Scope 3 reporting at Rönnskär) into Boliden's Internal Control System (BICS) for the first time; "many of the suggested controls were already in place, whereas some remained to be implemented," with the work to continue in 2026. The statement is subject to external limited assurance under RevR 19.

Reference: pages 56-57.

Boliden's vision is "to become the most climate-friendly and respected metal provider in the world," built on four strategic areas: production/investment efficiency, profitable growth, reducing climate footprint, and care for people, environment and society. Operations run through two business areas: Mines (seven units: Aitik, the Boliden Area, Garpenberg, Zinkgruvan, Tara, Kevitsa, Somincor) and Smelters (five units: Bergsöe, Rönnskär, Harjavalta, Kokkola, Odda). Revenue in 2025 was SEK 93,509m, headcount 8,308.

Key operational challenges: long-term reclamation (provisions of SEK 13,813m), managing water discharges and tailings, decarbonizing smelters (fossil reducing agents) and electrifying open-pit fleets. The Green Transition Metals portfolio includes Low-Carbon Copper (1.5 kg CO2e/kg vs. a global average of 4.0) and Low-Carbon Zinc (1.0 vs. 3.5), plus Recycled Zinc, Copper and Lead. Boliden paid SEK 1,454m in corporate tax in 2025.

Reference: pages 57-58.

Key stakeholder groups: employees and value chain workers, local communities including indigenous peoples, business partners, customers, authorities, and shareholders/capital markets. Engagement channels include annual employee surveys, union dialogue, Capital Market Days, the AGM, and a whistleblower/grievance portal.

Own workforce engagement runs through health and safety pulse meetings, committees at all sites with over 50 employees, and union dialogue. Value chain worker engagement happens through site visits and interviews with workers or union representatives during due diligence. Affected-community engagement runs through permitting consultations, ICMM/Svemin membership, and special consultations with indigenous peoples (Sami villages).

Stakeholder views are shared with the relevant councils (HR, Ethics and Compliance, Environment, Security, Climate Committee), Group management and the Board as part of the routines described under GOV-2.

Reference: pages 59-61 (topical overview table); per-topic detail at pages 72, 82, 86, 89, 93, 98, 109, 114, 116.

The 2025 DMA revisit "primarily related to limit disclosures of positive impact, in order to align with recent ESRS guidance," and confirmed the acquisition of Somincor and Zinkgruvan "did not affect the assessment for the reporting year." Material topics are climate change, pollution, water and marine resources, biodiversity and ecosystems, resource use and circular economy, own workforce, workers in the value chain, affected communities, and business conduct.

Per-topic IROs, policies, actions, targets and performance are tabulated at the head of each chapter (see IRO counts for the full tally). Example targets: Scope 1-2 GHG -42% and Scope 3 -30% by 2030 vs. 2021; zero significant environmental incidents; biodiversity increase in all regions by 2030 vs. 2020; LTIF -30% year on year; Diversity and inclusion index >83.

Reference: pages 62-63.

Boliden's DMA evaluates both financial and impact materiality. Steps: business-context/stakeholder mapping, identifying material topics from a long list against ESRS and external frameworks, validating IROs via internal/business workshops, assessing significance (severity by scale/scope/irremediability/likelihood; risk and opportunity by likelihood and financial effect using Boliden's risk matrix), then aggregating, validating and applying materiality thresholds. The full DMA is refreshed "every 3-5 years"; the 2025 review aligned methodology with the final ESRS standard.

Climate-specific: physical risk assessed with IPCC RCP 4.5 and 8.5 scenarios across present/2030/2050 horizons, covering hazards including extreme heat/cold, storms, flooding, drought, wildfire and landslide; "no climate-related physical risks along the upstream and downstream value chain have yet been assessed." Transition risk/opportunity assessed annually via a cross-functional workshop (latest: autumn 2025), rated by likelihood, magnitude and duration on a heat map; "none have been identified as incompatible with a future climate-neutral economy."

Biodiversity IROs use the TNFD LEAP framework without scenario analysis, covering climate change, land-use change and pollution as the relevant nature-loss drivers. Business conduct risk identification runs a yearly Group E&C workshop on anti-corruption, sanctions, AML and human rights.

Reference: page 64 (narrative); pages 65-68 (ESRS content index, Appendix).

"Boliden's sustainability statement covers the topics climate change, pollution, water and marine resources, biodiversity and ecosystems, resource use and circular economy, own workforce, workers in the value chain, affected communities, and business conduct." Material topics "are mainly in areas that are more directly impacted by mining and smelting operations, such as environmental management, occupational health and safety, affected communities and human rights in the supply chain."

Omitted topic: "Boliden does not consider consumers and end-users to be a material sustainability topic as we mainly operate at the beginning of supply chains as an extractor, processor and initial distributor of raw materials." Disclosure requirements and datapoints were selected per "ESRS 1 Appendix E 'Flowchart for determining disclosures under ESRS'." The content index lists each covered DR and datapoint with a page reference, SFDR/Pillar 3/Benchmark Regulation/EU Climate Law flags, and marks several datapoints "Phase-in" or "Non-material" (e.g. all E1-9 physical-risk datapoints are flagged Phase-in with no page reference).

Reference: page 73 (also 74-77).

Near- and long-term GHG targets were approved by the Board in 2022; Scope 1-3 2030 targets are SBTi-validated, with Scope 1-2 consistent with 1.5C. Boliden commits to net-zero Scope 1-2 by 2050. In 2025 the 2021 base year was recalculated under SBTi guidance to include the acquired Somincor and Zinkgruvan mines.

Locked-in emissions are assessed qualitatively, concentrated in "energy-intensive processes required for the extraction and processing of metals." Actions are grouped under Scope 1-2 levers (process increase, electrification, energy efficiency, renewables, heat/steam reduction, grid decarbonization) and Scope 3 levers (process increase, indirect Scope 1-2 effects, technology improvements, internal sourcing, transport, stakeholder engagement).

Boliden's operations are covered by the EU Paris-aligned Benchmarks (not excluded). Estimated decarbonization investment to 2030 is SEK 2,500-3,000m; SEK 1,580m of EU Taxonomy-eligible CapEx was reported in 2025 (construction of new buildings), with funds "difficult to allocate ... exclusively to decarbonization" since projects serve multiple purposes.

Reference: back-filled from ESRS 2 IRO-1 (pages 62-63) and the SBM-3 climate resilience section (page 72), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Boliden classifies climate risks as physical and transition (E1-SBM-3-18, page 72). Physical risk methodology: an overall assessment of all operational assets plus detailed scenario analyses at four business units between 2020-2023, using IPCC RCP 4.5 (mild mitigation) and RCP 8.5 (worst-case, emphasized for consistency with financial-statement climate assumptions) across three horizons: present, 2030 (medium-term) and 2050 (long-term). Hazards assessed: extreme heat/cold, storms, flooding, drought/water stress, wildfire, landslide, rated low/medium/high exposure per site. "No climate-related physical risks along the upstream and downstream value chain have yet been assessed but will be taken into consideration in the future."

Transition risk/opportunity methodology: an annual cross-functional workshop (latest autumn 2025) rating policy/legal, technology, market and reputation shifts by likelihood, magnitude and duration on a heat map, covering own operations, upstream and downstream; no assets or activities were found "incompatible with a future climate-neutral economy."

Reference: back-filled from ESRS 2 SBM-3 (E1-SBM-3-19, page 72), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"Climate resilience analysis is an integrated part of our strategic risk management and is reviewed annually" as part of the spring-to-December strategic planning cycle (budget and Long-Term Plan), with critical assumptions covering energy consumption, technology deployment, commodity prices and EU legislation. "No material physical or transition risks are excluded," and impacts are assessed across short, medium and long term.

The most recent major revision of transition risks was completed in 2024; physical risks were last updated 2020-2023, with a new comprehensive revision planned following the Somincor/Zinkgruvan acquisition. Identified long-term uncertainties include grid constraints and slower-than-expected grid decarbonization, mitigated by exploring on-site fossil-free energy generation. "Boliden has built resilience against climate-related transition risks," evidenced by SBTi-validated targets and green-bond-linked financing (see E1-1).

Reference: page 74.

Climate mitigation/adaptation policy sits across the Environmental Policy (measuring, tracking and reducing GHG emissions, limiting site risks, improving energy efficiency, minimizing fossil-fuel dependency), the Energy Policy (business units encouraged to deploy renewables; must "reduce its dependency on fossil fuels by using fossil-free energy... where possible"), and the Climate Commitment ("Boliden's strategies and actions to reduce GHG emissions and address climate change impacts"). The Code of Conduct and Business Partner Code of Conduct extend expectations to business partners on climate impacts. All policies are approved per the Board/CEO/management framework described under GOV-2 and apply to everyone working at or for Boliden.

Reference: pages 74-75.

Actions are organized by decarbonization lever, with financial resource needs of "approximately SEK 2,500-3,000m ... required until 2030" (OpEx not considered significant). 2025 actions taken: battery trucks at Aitik; doubled trolley utilization at Kevitsa; an underground trolley at Rävliden/Kristineberg; Project Ecolink at Rönnskär (waste heat to Skellefteå district heating); a supplementary cementitious by-product project (patent filed, one approved); hydrogen peroxide explosives at Kankberg; supplier climate-roadmap KPI covering ~100 companies.

Planned 2026-2027 actions: personnel-vehicle electrification at mines from 2027; Rävliden's first fully electrified mine; an electric boiler at Rönnskär (2027); a 100 GWh solar plant at Somincor covering ~30% of annual electricity need by end-2026; expanded hydrogen-based explosives roll-out; expanded supplier climate-roadmap requirements.

Reference: page 76 (table pp.76-77, performance p.79).

Targets: Scope 1-2 "42% lower absolute emissions in 2030 compared to base year 2021"; Scope 3 "30% lower"; net-zero Scope 1-2 by 2050 per ICMM standards; product-intensity targets of 1.5 kg CO2e/kg copper and 1.0 kg CO2e/kg zinc by 2030 (100% of production). Targets use the location-based method, are SBTi-validated (2023) against a 1.5C pathway, and include "no GHG removals, carbon credits or avoided emissions."

In 2025 the 2021 baseline was restated to SEK... to include Somincor/Zinkgruvan: updated Scope 1-2 baseline is 1,107 ktonnes CO2e. 2025 low-carbon production share: 27% copper (target 100% by 2030), 24% zinc (target 100%). Progress is tracked monthly (Scope 1-2) and annually (Scope 3), assured externally.

Reference: page 78.

Total energy consumption rose 9% to 6,157,764 MWh (2024: 5,636,460), mainly from the Somincor/Zinkgruvan acquisitions and the Tara ramp-up. Fossil energy consumption rose 22% to 4,673,760 MWh (share 65%, up from 59%), driven by increased purchased fossil electricity/heat/steam. Renewable energy consumption was roughly flat at 1,324,916 MWh (share 19%, down from 20% as the denominator grew). Nuclear-source consumption fell 15% to 1,145,744 MWh.

Boliden's mining and smelting operations are "defined as high climate impact sectors in NACE Sections B and C"; energy intensity was 730 MWh per EUR m net revenue from those activities (2024: 723). Allocation follows the market-based method as required by ESRS, though Boliden "favors the location-based method" for its Scope 2 target. Self-generated non-fuel renewable energy rose sharply (616 vs 62 MWh) after Bergsöe's solar panels became fully operational.

Reference: page 79 (methodology pp.79-80).

2025 gross emissions: Scope 1 685,577 t CO2e (55% under EU ETS); Scope 2 market-based 1,853,894 t CO2e (location-based 260,161); Scope 3 3,991,903 t CO2e, up 4% on higher procurement and sales volumes. Total market-based GHG emissions were 6,531,375 t CO2e (up from 5,958,782 in 2024). Largest Scope 3 categories: purchased goods and services (2,157,382 t), processing of sold products (722,977 t), capital goods (394,718 t).

2025's acquisition of Somincor/Zinkgruvan triggered a baseline restatement; the new base-year-2021 Scope 1-2 figure is 1,107 ktonnes CO2e vs. the previous baseline's ~1,000 ktonnes. Emissions are calculated under the GHG Protocol, operational control approach; "12% of the GHG emissions in Scope 3 are calculated using primary data." Categories 8, 11, 13, 14 and 15 are excluded as "non-applicable." Biogenic emissions were 40,577 t CO2.

Reference: page 81.

"Boliden does not currently utilize Carbon Capture and Storage (CCS) or Carbon Capture, Utilization and Storage (CCUS) techniques," though their potential use is being explored. Boliden has "no GHG emission reductions or removals from climate change mitigation projects outside our value chain," "have not purchased, nor do we intend to purchase, carbon credits." Net-zero by 2050 (Scope 1-2, per ICMM) rests on full mine electrification, smelter electrification "wherever feasible," biochar/alternative reduction agents where electrification is not possible, and a low-carbon Nordic grid; any residual emissions "will potentially be addressed through GHG-removal techniques directly connected to Boliden's own operations," to be explored in future years.

Reference: page 81.

"From 2024, Boliden's internal shadow carbon pricing is set to EUR 100 per tonne of CO2e for Business Area Smelters," applied to all smelter units' Scope 1 EU ETS emissions, covering 55% of Boliden's total Scope 1 emissions (685,578 t CO2e); Scope 3 coverage is currently 0%. The price is reviewed annually against ETS historical/current prices, anticipated free-allowance supply, metal demand growth and mitigation cost, and is used to compare investment scenarios. "Carbon pricing at Business Area Mines is currently not needed as targets are sufficient to achieve the desired decarbonization," though a pricing mechanism could be introduced if extra incentive is required.

Reference: page 82.

Policies address "pollution of air, water and soil in own operations." The Environmental Policy applies "a principle of caution with regard to the use of substances considered hazardous to humans and/or the environment, including replacing and minimizing the use of substances of concern and substances of very high concern," though it "does not list specific pollutants" (material emissions are in the E2-4 tables). The Code of Conduct and Business Partner Code of Conduct set expectations on Boliden and partners "to prevent, mitigate, and remediate impacts and risks related to pollution of air, water, and soil, including responsible waste and tailing management."

Reference: pages 82-83.

Pollution prevention follows the mitigation hierarchy (avoid, reduce, restore, regenerate, transform), applying Best Available Techniques (BAT) under the EU Industrial Emissions Directive and a certified ISO 14001 environmental management system at every Boliden site. Chemicals management requires review/approval of new chemicals, the substitution principle, risk assessment and a site chemical coordinator; General Managers are responsible for REACH compliance. Seveso III sites maintain safety reports and emergency preparedness plans.

2025 actions: a heat exchanger replacement at the sulphuric acid plant and closure of a mercury emission point source at Kokkola (air); a new water treatment plant at Odda, plus new plants at Kristineberg and Zinkgruvan and a mined-out pit used for water storage at Aitik (water).

Reference: pages 83-84.

Targets: no increase in metal emissions to air/soil (intensity ≤30, NCP metal equivalents per Mtonnes metal produced), SO2 to air ≤6.0 ktonnes, metal discharges to water intensity ≤44, N-tot to water ≤232 tonnes, and "no significant environmental incidents." "Boliden has not defined targets for substances of concern and substances of very high concern." Emissions to land are "not applicable ... as there is no waste subjected to land treatment or deep injection" under Directive 75/442/EEC.

Ecological thresholds follow the EU Water Framework Directive EQSs and Ambient Air Quality Directive; ambient air is monitored at Kokkola and Harjavalta using bioindicators (lichen, moss, needles).

Reference: page 85.

2025 air emissions: Cu 853 kg (2024: 1,304), Zn 11,302 kg (12,822), Pb 1,243 kg (1,521), Hg 32.9 kg (24.6), SOx 5,988 t (5,938, below target), NOx 422 t (388). Metal-to-air intensity fell to 21 (from 33). 2025 water emissions: Cu 1,112 kg, Zn 3,768 kg, As 645 kg, N-tot 183 tonnes (198, below target). Metal-to-water discharge intensity fell to 35 (from 59). "During 2025, no significant environmental incidents occurred."

Only pollutants in Annex II of Regulation (EC) 166/2006 are disclosed as metrics. Measurement follows EN/ISO standards with internal and external laboratory verification; the air/water reporting period runs December-November for lab turnaround.

Reference: page 85.

Substances of concern are "predominantly inorganic," inherent to mined ores and concentrates, most commonly lead, cadmium and certain arsenic compounds; SVHCs also occur in explosives, flotation agents, lubricants and diesel. Per ESRS E2 paragraph 34, volumes must be disclosed for generation/use/procurement and for outflow; Boliden discloses neither this year: "Boliden is currently not able to disclose used volumes of SoCs nor used volumes of SVHCs," because authority-reported amounts do not map to the SoC/SVHC classification.

As a partial substitute, Boliden reports counts rather than volumes: of 7,079 articles in its chemical database, 2,821 contained SoCs and 485 contained SVHCs; a pilot study at one mine found 2.3% of purchased process chemicals were SVHC-classified. The company states newly article-linked purchasing data "will enable us to track volumes of specific substances on a more granular level going forward," targeted for 2026 reporting.

Reference: page 86.

Policies address "use and sourcing of water in own operations." The Water Management Commitment (aligned to ICMM's water-management guidelines) covers "transparent corporate water governance, managing water at operational sites effectively, and collaborating to achieve responsible and sustainable water use." Water risk/stress is classified via the Aqueduct Water Risk Atlas: most sites sit in low water-risk regions, except Tara, Zinkgruvan and Somincor ("Low to medium" risk), with Somincor's surficial withdrawal source in a watershed rated "High" risk and "Extremely High" water stress. The Environmental Policy and Code of Conduct/Business Partner Code of Conduct extend water-management expectations to the value chain.

Reference: pages 86-87.

"The areas where Boliden operates generally have good access to water," with "no water sources ... significantly affected by water withdrawal." Somincor is the one unit in a higher drought-risk region. Actions follow the mitigation hierarchy (avoid/reduce use, reclaim/reuse water, restore aquatic ecosystems), with site-specific water balances maintained at the catchment level. Water management is delegated from the Board/Group management to business-unit water management groups.

2025 target met: "all operative mining business units have developed and completed water management plans" by year-end (with Somincor/Zinkgruvan integration continuing into 2026). Seveso III sites maintain emergency plans for excessive discharge and dam failure, aligned with GISTM requirements.

Reference: page 87.

Targets: "no significant environmental incidents" (met in 2025) and unit water management plans in line with the Group plan "by 2025" (also met). Ecological thresholds follow the EU Water Framework Directive Environmental Quality Standards and national river basin specific pollutants, monitored via aquatic-environment sampling at discharge points and assessed against local, national and European standards. Thresholds are set at EU level and implemented nationally; business units hold responsibility for site-level awareness and compliance, consolidated at business-area and Group level.

Reference: page 88.

2025 water metrics: total water consumption 66,044,528 m3 (2024: 6,595,845 – a large increase driven largely by the Somincor/Zinkgruvan acquisitions); water consumption in water-risk areas 655,379 m3 (2024: 0); total water recycled and reused 203,540,914 m3 (2024: 175,897,267); total water stored 42,487,304 m3. Consumption = (operational + Other Managed Water withdrawal) minus total discharge minus change in storage. Withdrawal and discharge volumes are continuously measured at all sites.

Reference: page 89 (see also page 56).

"Boliden has developed guidelines for a biodiversity transition plan outlining the path toward our biodiversity target, defining milestones, principles of work and activities for implementation both short and long term," addressing "material nature related aspects through impact mitigation strategies, forward-looking risk management practices." Each business unit is expected to build its own roadmap under the guidelines, published at the start of 2025.

Flagged limitation: the biodiversity chapter carries a general phase-in note that Boliden "mainly phase[s] in disclosure requirements in the areas of transition plan, actions and targets, primarily related to site specific disclosures and biodiversity offsets," so "the reporting on biodiversity and ecosystems for the reporting year is not fully complete." Resilience of the strategy with respect to biodiversity is cross-referenced to page 56 (Operational challenges related to sustainability matters).

Reference: page 89.

Policies address "biodiversity and ecosystems affected by own operations." The Environmental Policy commits to contributing "to increased biodiversity in all regions where we operate by 2030," via the mitigation hierarchy (avoid, minimize, restore, compensate). The Biodiversity and Nature Commitment commits to a "nature positive future ... across four spheres of influence – direct operations, value chains, landscapes and system transformation" and to avoiding exploration or mining "in World Heritage properties." Boliden "does not have a deforestation policy," but treats deforestation controls as integrated into the biodiversity commitment and the Business Partner Code of Conduct, plus legally required replanting after timber harvest.

Reference: pages 90-91.

Mitigation-hierarchy actions: Avoid (environmental impact assessments and species surveys shaping project design), Minimize (monitoring programs for air, water/sediment, soil, dust and bioindicator species), Restore (ecological restoration of closed-mine sites), Compensate ("protection or restoration of habitats in the vicinity of impacts," like-for-like or better). Biodiversity management plans are "implemented at all mines, with a phase-in plan for acquired mines Somincor and Zinkgruvan as well as for smelters." Boliden commits to protecting/restoring 30% of non-operational landholdings (forests, wetlands, legacy sites) partly via FSC-aligned forestry.

2025 actions: biodiversity guidelines published; site roadmaps completed except at Somincor/Zinkgruvan; CLIMB biodiversity-metric baselines completed at Aitik, the Boliden Area, Garpenberg and all smelters; a UK-Biodiversity-Net-Gain-derived metric developed for Tara.

Reference: page 91.

Target: "increase biodiversity in all regions where we operate by 2030, compared to the base year 2020," informed by the Kunming-Montreal Global Biodiversity Framework, EU biodiversity strategy and national targets, and by the TNFD assessment. Progress measurement is acknowledged as a challenge: "we disclose the number of activities to promote biodiversity. During 2025, there were 78 (71) activities," with the caveat that "an activity can have a small or large impact, and comparison of numbers can be ambiguous."

Boliden has not set specific ecological thresholds for biodiversity itself, instead anchoring to the global framework's ambition to "protect 30% and restore 30% of the worlds land and sea."

Reference: page 91 (table continuing to p.92).

Land management, 2025 vs 2024 (hectares): Mines active 8,235 (7,308), Mines closed 2,205 (2,055), Smelter active 589 (576), Smelter closed 58 (58), Forestry 11,311 (10,903), Agriculture 1,501 (610), Protected 3,317 (3,297), Other 5,221 (5,026); Total 32,437 (29,832). Change in land management: mine operations -19.4 ha, smelter operations +13.4 ha in 2025.

"As our largest impact on biodiversity comes from the conversion of natural habitats to mines, we report areas of land, area developed, area protected, area restored and offset," with a red-listed/protected-species register published per site at www.boliden.com.

Reference: page 93.

Policies cover resource use and the circular economy in own operations. The Environmental Policy commits to "minimizing waste and recycling of material, ensuring dam safety, and promoting the sustainable use of resources." The Tailings Governance Commitment covers responsible waste/dam-safety management and reprocessing tailings for resource recovery. The Code of Conduct and Business Partner Code of Conduct extend responsible waste and resource-efficiency expectations to business partners.

Reference: pages 93-95.

Boliden is "one of Europe's leading recyclers of used lead batteries and scrapped electronics": the Rönnskär smelter recycles electronic scrap using Kaldo technology; Bergsöe recycles ~4 million lead-acid batteries/year, producing 50,000 tonnes of lead annually with "almost 100% ... from secondary sources." Boliden is "fully committed to ICMM's Global Industry Standard on Tailings Management (GISTM)": its three highest-consequence active facilities (Aitik, Kevitsa, Somincor) are in full third-party-certified conformance; others are self-assessed in full or partial conformance, targeting full conformance by 2027.

R&D: SCMentum, a low-carbon cementitious by-product from smelter slag, is "ready for scale-up"; a Kevitsa pilot explores using tailings/waste rock for carbon capture and storage; Kokkola is preparing to reprocess 400 ktonnes of landfilled sulphur-bearing waste from 2027.

Reference: page 95.

Circular-economy roadmaps target: extracting value from waste, increasing utilization of currently discarded waste fractions, minimizing/reducing deposited waste volume, ensuring safe deposition, and developing circular-economy solutions. "Waste reduction in absolute amounts for each initiative is a given parameter when evaluating each project's potential and business value," and effectiveness is tracked through regular roadmap and project review rather than a single headline numeric target.

Reference: page 95.

2025 material inflows (ktonnes): mined rock 153,619 (2024: 117,975), milled ore 64,545 (56,081), concentrate produced 1,820 (871), smelting materials 2,706 (2,714), other materials 1,030 (834), non-renewables (fuels, explosives, chemicals) 185 (176). Recycled materials input: 311,769 tonnes (2024: 329,165) against a total smelting feed of 2,706,396 tonnes, giving a recycling input rate of 12% (unchanged from 2024).

Recycled materials "include secondary materials from external sources and secondary materials sent from one business unit to another," excluding internally recirculated by-products and slag sent from smelters to mines.

Reference: page 95 (recyclability); waste tables on page 96 under the Waste entry.

Boliden's products are "zinc, copper, nickel, lead, gold and silver," plus sulphuric acid as the most important by-product. Metal "recyclable content" is 100% for all Boliden's metal products since metals "can be endlessly recycled." Sulphuric acid recyclability depends on use: in "large-scale uses, such as ... pulp and paper and fertilizer industries, the acid becomes non-recyclable post-use," though contaminated acid can sometimes be refined to high grade.

The full quantified waste-outflow table (extractive waste reuse/disposal, waste diverted from/directed to disposal) is carried under the Waste entry below to avoid duplicating the figures.

Reference: page 96.

Extractive waste (tonnes, 2025 vs 2024): reused as backfill – waste rock 2,433,020 (1,721,791), tailings 3,534,636 (1,392,139); reused as construction material – waste rock 31,441,518 (8,363,675), tailings 1,698,533 (1,610,500); landfilled waste rock 50,733,376 (47,528,402); sold waste rock 5,487 (5,677); tailings management facility 51,851,683 (52,155,859); total 141,698,253 (112,778,044).

Non-hazardous waste diverted from disposal: 128,885 t (2024: 72,156). Hazardous waste diverted: 75,259 t (61,208). Non-hazardous waste directed to disposal: 206,713 t (214,882, mostly internal landfill). Hazardous waste directed to disposal: 1,192,373 t (1,181,607), dominated by internal landfill (718,279 t) and deep-well/underground deposit (175,311 t). Non-recycled process waste: 87% (2024: 91%). Tailings/waste rock used for underground backfill "are not considered to be waste and are not reported as such."

Reference: pages 98-99.

Policies: Code of Conduct, Data Privacy Policy, Diversity Equity and Inclusion Policy (renamed/updated in 2025), Health and Safety Policy, Human Rights Commitment, a new 2025 Remuneration Policy, and the Whistleblower Policy, all guided by the UNGPs, ILO Fundamental Principles and OECD Guidelines. All Boliden units hold ISO 45001:2018 certification. "Our code of conduct outlines our zero tolerance towards all sorts of harassment and discrimination."

DEI commitments include striving "to increase the representation of women at all levels" in "a traditionally male-dominated industry," with each operating unit required to hold a written DEI action plan. Boliden joined ICMM's 2023 industry-wide DEI position statement and continued collaborative work in 2025. Disability accessibility is addressed through facility adaptations and assistive technology.

Reference: pages 99-100.

Engagement runs through collective agreements, local employee-representative councils, and a European Works Council (renewed in 2025; meets Group management three times yearly plus as needed). Three employee representative board members and three deputies sit on the Board. Business-area forums meet quarterly; site forums range from weekly to quarterly.

A Group-wide human rights working group (Ethics and Compliance, HR, sales, sourcing, procurement), running since 2023, coordinates human-rights due diligence across processes including risk assessment, Group/local human rights impact assessments and the annual Group risk process. Effectiveness is tracked via the annual My Opinion employee survey response rate, engagement index, and grievance-mechanism usage. The survey is run annually (2025 was the fifth year), with results reviewed by Group management and action plans shared with the Board and the European Works Council.

Reference: page 100.

Reporting channels: direct manager, manager's manager, local HR, the Group Ethics & Compliance function, or the independent third-party whistleblower channel (online, phone or in-meeting), with a five-step handling process (receipt, evaluation, investigation, resolution, monitoring). Trust and awareness are monitored annually via the Ethics and Compliance index in My Opinion. Boliden "applies zero tolerance for retaliation against anyone who reports serious wrongdoing ... in good faith."

Remedies available include "apologies, restitution, rehabilitation, restoration, financial or non-financial compensation," plus harm prevention. All employees are covered by workplace insurance for occupational accidents, and Boliden conducts root-cause analyses for serious risks or injuries.

Reference: pages 100-102.

Health and safety actions align with ISO standards, incident review for preventive learning, and proactive risk/near-miss reporting. On forced/child labor, Boliden assesses risk as "very low" but launched a 2025 on-site ethics-and-compliance assessment program covering all sites. DEI actions in 2025: updated DEI policy, a new internal DEI expertise network, and preparation for the EU Pay Transparency Directive (job-architecture and data-quality work).

A concrete remediation example: a 2025 cyberattack on an external supplier holding Boliden employee data led Boliden to suspend the affected systems until the supplier implemented round-the-clock monitoring, network clean-up and third-party-verified remediation; the breach was reported to the relevant authority and affected employees were informed. Effectiveness is tracked via My Opinion, health and safety records, turnover and diversity indicators.

Reference: pages 102-103.

2025 social targets, approved by the Board: health and safety – "zero harm to people" (long-term), LTIF -30% vs. previous year, Proactivity index >5, Safety Culture index >74, Organisational and social work environment index >72, sick leave <4%; people management – Leadership index >77, Engagement index >76, Diversity and inclusion index >83, and "Top 100 positions with at least one internal candidate in the succession plan 100%." Targets are set at Group level, approved by the Board (with employee-representative participation), and followed up monthly/quarterly.

Reference: pages 102-103.

Total headcount 8,308 (2024: 6,378), by country: Sweden 4,348, Finland 1,728, Portugal 1,259, Norway 552, Ireland 403, Other 18. Gender split: female 1,850 (22.3%), male 6,458. 7,840 permanent / 468 temporary employees; 8,154 full-time / 154 part-time. No non-guaranteed-hours employees. Employee turnover: 454 permanent employees left, a 5.8% turnover rate (2024: 537, 8.9%).

From January 1, 2025, Boliden introduced new FTE and headcount definitions (overtime/flexible hours now included in FTE; headcount counts working agreements including employees on leave). Data is sourced from the Group HR IT system plus local HR/payroll systems at newly acquired Somincor and Zinkgruvan.

Reference: page 103.

Non-employees are defined as agency workers, consultants and self-employed individuals directly working in Boliden's operations (excluding external contractors), measured as actual headcount at December 31. "The total number of non-employees in Boliden by December 31, 2025, was 50, of which 25 (50%) were female."

Reference: page 104.

All employees in Boliden's five EEA countries of significant employment – Sweden, Norway, Finland, Ireland, Portugal – are covered by collective bargaining agreements: 100% coverage in each, totaling 8,290 employees. Social dialogue/workplace representation in the EEA is rated in the "80-100%" band. Reporting on non-EEA collective bargaining coverage is not applicable, since Boliden's only non-EEA employees (England) number fewer than 50.

Reference: page 104.

"In 2025, the proportion of female employees was 22.1% (22.9%)." Women held 34% of Boliden's top-100 management positions (unchanged from 2024), and 4 of 12 business units were led by women (2024: 2). Board: AGM-elected non-executive members 50/50 female after one resignation (44/56 before); employee-representative members 0% female; Group management 33% female. Age distribution: under 30 – 17.9%, 30-50 – 55.0%, over 50 – 27.1%.

Reference: page 104.

"All of Boliden's employees are paid an adequate wage in line with applicable collective bargaining agreements in the countries where we operate and internal reviews are carried out to ensure that adequate wages are paid." The Remuneration Policy's purpose is "to ensure equality and fair treatment in all remuneration matters," with a "pay for performance" philosophy that is "market-based but not market-leading."

Reference: page 105.

All employees in Boliden's five countries with 50+ employees (Sweden, Norway, Finland, Ireland, Portugal) are covered by social protection against loss of income from sickness, unemployment, occupational injury/disability, parental leave and retirement, combining public programs with Boliden-specific top-up coverage in several categories. Employees in the smaller countries (Denmark, Great Britain, Germany, each under 50 employees) are also covered from the start of employment.

Reference: page 105.

"In most of the countries where Boliden operates, data collection regarding disabilities is legally restricted," as asking employees for this information is generally considered an unlawful privacy invasion; the exception is Portugal, where Boliden can report the datapoint. "In 2025 altogether 0.16% of the total workforce in Portugal were people with disabilities, of which 0.08% was female employees," sourced from the local Portuguese HR system.

Reference: page 105.

"Our aim is for 100% of our employees to receive an annual performance- and career-development review." White-collar review rate: 92% (2024: 93%) via a new 2025 competence-and-personnel-planning tool; blue-collar reviews are conducted but not yet captured in that tool, so the rate "was therefore not measurable in 2025." Average training hours per employee in 2025: male 8.2 (10.2), female 12.7 (11.0), white-collar 10.8 (10.6), blue-collar 8.4 (9.3), total 9.2 (10.4). No group-wide training-hour targets are set; methods and extent are decided locally.

Reference: pages 105-106.

"All Boliden units have an occupational health and safety management system in line with ISO 45001:2018," covering 100% of employees, non-employees and contractors. No work-related fatalities have occurred on sites or areas controlled by Boliden since 2008. The proactivity index (proactive risk reports per reactive deviation) rose to 8.1 (6.4); excluding newly acquired units not yet fully harmonized, it was 7.8. Accidents with absence (incl. contractors) fell to 76 (89); workdays lost to accidents rose to 941 (528), "most common types ... slips, trips and falls, and finger/hand injuries."

Rate of recordable work-related accidents (TRIFR): employees 10.9, contractors 5.2. Sick leave rate by country (2025): Sweden 4.6%, Norway 7.2%, Finland 5.0%, Ireland 4.4%, Portugal 3.7%, Group 4.7% (5.2%).

Reference: page 106.

"100% of Boliden's employees are entitled to take family-related leave," and Boliden supports part-time work and occupational health services alongside paid leave. The report gives the share of employees who utilized family-related leave by gender and country for 2025 (e.g. Sweden 83% male / 66% female, Norway 186%/45%, Finland 5%/49%, Portugal 197%/NA, Group 82%/57% – figures above 100% reflecting leave taken by more employees than the reporting-period headcount in some categories).

Reference: pages 106-107.

"Boliden's unadjusted gender pay gap is currently -4.2%, indicating that, on average, female employees earn less per hour annually than male employees." By country: Sweden -3.0%, Norway -0.3%, Finland -8.8%, Ireland -4.6%, Portugal -8.6%. By category: white-collar basic salary -10.1% (variable components -30.8%), blue-collar basic salary -4.2% (variable -8.7%).

"The remuneration ratio of the highest paid individual to the median, excluding the highest paid individual is 25.7 to 1," attributed to a largely operational (lower-paid) workforce and positions concentrated in regions with lower living costs. Remuneration includes a profit-sharing program paying up to SEK 40,000 per full-time employee when return on capital employed reaches 18%.

Reference: page 107.

Full-year 2025: 36 incidents of discrimination/harassment, 79 complaints filed via employee channels, 0 SEK in fines/penalties/compensation for discrimination, 1 severe human rights incident, 0 cases of UNGP/ILO/OECD non-respect. "Boliden did not identify any cases concerning child labor, forced labor, or human trafficking related to its own workforce." The one severe incident was a cyberattack on a third-party supplier system holding employee data; it "could not be ruled out that sensitive personal information had been exposed," was reported to the relevant authority, affected employees were informed, and the supplier was "forced to remedy and take action."

Entity-specific: the My Opinion survey (87% response rate, 2024: 89%) scored Safety Culture 75, Leadership 78, Engagement 80, Psychological safety 85, Ethics and Compliance 82. Newly acquired Somincor and Zinkgruvan did not participate in 2025 but will join in 2026.

Reference: page 110.

Key policies: the Code of Conduct (available in English, Swedish, Finnish, Norwegian, Portuguese); the Business Partner Code of Conduct, aligned with the UNGPs and OECD Guidelines, triggering "time-bound corrective actions" where a partner is non-compliant and explicitly addressing human trafficking, forced/compulsory and child labor; the Human Rights Commitment; and the 2025-launched Responsible Sourcing Policy setting "key underlying principles and requirements for when Boliden source goods, materials and services."

Reference: pages 110-111.

Vulnerable-worker identification uses the CAHRA (Conflict-Affected and High-Risk Area) methodology and a heightened-risk flag for gold-bearing supply chains, subject to yearly third-party LBMA responsible-sourcing audits. Engagement happens through on-site due-diligence visits, normally with legitimate worker representatives (local unions where present); "during the year, Boliden held six dialogues with workers in the value chain of metals and minerals, one of these was with female workers in a context of elevated gender risks," with "none of the dialogues [bringing] up serious risks."

"As Boliden is a decentralized organization, modalities of engagement ... is tailored to each site's or function's operational setup," through supplier forums initiated locally and prioritized by risk.

Reference: pages 111-112.

Value chain workers can report via Boliden's Ethics and Compliance function, the whistleblower channel, or (Business Area Mines) a feedback portal; both the portal and whistleblower channel allow anonymous reporting. "While workers in our value chain may directly contact Boliden through the whistleblowing channel, this option is rarely used by this group," so Boliden instead "engages with all raw material suppliers to assess the existence of grievance mechanisms." Where heightened risk is identified, Boliden verifies grievance-channel effectiveness and trust directly with worker representatives and establishes a risk mitigation plan with regular follow-up.

Reference: pages 111-113.

Due diligence follows the OECD Guidelines and OECD Due Diligence Guidance for minerals from conflict-affected/high-risk areas (see pages 122-124). 2025 incidents: "one serious human rights incident" – an occupational accident causing physical injury to a contractor's employee, leading to an investigation and fines for both Boliden and the contractor; separately, a living-wage gap was identified at one supplier (treated as a systemic risk given the national minimum wage) and a payment-irregularity case was remediated by the supplier, with whom "Boliden is no longer doing business." No widespread/systematic negative impacts were identified during the year, though "widespread risks are recognized in certain geographies."

2025 actions: a three-day on-site assessment at one mine; new value-chain KPIs; an ethics e-learning for contractors; a dedicated part-time human-rights/labor-risk procurement role; an updated Business Partner Code of Conduct; and an internal country-risk-assessment tool.

Reference: page 113.

Strategic targets for value chain workers: "long-term ambition: zero harm to people," LTIF -30% vs. the previous year's level, Proactivity Index >5 – the same framework as own-workforce targets, "set at group level without involving value chain workers directly." 2025 performance: contractor LTIF 4.1 (2024: 6.8); contractor Proactivity Index 5.1 (4.3). Contractors with more than 2 LTIs in a rolling 36-month period require follow-up, escalated to Procurement if needed; every site accident is investigated for root cause.

Reference: page 114.

Policies of particular relevance: the Human Rights Commitment (aligned to UNGPs, ILO and OECD Guidelines, promoting "open and long-term dialogue with affected communities"); the Indigenous People Commitment, relevant because "some of Boliden's operations are located in the northern part of the Nordics where the Sami population have special rights"; and the Tailings Governance Commitment (GISTM requires transparency and stakeholder dialogue). Boliden is also an active member of ICMM and Svemin.

Flagged limitation: the affected-communities chapter carries a general phase-in note – Boliden "mainly phase[s] in disclosure requirements in the areas of process for engagement and remediation, actions and metrics," due to decentralized processes, so "the reporting on affected communities is not fully complete."

Reference: page 115.

Engagement occurs via project-development impact assessments with early stakeholder involvement, regulated public consultations, and "special consultations" with indigenous peoples carried out early to inform mitigation-hierarchy decisions, followed up regularly by operations. Boliden also runs local site-level initiatives and, for exploration activities, publishes work plans and advertises to inform residents, using ICMM-aligned grievance mechanisms published on its corporate website.

Reference: page 115.

Each unit's general manager is responsible for correctly conducted community consultations, supported by specialists in both business areas. Each operating unit maintains a whistleblowing channel, and mining operations additionally provide a public grievance portal; the whistleblower channel guarantees anonymity, "whilst the grievance mechanism is not." Remedies, including relocation, follow established mining-industry standards on a case-by-case basis, with overall responsibility resting with the EVP People and Sustainability.

Reference: page 115.

Boliden applies the mitigation hierarchy for community impacts, particularly for indigenous peoples: avoidance (exploration excluded from certain geographies and seasons, e.g. to protect reindeer husbandry) through to compensation (the Sarkanenä Sustainability Park near the Aitik mine). Social/socioeconomic sustainability analyses and human rights impact assessments support permitting decisions.

2025 actions: meetings on collaborative agreements with Sami villages and participation in reindeer-husbandry support projects (e.g. supplementary winter feeding), including engagement tied to the Laver development project in southern Norrbotten; "regarding concentrate supply, Boliden has not been directly involved in any remedial actions"; six upstream/downstream community-engagement activities were carried out on concentrate sourcing, with "no material change from earlier."

Reference: page 115.

"Boliden does not currently have related targets and is strengthening the reporting structure for affected communities, whereafter targets shall be developed both for own operations and the value chain." In the meantime, Boliden assesses cases reported through its various channels: "for communities affected by Boliden's own operations and our value chain, no severe human rights issues or incidents were reported during the year."

Reference: pages 116-117.

Policies: Code of Conduct (with a detailed handbook), Whistleblower Policy, Business Partner Code of Conduct, Human Rights Commitment, Anti-Corruption Policy, Sanctions Policy and the 2025-launched Responsible Sourcing Policy. Code of Conduct training is e-learning/classroom, dilemma-based, ~30 minutes, covering health and safety, fair working conditions, anti-corruption, conflicts of interest, sanctions and more. "During 2025, 25% of Boliden's own workforce completed the Code of Conduct training. Among employees in functions identified as high-risk for bribery and corruption, the completion rate was 8%," with focused 2026 training planned for those functions.

Whistleblowing is run by an independent external provider with anonymous reporting; access is restricted to two Group-level individuals. High-risk functions for corruption include procurement, sales, treasury, legal, and senior/business-area management.

Reference: pages 118-119.

Supplier payments are managed by each legal unit's finance department under local payment instructions. New business partners undergo risk screening (sanctions, country, industry, volume) and self-assessment questionnaires against the Business Partner Code of Conduct, with interviews/on-site assessments where needed; gaps trigger a mutually agreed improvement plan, and agreements are paused or terminated "if it is deemed too difficult or not possible for the business partner to sufficiently improve." Contract signing requires commitment to the Code and a sanctions clause.

For the mineral value chain specifically, a dedicated team oversees evaluation, escalates high-risk cases and monitors improvement plans; Boliden adheres to the LBMA Responsible Gold and Silver Standards, appears on the LBMA's Good Delivery List, and requires country-of-origin documentation to avoid conflict minerals (see OECD chapter, pp.122-124).

Reference: page 118.

Boliden applies "a zero-tolerance approach to bribery and corruption, including facilitation payments," governed by the Anti-Corruption Policy, Code of Conduct and Business Partner Code of Conduct, with the four-eyes principle and built-in ERP authorization procedures for detection. Locally identified suspected cases are reported to the Chief E&C Officer, who determines the investigation approach; cases from Group E&C or the whistleblower channel are led by, or closely monitored by, the Chief E&C Officer and always run through an independent function separate from the implicated management chain. Confirmed cases go to the relevant authority and the Board.

Training: Group management completed Code of Conduct training in late 2023, the Board in 2025; dedicated anti-bribery/corruption/AML/sanctions/trade-compliance training for Group and business-unit management and at-risk functions is planned for 2026.

Reference: back-filled from ESRS 2 SBM-3 (page 61) and the G1 Business conduct chapter (pages 116-119). This disclosure requirement did not exist as a standalone 2023-ESRS DR; under the 2023 ESRS its ground was covered by MDR-T.

Boliden's SBM-3 topical overview states plainly for business conduct: "To track the effectiveness of our Code of Conduct we measure and follow up on training in business conduct, ethical breaches, whistleblower reports and incidents of corruption. Disclosure requirements according to MDR-M and MDR-T are found on pages 116-119." No single numeric business-conduct target (e.g. a target completion rate or a target incident count) is stated; instead, effectiveness is tracked against the metrics actually reported under G1: Code of Conduct training completion (25% overall, 8% in high-risk functions), zero anti-corruption convictions/legal cases in 2025, 66 categorized whistleblower reports, and average payment time (32.0 days, 87.6% within terms). This is MDR-T's "tracking effectiveness in the absence of a stated target" limb, so the entry is recorded as reported.

Reference: page 119.

"During 2025, Boliden was not involved in, nor convicted of, any violations of anti-bribery and corruption laws, and was not subject to any related public legal cases." "Boliden did not receive any reports related to corruption or bribery in connection to own employees or business partners." A new "on-site assessment" routine (combining risk assessment and internal audit) launched in 2025, with the first assessment completed and all Group sites planned for review by 2028.

Entity-specific whistleblower data: 66 reports in 2025 (2024: 49), categorized as Discrimination/Harassment 23, Health and Safety 17, HR 10, Fraud 8, Other 7, Environment 1, Conflict of Interest 0, Corruption 0.

Reference: page 119.

"Boliden aims to treat all suppliers fairly and to pay all invoices within the agreed payment terms." General supplier payment terms are 45 days. "The average time Boliden takes to pay an invoice was during 2025 32.0 days and 87.6% were paid within the agreed payment terms." "By the end of the reporting period, Boliden had 2 ongoing legal proceedings outstanding for late payments," defined as unpaid invoices that have passed the reminder stage and entered a debt-collection process via agency or court.