Bonava

Governance roles

Reference: page 70 (index page 70).

"The Board of Directors holds ultimate responsibility for reviewing, monitoring, and guiding Bonava's sustainability initiatives", with the allocation of tasks set out in its Rules of Procedure. Two Board committees exist: the Audit Committee, "responsible for overseeing financial reporting and sustainability reporting", and the Remuneration Committee.

Delegation chain (page 70): the Board has delegated daily responsibility for sustainability to the CEO, who has delegated strategic responsibility to the SVP Brand & Culture. The Group Head of ESG Control & Reporting coordinates sustainability activities and reports to SVP Brand & Culture, and also leads the ESG Committee, which supports the Executive Management Group and coordinates across business units. An investment workgroup handles ESG in investments, the Risk Committee runs risk and compliance, and topic-specific councils cover health, safety, employees, environment and climate.

Composition (page 70): seven non-executive directors, three women and four men, a 43/57 average women-to-men ratio in 2025. All directors elected by a General Meeting are independent of the company and Executive Management; five of seven are independent of major shareholders. "Bonava has no employee representatives or other workers on the Board." In 2025 "the Board of Directors initiated sustainability certification via external training companies."

Information provided to and matters addressed by the bodies

Reference: page 70 (index page 70).

Progress against the strategic sustainability targets "is an integral part of financial monitoring" and is "tracked on a quarterly basis". Bonava's sustainability targets are approved by the Board of Directors.

Reporting cadence (page 70): the Board "receives monthly reports on workplace incidents, including analyses and lessons learned from them", plus information on other serious incidents such as environmental ones when needed. The annual Board cycle set by its Rules of Procedure is:

• Q1 review of the Annual Report including the Sustainability Report, short-term incentive results and long-term incentive documentation
• Q2 status update on material health and safety indicators
• Q3 "Update and discussion of Bonava's management of material impacts, risks and opportunities pertaining to Bonava's organisation, targets and key performance indicators"

Reporting reaches the Board via the CEO, CFO, CLO and SVP Brand & Culture, and each Board committee reports on its own activities, observations and proposals. From 2025 Bonava began publicly reporting health and safety target performance quarterly, and from Q1 2026 will also report quarterly climate data (kg CO2eq/m2 GFA, from LCAs) (page 70).

Sustainability in incentive schemes

Reference: page 70 (index page 70; also listed as ESRS 2 GOV-3-E1, page 70).

"Climate has been integrated into Bonava's strategic and long-term targets and impacts the variable remuneration to senior executives, including the CEO. Starting in 2025, climate performance comprises 10 per cent of the total assessment in the short-term incentive program (STI)" (page 70).

The climate assessment rests on three stated principles (page 70):

• Materiality rewarding "insights that lead to reductions in emissions, with LCAs from project types as the foundation for assessments, combined with economic sustainability in projects"
• Measurability quantifiable actions for a better decision basis
• Market taking local conditions and maturity into account (laws, customers, maturity of material suppliers and technology)

"The framework is related to Bonava's emission reduction plan Step 1, which is based on identifying emission reduction opportunities in 2025." The STI programme "also includes a clause related to health and safety". The Group's ESG Committee assesses climate performance and recommends outcomes to the Remuneration Committee, which decides. Remuneration detail is cross-referenced to Note 4, pages 144-147 (page 70). Proactive health and safety work also forms "part of the performance-based evaluation of Executive Management" (page 112).

Statement on due diligence

Reference: page 71 (index page 71).

Bonava presents a mapping table of "references to the different components of the Bonava due diligence process" against the core elements of due diligence (page 71):

The table reproduces the ESRS labelling as printed, including the duplicated "c)" and the absence of a "d)" row.

Risk management and internal controls over sustainability reporting

Reference: page 71 (index page 71).

Bonava applies "the Group's Internal Control Policy", with "an annual cycle of risk assessment and minimum requirements for internal control, as well as self-assessment, which is reported to the Audit Committee and the Board". Two risk types are distinguished:

1. Reporting risks - non-compliance with transparency requirements and immaterial or irrelevant information. Managed via "an annual risk assessment of ESG reporting that encompasses materiality, data and process risks, internal and external auditor feedback and regulatory developments".
2. Data quality and reliability risks - the framework "requires annual validation, verification and review of the reliability of the data", by a designated control owner.

Topic owners assess validation; the control owner consolidates and prioritises on likelihood, impact and control maturity. Two material 2025 risks are named: that "the CSRD regulations [were] still being new, and industry practices for interpretation and application of the regulations were continually evolving", and "the introduction of new data methods and indicators in sustainability reporting, for example, concerning climate risk assessment, where our organisation is still maturing" (page 71).

Strategy, business model and value chain

Reference: pages 63-64 (index pages 63-64).

"Bonava develops land into attractive, sustainable neighbourhoods... We construct several types of homes: multi-family housing, single-family homes and semi-detached houses with various types of tenure." With 900 employees, Bonava operates in Germany, Sweden, Finland, Estonia, Latvia and Lithuania (page 63).

Three sustainability core themes carry the strategy: Embedded environmental respect (E1, E2, E4, E5), People-centric culture (S1, S2) and Governance for high performance (G1) (pages 61-62). Four Group-wide strategic sustainability targets are set, plus business-unit targets for E5 (page 63).

Value chain (page 64): upstream covers operators who "extract, refine and process raw materials" and contractors running construction production; own operations run land acquisition, project planning, project execution, marketing and sales, and customer service; downstream covers customers "primarily consumers, but also investors who in turn let the housing units to tenants", the use phase and demolition. Material matters are mapped per stage, e.g. E2 substances of concern upstream and downstream.

Current financial effects are "linked primarily to the climate" (page 63). EU Taxonomy: eligible turnover SEK 7,725m (93%), aligned SEK 461m (6%); eligible CapEx SEK 59m (100%), aligned 0% (page 74).

Interests and views of stakeholders

Reference: pages 65-66 (index pages 65-66; also SBM-2-S1 and SBM-2-S2, page 65).

Five stakeholder groups are tabulated with how the dialogue was organised, its purpose, example outcomes and how the Board is informed (pages 65-66):

• Customers - public events, investor dialogues, the customer portal, customer service, NPS. "Bonava measures customer satisfaction, which is a strategic target that is tracked by the management team in conjunction with quarterly reviews and reported to the Board."
• Employees - the annual Passionate Workplace survey, the P&D process, monthly one-to-ones, off-boarding surveys, worker protection representation, an annual Health and Safety Awareness Week. "Health and safety information is reported monthly to the management team and the Board."
• Investors, financiers, owners - investor meetings, ESG rankings, Capital Markets Days, green financing dialogue; outcomes include evaluation of the Green Financing Framework.
• Suppliers - "The suppliers with the greatest impacts, risks and opportunities are the contractors who build our houses", addressed through supplier requirements, third-party auditing and onboarding.
• Public authorities and municipalities - planning, permits and coordination, with dialogue by business unit leaders and the Executive Management Group.

Material impacts, risks and opportunities

Reference: pages 63-64 and 67-68 (index pages 63-64, 67-68), with per-topic tables on pages 75, 88, 90, 93, 98-99, 110 and 117.

"In summary, Bonava has identified 12 material sustainability areas, all of which were previously classified as material for Bonava" (page 67). The IRO-2 table lists them under seven topical standards: E1 (climate change mitigation, climate change adaptation, energy), E2 (substances of concern and very high concern), E4 (direct impact drivers of biodiversity loss or impacts on the state of species), E5 (resource inflows including resource use; waste), S1 and S2 (working conditions; equal treatment and opportunities for all) and G1 (corruption and bribery).

Those 12 sub-topics expand into 27 individually typed IRO rows: E1 3 negative, 2 risks, 1 opportunity (page 75); E2 1 negative (page 88); E4 1 negative, 1 risk (page 90); E5 2/2/2 (page 93); S1 2/2/2 (pages 98-99); S2 3 negative, 1 risk (page 110); G1 1 negative, 1 risk (page 117). Each row carries value chain position and time horizon.

E3, S3 and S4 are not material. Anticipated financial effects under SBM-3 paragraph 48(e) are omitted under phase-in (page 60); current financial effects are "linked primarily to the climate" (page 63).

Process to identify and assess material IROs

Reference: page 69 (index page 69; also cited for IRO-1-E2, E4, E5 and G1, and for E1 at pages 69 and 77-78).

"Bonava's ESG Committee has been designated a steering group" for the DMA (page 69).

Impact materiality: in 2023 Bonava "established a Group-wide project team with subject matter experts and representatives from Bonava's business units", with dialogues involving "industry players, competitors, networks, auditors, banks and investors", then calibration with business unit representatives.

Financial materiality: risks and opportunities "were assessed by its Risk Committee, as well as parts of the Group-wide project team", led by the Group Head of ESG Control and Reporting with the Group Head of Risk and Compliance.

Review and validation: a second project-team review, calibration "after dialogue with industry peers", validation by the ESG Committee, presentation to Executive Management, then the Board, "which approved the materiality assessment in February 2025".

Stated assumptions: short term = current calendar year, medium term 2-5 years, long term over 5 years; scoring 1 to 5; threshold ">1.5"; impacts scored on severity and likelihood, risks and opportunities on likelihood and scale of financial effect; "Risk-reducing factors that are already part of our daily operations have not been considered" (page 69).

Disclosure requirements covered

Reference: pages 123-130 (index pages 123-130).

Bonava publishes a genuine two-part ESRS index. The "Content index IRO-2 / List of material disclosures" (pages 129-130) lists each DR the statement covers with its page range, under ESRS 2, E1, E2, E4, E5, S1, S2 and G1, including the ESRS 2 topical cross-cuts (SBM-3-E1 page 75, IRO-1-E2 page 69, SBM-2-S2 page 65) and Article 8 of the Taxonomy Regulation (pages 72-74). E4-1 is listed with "Phase-in" in place of a page reference.

The "List of datapoints originating from other EU legislation" (pages 123-128) adds a Material / not material column per datapoint. That is what pins several omissions down: E1-5 energy consumption and mix, E1-5 energy intensity and E2-4 E-PRTR pollutants are "Not material"; the E3, S3, S4 and G1-1 datapoints are "Not material"; the E1-9 datapoints are "Phase-in" (pages 124-128).

Absent from the content index: E1-5, E1-7, E1-8, E1-9, E2-4, E2-6, E4-1, E4-6, E5-6, S1-7, S1-11, S1-12, S1-13, S1-15, all of E3, S3 and S4, and G1-1, G1-2, G1-5, G1-6. "In previous years, the Sustainability Report was based on the Global Reporting Initiative (GRI)" (page 60).

Climate Transition Plan

Reference: pages 76-77 (index pages 76-77).

"Our new baseline and updated climate targets form the basis of the company's Group-wide three-step transition plan. To date, steps one and two have been adopted by the Executive Management Group" (page 76).

• Step One, completed 2025, "focused on developing insights and identifying opportunities for reducing embodied emissions", using one or two representative project types per business unit
• Step Two requires all business units, "by 2026 at the latest", to adopt a portfolio-wide emission reduction plan through 2030, revised annually
• Step Three is annual delivery against "annual emission targets (kgCO2eq per sqm) in completed projects up through 2030"

Step One findings per business unit: Germany found potential in "material substitutions, increased use of wood instead of concrete"; Sweden in lower-GWP concrete and steel plus HV100 fuel, "concentrated in life cycle stages A1-A5"; the Baltics in material-for-material exchanges, limited by "high cost sensitivity of the affordable housing segment" (page 76).

Funding: "Bonava has not made any significant or specific investments (CapEx) as a direct result of current measures" (pages 76, 79). Locked-in emissions are qualitative: cement and steel "have locked-in GHG emissions that cannot be fully eliminated unless the manufacturing industry becomes carbon-free". "Bonava is not exempt from the EU Paris-aligned Benchmarks" (page 77).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 climate chapter, where this content is disclosed in the FY2025 report (pages 77-78, 81; the index lists ESRS 2 IRO-1 for E1 at pages 69 and 77-78). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risk classification: the E1 risk table is split explicitly into transition risks (regulatory, market, technology and processes, reputation and brands) and physical risks (temperature, water, mass movements and ground stability, wind) (page 78).

Scenarios named: transition risk is assessed against "Bonava's interim climate targets for 2030, aligned with the SBTi 1.5 C pathway, as no net-zero target has yet been set", benchmarked against "the IEA's Net Zero by 2050 scenario"; physical risk uses IPCC RCP 4.5 ("global warming of up to 2.6 C") and RCP 8.5 ("global warming of 4.9 C"), "with a time horizon extending to the year 2100" (pages 77, 81).

Method and scope: physical risks are "assessed over the expected project lifetime of approximately 50 years" and "evaluated at the business-unit level for each new investment"; exposure uses "national climate maps and databases on natural hazards", vulnerability the planned investment's characteristics. Only "high-high" risks trigger adaptation measures. Timing: carried out in 2025, covering "all investments made in 2025" (pages 77, 81).

Resilience in relation to climate change

Back-filled from the E1 resilience section and ESRS 2 SBM-3 (pages 77-78, 81). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"The resilience analysis was carried out in 2025 by the ESG function at Group level as a structured qualitative assessment of Bonava's overall strategy and business model, based on the TCFD categories for transition risks and physical risks", drawing on governing documents, the internal control framework, the SBTi commitment, business-unit risk and market analyses, climate scenarios and stakeholder dialogues (page 77).

Result: "Bonava's strategy and business model are currently robust. Identified transition risks are assessed to be manageable within the existing business model and governance, while physical climate risks are primarily local and project-specific", supported by 1.5 C transition scenario analysis and site-level RCP 4.5 and RCP 8.5 assessments "which indicate no systemic material exposures or vulnerabilities" (page 77).

Capacity to adapt: "Climate-related competence is being developed within existing roles and processes. No need for specific retraining or asset divestment has been identified" (page 77).

Gaps: the analysis is qualitative, and "No threat descriptions for wind-related risks have been reported" (page 78). No quantified financial resilience is given, consistent with the SBM-3 paragraph 48(e) phase-in (page 60).

Policies related to climate change mitigation and adaptation

Reference: page 79 (index page 79), with policy descriptions on pages 119-122.

"We undertake to monitor and regularly adjust our climate targets, as well as implement climate-related measures to reduce the impact of Bonava's operations on global warming in line with the Paris Agreement. This is set out in Bonava's Sustainability Policy" (page 79), "Adopted by the Board of Directors on 6 December 2024" (page 119).

The Group-wide guidelines for environmental and climate action, "Adopted by SVP Brand & Culture on 5 May 2025", require all business units to (page 79):

• adopt measurable procedures enabling the science-based climate targets
• begin LCAs early and "establish local emission reduction plans on the basis of insights from the LCA process"
• "meet or exceed local and international standards and certifications for energy efficiency, such as Nordic Swan Ecolabel, RTS, BREEAM and others"
• integrate renewable energy into project design and "use renewable energy for construction sites and commissioned buildings"

For adaptation, "from 2025 onwards each business unit will also conduct a climate and vulnerability assessment for each new investment". The third-party risk strategy requires materials and services at sites to support Bonava's environmental ambitions, meaning "safe, low-carbon materials from reliable sources" (page 79).

Actions and resources in relation to climate change policies

Reference: pages 79-81 (index pages 79-81).

No key actions were defined for the year: "For 2025, no specific key actions have been defined, as the year has focused on generating insights into emission-reduction opportunities within each business unit. During 2026, each business unit will develop and adopt an emission-reduction plan aimed at 2030... In these plans, the quantitative contribution of the main drivers to achieving the targets will be defined" (page 79). No significant or specific CapEx was allocated.

Governance sits with the Environment and Climate Action Council, meeting monthly with all business units represented. Three drivers are described: resource efficiency and choice of materials, efficient buildings, and energy transition, where "Emissions in Scope 1 and 2 account for approximately 0.5 per cent of our total emissions" and "Nearly 90 per cent... come from fossil fuels, primarily from the German operation" (page 80).

Named 2025 activities (page 80): Germany converted its vehicle fleet to electric, with emissions "temporarily offset via TUV-certified projects (outside SBTi)", and required solar panels on new projects where technically feasible; Sweden cut the Arsta Park footprint "by 20 per cent" and halved the Villa Verde pilot's impact ("A1-A5: -40 per cent"). All business units completed climate risk and vulnerability assessments for 2025 investments (page 81).

Targets related to climate change mitigation and adaptation

Reference: pages 82-84 (index pages 82-84).

"Bonava's updated climate targets were set in 2025. The short-term climate targets are science-based and validated by the SBTi and their new guidance for the construction sector" (page 82). Base year 2024, replacing 2018, with the metric moved "from measuring emissions per housing unit to measuring emissions per square metre".

Targets for 2030 vs base year 2024 (page 82):

Plus: "Bonava undertakes not to install any new fossil fuel equipment... as of 1 July 2030."

Outcomes 2025 (page 83): Scope 1 and 2 1,246 tCO2eq from 1,495, -17%; embodied intensity 437 kgCO2eq/m2 from 475, -8%, against a 2030 target of 281; use-phase intensity 365 kgCO2eq/m2 from 350, +4%, against a 2030 target of 169.

Ambition basis (page 84): Scope 1 and 2 uses the SBTi Absolute Contraction Approach "based on IPCC AR6 1.5 C pathways and operationalised through the IEA Net Zero by 2050 (NZE) scenario"; embodied emissions the Sectoral Decarbonization Approach on "the IPCC AR6 C1 1.5 C scenario"; use-phase emissions a methodology "consistent with a well-below 2 C scenario". No net-zero target is set (page 77).

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 85-87 (index pages 85-87).

Totals, tCO2eq (page 85):

Largest Scope 3 categories: Cat. 2 capital goods (new buildings, LCA A1-A5) 89,494 (140,482), Cat. 11 use of sold products (LCA B6) 74,602 (103,386), Cat. 12 end-of-life (LCA C1-C4) 8,906 (14,461). "Scope 1 decreased 17 per cent", Scope 2 market-based 11%, and "Scope 3 decreased 31 per cent, primarily as a result of less construction activity and fewer completed projects" (page 85). Intensity 25 tCO2eq per SEK m on completed projects (34 in 2024); biogenic emissions 5,667 with capture reported as equal "due to lack of reliable data".

Method and limits: "Approximately 95 per cent of Bonava's Scope 3 emissions are calculated using project-specific LCA inputs and supplier activity data" (page 86); categories 9, 10, 14 and 15 are excluded with reasons (page 87). The company flags its own gap: "The current table does not fully reflect the Scope 3 disaggregation required under ESRS E1 and the GHG Protocol" (page 87). "Bonava's metrics are not validated by any external body" (page 85).

Policies related to pollution

Reference: page 88 (index page 88), with policy descriptions on pages 119-122.

"Bonava's Sustainability Policy states that all of Bonava's operations must avoid using substances of concern and substances of very high concern (harmful substances). Bonava's environmental and climate action guidelines also state that all business units must minimise the use of substances that are hazardous to human health" (page 88). The guidelines require every business unit to:

• "conduct regular assessments to identify how harmful substances are used in the operation"
• "maintain a list of the potential risks of harmful substances, and actively search out and evaluate safer alternatives"
• "replace harmful substances with safe alternatives where possible"
• implement "best practices for the safe management, storage and disposal of these substances"
• "report incidents pertaining to the use of hazardous substances via Bonava's case management system"

A stated gap: "Bonava's Group-wide guidelines for environmental and climate action do not yet contain an agreed list of covered pollutants or substances, since this approach was established after the guidelines entered force. This will be formalised in a future revision" (page 88). The third-party risk strategy adds annual spot checks on safe materials, and the Internal Control Policy includes controls on "the sourcing of safe materials" (page 88).

Actions and resources related to pollution

Reference: pages 88-89 (index pages 88-89).

Work runs through "Bonava's Group-wide environmental governance forum - Bonava's Environment and Climate Action Council", with no significant CapEx allocated. Because "We have not yet adopted a strategic target for pollutants... these actions are thus being carried out within the timeframe of current legislation and the project plans we have in place for complying with this legislation" (page 88).

Forward action: "As of 2026, Bonava will be introducing a two-step model for management and reporting of substances of concern and substances of very high concern. Legally banned substances must be controlled through sourcing procedures and contractual requirements confirming their absence. Moreover, a risk-based assessment must be applied to groups of high-risk materials in order to identify and phase out substances of very high concern" (page 88).

Named 2025 activities (pages 88-89): Germany separates hazardous waste "(e.g. asbestos separately)"; Sweden uses Nordic Ecolabelling controls and "handover of complete lists of materials for verification"; Finland uses "M1-rated safe materials... where possible"; the Baltics run "Routine daily checks of material deliveries".

Targets related to pollution

Reference: page 89 (index page 89).

"Bonava currently does not have a target for environmental pollution, since the primary focus is compliance" (page 89). Consistent with MDR-T, the company describes how effectiveness is tracked in the absence of a target:

"We monitor our policy commitments using a structured framework for internal control that is updated annually on the basis of our material environmental and climate priorities. Every year, the business units assess the effectiveness of their internal controls, including how well environmental criteria - such as the management of harmful substances - are integrated into purchasing and supplier partnerships. Bonava's Group function reviews these assessments and provides feedback and pertinent suggestions for improvement. This recurring, evidence-based process ensures that we deliver on our commitments" (page 89).

A second monitoring route is the third-party risk strategy, which "provides a structured and transparent framework for managing sustainability-related risks in external partnerships. Each business unit is responsible for developing and implementing its own action plan for applying the minimum requirements defined in the strategy, which pertain, for example, to the procurement of safe and sustainable materials. The effectiveness of these action plans is monitored annually through a review by the Group Head of Risk and Compliance" (page 89).

Substances of concern and substances of very high concern

Reference: page 89 (index page 89).

Bonava reports no amounts. "Bonava does not currently have any specific metrics related to substances of concern" (page 89). Against ESRS E2 paragraph 34, neither limb is answered: no totals generated, used or procured, and no totals leaving facilities as emissions, as products or as part of products, split by hazard class. Bonava's stated reason: "We do not believe that conducting a detailed, mass-based quantification will be feasible, considering the nature of construction operations and the scope of Bonava's value chain".

Method 1 covers EU-banned substances, citing Reg. (EU) 2019/1021 (POPs), Reg. (EU) 2017/852 (mercury), Reg. (EC) 1005/2009, Directive 2011/65/EU (RoHS) and REACH Annex XVII. "No mass-based quantities will be reported for these categories, as they are legally banned and therefore assumed to be zero by default."

Method 2 covers REACH Article 57 candidate-list substances, "for example, phthalates, bisphenols, flame retardants and PFAS". Tier 1 suppliers "will be asked to declare annually if harmful substances are present at levels above 0.1 per cent w/w".

Level 1 high-risk groups are named (PVC, polyurethane foam, polystyrene; sealants, adhesives, paints; floor coatings; cables; insulation foam; membranes); Level 2 inert materials "will be exempted from detailed assessments". The material impact sits downstream (page 88).

Policies related to biodiversity and ecosystems

Reference: page 90 (index page 90), with policy descriptions on pages 119-122.

"Bonava's Sustainability Policy states that we are to strive for sustainable use of land by selecting development areas through a structured due diligence process that supports the EU Taxonomy for sustainable finance. This approach includes prioritising the use of land that encompasses protection of and/or compensation for threatened ecological values" (page 90).

The guidelines for environmental and climate action require all business units to (page 90):

• "prioritise the use of previously exploited or less ecologically sensitive areas (brownfield sites), when reasonable from an economic and development perspective"
• apply land-use strategies with conservation principles: "increasing the proportion of green spaces where possible; construct green roofs and green infrastructure; re-plant trees that needed to be removed during construction; integrate solutions for stormwater management; and use only certified wood"
• "ensure processes to identify species at risk of extinction within project areas"
• "develop and implement species-appropriate conservation plans in accordance with local requirements"

"Our Group-wide Internal Control Policy and our third-party risk strategy state that the need for nature protection must be assessed as a basic requirement of the due diligence process" (page 90).

Actions and resources related to biodiversity and ecosystems

Reference: pages 90-91 (index pages 90-91).

Work runs through the Environment and Climate Action Council; no significant or specific CapEx was allocated, and "Where strategic targets are absent, measures are taken within the time frame of applicable legislation and project plans" (page 90).

Sustainable use of land: "When we acquire land, we assess the risk of ecological impact on the location we have chosen. We investigate whether the project is located in or near a biodiversity hotspot and whether there is a risk of threat to a species." Named measures include "establishing breeding sites, relocating species to neighbouring suitable habitats, gathering dead wood to create habitats", plus soil remediation where needed (page 90).

Named 2025 activities (page 91): Germany works to the Federal Nature Conservation Act (BNatSchG), BArtSchV, BauGB and UVPG, with native insect-friendly planting and "installing bird and bat roosts". "Bonava Sweden now conducts a nature inventory ahead of each project"; in the Fjarilshusen district "over 120 plant species have been selected with a focus on pollinators". In Finland land is acquired "where nature and biodiversity issues have largely already been addressed in the planning process". In the Baltics "a nature inventory is conducted in every project prior to planning", producing the integration of an old oak at Forest Gate in Vilnius.

Targets related to biodiversity and ecosystems

Reference: page 91 (index page 91).

"Bonava currently does not have a target for environmental biodiversity, since our primary focus in this area is compliance" (page 91). In place of a target, the company sets out how it tracks effectiveness, in the MDR-T pattern:

"We monitor our policy commitments using a structured framework for internal control that is updated annually on the basis of our material environmental and climate priorities. Every year, the business units assess the effectiveness of their internal controls, including how well environmental criteria - such as the management of harmful substances - are integrated into purchasing and supplier partnerships. The Group function reviews these assessments and provides feedback and suggestions for improvement. This recurring, evidence-based process ensures that we deliver on our commitments" (page 91).

Note that the text as printed refers to "the management of harmful substances" rather than to a biodiversity criterion, repeating the wording used for the E2 target disclosure on page 89. The monitoring that is specific to biodiversity sits in the E4-5 metrics instead, which track land use, biodiversity hotspots and species protection "In addition to compliance" (page 91).

Impact metrics related to biodiversity and ecosystems change

Reference: pages 91-92 (index pages 91-92).

Metrics "focus on land use, biodiversity hotspots and species protection. Bonava's metrics are not validated by any external body" (page 91).

"2 of 21 projects for 2025 - corresponding to an estimated plot size of 40,716.61 m2 (approximately 4 hectares) - were located in or near a biodiversity hotspot", classified as drinking-water protection areas and nature conservation areas (page 92).

"There were 14 protected species and species groups affected... According to the IUCN Red List, all of the species identified were classified as Least Concern. None of the species are classified as threatened at the global level." Named species include house sparrow (Passer domesticus), common pipistrelle (Pipistrellus pipistrellus) and pool frog (Pelophylax lessonae); "All species and species groups have been found in projects in Germany". Compensation included bat roosts, bird boxes and "replacement planting of approximately 30 trees" (page 92).

Policies related to resource use and circular economy

Reference: pages 93-94 (index pages 93-94), with policy descriptions on pages 119-122.

"Bonava's Sustainability Policy states that, in order to reduce emissions and the need for raw materials, we will aim for a circular production model through employing resource-efficient design and production. Our ambitions in this regard should include managing waste efficiently, using recycled or reused materials where possible, and choosing materials with the smallest possible climate footprint" (page 93).

The guidelines for environmental and climate action require all business units to (pages 93-94):

• "conduct LCAs in order to understand the environmental impact of resources used"
• "optimise resource use in key building materials such as cement-based products (concrete, large masonry blocks, plaster), steel and wood"
• "identify and prioritise the use of materials that are sustainable, repairable and recyclable"
• "preferably use materials from sustainably managed resources (e.g. FSC-certified timber) where possible"
• "design buildings for easy demolition, allowing end-of-life recycling of materials"
• "implement recycling programmes within Bonava's operations, and downstream in the value chain"

The third-party risk strategy requires "safe, low-carbon materials from reliable sources", and the Internal Control Policy includes guidelines on procurement of low-carbon materials (page 94).

Actions and resources related to resource use and circular economy

Reference: page 94 (index page 94).

Work runs through the Environment and Climate Action Council; no significant or specific CapEx was allocated, and "The time frame for these actions is aligned with our business unit-specific objectives" (page 94).

Circular production model: "Each business unit ensures that construction sites have a functioning waste management system for sorting, hazardous waste, recycling, reporting and compliance... Responsibility for sorting waste is included in onboarding and agreements with subcontractors."

"Since 2024, we have adopted the 'cascade principle' for wood use", with high-value applications (construction and furniture) and medium-value applications ("plywood and oriented strand board"). Bonava "follows the EU waste hierarchy under the Waste Framework Directive": prevention, re-use, materials recycling, other recycling, disposal (page 94).

Named 2025 activities (page 94): Germany tracks hazardous waste in ZEDAL, identified "Shortcomings in tracking non-hazardous waste" and is introducing "a new monitoring system with clear site responsibility" plus "at least ten annual internal spot checks"; Sweden integrated sorting requirements and waste reduction targets into sourcing templates; Finland developed site-specific plans with Remeo Oy; the Baltics re-use "Waste from facade insulation... as filler in floor structures".

Targets related to resource use and circular economy

Reference: page 95 (index page 95).

"As part of our overall sustainability strategy, we are improving our methods for calculating waste data and evaluating the feasibility of setting a Group-wide target for circular use of materials. We are currently monitoring developments in this area through business unit-specific targets in Finland and Sweden" (page 95).

"Currently, no waste targets are established for Germany and the Baltics" (page 95). The Swedish waste intensity target was missed: it "was achieved in one of the completed projects, while the other exceeded the limit because the requirement was introduced after construction had started". The low-carbon concrete and recycled steel targets could not be evaluated, the Nordic Ecolabel version 4 requirements having come in after construction began. "The target period is 'ongoing'."

Resource inflows

Reference: page 96 (index page 96).

"We report materials use at the project level for completed projects during the reporting year. The main resources comprise building materials such as concrete, cement-based products, steel and wood-based materials" (page 96).

Materials used, 2025 (page 96):

Secondary reused components are 0.0 for every material. 2024 comparatives include cast-in-place concrete 132,363.0 m2 and steel 12,850.3 tonnes at 18.1% recycled.

"Fewer projects were completed in 2025 than in 2024 and the project portfolio was changed" (page 96). Limitation: "Data is based primarily on project-specific LCAs. In the absence of LCA data, material use is estimated on the basis of typical projects and square metres completed... These metrics are not validated by any external body" (page 96).

Resource outflows

Reference: page 97 (index page 97).

Bonava's E5-5 disclosure consists of waste by category and treatment route. No outflow data on products, materials or recyclable content of products is given, consistent with a developer that transfers completed homes rather than placing products on a market.

Waste, 2025, metric tons (page 97):

"A significant share of Bonava's waste in 2025 was processed through recycling, with 61.3 per cent managed through open- and closed-loop recycling. The remaining 38.7 per cent was managed through other forms of recycling and recovery measures... including preparation for re-use, as well as incineration - the latter with 100 per cent energy recovery" (page 97).

Limitation: German non-hazardous construction waste "is extrapolated on the basis of totals from other business units", and "These metrics are not validated by any external body" (page 97).

Waste

Reference: page 97, with construction-phase waste also feeding Scope 3 Category 2 (pages 86-87) and waste targets on page 95.

Total waste generated in 2025 was 93,714.1 tonnes, split 83,505.6 tonnes non-hazardous (24,047.8 construction, 59,457.8 demolition) and 10,208.5 tonnes hazardous (1.4 construction, 10,207.1 demolition) (page 97).

Diverted from disposal: open-loop recycling 31,616.1 t, closed-loop recycling 25,874.3 t, preparation for reuse 15,387.6 t. Directed to disposal: landfill 18,465.9 t, incineration 2,370.2 t. Hazardous demolition waste dominates landfill at 9,436.4 t, and 61.3% of total waste went to open- and closed-loop recycling (page 97).

Composition (page 97): "This waste contains a mixture of non-metallic minerals (such as concrete, bricks, glass, gypsum, aggregates and soil), metals... plastics... and bio-based materials (wood, paper and cardboard) as well as critical and hazardous substances such as asbestos (if necessary), mineral oil, batteries and electrical waste."

Method: weight-based data per completed project, primarily from project LCAs, with supplier reports in Finland, Sweden and the Baltics. "In Germany, where such data is not available, waste quantities are estimated using data from other business units" (page 97). Against business-unit targets, Finland reached 85% recovery (target 75%) and Sweden 91% sorting (target 85%), but 45 kg/m2 against a 30 kg/m2 ceiling (page 95).

Policies related to own workforce

Reference: page 99 (index page 99), with policy descriptions on pages 119-122.

"Bonava has a long-term vision for health and safety in which everyone should return home safe and sound, every day." The Sustainability Policy's stated aims include "being a diverse and inclusive workplace that reflects society and its population", "creating a healthy and safe workplace for everyone" and "achieving an empowering employee experience where our people have a high sense of well-being, work-life balance and possibility for self-leadership and development" (page 99).

The Code of Conduct states that "we do not accept discrimination, harassment or bullying of any kind" and that "we will ensure equal opportunities in recruitment and other development opportunities, irrespective of gender, sexual orientation, ethnic background, religion, disability or age".

"Through the Code of Conduct and Sustainability Policy, we commit to operating in a way that fulfils the core principles of human rights, labour, environmental and anti-corruption in the UN Global Compact, the OECD Guidelines for Multinational Enterprises, and the ILO Declaration". A Group-wide HR Procedure and Health and Safety Procedure add specific commitments.

Policy still in development: Group-wide guidelines covering "diversity, equality and inclusion, recruitment, on- and off-boarding, employee feedback, and learning and development" "are expected to enter force in 2026" (page 99).

Processes for engaging with own workforce and workers' representatives

Reference: page 100 (index page 100; also SBM-2-S1, page 65).

Two primary channels (page 100):

• Direct dialogue through the performance and development process and "Bonava's annual employee survey, which is supplemented by pulse surveys and targeted surveys in specific areas", giving "glimpses into the well-being and experiences of employees related to stress, safety, leadership, development, inclusion, gender equality and discrimination". Cases via the Group-wide case management system or SpeakUp "indirectly capture the perspective of employees".
• Trade union collaboration and representation: "Dialogue with trade unions and/or employee representatives is conducted regularly at the national and local levels, and serves as a central tool for identifying and managing impacts on the work environment and rights". "Occupational Health and Safety Group meetings, or the equivalent, are held regularly in all business units, with employer and employee representatives both in attendance."

"The overall responsibility... lies with Bonava's HR function and the Health and Safety function."

Effectiveness: "We routinely assess processes and procedures for employee dialogue - for example, by tracking the response rate to Bonava's employee surveys... We also evaluate the perceived confidence in Bonava's SpeakUp system... and whether proposals from employees have led to actions" (page 100).

Processes to remediate negative impacts and channels to raise concerns

Reference: page 100 (index page 100).

Channels listed are "Anonymous reports via SpeakUp", a "Reporting system for health and safety", "Dialogue with immediate supervisor, ethics advisors and HR", "Cooperation with trade unions and employee representation" and "Employee surveys" (page 100).

"Cases that come in via SpeakUp are initially assessed by the Head of Risk and Compliance, who in turn appoints a responsible investigator as needed. Our SpeakUp channel is operated by an independent provider and permits anonymous reporting. All cases are handled confidentially."

"Actions for an incoming case may include disciplinary measures, adjustments to the work environment, support for the parties involved, and offers of occupational health care or psychological support. Bonava does not have a general compensation program but applies assessments on a case-by-case basis." "Cases are monitored locally via HR and line managers... in the event of recurring patterns and/or feedback, HR can monitor more frequently."

Awareness: intranet, town hall meetings, managers' meetings and Awareness Weeks are used to remind staff; "As part of Bonava's onboarding, all new employees undergo mandatory online training in the Code of Conduct, guidelines against discrimination and harassment and the use of SpeakUp" (page 100).

Taking action on material impacts on own workforce

Reference: pages 100-102 (index pages 100-102).

Actions rest on "Bonava's employee strategy and Everyone Plans, with a focus on creating safe and healthy workplaces, an inclusive culture and strong leadership centred on learning"; from autumn 2025 a sharper "Employer of Choice" focus was decided, "where activity will intensify in 2026". No significant CapEx was allocated (page 100).

Working conditions: "All of Bonava's employees are covered by robust work environment protections in the form of legislation, local requirements and regulations as well as collective bargaining agreements that include the right to sick pay, parental leave and vacation". "Everyone Plans are monitored on a monthly basis by each BU President" (pages 100-101).

2025 activities (pages 101-102): external partners provided "support from therapists, health coaches, physical health challenges and health screenings"; Finland was again awarded the Mental Health Friendly Workplace badge. The Group-wide Committed to Growth leadership programme "comprises 60 hours of facilitated workshops as well as an individual leadership assessment", with "Around 50 leaders" in the 2025-2026 cohort; Upskill and Learning on the Job were launched.

Inclusion and pay (page 102): "We conduct regular salary surveys to determine potential pay gaps", and ahead of the EU pay transparency directive Bonava "began developing a new Pay Progression Policy".

Targets related to own workforce

Reference: pages 102-103 (index pages 102-103).

Targets are "directly linked to our policy commitments for a healthy, inclusive and safe workplace with good opportunities for learning and development", set using "insights from such measures as employee surveys, exit interviews, feedback received by HR and dialogue with trade union representatives" (page 102).

Engagement Index (page 102): "Employee engagement must be in line with the top 10 per cent of companies, according to Brilliant Future's high-performance benchmark - which in 2025 was 89." Outcome 86 (2024: 83) against a target level of 89 (2024: 81). "Although the target of 89 was not achieved, the result is deemed to be strong and in line with internal expectations." The benchmark draws on "approximately 800,000 responses from over 350 organisations".

Everyone Plan fulfilment (page 103): "The target is to achieve at least 90 per cent of these actions annually." Group outcome 97% in 2025, "surpassing both the Group's target and the 2024 outcome" (page 62), Germany 93% (2024: 87%).

Bonava cross-refers the severe incidents target: it "is related to Bonava's own workforce since the objective includes severe incidents for both Bonava's own workforce and workers in the value chain" (page 102). Results are shared via the intranet and quarterly and annual reporting, with HR reporting "routinely" to Executive Management.

Characteristics of the undertaking's employees

Reference: pages 104-105 (index pages 104-105).

Headcount at 31 December 2025 (page 104): 909 permanent and 39 fixed-term, 95% salaried and 5% skilled workers, 41% women and 59% men.

2024: 883 permanent, 42 fixed-term. "The gender distribution is between men and women, since no other gender definitions are registered in our systems." The diversity table separately totals 948 employees for 2025 (page 106).

Turnover (page 105): 121 leavers, a rolling 12-month rate of 12.7%, highest in Latvia at 22.6% and lowest in Germany at 8.5%. "Starting in 2025, employee turnover is calculated by dividing the number of employees who left Bonava by the average number of employees over the last 12 months", a change from the prior year-end denominator, so "we will not report any data for 2024". "The number of employees who left Bonava was largely driven by reorganisations." Bonava's workforce "comprise[s] primarily salaried employees, as well as a few skilled workers" (page 98).

Collective bargaining coverage and social dialogue

Reference: page 105 (index page 105).

"The majority of Bonava's salaried employees and skilled workers are covered by collective bargaining agreements. In Germany and Sweden, employees are largely covered... with exceptions for students in Germany and the CEO in Sweden. Finland and Latvia have lower or no coverage... In Finland, upper-level salaried employees are not covered by collective bargaining agreements. As regards the number of employees who are represented by workers' representatives, all countries have close to 100 per cent representation. This shows that there is worker representation even in countries where collective bargaining agreements are absent or limited" (page 105).

Method: "Starting in 2025, collective bargaining agreement coverage has been reported as a range. In previous years, an exact value was reported." Definitions of representative vary: the German Works Council, Nordic trade union representatives, and in Latvia "the business unit's health and safety representative has been appointed a workers' representative". The representation indicator was new in 2025, so "no data is reported for 2024" (page 105).

Diversity metrics

Reference: page 106 (index page 106).

Gender distribution, 2025 (page 106):

2024 comparatives: Board 2 women and 5 men (29%/71%), Executive Management Group 3 women and 4 men (43%/57%), other employees 374 women and 544 men (41%/59%).

Age distribution (page 106): under 30 years 107 employees (11%), 30 to 50 years 531 (56%), over 50 years 310 (33%), total 948 (2024: 111, 527, 287, total 925).

"During the year, changes in the composition of the Board of Directors and Executive Management led to an increase in the proportion of women on the Board and a decrease in the proportion of women in the Executive Management Group. The gender breakdown for the remainder of Bonava's employees is the same as for 2024. The age structure for 2025 is broadly in line with that of 2024, with a clear majority of staff still in the 30-50 age range" (page 106).

Method: "Bonava's diversity metrics encompass gender and age distribution. This information is collected into Bonava's system for employee data and is based on the number of employees at 31 December 2025" (page 106). No metric on the proportion of top management or on other diversity dimensions is reported; persons with disabilities fall under the S1-12 phase-in (page 104).

Adequate wages

Reference: page 106 (index page 106).

Bonava reports adequacy as "Fulfilled" for every business unit: Germany, Sweden (including the Group function), Finland and the Baltics (page 106).

"All employees in the Group have salaries that meet the criteria for adequate wages under ESRS S1-10. The criteria are met either by national minimum wages or collective bargaining agreements" (page 106).

Benchmarks used (page 106):

• Germany: Eurostat minimum wage statistics
• Sweden: "There is no statutory minimum wage. Minimum wage is based on current collective bargaining agreements"
• Finland: "There is no statutory minimum wage. Minimum wage is based on current collective bargaining agreements"
• Baltics: Eurostat minimum wage statistics

"We report on adequate wages on the basis of basic salary data recorded at 31 December 2025. Basic salaries are supplemented by other remuneration - if any - such as allowances, bonuses, benefits and overtime pay, in order to assess the total remuneration of an employee. The wage data is gathered from wage systems into Bonava's system for employee data. Apprentices are excluded from the calculation" (page 106).

No prior-year comparison is available: "We have not previously reported on wage adequacy, which is why data from previous years is absent" (page 106). The disclosure is a qualitative fulfilment statement rather than a percentage of employees paid below an adequate wage benchmark.

Health and safety metrics

Reference: page 107 (index page 107), with self-defined office metrics on page 108.

Management system: "Bonava's minimum requirements and management system was developed in accordance with ISO 45001. Operations in Germany are ISO 45001 certified. All employees (100 per cent) are covered by Bonava's operational management system for health and safety. One possible exception is employees in investor projects, where the investor's health and safety requirements may take priority" (page 107).

Group totals (page 107):

A discrepancy to check: the narrative states "In 2025, there were ten reported cases of work-related ill health and six work-related injuries", while the table totals three injuries for 2025 (page 107).

"The most frequent causes of injuries are same-level falls (stumbling, slipping), contact with sharp objects and injuries caused by hand-held tools. Cases of work-related ill health included symptoms of burnout and cases linked to stress." Ill health "is only reported for Sweden and the Group function"; Germany and Finland cannot record causes of sick leave "due to confidentiality and the GDPR" (page 107).

Compensation metrics (pay gap and total compensation)

Reference: page 109 (index page 109, titled "Remuneration metrics (pay gap and total remuneration)").

"In summary, the analysis shows that the highest paid employee earns 13.5 times more than the median value of total remuneration for all employees at Bonava. The gender pay gap in the Group is that average pay for men is 10.9 per cent higher than for women" (page 109).

Method: the figures include "contractual basic salary and, where applicable, allowances, bonuses paid, tax-free and taxable benefits, benefits in kind and overtime payments", from employee data at 31 December 2025 plus local payroll information. "To ensure comparability, salaries for part-time employees were adjusted upward to full-time salaries. For employees on parental leave, the basic salary is calculated as if the person were actively employed. Apprentices and line consultants are excluded from the calculation, as are the CEOs of Bonava Group and Bonava Sverige AB."

No comparatives: "We have adjusted the calculation method for 2025. Previously, we based the information on basic salary alone, which means that the data for 2024 is not comparable" (page 109). Excluding the two CEOs while reporting a highest-paid-to-median ratio is a scope choice a reader should weigh.

Incidents, complaints and severe human rights impacts

Reference: page 109 (index page 109).

Group figures, 2025, all nil (page 109):

"No incidents or confirmed complaints were reported in the 2025 financial year. A small number of anonymous and unspecified complaints were received, which could not be investigated due to limited information" (page 109). The qualifier matters: the nil return covers confirmed cases, and some anonymous reports could not be assessed.

Scope: "Incidents and complaints encompass discrimination and/or harassment on the basis of gender, transgender identity or expression, ethnic affiliation, religion or other statement of faith, disability, sexual orientation and/or age. The data is based on information received by Bonava's local or central HR functions or via SpeakUp... Information relating to severe cases of human rights violations pertain to serious human rights incidents linked to the workforce - for example, forced labour, child labour and/or human trafficking" (page 109).

The corresponding value chain position sits under S2, where discrimination and harassment in the value chain is reported as an actual negative impact (page 110).

Policies related to value chain workers

Reference: pages 110-111 (index pages 110-111), with policy descriptions on pages 119-122.

"Our Sustainability Policy maintains that we must aim to create a healthy and safe workplace for everyone, everywhere, every day by integrating health and safety in all aspects of our operation" (page 110).

"All of the suppliers in Bonava's housing projects must fulfil Bonava's Group-wide supplier requirements, which apply to both direct suppliers and sub-suppliers. These requirements are based on the UN Global Compact and include respect for human rights, good working conditions, the environment and anti-corruption. This includes prohibitions on child and forced labour, slavery and human trafficking as well as requirements for non-discrimination, freedom of association and collective bargaining, and fair wages. Suppliers must also offer a safe and healthy working environment... Each business unit is responsible for monitoring compliance" (page 110).

The Group-wide Health and Safety Procedure "applies to and is implemented by the entire organisation and external partners via contracts", covering "Systematic, proactive and preventive initiatives to eliminate the risk of serious harm" and "A learning culture of evaluating incidents, training, exchange of experiences and continual improvement" (page 111). Bonava applied phase-in to S2 while still reporting "the majority of the requirements" (page 60).

Processes for engaging with value chain workers

Reference: page 111 (index page 111; also SBM-2-S2, page 65).

"We conduct systematic work and engage in ongoing dialogue with our suppliers and contractors at our construction sites" through three routes (page 111):

• "In procurements, we set clear requirements for ensuring the right expertise and abilities."
• "In our supplier requirements, we set requirements for human rights, labour rights, environmental protection and anti-corruption."
• "In conjunction with project implementation, we work on introducing, coordinating, monitoring and evaluating our contractors through coordination meetings, safety inspections and other types of inspections where we are in direct dialogue with workers in the value chain as well as with legitimately appointed representatives."

Effectiveness: "To assess the contact with workers at construction sites, we monitor monthly reporting from subcontractors in Bonava's health and safety management systems. We continually work to ensure and improve the accessibility of reporting... in order to understand the perspectives of those workers who may be at particular risk of impact and/or who are marginalised" (page 111).

Engagement is mediated through contractors and site processes rather than workers' own representative organisations upstream, matching the stated limits: "our opportunities for exerting influence and control upstream are limited" (page 113).

Processes to remediate negative impacts and channels for value chain workers

Reference: page 111 (index page 111).

"Bonava has a structured procedure for assessing which actions are necessary and appropriate when an actual or potential negative impact is identified. An accident or other negative impacts on workers in the value chain is handled on a case-by-case basis, and Bonava's Procedure Reports of Misconduct serves as guidance if a case is brought to our attention" (page 111).

"Workers located at Bonava construction sites can always contact Bonava's site manager to report a problem. Bonava also has SpeakUp, an anonymised whistleblowing function, available to all workers in the value chain. Bonava's supplier requirements include information on the whistleblowing function as an annex to regular supplier contracts" (page 111), with contract coverage quantified at 1,906 contracts and 98% (page 116).

"Actions for an incoming case may include disciplinary measures or adjustments to the work environment. Bonava does not have a general compensation program but applies assessments on a case-by-case basis. Cases are monitored locally via HR and line managers."

A stated gap: "We currently do not have a structured procedure for assessing the extent to which workers in the value chain trust the reporting channels, but it is our understanding that the channels are being used as intended" (page 111).

Taking action on material impacts on value chain workers

Reference: pages 111-113 (index pages 111-113).

Actions "are driven by Bonava's internal strategies and legal requirements, as well as requirements from trade union and industry organisations and banks. One example is the bank initiative in Sweden." No significant or specific CapEx was allocated (page 111).

Everyone Plans are "our key working tool for creating safe and healthy workplaces", built on Leadership, Proactivity and Learning, owned by Business Unit Presidents. Named 2025 activities: Germany built "a structured leadership system for health and safety"; Sweden introduced "management-led audits"; Finland added Safety Moments; the Baltics introduced "a structured maturity model (Hudson model)" (pages 111-112). A Time Out tool lets anyone pause work (page 112).

Third-party risk strategy minimum requirements (page 112): humane working conditions, humane materials production, minimum wages, legal employment ("All work is recorded, taxed and insured"), competence, risk assessment and correct equipment. In 2025 Germany, Sweden and Finland "developed implementation plans... on the basis of gap analyses", the Baltics plan "under development" (page 113).

Stated limits: "our opportunities for exerting influence and control upstream are limited", so the emphasis is "on respecting and promoting human rights at Bonava's construction sites" (page 113).

Targets related to value chain workers

Reference: page 114 (index page 114).

"Bonava's strategic goal for workers in the value chain is to reduce the frequency of severe incidents" (page 114).

Target: "Halving the frequency of severe incidents, including both injuries and near misses through 2026. The base year is 2022 and the target is a frequency lower than 7.1."

"23 severe incidents - of which 11 injuries and 12 near misses... The increase... is linked primarily to a greater number of reported near misses in the Baltics... due to a strengthened culture of reporting and more proactive risk identification... rather than an actual increase in near misses and accidents having occurred." Group frequency stays inside the <7.1 target but rose from 4.3 to 5.7.

Method: severe incidents cover "injuries leading to four or more days of sick leave and/or link to actual or potential risk with consequence (4 or 5) and/or risk score of over 10", per million hours worked, applying to "own workforce, contractors and subcontractors" via the BIA system (page 114). Supporting self-defined metrics: 3,306 hazards and 2,882 audits and inspections (page 115).

Prevention and detection of corruption and bribery

Reference: pages 117-118 (index pages 117-118).

"[W]e have introduced an integrity initiative: Our Foundation, which includes a firm stance against... all forms of corruption and bribery... We have also appointed ethics advisors in all our markets" (page 117).

Governing documents (page 118): the Code of Conduct, permitting gifts and entertainment "only if they do not create conflicts of interest"; supplier requirements with audit rights and possible "suspending or terminating the cooperation"; the third-party risk strategy, with "minimum safeguards related to auditing corruption risks, control mechanisms in land acquisition, anti-corruption training, and checks of purchasing decisions, card payments... sponsorships and donations".

Detection: reports go to line managers, local ethics advisors or SpeakUp. "[O]ur business legal teams... have initiated annual compliance audits", with results "evaluated by Executive Management". "An incoming case is never investigated by any parties that are affected by or involved in the case", and reporters are protected from retaliation.

Training: "By the end of the year, 84 (94) per cent of all employees had completed Bonava's previous online training and 64 per cent had completed the new course", reported quarterly to the Board. "No separate or individually targeted training courses in anti-corruption and bribery were conducted for the Board of Directors."

Targets related to business conduct

Back-filled from the business conduct chapter and the strategic overview, where targets are addressed as part of the MDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

Bonava sets no business conduct target. In the strategic overview table, the G1 strategic target for corruption and bribery reads "No target", with outcome "n/a" (page 62). The G1 chapter carries no targets section and no MDR-T heading, unlike E1-4, E2-3, E4-4, S1-5 and S2-5.

Consistent with MDR-T's other limb, effectiveness is tracked instead:

• Annual compliance audits, newly introduced: "Bonava is introducing annual compliance audits to enhance control over third-party risks, improve our capacity for detecting irregularities and ensure that our anti-corruption checks are effective... with the first audit cycle focusing on the procurement process" (page 62). Results are "evaluated by Executive Management" (page 118).
• Training completion: 84% (94%) on the previous ethics course and 64% on the new one, "reported quarterly to the Board" (page 118).
• Incident tracking via SpeakUp and the misconduct procedure, compiled for the Board, with a nil G1-4 return for 2025 (page 118).

No measurable outcome-oriented target, baseline or target year is disclosed.

Incidents of corruption or bribery

Reference: page 118 (index page 118, listed as "G1-4 - Confirmed incidents of corruption or bribery").

Nil return for 2025: "Bonava did not receive any convictions or pay any penalty amounts for violation of anti-corruption and anti-bribery laws in 2025" (page 118).

The two G1-4 datapoints derived from other EU legislation are both marked "Material" in the datapoints list, with page 118 as the reference: "ESRS G1-4 - Fines for violation of anti-corruption and anti-bribery laws paragraph 24 (a)" and "ESRS G1-4 - Standards of anti-corruption and anti-bribery paragraph 24 (b)" (page 128).

The disclosure is limited to convictions and fines. No count of confirmed incidents, of incidents involving dismissal or disciplinary action against own workers, or of contracts with business partners terminated or not renewed because of corruption-related violations is reported, and no breakdown of public legal cases is given. The surrounding G1-3 text describes the investigation route that would produce such figures, including outcomes running "from amended internal routines to formal warnings, termination of employment and/or a police report", and states that investigation results are "compiled for the Board" (page 118). For own workforce, the separate S1-17 table also reports zero incidents of discrimination, zero complaints and zero serious human rights cases, with amounts of SEK 0 (page 109).