Boozt

The role of the administrative, management and supervisory bodies

Reference: page 36.

Boozt has a two-tier governance system: the supervisory and administrative body is the Board of Directors, and the management body is the Group Management. Sustainability responsibility is shared across the Board rather than held by a single member, though the Chair of the Board has final responsibility for the effectiveness of the Board's oversight of sustainability issues.

On management level, the CFO, working with the CEO, holds the highest level of responsibility for climate-related and sustainability matters, and the CHRO is responsible for diversity and inclusion. No employee representative sits on the Board. Board member expertise, independence and diversity are detailed in the corporate governance report (pages 92-93).

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

Reference: page 37.

The Board of Directors and the Audit Committee exercise oversight of material sustainability matters through a reporting framework in which the Head of Sustainability and ESG provides formal updates at least twice per year. These briefings cover the identification and assessment of material impacts, risks and opportunities, and the implementation of due diligence processes, including the results and effectiveness of policies, actions, metrics and targets.

In 2025, the Board's sustainability competencies were evaluated through an annual internal assessment mapping professional experience and education against the topics identified in the 2025 Double Materiality Assessment.

Integration of sustainability-related performance in incentive schemes

Reference: page 37.

Boozt implemented short-term incentives (STI) for Group Management directly tied to environmental and social targets aligned with the Care-For strategy, including increasing the share of recycled waste at the Fulfilment Centre and maintaining a high eNPS employee engagement score. These targets were developed with the Head of Sustainability and ESG and Group Management and approved by the Board.

The proportion of short-term variable remuneration (STIP) for Group Management linked to sustainability-related targets for 2025 was 9%. No incentive schemes tied to environmental or social targets are in place for the Board of Directors.

Statement on due diligence

Reference: page 75.

Boozt presents a due diligence table mapping the core elements of due diligence to the sections of the sustainability statement that address them: (a) embedding due diligence in governance, strategy and business model points to GOV-2, GOV-3, SBM-1 and the SBM-3 sections per topic; (b) engaging with affected stakeholders points to SBM-2, IRO-1, S1-1/S1-2 and S4-1/S4-2; (c) identifying and assessing adverse impacts points to IRO-1 and S1-3/S4-3; (d) taking action points to S1-4, S4-4 and G1-3; and (e) tracking effectiveness and communicating points to S1-4/S1-5, S4-4/S4-5 and G1-4.

Risk management and internal controls over sustainability reporting

Reference: page 37.

Boozt conducted a risk assessment of its ESRS reporting areas, looking at scale of impact and risk of misstatement, and found the most significant reporting risks in areas relying on value chain and third-party data. A reporting procedure and handbook govern data collection, validation, consolidation and reporting, applying the principles of relevance, faithful representation, comparability, verifiability and understandability, with internal controls at each stage (locking confirmed registrations, regulating access permissions).

ESG risks were integrated into Boozt's yearly internal audit and self-assessment (begun 2024, expanded 2025); findings were presented to the Audit Committee. Beyond the required limited assurance, no further external validation has been sought.

Strategy, business model and value chain

Reference: pages 34-36.

Boozt is a Nordic online department store selling Fashion, Kids, Sport, Beauty and Home products via two segments, Boozt.com and Booztlet.com, built on in-house technology. It partners with over 1,600 brands and maintains control over its full value chain, from curated selection and purchasing through to local fulfilment at its Ängelholm Fulfilment Centre and returns handling, rather than outsourcing key operations to third parties.

At end-2025 Boozt had 1,054 employees across five locations in Sweden (816), Denmark (180) and Lithuania (58); the headquarters moved from Malmö to Copenhagen in February 2026. The Nordic region generates 90% of revenue.

Interests and views of stakeholders

Reference: page 39.

Boozt uses a "top-down" method to capture IROs related to its role as a third-party retailer, engaging six stakeholder groups through tailored channels: employees (union meetings, engagement surveys, intranet); brand partners (Partner Portal, ESG supplier scorecard); consumers and end-users (webshop, NPS, Trustpilot, Claims Process, Fair Use policy); shareholders and banks (ESG ratings such as MSCI, Sustainalytics, CDP, investor relations); communities and NGOs (sponsorships, The Industry We Want); and distribution partners (Position Green ESG software reporting).

Stakeholder engagement directly informs and validates the Double Materiality Assessment.

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

Reference: page 43 (table), with narrative on pages 41, 44-45, 50-51, 59-65, 67-70, 71-73.

Boozt's 2025 Double Materiality Assessment identified 18 material sustainability matters, which "are in some cases consolidated and substantiated by the 17 associated impacts, risks, and opportunities (IROs)" presented in the SBM-3 overview table (page 43). The 17 IROs span E1 Climate Change (3: Scope 1&2 emissions, Scope 3 emissions, chronic physical risk), E5 Resource use and circular economy (2: resource inflow depletion, resource outflows/waste), S1 Own workforce (3: health & safety, equal treatment, working conditions), S4 Consumers and end-users (4: information/Made With Care, misleading information, social inclusion, privacy), and G1 Business conduct (5, including corporate culture, animal welfare, supplier dependency, corruption, whistleblowing).

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

Reference: pages 40-41.

Boozt's DMA follows four steps: (1) context setting and annual review of the business model, value chain and sector; (2) top-down topic identification against the ESRS 1 AR16 list of sustainability matters, supplemented by benchmarking and media analysis (through which the entity-specific topic of privacy and data protection was identified); (3) stakeholder engagement and topic assessment, using interviews and a 5x5 severity/likelihood matrix for impact materiality (severity over 4 is automatically material); and (4) confirmation of material topics and IROs.

Financial materiality uses a 5x5 magnitude/likelihood matrix against EBIT, with a substantive risk defined as a potential negative impact of more than -2.5% of EBIT at "likely" to "virtual certain" probability (opportunities: +2.5%).

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

Reference: pages 76-78.

Boozt publishes a "Content index of disclosure requirements" cross-referencing each disclosure requirement it covers to its location in the Annual Report, noting that "disclosure requirements fulfilled through incorporation by reference are identified with an asterisk (*)" and that "for disclosure requirements not yet applicable under phase-in provisions, no reference is provided." The index covers ESRS 2 (GOV, SBM, IRO), E1, E5, S1, S4 and G1. A second table (pages 78-79) maps ESRS 2 Appendix B datapoints deriving from other EU legislation (SFDR, Pillar 3, Benchmark Regulation, EU Climate Law), marking several environmental sub-datapoints "not material", "not applicable" or "phased-in".

Transition plan for climate change mitigation

Reference: page 45.

Boozt has set SBTi-validated near-term science-based targets and systematically defined the main GHG contributors in its own operations and supply chain. "While many essential components of a formal transition plan, such as identified decarbonisation levers... and near-term targets... are already established, a formalized and fully implemented plan is currently work in progress and is expected to be adopted in the next two years."

A concrete decarbonisation action already in place is the 2019 Fair Use policy, which pauses customers who drive excessive returns; by end-2025 roughly 74,000 customers had been paused, avoiding approximately 568 tonnes CO2e in 2025 (2024: 480 tonnes).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 climate DMA section, pages 40-41 and 44-45. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Boozt's DMA "identifies climate-related IROs through a specialized screening process... evaluat[ing] our technological infrastructure and Nordic supply chain against transition risks, such as evolving greenhouse gas regulations, and physical risks, including the impact of temperature variability on fashion seasonality," assessed for potential EBIT impact (page 40-41). The identified physical risk is chronic, weather-driven demand volatility affecting inventory planning (page 44).

"Boozt has not conducted a specific climate-related scenario analysis to inform the assessment of impacts, risks and opportunities over the short-, medium- or long-term yet. This will be part of the development of the transition plan" (page 45).

Policies related to climate change mitigation and adaptation

Reference: page 45.

"Climate change mitigation and energy efficiency are addressed in Boozt's Code of Conduct, Supplier Code of Cooperation and its Environmental policy." The Code of Conduct encourages employees to reduce energy usage and travel only when necessary. The Environmental policy "defines the main principles regarding how the company should consider the environmental impact of the operations within the Group" and commits to reporting progress through established standards such as the Greenhouse Gas Protocol. Boozt does not maintain a single standalone climate policy; mitigation and adaptation commitments are embedded across these three documents.

Actions and resources in relation to climate change policies

Reference: page 45.

Boozt's main 2025 climate action was increasing renewable electricity: it is "committed to being fully powered by renewable electricity by 2030" via Guarantees of Origin and Renewable Energy Certificates, reaching 87.8% renewable energy and 97.9% renewable electricity in 2025 (92.1% from bundled contractual instruments).

On the value chain side, the 2019 Fair Use policy discourages unnecessary returns; by end-2025 approximately 74,000 customers had been paused, avoiding roughly 568 tonnes CO2e (2024: 480 tonnes), out of more than 3 million active customers who generate around 22% of total return volume.

Targets related to climate change mitigation and adaptation

Reference: page 46.

Boozt's SBTi-approved near-term targets, from a 2022 base year: reduce absolute Scope 1 and 2 GHG emissions 55% by FY2032; increase active annual sourcing of renewable electricity from 98.2% (FY2022) to 100% by FY2030; and reach 88% of suppliers (by spend on purchased goods and services) with science-based targets by FY2028. "In accordance with ESRS E1-4, these targets are achieved through direct internal reductions and do not include GHG removals, carbon credits, or avoided emissions."

2025 progress: Scope 1&2 market-based emissions were 198.6 tonnes CO2e versus a 192.5 baseline (+1.8% YoY, against a -55% by 2032 target); 54% of suppliers (by spend) now have science-based targets (2024: 51%).

Energy consumption and mix

Reference: page 47.

Total energy consumption in 2025 was 6,037.2 MWh (2024: 6,035.9), of which 87.8% came from renewable sources (2024: 88.8%) and 12.1% from fossil sources (2024: 11.1%), with 0.1% from nuclear. Renewable electricity reached 97.9% of total electricity consumption. The Fulfilment Centre's on-site solar panels generated 443.2 MWh, of which 388 MWh (11.2% of the facility's electricity) was consumed directly on-site.

As an online retailer, Boozt falls under high climate impact sector G (wholesale and retail trade) per Regulation (EU) 2022/1288; energy consumption per net revenue from that sector was 0.73 MWh/SEK million.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 47-49.

2025 gross emissions: Scope 1: 102.5 tCO2e (2024: 104.0, -1.5%); Scope 2 market-based: 96.1 tCO2e (2024: 91.1, +5.5%); Scope 3: 192,438.8 tCO2e (2024: 202,952.2, -5.2%), of which purchased goods and services is the largest category at 84.8% of Scope 3. Total market-based GHG emissions were 192,637.3 tCO2e (2024: 203,147.3, -5.2%); GHG intensity was 23.2 tCO2e per SEK million net revenue (2024: 24.6).

Scope 3 represents 99.9% of Boozt's total footprint. A reporting error by a third-party distributor in Scope 3 Category 4 (upstream transportation and distribution) required restating the 2024 figures.

Policies related to resource use and circular economy

Reference: page 51.

"Resource use and circular economy are addressed in Boozt's Code of Conduct and in its Environmental policy." The Environmental policy addresses circularity of textiles, "stating that the company should help to reduce the waste problem by using renewable materials and handling recyclable waste in a safe and responsible way." A garment-handling hierarchy applies to unsellable stock: items that can still be worn are sold via Boozt's physical outlet store, donated to charity or sent back to the supplier; garments with significant faults are either returned to the supplier or submitted for material recycling, overseen by the Group CEO with the Head of Sustainability and ESG monitoring implementation.

Actions and resources related to resource use and circular economy

Reference: pages 51-52.

Boozt now fully uses a pack-size on-demand machine producing perfect-fit boxes for odd-sized articles, reducing shipping volume and filling material, and increased its fleet of reusable metal cages for shipping by 91%, creating a return loop with distributors. Since 2023 Boozt has participated in the EU-funded LIFE-REZIP project, testing a circular packaging concept; the 2025 pilot at the Fulfilment Centre "confirmed the need for further design improvements" and findings were shared with project partners. Returned bubble wrap is reused for packing fragile items; planned testing of paper packaging to replace plastic shipping bags was moved to 2026.

Targets related to resource use and circular economy

Reference: page 52.

In 2022 Boozt set a voluntary target to increase the share of recycled waste at its Fulfilment Centre to 80% by 2026, from a 60.8% baseline. The target was reached ahead of schedule in 2024 at 81.7%, and recycled waste rose further to 83.3% in 2025. "Since we have already surpassed our original objective, we will reassess and set a new formalised target in late 2026 to ensure continued alignment with our evolving business operations." Boozt has no quantified target for resource inflows (packaging) beyond tracking recycled content and sustainable sourcing shares.

Resource inflows

Reference: page 52.

Boozt's resource-inflow tracking is limited to the packaging materials added at its warehouse for shipping (it does not track product-level inflows, "due to lack of data availability"). Total purchased packaging material in 2025 was 1,712.0 tonnes (2024: 1,472.8), comprising cardboard/paper (1,395.2 tonnes, 81.5%) and plastic (316.8 tonnes, 18.5%). 86.2% of purchased packaging consisted of recycled content (2024: 88.2%), and 78.9% of the biological (cardboard/paper) material was sustainably (FSC) sourced. Despite higher total packaging volumes, plastic procurement fell, driven by a 14% reduction in filling material.

Resource outflows

Reference: pages 50-51, 53.

Boozt's online platform "generates waste from packaging and products, impacting both our operations and the environment." Within operations, returned packaging, employee and construction waste is managed with a third-party partner; at the customer end, Boozt "lacks direct control over the end-of-life management" of purchased products and packaging. The topic is flagged double material because of a growing regulatory burden: expanding Extended Producer Responsibility (EPR) fees and the incoming Packaging and Packaging Waste Regulation (PPWR) are expected to raise costs, particularly for single-use plastics and non-recyclable materials, compounded by Boozt's projected growth.

Waste

Reference: page 53.

Boozt generated 2,363.0 tonnes of waste in its own operations in 2025 (2024: 2,419.6), mostly from Fulfilment Centre packaging and automated-system maintenance (including a small amount of hazardous waste). 99% was diverted from disposal through recycling or energy recovery (2024: 99.3%): recycling accounted for 1,895.7 tonnes and other recovery for 443.6 tonnes. Hazardous waste directed to disposal was 23.8 tonnes; total non-recycled waste was 1.0% of the total (2024: 0.7%). No radioactive waste was generated. The technically recyclable content of total packaging material was 95.6%.

Policies related to own workforce

Reference: pages 60, 63, 65.

Own-workforce policies are distributed by sub-topic rather than consolidated: working conditions draws on the Code of Conduct, Group HR policy and Group policy - Dignity at Work; health and safety on the Group Work Environment policy, "overseen by the CEO with ultimate responsibility residing with the Board of Directors"; and equal treatment and opportunities on the Code of Conduct's zero-tolerance stance on discrimination. Human rights commitments (secure employment, fair wages, freedom of association, work-life harmony) are anchored in the UN Guiding Principles on Business and Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work.

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

Reference: page 60.

Boozt conducts employee engagement surveys at least once a quarter via an anonymous third-party tool, producing an employee Net Promoter Score (eNPS) used to identify early signs of stress or dissatisfaction. Workers' representatives are engaged through the Working Environment Group and, in Sweden, a collective bargaining agreement, which "ensures structured engagement with workers' representatives and provides a platform for employees to contribute to decisions that influence their working conditions."

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

Reference: page 60.

Boozt maintains a grievance procedure to address employee concerns "with sensitivity and confidentiality." Where internal procedures cannot be used, the Whistleblower policy provides a secure reporting channel operated in partnership with external provider 2Secure; issues raised are handled by a dedicated Whistleblower Committee comprising Boozt's General Counsel, CHRO and Chairman of the Board. Three separate whistleblower channels exist depending on the reporting entity, and have been expanded to cover job seekers, volunteers, shareholders, management, supervisory board members and suppliers in addition to the own workforce.

Taking action on material impacts on own workforce

Reference: pages 61, 63, 65.

Working conditions: a people-first headquarters relocation programme from Sweden to Denmark included AI chatbot support, a reduced 37-hour work week with no salary cut, extended paid parental leave, five extra annual leave days and enhanced health insurance. Health and safety: 18 safety walks were conducted in 2025, alongside traffic-management improvements (forklift/pedestrian separation), safety training and new safety knives reducing cut incidents. Equal treatment: development talks with an 80% participation target give employees a structured channel to discuss career growth and flag barriers to equal opportunity.

Targets related to own workforce

Reference: pages 62, 64, 65.

Boozt set annual minimum targets of +45 eNPS and 80% aggregated participation rate for its employee engagement survey. In 2025 it achieved 88% participation (exceeding the target) but an eNPS of 37, below the +45 target, which the company attributes to the year's organisational restructuring and headquarters relocation. For equal treatment, an 80% participation target for development talks was set and exceeded at 84.6% (892 employees). No quantified target exists for health and safety beyond the general +80% engagement-survey participation goal.

Characteristics of the undertaking's employees

Reference: page 62.

At 31 December 2025, Boozt employed 1,054 people: 552 women (52%) and 503 men (48%), across Sweden (816, 77%), Denmark (180, 17%) and Lithuania (58, 6%). 97% held permanent contracts (1,024 of 1,054); 1,004 were full-time and 50 part-time. 265 employees left during the year, an employee turnover rate of 25%, which the company attributes to organisational restructuring and the headquarters relocation to Copenhagen.

Collective bargaining coverage and social dialogue

Reference: page 63.

802 employees (76%) were covered by collective bargaining agreements in 2025 (2024: 84%), with coverage reaching 98% in Sweden. All employees were covered by worker representatives (2024: 100%). Boozt "strongly supports the freedom of association, allowing employees to freely engage in social dialogue and join associations."; the decline in overall CBA coverage year on year is not separately explained in the statement.

Diversity metrics

Reference: page 65.

At top management level, Boozt reports 23% female (11 headcount) and 77% male (36 headcount) representation. By age group, employees are 24% under 30, 67% aged 30-50, and 9% over 50. The company does not provide a board-level gender diversity figure within the S1 disclosure itself (board composition is incorporated by reference to the corporate governance report, pages 92-93).

Adequate wages

Reference: page 62.

"Employees are paid an adequate wage, aligned with the relevant benchmarks for each country" in Sweden, Denmark and Lithuania, assessed against Sweden's collective bargaining agreement, Denmark's DISCO-08 coded wages (the Danish version of ISCO-08) and Lithuania's national minimum wage. Yearly salary reviews are conducted in each location, with Boozt Fashion AB and Boozt Fulfilment & Logistics AB reviews done in collaboration with union representatives. The disclosure is based on the lowest wage within the lowest pay category, excluding interns and apprentices.

Social protection

Reference: page 62.

"Boozt ensures that all employees are covered by social protection against loss of income due to sickness, unemployment, employment injury, parental leave and retirement, in line with local standards." Boozt Group provides work injury, travel, illness and life insurance according to local legislation, and states that the relocation to Denmark will bring enhanced health coverage, including for employees' partners and children, with quicker access to medical specialists in both Denmark and Sweden.

Training and skills development metrics

Reference: page 65.

84.6% (892 employees) participated in regular performance and career development reviews in 2025, exceeding the +80% participation target (51.5% men, 48.5% women among participants). 112 employees attended internal sustainability-related training in 2025 (2024: 94), against a target set in 2022 to increase participation through 2026. BP-1 (page 38) notes that Boozt elected the phase-in relief for selected S1-13 datapoints.

Health and safety metrics

Reference: page 64.

100% of employees are covered by Boozt's Health & Safety Management system. There were 0 fatalities due to work-related injuries or ill health in 2025, and 3 recordable work-related accidents, giving a rate of recordable work-related accidents of 1.9. BP-1 (page 38) notes that Boozt elected the phase-in relief for selected S1-14 datapoints, so not every ESRS S1-14 metric is disclosed for 2025.

Work-life balance metrics

Reference: page 62.

"100% of our employees are entitled to leave through social policy and/or collective bargaining agreements." In 2025, 37.3% (393 employees) took family-related leave (parental leave, care of a sick child, or care of a close relative), of whom 42.7% (168) were men and 57.3% (225) were women.

Compensation metrics (pay gap and total compensation)

Reference: page 65.

The unadjusted gender pay gap, calculated as the difference between average gross hourly earnings of male and female employees as a percentage of male earnings, was 19.4% in 2025. The annual total remuneration ratio, comparing the highest-paid individual's total compensation to the median of all other employees, was 29.

Incidents, complaints and severe human rights impacts

Reference: page 63.

"No incidents of discrimination were reported through the whistleblower channel, and hence none have qualified as formal whistleblowing cases, in accordance with applicable legislation." No severe human rights incidents occurred during the year, and consequently no fines, penalties or compensation were paid in relation to such incidents.

Policies related to consumers and end-users

Reference: page 68.

Consumer-facing commitments centre on the Data protection policy, overseen by the Board with the Group CEO responsible for implementation, which "ensures compliance with the GDPR, national data privacy legislation, and is aligned with the UN Guiding Principles on Business and Human Rights." An Information security policy sets Boozt's security strategy, covering disaster recovery, access management and incident management. Product-information commitments are embedded in the Made With Care criteria rather than a single standalone consumer policy (read more on S4-4).

Processes for engaging with consumers and end-users about impacts

Reference: page 68.

Boozt engages consumers primarily online, through product detail pages on Boozt.com and Booztlet.com, and tracks satisfaction through Trustpilot (4.3/5) and an NPS score of 78 in 2025. More than 200 employees report into this engagement function; a further ~170 people support it through in-house platform development. Customer Service and Supply Chain staff received training on EU Green Deal directives and Made With Care criteria to strengthen informed consumer support.

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

Reference: pages 68-69.

Boozt operates seven channels to remediate actual and potential negative impacts for consumers, including TrustPilot, a Kindly chatbot, NPS, the in-house "Win-Back" process, CS Articles, the Claims Process and the Fair Use policy. A Data Protection Officer, appointed in 2023, provides a direct communication channel for data subjects and authorities. The Boozt Recall Process Guide sets a cross-departmental protocol (Buying and Merchandising, Customer Service, Legal, Fulfilment Centre) for managing product recalls and directly informing affected customers.

Taking action on material impacts on consumers and end-users

Reference: pages 69-70.

The Made With Care shop curates products with voluntary third-party environmental and social certification, addressing misleading-information risk under the incoming EU Empowering Consumers for the Green Transition Directive. An external accessibility audit (end-2024) under the European Accessibility Act led to a structured action plan targeting WCAG 2.1 Level AA compliance. On privacy and security: a 2025 Deloitte IT audit and annual penetration testing found no impactful weaknesses; a HackerOne bug bounty programme is in place; Boozt notified a supervisory authority of 1 data breach in 2025 (2024: 0), with 0 substantiated data protection complaints (2024: 1).

Targets related to consumers and end-users

Reference: page 70.

"Boozt currently does not have any targets to manage material negative impacts or advance potential positive impacts in relation to consumers and end-users." Instead, it tracks the Made With Care (MWC) shop's financial and reach metrics monthly: in 2025, MWC products were 3.1% of the assortment (2024: 2.6%), 7.1% of orders contained an MWC product (2024: 6.4%), and MWC products generated 2.4% of net revenue (2024: 2.0%).

Business conduct policies and corporate culture

Reference: page 72.

Boozt's Code of Conduct, approved by the Board and implemented by the Group CEO, anchors the "Care-Why" culture of Trust, Freedom and Responsibility, covering human rights, fair labour practices, environmental sustainability and data privacy. The Whistleblower policy commits to investigating potential issues "as soon as they are brought to the company's attention." Anti-corruption, insider and procurement policies, overseen by the Group CEO, prohibit bribery and corruption across Boozt AB, its subsidiaries, employees, board members and business partners, in line with the UK Bribery Act and the US Foreign Corrupt Practices Act, and are communicated to brand partners via the Buying and Merchandising department and Partner Portal.

Management of relationships with suppliers

Reference: pages 73-74.

The Procurement policy, overseen by the Group CFO, and the Supplier Code of Cooperation (an appendix to all trade agreements, based on the UN Guiding Principles on Business and Human Rights) set expectations for Boozt's over 1,600 brand partners. Compliance is tracked through the ESG supplier scorecard (40 yes/no questions, weighted by risk level); 51% of brands by cost of goods sold completed it in 2025 (2024: 51% by business volume, a methodology change). Boozt also co-launched the cross-retailer One Retail Hub and Brand Due Diligence Questionnaire (with ASOS, ABOUT YOU, Ellos Group, New Look, The Very Group and Zalando), and finances supplier decarbonisation support through Fashion Leap for Climate.

Prevention and detection of corruption and bribery

Reference: page 72.

Anti-corruption, insider and procurement policies address fraudulent billing, hiring and promotion fraud, and bribery for favoured treatment. "Investigations of allegations are conducted by a committee independent of the implicated management chain; outcomes are reported to the Board of Directors and relevant supervisory bodies." Supplier compliance is monitored via the ESG supplier scorecard, and policy efficacy is "assessed through internal audits and monitoring of reported incidents." No substantiated complaints of corruption, fraud, or anti-trust/competition-law breaches were reported in 2025 from employees or value-chain actors, and Boozt received no convictions or fines.

Targets related to business conduct

Reference: pages 72, 74 (part of MDR-T/GDR-T disclosures). G1-3 became a standalone 2025/2026 ESRS disclosure requirement; under the 2023 ESRS that this FY2025 statement is prepared against, business conduct targets fell under MDR-T.

Boozt states no quantified target for corruption prevention or supplier relationships. It instead tracks effectiveness: "Relevant policies are updated annually... and are assessed as part of Boozt's annual internal control assessment process to verify they effectively address identified impacts, risks, and opportunities" (G1-1 accounting policy, page 74); the anti-corruption policy's efficacy is "assessed through internal audits and monitoring of reported incidents" (page 72); and supplier-relationship management is tracked through the ESG supplier scorecard completion rate (51% of brands by COGS in 2025) and zero substantiated complaints in 2025.

Incidents of corruption or bribery

Reference: page 72.

"No substantiated complaints of corruption, fraud, anti-trust or competition laws were reported in 2025 from either actors in our value chain or employees. Boozt did not receive any convictions or fines for violations of anti-corruption or anti-bribery laws in the year, nor has it been subject to any legal action related to corruption or bribery."

Payment practices

Reference: page 74.

Payment terms run from net 30 days for general vendors to net 90 days for brand partners, set during vendor onboarding and governed by the Procurement policy and the Boozt Trade Agreement, with direct Finance Department oversight to prevent delays. "Boozt currently has no outstanding legal proceedings related to late payments." The company acknowledges that "obtaining precise, specific data on payment practices solely related to Small and Medium-sized Enterprises (SMEs) remains a challenge."