Bufab AB (publ)

Role of administrative, management and supervisory bodies

Reference: pages 50-51.

Bufab conducts an annual materiality assessment of the entire value chain, "with particular focus on areas where purchasing volumes are high (steel and stainless steel) or where risks are known (e.g., forest-based products and conflict minerals)." The assessment, together with identified risks and opportunities, is presented to the Board of Directors, "which decides on and approves further actions. The Board has ultimate responsibility for the company's materiality" (p.50). There are no employee representatives on Bufab's Board of Directors.

The Board approves and follows up on targets and KPIs twice per year; progress is presented under E1-4, E1-6, E5-3-5, S1-9, S1-13-14, S2-5, G1-1 and G1-3 (p.50).

Competence: Bufab has "a global and regional sustainability organisation with relevant expertise in climate, environmental matters, human rights and business ethics," and assesses that the Board and Group Management "have sufficient competence to oversee and manage the material matters identified in section IRO-2, page 64" (p.51). Governing documents include a Sustainability Policy, Environmental Policy, Code of Conduct, Supplier Code of Conduct, Whistleblower Policy and Anti-bribery Policy, each approved by the Board or CEO and reviewed on an annual cycle.

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

Reference: page 52.

"During the year, the Board of Directors and Group Management updated and adopted Bufab's double materiality assessment. These bodies have also reviewed and revised the company's policies and carried out a follow-up of the sustainability work." Bufab has further defined which policies require Board approval and which require Group Management approval (p.52).

A reporting cadence table sets out how often each governance body receives sustainability information: policy review and the materiality assessment go to both Management and the Board annually; targets, progress in actions and due diligence go to Management monthly and the Board bi-annually; whistleblower matters go to Management on demand/bi-annually and the Board on the same basis (p.52).

Integration of sustainability-related performance in incentive schemes

Reference: page 52.

Remuneration guidelines for the CEO and senior executives were adopted at the AGM on 24 April 2025. "Climate-related targets are included in the remuneration model for all members of Group Management, strategic functions and local Managing Directors," through a short-term variable incentive (STI) "linked to a selected sustainability target relating to the implementation of Bufab's Sustainable Supplier Engagement Program (SSEP)." Members of Group Management "may receive a maximum of 6.25 percent of their base salary upon full achievement of the sustainability target" (p.52).

The STI KPI is "the share of the Group's purchasing volume covered by suppliers that have reached Step 3 in the SSEP," with full outcome at 70% of volume by end of 2025. Share of base salary at maximum STI: CEO and president 60% (10% sustainability-linked), Group Management 50% (10%, one member 30%), Board of Directors 0%.

Statement on due diligence

Reference: page 52; Table GOV-4 in the Appendix.

"During the year, Group Management and the Board of Directors addressed all material matters within the framework of the company's regular governance and follow-up processes. In connection with acquisitions, a sustainability review covering all ESRS areas is conducted. The results are presented to Group Management and the Board prior to decision-making. An external legal due diligence review is also performed in connection with acquisitions" (p.52).

Due diligence is further embedded through the Supplier Code of Conduct (signed by all suppliers and distributors, covering labour, anti-corruption, human rights and environmental requirements), risk-based supplier screening and on-site audits (goal: 80% of purchasing volume assessed by 2026), mandatory Code of Conduct and Anti-corruption Policy training, and a "Red Flag" escalation process for severe deviations. See Table GOV-4 in the Appendix for the mapping of due diligence core elements to report sections.

Risk management and internal controls over sustainability reporting

Reference: page 53.

The internal control framework's objective is "to ensure that the sustainability information reported is accurate, complete, comparable and reliable, and that it complies with applicable legal requirements and reporting standards, including the CSRD and ESRS" (p.53).

Governance and responsibilities: the Board "establishes overarching frameworks and objectives for the sustainability agenda," the President & CEO "is responsible for ensuring that appropriate processes and internal controls exist," and operational responsibility sits with the Group Sustainability function alongside Finance, Sourcing and HR.

Risk assessment and controls: Bufab "conducts regular risk assessments of sustainability reporting, including identification of risks associated with data collection, consolidation, calculations and reporting." Control activities include "reasonableness checks, reconciliations, reporting instructions, training, standardised definitions and follow-up of deviations," with each level (company, region, Group) "responsible for verifying and signing off that submitted information is accurate and complete" (p.53). Bufab does not have a formal internal audit function but conducts internal reviews within the management system, and in 2025 decided all companies would be audited by a third party.

Market position, strategy, business model(s) and value chain

Reference: pages 54-56.

Bufab "is a trading company that offers its customers a complete solution as a Supply Chain Partner for sourcing, quality assurance, sustainability, and logistics of C-parts." Its business model is "built on taking full responsibility for the customer's C-parts sourcing ... This reduces customers' administrative burden and complexity" (p.54).

Scale: products to customers in 77 countries across more than 30 industry segments; about 175,000 articles delivered from around 8,000 suppliers in 2025; steel is "more than 90 percent of total material volume." The Group comprises 65 companies in 31 countries across five regions, with 1,853 employees at 31 December 2025 (p.54).

Value chain: the report maps a nine-stage chain from raw-material extraction (steel, stainless steel, aluminium, copper, brass; smaller volumes of plastics, wood and rubber) through processing, manufacturing, transport to Bufab, storage/distribution, transport to customer, product use and end-of-life/recycling (pp.55-56). Material topics are mapped to each stage: upstream (E1 Climate Change, E2 Pollution, E5 Circular Economy, S2 Workers in the Value Chain, G1 Responsible Business Conduct), own operations (E1, E2, S1 Own Workforce, G1), and downstream (E2, E5) (p.56).

Interests and views of stakeholders

Reference: page 57.

Bufab identifies seven stakeholder groups: customers, suppliers, employees, shareholders, institutions and municipalities, national and regional legislators, and nature (p.57).

A table sets out the engagement channel, topics in focus and Bufab's response per group, e.g. customers (surveys, customer service, sustainability reports; topics: environmental impact of products, supply-chain ethics, transparency); suppliers (Codes of Conduct, audits, supplier portals; "Bufab has succeeded in consolidating 80 percent of purchases to approximately 550 suppliers that comply with Bufab's requirements"); employees (surveys, union meetings; "we work to maintain low staff turnover and increase engagement").

"The results from stakeholder dialogues are systematically used as input in Bufab's double materiality assessment." Between 2023-2025 both employee and customer surveys were conducted; customer surveys "showed that Bufab is working on the right issues and that there is substantial interest from customers regarding sustainability" (p.57).

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

Reference: page 58; see further pages 65 (E1), 74-75 (E2), 78 (E5), 85 (S1), 96 (S2), 101 (G1).

"Bufab's material impacts, risks and opportunities are identified through an assessment based on the principles of double materiality," covering actual and potential impacts on people and the environment as well as financial effects (p.58). "Of particular importance are climate impact, resource use, working conditions in the value chain, and business ethics" (p.58).

Material topics (double materiality matrix, p.58): E1 Mitigation of climate change and Energy; E2 Substances of Very High Concern (SVHC); E5 Resource inflows, Resource outflows and Waste; S1 Working conditions and Equal treatment; S2 Working conditions, Equal treatment and Other work-related rights; G1 Corruption and bribery, Corporate culture, Supplier relationships and Whistleblower protection.

Assessed not material: E3 Water and Marine Resources, E4 Biodiversity and Ecosystems, S3 Affected Communities, S4 Consumers and End-Users (p.58).

Per-topic tables "present material impacts, risks and opportunities related to each ESRS sub-topic," including time horizon and value-chain location. Climate-related risk identification and scenario analysis is presented in the E1 chapter (pages 65-67, back-filled under E1-2 and E1-3, 2025 ESRS numbering).

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

Reference: pages 61-63.

Bufab's materiality assessment "is updated annually and covers all steps in the value chain, with particular focus on value chains with high purchasing volumes (steel and stainless steel) and value chains with known risks (e.g., forest products and conflict minerals)" (p.61).

Impact materiality: severity (degree of harm/benefit, how widespread, restorability) multiplied by likelihood. Financial materiality: analysed through the Group's enterprise risk management framework, with a threshold of "SEK 30 million of EBITA" used to identify impacts, risks and opportunities that may be financially significant, across short (<1 year), medium (1-5 years) and long (>5 years) horizons; "climate scenarios are also applied, considering both rapid and slow transitions" (pp.61-62).

By topic (p.62-63): E1 climate risk was assessed using IPCC AR6 and scenarios SSP1-1.9 and SSP2-4.5, covering physical risks (temperature, wind, water, land; chronic and acute) and transition risks/opportunities, then a resilience analysis. E2 pollution: "Bufab assesses the impact as moderate," with no Annex II (EC 166/2006) emissions other than GHG. E3 water: WWF Water Risk Assessment; greatest risk in the supplier base. E4 biodiversity: WWF Biodiversity Risk Filter. S3 and S4 are explicitly stated as "(not material)."

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

Reference: page 64; "List of disclosure requirements" table, pages 108-112.

"The identification of material impacts, risks and opportunities has been carried out through a double materiality assessment covering both own operations and the upstream and downstream value chain. Based on this analysis, the company has determined which topic-specific ESRS standards are material and which disclosure requirements are applicable and to be included in the sustainability statement" (p.64).

The Appendix content index lists, with page references, the disclosure requirements covered under ESRS 2, E1, E2, E5, S1, S2 and G1. It omits E3, E4, S3 and S4 entirely, and within the covered standards omits E1-7 and E2-4 (both separately marked "NM*" - not material - in the accompanying SFDR/Pillar 3/Benchmark Regulation/EU Climate Law datapoint cross-reference table), and G1-5 and G1-6. "Decisions regarding the scope of reporting are made within the framework of the company's governance and management structure" (p.64).

Transition Plan for Climate Change Mitigation

Reference: pages 67, 74.

"Bufab's climate transition plan is integrated into the Group's overall strategy and is formally approved by Group Management and the Board of Directors. The plan aims to ensure that Bufab's operations and value chain are aligned with the Paris Agreement objective of limiting global warming to 1.5 °C and achieving net-zero emissions no later than 2050" (p.67). The plan "is based on Bufab's science-based climate targets, validated by the Science Based Targets initiative (SBTi), and covers the full value chain. Bufab is not subject to exclusion under the EU climate-related benchmark criteria" (p.67).

Two pathways: (1) carbon-neutral own operations (Scope 1+2) via vehicle-fleet electrification, more renewable energy and energy efficiency; (2) reduced Scope 3 emissions via purchased-goods/transport requirements, supplier engagement and a shift to lower-impact materials and suppliers.

Governance: Group Management is responsible for implementation and follow-up with regular Board reporting; regional organisations report quarterly progress; climate targets are linked to management incentive structures (p.67). For funding, see E1-8, and for a quantified EU ETS cost sensitivity, pages 73-74.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 (pages 61-62) and the E1 climate-DMA section (pages 65-67) of the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Methodology (IRO-1, p.62): Bufab "assessed through an inventory of the Group's emissions in Scope 1, 2 and 3" and evaluated climate IROs "over the short, medium and long-term," screening "key assets and activities" against temperature, wind, water and land-related hazards (chronic and acute), then a resilience analysis.

Scenarios used (p.62, p.66): physical risk - IPCC AR6 SSP1-1.9 (1.5°C), acting as the "rapid transition" case with "reduced physical risks, increased transition risks"; and SSP2-4.5, the "slow transition" case with "increased long-term physical risks, but lower transition risks in the short and medium term." Both scenarios are drawn from the IPCC Sixth Assessment Report (AR6) and cover the entire value chain.

Scope and risks (p.65-66): physical disruption to intercontinental transport (Asia-Europe/USA); transition risk from CBAM (from 2026), EU ETS and EU ETS2; a market opportunity from demand for lower-climate-footprint products. No temperature-projection rationale per scenario, or named assumption set beyond the scenario labels, is given.

Resilience in relation to climate change

Back-filled from the E1 climate-DMA section (pages 66-67) and ESRS 2 IRO-1 (page 62) of the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"Based on the climate scenario analysis, a resilience assessment has been conducted to evaluate how robust Bufab's business model and strategy are in relation to identified climate related risks" (p.66).

Strengthening factors: "a global and diversified supplier network and flexible warehouse and logistics structure," experience managing past disruptions (the pandemic, the 2021 Suez Canal blockage), "limited ownership of production facilities, which enables flexible sourcing," and "limited ownership of properties and vehicles." Exposure: "the reliance on external suppliers entails a structural exposure to climate related risks," which Bufab is managing by building out supplier- and product-level climate data, "although they have not yet been fully validated for climate reporting purposes" (p.66).

Conclusion: "Overall, Bufab's business model is assessed to have strong resilience to both transition related and physical climate related risks" (p.66). No quantified time horizon for re-running the assessment, and no separate adjust/adapt capacity analysis (e.g. asset redeployment) beyond the low-fixed-asset-ownership point, is given.

Policies related to climate change mitigation and adaptation

Reference: page 68.

Bufab's policies "set out targets and commitments related to the environment and climate, including net-zero emissions by 2050 and a reduction of Scope 3 emissions by 2031 (base year 2021). All targets for Scope 1, 2 and 3 are aligned with the 1.5°C pathway of the Paris Agreement and have been validated by the Science Based Targets initiative (SBTi). For Scope 1 and 2, Bufab aims to be climate neutral by 2030 at the latest." The Environmental Policy also sets a target "to use 100 percent renewable energy by 2030" (p.68).

The governing policies are the Sustainability Policy (Board-owned) and Environmental Policy (CEO-owned), reviewed quarterly at business-unit level, aligned to OECD Guidelines, UN Global Compact, ISO 14001, ISO 50001 and the Paris Agreement's 1.5°C ambition.

Adaptation: "At present, Bufab does not have separate policies or targets specifically related to climate adaptation, as physical climate risks are currently managed through the Group's business model, geographical diversification and the high adaptability of its supplier network" (p.68).

Actions and resources in relation to climate change policies

Reference: pages 69-70.

Targets: "Scope 1 and 2 emissions are to be reduced in absolute terms by 46.2% by 2031. For Scope 3, the target is to reduce emissions intensity by 55% by 2031 (base year 2021)" (p.69).

Scope 3 (Sustainable Supplier Engagement Program, SSEP): a four-step programme (data collection, knowledge-building/baseline, target-setting aligned with Bufab's 55%-by-2031 goal, annual follow-up). In 2025, "70% of Bufab's order volume was sourced from suppliers that had set climate targets in line with Bufab's expectations," and "approximately 70% of the purchasing volume had reached Step 3 of the programme." More than 60 key account purchasers drive implementation (p.69).

Scope 1+2: focus areas are "transition to 100% renewable electricity, phase-out of fossil fuels for heating, and electrification of the vehicle fleet." Remaining emissions may be offset by carbon credits, though "the company currently has no plans to introduce such offsetting before 2030" (p.70). Current actions: a renewable-electricity PPA, the Rudhälls relocation (>50% estimated energy decrease), and "approximately 68% of the year's additional CapEx related to electric passenger vehicles."

"These actions are not expected to have a material financial impact on Bufab, nor to affect its existing financing" (p.70).

Targets related to climate change mitigation and adaptation

Reference: page 71.

Scope 1+2 targets were validated by SBTi in 2022, "in line with the Paris Agreement, which aims to limit global warming to 1.5°C." Scope 2 is measured market-based. "During 2025, Bufab continued to reduce greenhouse gas emissions both in its own operations and in the value chain," with Scope 1+2 down 33% and Scope 3 intensity down 41% versus the 2021 baseline, and 70% of purchasing volume covered by the climate-related supplier programme by year end (p.71).

Energy consumption and mix

Reference: page 72.

"Bufab has a programme in place to improve its energy performance. Over the past year, the company has improved its energy performance and increased the share of renewable energy in its energy mix. Fossil fuels are primarily used as fuel in Bufab's vehicle fleet" (p.72). "The company has no energy use associated with sectors with high climate impact. Accordingly, there is no energy intensity ... to report that relates to activities with significant climate impact" (p.72).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 72-73.

GHG intensity (market-based) per SEK million net sales: 78.1 in 2025 vs 84.5 in 2024 (-7.5%). Scope 3 is dominated by "Purchased goods and services" (578,588 tCO2e, 2025) and "Upstream transportation and distribution" (48,993 tCO2e); these two categories "account for approximately 98 percent of the Group's total emissions," so other Scope 3 categories are excluded from reporting as non-material (p.73). Emissions are calculated under the GHG Protocol Corporate Standard and Scope 2 Guidance; Scope 3 currently uses spend-based factors (Quantis) with a transition under way to weight/material-based calculation. During the year Bufab acquired Novia Group and divested a smaller US manufacturing unit, with base-year emissions adjusted accordingly.

Internal Carbon Pricing

Reference: pages 73-74.

"The company uses internal carbon pricing as a tool to assess risks and opportunities related to carbon emissions with the support of the EU ETS," applied "to analyse the consequences of CBAM (Carbon Border Adjustment Mechanism)." EU ETS price forecasts "have been simulated and used as a basis for assessing potential future costs and form part of the 3-year budget (80, 100 EUR)" (p.74).

Sensitivity analysis (EU ETS price scenarios, CBAM phase-in):

"The results of these analyses have been used as input to this year's budgeting process as well as in establishing costing parameters," and will "continue to be used more strategically in procurement and supplier decisions" (p.74).

Expected financial effects of material risks and opportunities related to climate change

Reference: pages 65-67 (material risk/opportunity table), 70, 73-74 (EU ETS sensitivity). Listed in the Appendix content index (p.108) without a printed page number against the row.

The climate risk/opportunity table (pages 65-67) quantifies materiality thresholds directly: the physical-risk disruption to intercontinental transport is assessed as "potentially material (>30 SEK million in earnings impact)" in extensive/prolonged scenarios, and the combined CBAM/EU ETS transition risks are "assessed as potentially leading to material cost increases (exceeding 30 SEK million)," which "Bufab intends to integrate ... into its costing models and adjust pricing accordingly."

The EU ETS/CBAM sensitivity analysis under E1-8 quantifies a range from 112 SEK million (Year 1, 90 EUR/tCO2e) to 275 SEK million (2034, 160 EUR/tCO2e, 100% phase-in) (pp.73-74). Separately, the company states that its currently planned decarbonisation actions themselves "are not expected to have a material financial impact on Bufab, nor to affect its existing financing" (p.70) - a statement about the cost of implementing the plan, not about the risks/opportunities it is designed to manage.

Policies related to pollution

Reference: pages 75-76.

Through its Environmental Policy, "Bufab has committed to protecting the environment by preventing pollution and reducing and mitigating the negative impacts of resource consumption and waste generation across its operations and value chain." All Group companies must implement an ISO 14001 environmental management system. "Bufab does not consider its direct operations to have a material impact in relation to pollution" (p.76).

Through supplier policies, "Bufab requires suppliers to declare substances that are restricted or of concern and encourages them to work proactively towards their phase-out." Bufab "monitors the regulatory landscape and applies, as a minimum requirement, compliance with REACH, RoHS, POPs and other applicable legal requirements, regardless of where it operates" (p.76). Governing policies: Supplier Code of Conduct, Procurement Policy, Environmental Policy and Quality Policy, aligned to OECD Guidelines, UN Global Compact and ISO 14001.

Actions and resources related to pollution

Reference: pages 76-77.

"Local companies work to identify and manage substances on the EU Candidate List of Substances of Very High Concern (SVHC). Bufab has invested in a central system that supports local companies," prioritising phase-out of high-risk substances and following up supplier compliance via audits (p.76). Transport providers are required to use "vehicles with Euro 6 or higher."

Bufab reports SVHC presence (>0.1% w/w) to the SCIP database under the EU Waste Framework Directive and REACH, and provides customer transparency under REACH Article 33. "Bufab currently has no direct key performance indicators or targets for reducing pollution," relying instead on indirect indicators such as recycled/renewable material share (p.77).

Completed actions: a global SCIP registration system, a restricted/prohibited substances list embedded in supplier requirements and audits. Planned: globally coordinated supplier/article screening campaigns. "These measures do not entail any material financial impact for Bufab nor any impact on existing financing" (p.77).

Targets related to pollution

Reference: page 77.

"At present, Bufab has not established formalised Group-wide targets related to these areas. Instead, the work is governed through policies, management systems and follow-up at company level" (p.77).

All companies must comply with Bufab's Restricted Materials and Substances List (RMSL), which "specifies substances that are prohibited, restricted or of concern"; suppliers confirm compliance by signing it and the Supplier Code of Conduct, with "identified gaps ... continuously followed up within the framework of Bufab's supplier engagement activities" (p.77). This is MDR-T-style effectiveness tracking in the absence of a quantified pollution target.

Substances of concern and Substances of Very High Concern (SVHC)

Reference: page 77.

"Bufab has identified the presence of substances included on the REACH Candidate List (SVHC). The presence mainly refers to lead contained in certain metal products, primarily in steel, aluminium, and copper alloys," with lead sometimes "exceed[ing] the threshold of 0.1 percent (w/w)." DEHP, also an SVHC, "occurs in certain plastic products" (p.77).

"Bufab is dependent on information from suppliers in the value chain to identify and quantify the presence of substances of concern in products and materials. Access to updated and detailed quantity data is currently limited." The delivered-weight figures for lead and DEHP are phase-in items under ESRS 1 Appendix C "due to limited availability of reliable data" (p.77).

KPI: "Sales volume in % of products containing SVHC substances" was 2% in both 2025 and 2024.

Expected financial effects from material pollution-related impacts, risks and opportunities

Reference: page 77. Listed in the Appendix content index (p.108) without a printed page number against the row.

The E2 chapter's measures-and-resources discussion states directly: "The measures are primarily linked to the resources required to manage Bufab's supply chain. According to our current assessment, these measures do not entail any material financial impact for Bufab nor any impact on existing financing. Should implementation of the initiatives described in this plan require additional resources or investments, this will be integrated into our ordinary financial planning. Any material effects on the financial statements will, when relevant, be identified and reported" (p.77).

No separate quantified financial-effect figure for the SVHC/pollution impacts or risks themselves (as distinct from action costs) is given elsewhere in the E2 chapter.

Policies related to resource use and circular economy

Reference: page 79.

Bufab is "affected by standards that require durability, reparability, and recyclability of products, as well as restrictions on the use of hazardous materials," and "focuses on increasing the use of recycled materials and improving recyclability." The company "has defined an ambition to increase the share of recycled material in its products" and "set an ambition for overall recyclability to exceed 90 per cent in sold products" (p.79).

Bufab also "aims to reduce waste to landfill and to decrease total waste generated in its operations," managed through each local company's environmental management system, with recycled content tracked via the Sustainable Supplier Engagement Program (SSEP). Key points: waste and waste management, use of recycled materials, end-of-life treatment of products.

Actions and resources related to resource use and circular economy

Reference: pages 79-80.

Through the SSEP, "Bufab collects data on the use of recycled materials and encourages suppliers to gradually increase the share of recycled content in their products," and "has obtained available supplier data regarding recycled steel within its systems" (p.79). Operational waste management follows the EU waste hierarchy (prevention, reuse, recycling prioritised).

Completed actions (p.80): data collection on recycled materials via SSEP; a global material-risk/chemical-compliance system; quality-organisation investment; the SCIP registration system; a prohibited/restricted-substances list; a "Zero Landfill" programme and training; mapping of global steel mills using scrap-based (EAF) production. Planned: increasing the share of recycled materials. "These measures do not result in any material financial impact on Bufab nor any impact on existing financing" (p.80).

Targets for resource use and circular economy

Reference: page 80.

"In 2025, the company adopted a target that 80 per cent of its purchasing volume shall consist of recycled material by 2031 ... Reporting on the outcome of this target has not yet commenced" (p.80).

"The above targets have been established on a voluntary basis and are not subject to any binding legal requirements." The waste targets are "based on international circular economy guidelines, the EU waste hierarchy and established environmental management standards" (p.80).

Resource inflows

Reference: page 81 (combined E5-4/E5-5 content-index entry).

Bufab "purchases items primarily consisting of technical materials such as steel, aluminium, copper, and other metals," plus smaller shares of plastics, electrical/electronic components, and biological materials (wood, natural rubber, <1%) (p.81). Material composition of purchased articles: steel 76%, stainless steel 10%, plastics 3%, aluminium 2%, brass/zinc <0.5% each, wood <1%, other 8%.

"Bufab is dependent on information from the value chain to assess and quantify the share of virgin and recycled materials in products and materials. The availability of reliable and detailed data is currently limited." The "Share recycled as % of total" and "Share virgin as % of total" rows are reported as blank for both 2025 and 2024, with the company "currently working to integrate data on recycled material into its data warehouse" and planning to "begin reporting the amount of recycled material once verified data becomes available" (p.81). "For the reporting year 2025, the company applies the phase-in provisions set out in Appendix C of ESRS 1."

Resource outflows

Reference: page 81 (combined E5-4/E5-5 content-index entry).

"As Bufab is primarily a trading company, the volume of materials entering its warehouses is in principle the same as the volume leaving them. However, a certain amount may become obsolete and is then reported as waste. No significant resource inflows are therefore consumed in the company's own processes" (p.81).

Material outflow (delivered weight): 104,275 tonnes (2025) vs 109,815 tonnes (2024). "Material recyclability rate" was 97% in 2025 (96% in 2024), estimated on spend data; 100% of articles containing SVHC substances were registered in SCIP in both years. For wood- and rubber-based products the cascading principle applies, "meaning that reuse and recycling are prioritized over energy recovery or incineration," and wooden pallets are reused. Waste generated specifically is reported under E5-5-Waste.

Waste

Reference: page 81.

Hazardous-waste breakdown 2025: recycling 8t, other recovery 61t, landfill 0t, incineration 4t, other disposal 2t. Non-hazardous breakdown 2025: recycling 1,592t, other recovery 217t, landfill 166t, incineration 115t, other disposal 25t.

Bufab "has established targets and works to reduce the amount of waste generated from its operations, as well as to reduce the amount of waste sent to landfill" (p.81). See E5-3 for the associated waste-ladder targets and outcomes.

Policies related to own workforce

Reference: pages 86-87.

"Bufab has established policies for identifying, assessing and managing the consequences that affect our workforce, including risks and opportunities related to their wellbeing, work-life balance, development and working environment," covering the entire workforce (p.86). As a minimum, Bufab adheres to "the UN Guiding Principles on Business and Human Rights, the ILO Core Conventions and internationally recognised standards relating to fundamental freedoms and human rights." The HR policy and recruitment procedures stipulate "zero tolerance for forced labour and child labour," communicated to suppliers and business partners too.

An inclusion and diversity policy covers "ethnicity, skin colour, gender, sexual orientation, gender identity, disability, age and religion" (p.87). All companies must implement a health and safety management system aligned with working-environment requirements. Governing policies (Board- or CEO-approved): Code of Conduct, HR Policy, Health & Safety Policy, GDPR Policy, IT Policy, Sanctions and Export Control Policy.

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

Reference: page 88.

"Direct engagement with employees mainly takes place at the local level and is adapted to the conditions and needs of each region," with training and information provided in several languages. "Bufab has a positive approach to freedom of association and the right to collective bargaining, and respects local forms of worker representation in accordance with applicable legislation" (p.88).

Bufab has "global procedures for performance and development reviews," an annual global employee survey (results under S1-15), and local health-and-safety committees where legally required. Engagement effectiveness is evaluated through the survey's response rate, overall index and eNPS score, which "indicate that employees are engaged and that Bufab succeeds in creating a work environment where employees feel involved and heard" (p.88).

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

Reference: page 88.

"Employees have access to Bufab's whistleblowing channel, which has been established in accordance with the EU Whistleblowing Directive. The channel is available to all employees, including volunteers and temporary staff," via web platform, telephone, email or in-person meeting, and "is managed by an external provider, SpeakUp, which guarantees anonymity and security for users" (p.88).

Remediation "may include ... organisational changes, correcting incorrect decisions, offering support or compensation to affected individuals." "Bufab has not provided any material remediation during the past year." Bufab "protects anyone who uses the whistleblowing channel in good faith from retaliation." During the year, twelve cases were reported and handled via this channel (cross-referenced from G1-1, p.103).

Taking action on material impacts on own workforce, and approaches to mitigating material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions

Reference: page 89.

"Two central risk areas have been identified": work-life imbalance, and work-related incidents that "may have negative financial effects and harm Bufab's reputation" (p.89). Preventive measures include global health-and-safety routines adapted locally, flexible working hours/remote work, crisis-management plans, mental-health support and living-wage guidelines. Reactive measures include rapid incident handling, investigation and corrective action, and occupational health/counselling support.

"Bufab has no known history of incidents related to child labour or forced labour within its own workforce." "The measures implemented have contributed to greater awareness and an improved working environment. Preventive work has reduced the number of reported incidents and strengthened employees' perception of work-life balance. However, challenges remain, particularly in regions with limited legal protection" (p.89). Targets are reported under S1-5.

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

Reference: page 90.

Targets are developed "based on an assessment of the Group's operational needs, relevant industry practice, and internationally recognised guidelines," informed by dialogue with employees and worker representatives and benchmarked against the UN SDGs. "The company is aware that the [zero-accidents] target is challenging in the short term" (p.90).

Characteristics of the undertaking's employees

Reference: pages 90-91.

Total headcount at 31 December 2025: 1,853 employees (32% women, 68% men); 1,743 permanent, 110 temporary; 1,694 full-time, 159 part-time.

By region: Europe North & East 505, Europe West 298 (UK/Ireland 364 separately listed), Americas (North America 34, Mexico 44), Asia-Pacific (China 66, Singapore 52, India 38, Taiwan 16), plus country detail for Sweden, Denmark, Poland, Finland, Norway, Estonia, Slovakia, Hungary, Romania, the Netherlands, France, Italy, Austria, Czech Republic, Germany, Spain, Switzerland and Türkiye. The United Kingdom is the largest single country (364 employees, 26% women). Overall staff turnover rate: 39% (p.91); figures are "extrapolated to some extent" where central personnel-data systems are lacking.

Characteristics of non-employee workers in the undertaking's own workforce

Reference: page 91.

"A small share of Bufab's workforce consists of non-employees who work in the company's own operations but without a direct employment contract with Bufab," typically specialist cover during parental leave, peak workloads or vacancies (p.91).

"There were no significant changes in the volume of non-employee workers during the reporting period." Most common assignments: covering vacancies/temporary needs, administrative/operational peak support, and specialist competence (e.g. IT).

Collective bargaining coverage and social dialogue

Reference: page 92.

"We uphold freedom of association and the right to collective bargaining. Bufab operates in 31 countries, where labour market traditions and conditions differ across markets." "44 percent of our employees are covered by collective agreements" (p.92).

A coverage-band table places countries by collective-bargaining coverage: 80-100% Sweden, Denmark, Netherlands, France (social dialogue); 60-79% Austria; 40-59% Poland, Germany; 20-39% Poland; 0-19% United Kingdom, China, Singapore, USA (with workplace representation noted for Finland, Italy, Germany where EEA thresholds apply).

Diversity metrics

Reference: page 92.

"Bufab has policies that prevent discrimination and promote equal opportunities for everyone, regardless of background," covering ethnicity, gender, sexual orientation, disability and religion, with "positive action for vulnerable groups where appropriate" (p.92).

Bufab's highest operational management is "the CEO and the immediate management team reporting directly to the CEO"; "company management" refers to local management teams across Group companies.

Adequate wages

Reference: page 92.

"In 2025, all companies reported that they pay at least the salary that follows from applicable legislation and, in cases where minimum requirements are regulated outside the legislation, for example through collective agreements ... that these levels are exceeded" (p.92).

Bufab "has conducted a risk-based assessment of adequate salaries. Companies with many employees or where a potentially higher risk has been identified have analysed salary levels in relation to relevant national benchmarks for living wages." The analysis "shows that the salaries paid to employees in the analyzed companies exceed the identified benchmark for living wage." Sources used: Global Living Wage Coalition, IDH Living Wage Platform/Salary Matrix, WageIndicator Foundation, UN Global Compact guidance, the Ethical Trading Initiative and the Fair Wage Network.

Social protection

Reference: page 93.

"The companies report annually the proportion of employees covered by social protection in connection with various life events." Countries not covered for unemployment and pension: India, Singapore (all employees) (p.93).

Persons with Disabilities

Reference: page 93.

"Bufab has a positive view of a diversified workforce and works actively to promote inclusion throughout the organisation." The share of workers with disabilities was 1.1% in 2025, up from 0.7% in 2024 (p.93).

"Due to legal or cultural constraints, data may be missing or inaccurate. We follow the definitions of disability applicable in each country where Bufab operates. In some cases, it may also be difficult to draw a clear boundary in the reporting, which may affect the completeness of the underlying data" (p.93).

Training and skills development metrics

Reference: page 93.

"Bufab does not have a central data system where all training can be monitored, apart from our training portal containing central educations. The reported data is therefore based on information submitted by our companies" (p.93).

A third-party audit of Group-policy implementation was extended to all companies in 2025 (decided by Group Management in 2024) "in order to obtain improved oversight of local governance."

Health and safety metrics

Reference: page 93.

1. 2024 value for lost days was unreliable. "A requirement under this policy is that all companies within the Group must implement a management system based on ISO 45001 to support a safe and healthy working environment for all employees" (p.93).

Work-life balance

Reference: pages 93-94.

"In 2025, 799 employees took family-related leave. Of these, 43 percent were women and 57 percent were men." "Bufab does not have any subsidiaries where employees have not been entitled to paid family-related leave during 2025" (p.94).

Global People Survey 2025: 94% participation (consistent with 2024); Total Index 77 (down 1 point from 2024's 78); Leadership Index stable at 83; eNPS 17 (in the "good," 10-30 range). Focus areas for 2025 set from the results: recognising "Solutionists," strengthening Bufab Academy communications, reinforcing internal "circles," and building AI capability (p.94).

Compensation metrics (pay gap and total compensation)

Reference: page 95.

"The Chief Executive Officer has been expensed for the year with a base salary of SEK 5.9 million, variable remuneration of SEK 2.3 million, other benefits/remuneration of SEK 1.2 million and pension costs of SEK 1.8 million. Other employees had an average salary of SEK 0.60 million. The ratio between the CEO and other employees is 19 times" (p.95).

"Women's average salary was 82% of the men's average salary among Bufab's employees" (unadjusted gender pay gap), p.95.

Incidents, complaints and severe human rights impacts

Reference: page 95.

"No severe human rights violations or complaints to the National Contact Point for the OECD Guidelines were reported during the year. Consequently, no significant fines, sanctions or damages related to human rights matters occurred within the Group" (p.95).

Policies related to value chain workers

Reference: pages 96-97.

"Bufab requires suppliers to sign our Supplier Code of Conduct, which is based on the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises." Suppliers "must adopt the Supplier Code of Conduct in their own supply chains and ensure transparency and control" (p.97).

Purchasing-share-by-risk-country table (p.96) flags China (29.2% of purchases, Medium risk), Taiwan (15.4%, Medium), India (3.1%, High), Thailand (1.7%, High) and Vietnam (1.3%, High) for child-labour/forced-labour/compulsory-labour exposure. Governing policies: Supplier Code of Conduct, Policy on Modern Slavery, Procurement Policy, Sustainability Policy, Environmental Policy, Quality Policy, Sanctions and Export Control Policy.

Processes for engaging with value chain workers about impacts

Reference: page 98.

"Bufab applies a risk-based audit programme aligned with the UN Guiding Principles and the OECD Guidelines. During audits, employees of suppliers are interviewed to capture their perspectives and identify actual and potential impacts affecting them." Assignments "are carried out every five years but may also be conducted more frequently when risks or suspected deviations are identified," and include both announced audits and unannounced inspections (p.98).

Bufab's head of sustainability holds "operational responsibility for ensuring that the perspectives of workers throughout the value chain are genuinely gathered and taken into account." Effectiveness is assessed through audit results compared against prior follow-ups, with any shortcomings triggering dialogue with worker representatives.

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

Reference: page 98.

"Bufab has an established process for audits and for handling deviations. If deviations are identified through audits or other channels - such as whistleblowing or the Speak Up channel, which is also available to suppliers - there are procedures in place to address them immediately." Bufab applies "an escalation process and an internal 'red flag' process, where deviations are managed as projects under the supervision of Bufab's management" (p.98).

"During the reporting period, no serious incidents relating to human rights violations in the supplier base were reported, there has therefore been no need for compensation." Bufab allocates "dedicated sustainability teams, training, advisory support, and financial resources" to ensure corrective actions are effective and long-term.

Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actions

Reference: page 99.

Actions include the Supplier Code of Conduct, a "risk-based ESG audit programme," corrective action plans for non-conformities, ethical-sourcing criteria, and continuous follow-up. Bufab "provides training to suppliers and their employees ... in areas such as occupational health and safety, security, and human rights," extends its whistleblowing channel to suppliers' employees, and "collaborates with external organisations and industry initiatives" including the UN Global Compact (p.99).

Effectiveness is tracked against targets that "80 percent of supplier spend shall be covered by audits by 2026" and "70 percent of purchases shall be included in the Sustainable Supplier Engagement Program by 2025, with verified emissions reductions." Bufab "has zero tolerance for child labour and forced labour," requiring remediation (e.g. school enrolment for affected children) and supplier phase-out where violations are found (p.99).

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

Reference: page 100.

Targets are developed "through a structured process based on dialogue and collaboration with stakeholders across the value chain," with suppliers encouraged to involve trade-union and worker representatives in training, audits and follow-up.

Corporate culture and business conduct policies

Reference: pages 102-103.

Bufab's "Code of Conduct and the ethical guidelines ... apply to all employees, subsidiaries and business partners," aligned with the UN Guiding Principles and OECD Guidelines. Reports are made through "an external platform (Bufab SpeakUp)," compliant with GDPR and the EU Whistleblower Protection Directive (2019/1937); "all reports are acknowledged within seven days, and feedback is provided within three months" (pp.102-103).

"During the year, twelve cases were reported and handled in accordance with Bufab's processes" (2024: sixteen), all escalated to the Board; zero incident reports from independent external parties and zero CEO/CFO-reported incidents in both years.

Anti-corruption training: a campaign reached 1,866 employees, of whom 1,467 completed training during the year; "the company has had no confirmed cases of corruption or bribery during the year." Sales and Purchasing are identified as the highest-risk functions for corruption.

Management of relationships with suppliers

Reference: pages 103-104.

"Bufab manages its relationships with suppliers with a clear focus on sustainability, fairness, and accountability," through the Supplier Code of Conduct, risk assessment, contractual commitments and audits, supported by the Sustainable Supplier Engagement Program (SSEP). "Bufab's goal was for 70% of purchases to be included in SSEP and this goal was achieved by 2025" (p.104).

A resources table sets planned CAPEX/OPEX for the supplier programme from 2025 (CAPEX SEK 1.0m, OPEX SEK 6.0m) out to 2030-2034 (CAPEX SEK 5.0m, OPEX SEK 30.0m), covering sustainability systems, audit technology and ongoing training/audits/dialogue (p.104). KPI: "Share of order volume placed within the SSEP" - target and 2025 outcome both 70%.

Prevention and detection of corruption and bribery

Reference: page 105.

"Bufab has clear Codes of Conduct and anti-corruption policies that all employees and business partners are expected to be familiar with," reinforced by regular training for employees including management and supervisory bodies. Detection mechanisms: a secure, anonymous whistleblowing channel (telephone, email or digital platform), "regular internal and external audits of the company's financial transactions," and a conflict-of-interest policy requiring disclosure of ties such as family relationships with suppliers or customers (p.105).

"The company has no convictions for violations of anti-corruption and bribery laws." Bufab "also ensures regular follow-up and evaluation of its anti-corruption measures to confirm that the strategy and routines are effective and adapted to the company's needs" (p.105).

Targets related to business conduct

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

The G1 metrics table (p.105) sets two stated, measurable targets tied to corruption prevention: "Share of employees completing the Code of Conduct training during the past three years" - target 100%, 2025 outcome 82%; and "Share of purchasing and sales personnel who have not received anti-corruption training in the past three years" - target 0%, 2025 outcome 20%.

Effectiveness is also tracked in the absence of full target achievement, via zero-tolerance KPIs reported at 0 for the year: convictions for anti-corruption/bribery violations, fines for such violations, and confirmed dismissals or disciplinary actions for corruption or bribery offences (p.105). G1-1 separately reports twelve whistleblowing cases handled during the year, all escalated to the Board.

Confirmed incidents of corruption or bribery

Reference: page 105.

"The company has no convictions for violations of anti-corruption and bribery laws."