Bulten Ab

The role of the administrative, management and supervisory bodies

Reference: pages 29-30.

Bulten's administrative bodies consist of the Executive Management Team (EMT) and the non-executive Supervisory Board (Board), which includes employee representatives. Bulten has no additional administrative body within the meaning of ESRS.

The Board has overall responsibility for management and organization, including oversight of the sustainability strategy and its implementation, and is responsible for the annual and sustainability report. It is supported by the Audit Committee (monitors risk management and internal control, including ESG risks) and the Remuneration Committee (aligns executive incentives with sustainable value creation and oversees business conduct). The Board assesses sustainability work at least quarterly.

The CEO and EMT hold operational responsibility for sustainability strategy, goal-setting and progress. The CFO, an EMT member, manages sustainability activities day to day and is also responsible for investigating whistle-blower cases. A cross-functional Sustainability Committee, coordinated by the sustainability department, develops roadmaps and actions for EMT approval.

Board diversity (page 29): 7 members total, 4 men / 3 women (57%/43%) among AGM-elected members; age split 1 member 30-50 years, 8 members over 50 (table combines Board and EMT rows). Executive Management: 5 men / 2 women (71.5%/28.5%).

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

Reference: page 30.

Following the annual double materiality assessment (DMA) update, the sustainability function presents the updated list of material IROs to the EMT for review and approval, after which results are reported to the Audit Committee. The EMT factors the IROs into the company's strategy process, assigns responsibilities to relevant functions and sets targets.

Responsible Heads of Function report monthly or quarterly to the EMT on progress toward sustainability-related targets, and policy owners and the EMT review policy effectiveness throughout the year. The CFO provides quarterly updates to the Audit Committee on non-financial performance and progress against key sustainability metrics.

During 2025, the Board and Audit Committee were briefed on CSRD preparations and implementation, changes in material IROs, reporting scope, and supporting governance structures. Both the EMT and Audit Committee reviewed and addressed the full list of material IROs during the year (see SBM-3). The Board retains ultimate responsibility for sustainability oversight; the Audit Committee oversees the integrity of sustainability reporting while the Board reviews and approves the final disclosures.

Integration of sustainability-related performance in incentive schemes

Reference: page 30 (Corporate Governance Report pp.76, 97-98).

Since 2023, Bulten's short-term incentive (STI) program for senior executives has included a sustainability-related performance target tied to reducing indirect (Scope 3) GHG emissions in the supply chain. The current target focuses on increasing the share of scrap-based steel in the total annual purchased steel volume (excluding stainless steel), described by the company as "the most significant lever for reducing Scope 3 emissions." The target is reviewed annually for continued alignment with the Group's climate strategy and long-term Scope 3 reduction goal.

The Remuneration Committee proposes and the Board approves the sustainability target each year as part of the STI framework. Performance is assessed after year-end based on verified data, with results reviewed by the Remuneration Committee before payout is confirmed.

For 2025, the sustainability target represents 10 percent of the total STI opportunity, alongside financial and operational goals. The program applies to senior executives; long-term incentive programs do not currently include sustainability-related metrics.

Statement on due diligence

Reference: page 30.

Bulten has established a due diligence framework "to identify, prevent, mitigate, and account for actual and potential adverse impacts on people, the environment, and the economy arising from our own operations, our subsidiaries, and our value chain." The report maps the core due diligence elements to ESRS sections:

Also incorporated by reference: disclosure requirements on targets sit in the relevant thematic standards.

Risk management and internal controls over sustainability reporting

Reference: page 30.

The objective is to ensure ESG data is complete and accurate and to identify improvements in collection and consolidation. Responsibility for consolidating, controlling and reporting quantitative sustainability data sits with the Sustainability Department; internal control procedures were developed over recent years under GRI reporting, with the past four years subject to third-party limited assurance.

Each functional area owner maintains relevant policies and procedures; central functions (Sustainability, HR, and Purchasing) collect and validate data from systems and monthly local-unit reporting. Bulten states it "has identified a need for documenting the data collection, aggregation, and validation processes," planned for 2026.

Main risk: manual errors when entering data or converting units. In 2025, an ESG software system was implemented to support the DMA, sustainability reporting and data consolidation; API integration with HR, Purchasing and Health & Safety systems is planned for completion in 2026. Bulten also holds ISO 9001, ISO 14001 and ISO 45001 certifications to manage third-party operational risk.

Strategy, business model and value chain

Reference: pages 31-32; revenue/employee data on Directors' Report page 25.

Bulten is "a leading global manufacturer and distributor of fastening solutions," supplying automotive, consumer electronics, home appliances, medical technology, renewable energy, and gardening/leisure equipment customers. Its integrated model combines in-house production in Europe and Asia with fasteners sourced through a global distribution network, and includes Full Service Provider (FSP) and Vendor Managed Inventory (VMI) services. Under IFRS 8, Bulten has a single operating segment.

Value chain: upstream sourcing of raw materials (mainly steel wire, brass, aluminum) and finished products from a broad global supplier base; own operations (cold forging, threading, heat treatment, surface treatment, machining); downstream, fasteners become components in vehicles, electronics, white goods, medical equipment and renewable-energy systems, intended to be recycled at end of life alongside the products they are part of.

Five strategic sustainability focus areas structure the company's approach: Governance and Business Ethics; Sustainable Customer Offer; Sustainable Own Production; Sustainable Supply Chain; Diversity and Inclusion.

Interests and views of stakeholders

Reference: pages 33-34.

Bulten defines stakeholders as parties with ongoing interaction, parties extensively impacted by its operations, or parties that extensively impact its operations. Stakeholder insights feed the DMA, strategic planning and policy formulation. There have been no changes among key stakeholders in 2025.

Key groups and channels: Customers (sales contacts, sustainability evaluations/seminars; expect lifecycle GHG reduction and fossil-free own production); Employees and representatives (global surveys, trade union dialogue, annual development discussions; expect health & safety, fair wages, working conditions); Suppliers (selection processes, on-site audits, 2025 collaboration with steel suppliers on GHG reduction); Owners/investors/analysts (Board representation, 14 Board meetings in 2025, AGM, Nasdaq ESG database reporting); Local communities (cooperation groups, school/university links, permit-process dialogue); Governments/legislators/authorities (legal-update monitoring, permit contacts, industry associations).

Expectations are reviewed annually by the EMT; the Board is informed as needed.

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

Reference: page 34.

The overview of material IROs from the 2025 DMA is presented in the "Management of impacts, risks and opportunities" section (IRO-1) and detailed in each topical chapter. Material IROs primarily concern climate, energy efficiency, responsible sourcing and supply-chain working conditions, product circularity, employee health and safety, and business conduct. Bulten's sustainability roadmap (first developed 2016-2017, climate roadmap added 2021) sets out policies, targets, action plans and governance for these areas.

"No events resulting in any material financial effects occurred during the year in connection with the material sustainability-related risks or opportunities." Consequently, no material adjustments to reported assets/liabilities are expected within the next year.

Improvement possibilities were identified for IROs connected to due diligence on the deeper supply chain, to be reviewed in 2026. "No IROs identified, and no actions taken or planned, have resulted in any structural changes to the company's strategy or business model." All workforce categories that could be significantly affected are within the scope of disclosure; none were excluded.

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

Reference: pages 35-39.

Bulten's DMA follows ESRS 1 and EFRAG guidance; first conducted voluntarily in 2024 (reported under GRI) and revised in 2025 in a Sustainability Committee workshop of cross-functional representatives (production, sales, procurement, finance, HR, technology, innovation).

Impacts: assessed on severity (scale, scope, irremediability - moved to a 5-point scale in 2025, using the highest factor) and probability; threshold is severity or probability at least "medium." 33 impacts reassessed, 13 material.

Risks/opportunities: assessed on EBIT consequence (1-5) and probability (0-100%, five categories) against a Board-approved threshold. 16 reassessed, 5 material.

Climate scenarios (physical): IPCC RCP 2.6 and RCP 8.5, horizons 0-1/1-5/>5yr to 2050-2100 (Climate Impact Explorer, Climate Central, Swiss Re CatNet). (Transition): RCP2.6/SSP1 with IEA Net Zero 2050, plus intermediate RCP4.5/SSP2; long-term horizon extended to 10-15 years. Two significant transition risks: low-emission product demand, and energy-supply disruption.

Material topics: climate mitigation, soil pollution, water, circular economy, own workforce, value-chain workers, governance. Not material: E4, S3, S4 - screened, no significant impacts found.

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

Reference: page 39; Appendix A (pp.70-72) and Appendix B (pp.72-78, data points from other EU legislation).

Appendix A is Bulten's ESRS content index, listing every disclosure requirement fulfilled based on the DMA, with page references. It states: "The following topics have not been assessed as material for Bulten: ESRS E4 Biodiversity and Ecosystems, ESRS S3 Affected Communities, and ESRS S4 Consumers and/or End Users."

Phase-in: "Bulten has chosen to adopt the phase-in provisions provided by ESRS (see the list of phased-in disclosure requirements in ESRS 1 Appendix C). This contains the anticipated financial effects from material climate-, pollution-, water- and circular economy-related impacts, risks and opportunities (E1-9, E2-6, E3-5, E5-6). These disclosure requirements will be prepared and adopted by Bulten during its next reporting year... All other disclosures mentioned in the phase-in section in ESRS are either reported... or are not adopted due to immateriality" (page 28).

Confidentiality: "Bulten has not made use of the option to omit specific information for reasons of confidentiality nor the exemption from disclosure due to impending developments or matters in the course of negotiation" (page 28).

Transition plan for climate change mitigation

Reference: page 43 (with pp.44-46 for actions and targets).

Bulten's climate transition plan, "approved by senior management," sets out the path to its 2030 targets for Scope 1&2 and Scope 3, first set in 2021 and validated by the Science Based Targets initiative (SBTi) in early 2022. It supports limiting warming to 1.5°C per the Paris Agreement and aims for climate neutrality at latest by 2050; SBTi targets are due for review in 2026.

Strategic aspirations (without using offsets): reduce absolute Scope 1&2 emissions 30% by 2030 from 2019; reduce Scope 3 intensity per tonne of product sold 25% by 2030 from 2019; 100% renewable electricity at European and North American sites by 2025; 100% at all sites by 2030.

Decarbonization levers: renewable/self-generated electricity; converting gas-fueled hardening furnaces; energy efficiency; renewable-energy sourcing for all new investments; increasing secondary-material content; supplier partnerships; climate-neutral surface-treatment coatings.

2025 results: Scope 3 intensity fell 24% vs. 2019 (target 25%); the 2030 Scope 1&2 target was already achieved, with emissions down 70% vs. base year. Locked-in emissions are assessed before asset purchases and covered by the planned pathway; "these do not constitute 'lock-in assets'."

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and SBM-3, where this content is disclosed in the FY2025 report (pages 36-38, 42-43). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Physical climate risks were assessed in a dedicated workshop (finance, procurement, strategy, sustainability) using IPCC RCP 2.6 and RCP 8.5 scenarios, two contrasting future outcomes. Horizons: short 0-1yr, medium 1-5yr, long >5yr to 2050/2100. Tools: Climate Impact Explorer (Climate Analytics/Potsdam Institute/ETH Zurich), Climate Central's sea-level-rise tool, and Swiss Re CatNet. Identified hazards: floods, storms, heatwaves, heavy rainfall, heat stress, water scarcity, drought, sea-level rise (page 37).

Transition risks used RCP2.6/SSP1 with the IEA Net Zero Emissions by 2050 scenario (Paris-aligned) and an intermediate RCP4.5/SSP2 scenario (slower policy/technology development); long-term horizon extended to 10-15 years (page 38).

Two significant transition risks: customer demand for low-emission products, and systemic energy-market disruption to energy supply (page 38). No explicit global-average-temperature projection per scenario is separately quantified.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3, where this content is disclosed in the FY2025 report (pages 42-43). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Bulten "has carried out a qualitative analysis of the resilience of its strategy and business model, with a particular focus on transition risks and physical risks linked to climate change," covering facilities, business areas, supply chains and relevant markets, based on the SSP/RCP scenarios under E1-2, to 2030 and 2050. Impacts assessed: costs, production, supply-chain resilience, changing customer requirements; resilience judged by ability to maintain profitability.

Conclusion: "the company is assessed as having sufficient resilience in relation to material transition risks and physical risks and is able to adapt its strategy and business model to climate change in the short, medium and long term." Flood risk requires continued focus.

Adjustment capacity: the furnace-conversion analysis "shows that this can be achieved with limited investment, meaning that these do not constitute 'lock-in assets.' However, a prerequisite is competitive energy prices compared with natural gas. No incompatible assets or operations have been identified" (E1-1, page 43).

Policies related to climate change mitigation and adaptation

Reference: pages 43-44.

Bulten applies two policies to climate impacts, risks and opportunities in its own operations and supply chain: the Environmental Policy and the Code of Conduct for business partners, suppliers and service providers.

Environmental policy: "aims to reduce climate and environmental impact from its own operations and its products, along the entire value chain," applying to all subsidiaries. It states Bulten's net-zero ambition and aligns strategic goals with the targets and measures used to reduce energy consumption and GHG emissions, verified and approved by the SBTi. Specific targets embedded in the policy: -30% absolute Scope 1&2 by 2030, -25% Scope 3 per tonne sold by 2030 (2019 baseline), plus supporting energy targets (a 15% per-tonne energy-consumption reduction goal to 2024, and renewable-electricity sourcing goals). Changes to targets, KPIs and measures require Board and CEO approval; the policy will be updated in 2026.

Supplier code of conduct: requires business partners, suppliers and service providers to work continuously toward sustainable resource use, reduced environmental impact, improved energy efficiency and lower GHG emissions, integrated into supply-chain governance and monitoring.

Actions and resources in relation to climate change policies

Reference: pages 44-45.

Own operations (Scope 1&2): a comprehensive climate action plan has run since 2016. The 100% renewable-electricity target for European/North American sites was achieved in 2024; Asian sites target 2030. Feasibility studies on converting gas-fired hardening furnaces "have not resulted in a viable business case for conversion" to date; reassessed regularly. Local units pursue energy efficiency (heat recovery, equipment replacement, LED lighting, ventilation, climate control).

Supply chain (Scope 3): decarbonization is focused on steel raw materials, the finished screws category, and plating/transportation services - the categories with the largest emissions share per a 2021 GHG Protocol/SBTi screening. Bulten increases the share of recycled (scrap-based) steel, since green-hydrogen steel is not currently available in its wire-rod supply route.

Key 2025 actions: two sites signed renewable-electricity contracts (~2,000 tCO2e savings); motor/air-conditioning upgrades in Taiwan (~60 MWh, ~30 tCO2e/yr, ~€18,000 investment); a new heat-treatment furnace in Poland; DynaSty research-project implementation reducing atmospheric-gas consumption (~50 tCO2e/yr); and onboarding two new scrap-based-steel suppliers (~9,000 tCO2e reduction), bringing Bulten "almost" to its 2030 Scope 3 target already in 2025.

Targets related to climate change mitigation and adaptation

Reference: pages 45-46.

Targets were set in 2021 per the SBTi "well below 2°C" scenario and validated by SBTi; Bulten will review them in 2026.

Own production (Scope 1&2, market-based): -30% absolute by 2030 vs. 2019 base year (22,475 tCO2e), without offsets; target boundary covers all geographies. Achieved already in 2021 and improved further despite business growth. 2025 result: 15,732 tCO2e, a 70% reduction.

Supply chain (Scope 3): -25% per tonne of product sold by 2030 vs. 2019 (2.42 tCO2e/tonne baseline), narrowed to categories covering 75% of 2019 Scope 3 emissions - Purchased goods and services (raw materials, surface treatment, purchased screws) and Upstream transportation and distribution. 2025 result: 1.81 tCO2e/tonne, a 24% reduction (nearly at the 25% target).

Overall: total Scope 1, 2 and 3 emissions down 41% vs. 2019. Baseline was recalculated for the 2022 Russia divestment and 2023 Exim acquisition, with limited impact; methodology unchanged. Main levers: recycled raw-material content, renewable-electricity-produced raw materials, and supplier partnerships.

Energy consumption and mix

Reference: page 46 (table E1-5); accounting policies same page.

The 2025 decline is "primarily attributable to lower production volumes"; the renewable/fossil mix shift stems mainly from new renewable-electricity contracts at two facilities in Asia. Nuclear power is used at facilities in China and Taiwan via the standard national electricity mix. Entity-specific metrics: renewable-electricity share 95% (2024: 90%); average energy intensity 2.51 kWh/kg cold forged and machined goods (2024: 2.26). Bulten is a high climate-impact sector (NACE Manufacturing).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 46-47 (table E1-6); methodology same pages.

Scope 1 is mainly natural-gas combustion in heat furnaces plus fossil-based electricity at some Asian facilities; the largest emissions sit in the supply chain (raw materials and services). 97% of renewable electricity is certificate-backed (Guarantees of Origin, REC, Green Energy Certificates, Taiwan REC); the remainder is self-generated or residual mix. Scope 3 is 51% primary-data, 49% secondary-source (database) calculated. Scope 3 emission intensity is tracked per tonne of product sold, covering ~75% of Bulten's Scope 3 per the 2019 assessment. Biogenic Scope 2/3 are recorded as "Unknown."

Internal carbon pricing

Reference: page 47.

Full text of the disclosure: "The company does not currently apply any internal carbon pricing in its operations or in investment decisions."

This is a complete disclosure of a nil position rather than an omission: E1-8 is listed in Bulten's Appendix A content index at page 47, alongside E1-6. No shadow price, internal carbon fee, or implicit price used in investment appraisal is described anywhere in the climate chapter; investment decisions on climate-related actions (e.g. the Taiwan energy-efficiency upgrade, the Poland furnace replacement) are instead described in terms of direct CapEx/OpEx and emissions-reduction outcomes rather than an internal carbon price (E1-3, pages 44-45).

Policies related to pollution

Reference: page 48.

Bulten's material E2 scope is soil pollution only: "One material impact as well as one material risk to Bulten connected to pollution were identified... Both the material impact and the material risk identified have been categorized under own operations" (IRO-1, page 48).

The Environmental Policy covers this: it "summarizes its commitment to constantly strive to reduce material impact from own operations and products throughout the value chain related to soil pollution," committing Bulten to act responsibly, monitor and follow up on performance, and comply with applicable environmental laws in all countries of operation. It requires proactive assessment of environmental/climate impacts across the value chain, systematic activity programs with clear targets, employee training, and consistent business decisions. The policy will be updated in 2026.

Impacts related to emissions to soil in the supply chain are addressed through the Code of Conduct for business partners, suppliers and service providers. During the year, remediation was completed for an oil leak that occurred at a Bulten production facility in 2024; the investigation confirmed no further environmental damage resulted.

Actions and resources related to pollution

Reference: page 48.

Soil-contamination risk at Bulten's facilities is linked primarily to accidental leaks and aging concrete foundations. Any leakage is handled under local emergency response plans; preventive measures sit in local risk management and preparedness planning. Bulten's standard for preventive actions covers proper storage/containment of hazardous materials, fire-risk reduction, and collection of contaminated water and extinguishing materials.

Monitoring: regular audits and inspections of buildings, concrete structures, containment systems and equipment, plus soil sampling; foundation controls and measurements are part of ongoing risk assessments. A completed 2025 action was the remediation of a 2024 oil leak to the ground at one production facility, managed through the full local investigation-and-remediation process with no further environmental damage recorded.

Targets related to pollution

Reference: page 48.

Bulten's goal is "zero incidents that cause environmental impact, including soil contamination." The company explains there are "no systematic or intentional releases to the soil," so no regular soil-emission measurements or quantitative legal targets apply; instead Bulten relies on preventive measures, monitoring and maintenance programs to minimize leak risk and support the zero-incident goal.

All accidents/incidents involving potential soil contamination are reported to the Group per Group requirements and, where relevant, to local authorities under established local procedures. Entity-specific metric: number of accidents resulting in soil contamination - zero (0) in 2025, tracked as the company's chosen measure of progress toward the zero-incident goal.

Pollution of air, water and soil

Reference: page 48.

Bulten's only material E2 sub-topic is soil pollution (not air or water pollution, and not substances of concern). The two material IROs are "Emissions to soil from own operations" (potential negative impact - minor accidental leaks of lubricants or metals) and "Costs of remediating any soil contamination from the company's own operations" (risk), both categorized under own operations (IRO-1, page 48). Bulten's entity-specific metric under E2-4/E2-3 is the number of accidents resulting in soil contamination - zero (0) in 2025.

Appendix B lists "ESRS E2-4 Amount of each pollutant listed in Annex II of the E-PRTR Regulation... emitted to air, water and soil, paragraph 28" against the Regulation reference at page 48 (page 75), consistent with the soil-pollution scoping rather than an air/water emissions inventory - no E-PRTR pollutant quantities to air or water are reported, as air and water pollution were not identified as material sub-topics.

Policies related to water and marine resources

Reference: pages 48-49.

Bulten's single material E3 impact is "Withdrawal of Freshwater for own operations" (actual negative impact, own operations only); "no impacts, risks and opportunities specifically connected to marine resources have been identified" (IRO-1, page 48-49).

Water is drawn mainly from municipal supply, with a local stream used as cooling water at one facility. Production wastewater "is treated and reused to the extent possible"; contaminated water (including water-treatment concentrate) is collected by contracted specialists, and other water goes to municipal wastewater treatment. Each unit follows local permit requirements.

The Environmental Policy covers water: it commits to reducing/managing water as resource-efficiently as possible via process improvements, best practice and legal compliance in areas of material water risk, defining how withdrawal, consumption and treatment should be managed locally. Key 2025 action: continued in-house and third-party wastewater treatment at all sites, and resource-efficient product/technology development to reduce lifecycle environmental impact.

Actions and resources related to water and marine resources

Reference: page 49.

Bulten assessed water-scarcity risk using WRI's Aqueduct tool, identifying one production site in China in a medium-high water-scarcity area; that site uses water only for cleaning, drinking and hygiene, with no local-authority restrictions. A 2024-2025 switch from a solvent-based to a water-based cleaning process factored in water efficiency. Sites conduct their own water-dependency and impact risk assessments and engage with local authorities on permits; suppliers are required via the Code of Conduct to strive to reduce their own water use.

Poland surface-treatment plant (built 2023): designed with a strong focus on minimizing water consumption via internal treatment and recycling; around 75% of production water is recycled and reused. Contaminated water is neutralized, separated by sedimentation, then further treated by reverse osmosis, evaporation and crystallization for reuse. In 2025, a high-pressure reverse-osmosis system was installed, and 71% of the facility's water was recovered and reused during the year.

Targets related to water and marine resources

Reference: page 49.

Bulten previously held a group-wide target to cut water intensity per produced tonne by 10% up to 2024 versus 2019 (water intensity = total Group water intake / tonnes of cold-forged or machined steel). The company is now reviewing its environmental objectives and, "based on the fact that water availability and local conditions vary significantly between different operating locations," will establish local water-management targets rather than a single global target, to ensure responsible, efficient water use and reduce impacts on surrounding water bodies and ecosystems. Progress will be monitored through regular environmental-data reporting.

Bulten states explicitly: "Bulten has no mandatory obligation to implement water-related targets. Therefore, the water target can be considered a voluntary goal that Bulten has chosen to introduce at the Group level."

Water consumption

Reference: pages 49-50 (table); accounting policy same pages.

Consumption = total withdrawal minus water discharged to the environment or third parties; rainwater used at the Germany fire-fighting pond and river cooling water at the Sweden site are excluded, as both are returned to their source. The method changed in 2025 (from measured intake to intake-minus-discharge), restating the 2024 figure from 62.6 megaliters. December 2025 data is extrapolated from January-November actuals.

The reduction is "mainly due to the decrease in production volume, as well as some additional measures to optimize water use." One facility was newly identified in an increased water-stress area but records zero consumption under the ESRS definition, since all withdrawn water is externally treated before return to nature. Entity-specific metric: water intensity 1.59 liter/kg produced product (2024: 1.57).

Policies related to resource use and circular economy

Reference: page 50.

Bulten's material E5 IROs are two resource-inflow impacts - "Use of Fossil Energy Resources in Supply Chain" (actual negative impact, upstream) and "Use of large quantities of metal raw materials" (actual negative impact, own operations) - plus one waste impact, "Waste Generation" (actual negative impact, own operations); "No financial risks or opportunities have been identified" (IRO-1, page 50).

Main raw materials: wire rod of steel, stainless steel and aluminum, and rods of brass, steel, stainless steel and aluminum; waste is primarily scrap metal from processing.

The Environmental Policy names three material areas: improving raw-material efficiency, increasing raw-material circularity, and reducing waste with responsible waste management, pursued through targets, regular follow-up, employee empowerment and business decisions that factor in climate/environmental impact. The Code of Conduct for business partners, suppliers and service providers requires partners to continuously improve material efficiency, reduce waste, and improve waste management/recycling.

Actions and resources related to resource use and circular economy

Reference: pages 50-51.

Main circularity activities: increasing the use of raw materials with a high secondary-material share, and optimizing processes to minimize waste while increasing reuse/recycling. Scrap-based steel is now standard practice; the medium-term focus is expanding post-consumer scrap (steel used by end-users, more available than industrial scrap). Bulten collaborates directly with brass suppliers on scrap take-back and recycling.

Metal waste is sent for recycling, in some cases via direct collaboration with raw-material suppliers; washing/surface-treatment waste (oil, chemicals, contaminated water) is separated and recycled where possible, with the remainder sent for energy recovery or destruction. At the Poland facility, recovered oil from wastewater treatment is recycled on site and reused in the quenching bath, cutting fresh-oil consumption by 50%. Packaging is sorted and sent to external partners for recycling.

2025 actions: onboarded a new scrap-based steel-wire supplier using a high share of post-consumer scrap and renewable-electricity melting; began work to run wire-rod rolling on renewable electricity with the same supplier; two facilities added plastic-waste sorting. Elevated 2024 waste volumes (Poland water-treatment disturbances) returned to normal levels in 2025 through optimization and additional treatment steps.

Targets related to resource use and circular economy

Reference: pages 51-52.

Primary target: increase the share of scrap-based steel of total steel used in production. Scrap-based steel is defined as steel from electric-arc furnaces with over 70% scrap content; blast-furnace steel counts as entirely non-scrap despite typical 15-20% content. This target sits within the senior-executive STI scheme (GOV-3) and is reviewed and updated annually; it currently applies to the European organization only, as recycled-steel procurement can currently only be managed at that level (Asia efforts are underway).

For 2025, the target was 52% recycled material. Result: 61% for European operations, equating to 56% group-wide when extrapolated.

No specific circular-design-of-products target exists, though the Environmental Policy names product development that decreases lifecycle environmental impact as a key area. Waste target: reduce waste volume by 10% per tonne of goods produced by 2024 (2019 base year), a general goal not tied to a specific level of the waste hierarchy; Bulten is reviewing this alongside its other environmental goals. All E5 targets, both resource-inflow and waste, "are set as voluntary objectives."

Resource inflows

Reference: pages 51-52 (table); accounting policy same pages.

Main raw materials: wire rods of steel, stainless steel and aluminum, and rods of brass, steel, stainless steel and aluminum; plating/coating chemicals (zinc-nickel, zinc-phosphate, zinc-iron, zinc-flake). Coatings and raw materials contain no rare earth metals, but small quantities of tin and cobalt - metals associated with conflict-affected/high-risk areas - are managed through a conflict-minerals due-diligence process.

Total weight is calculated from received-goods data (raw materials plus finished products delivered), with intra-group double counting excluded. Secondary-material share uses supplier-specific recycled-content data where available and literature-based averages for aluminum/copper where not; packaging is excluded for lack of reliable data. Entity-specific metric: scrap-based steel use 56% (2024: 41%).

Resource outflows

Reference: page 52.

Bulten's products are fasteners - standard and customized - "largely made of metals, but there are also smaller amounts of plastic and rubber products," including both in-house manufactured and purchased items distributed through Bulten's quality-assured network.

Outflow management centers on waste streams rather than product take-back schemes. Steel scrap generated in processing is collected for metal recycling/reuse, supporting circular material flow. Washing and surface-treatment operations separate oils, lubricants, chemicals, metal sludge and contaminated water for recycling or recovery where feasible, on-site or externally; remaining fractions go to energy recovery or safe destruction. A specific saline residual material is generated by the Poland surface-treatment plant's wastewater treatment and sent for external handling under local environmental requirements. Packaging waste (cardboard, wood, plastic) is sorted and sent for recycling/material recovery.

No recyclable- or recycled-content rate is disclosed for products or packaging placed on the market, and durable-product outflow metrics are not separately quantified beyond the waste tables (see E5-5-Waste).

Waste

Reference: pages 52 (table); accounting policy same page.

Data is reported quarterly by local sites, mostly sourced from contracted waste-management providers, aggregated by Group sustainability; December is extrapolated from January-November actuals. The bulk of non-hazardous waste is steel scrap from own production; hazardous streams are largely saline residual material from the Poland surface-treatment plant's water treatment. The 2025 drop in non-hazardous waste reflects lower production volume and effective corrective measures for the Poland water-treatment disturbances that had elevated 2024 volumes. Entity-specific metric: waste intensity 0.21 kg/kg produced product (2024: 0.29).

Policies related to own workforce

Reference: pages 54-55.

Bulten aligns its policy framework with the UN Global Compact, UN Guiding Principles on Business and Human Rights, ILO standards, and the OECD Guidelines.

Code of Conduct: covers fair working conditions (labor-law compliance, at-least-minimum compensation, working-time/rest management), health and safety (zero-accident ambition, incident analysis), freedom of association, and zero tolerance for harassment, discrimination and child/forced labor including trafficking.

Health and safety policy: targets a long-term sustainable workplace, zero accidents, zero tolerance for discrimination/harassment/substance use at work, with local site directives supplementing the global policy.

Global HR Policy and manual: builds a workplace "on trust, openness, and participation," guided by core values (Professional, Innovative, Dedicated, Empowered); requires age/identity/work-permit verification before employment, prohibits recruitment-cost charges and ID confiscation, and upholds freedom of association.

Policy on forced labor and trafficking: a separate Statement Against Modern Slavery and Human Trafficking describes safeguards including free termination rights, no deposits and no ID confiscation. All policies are reviewed on new legal requirements or operational change; mandatory Code of Conduct training is given to new employees and managers.

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

Reference: page 55.

Key mechanisms: an Employee Engagement Survey (EES) every 18 months with an external partner (May 2025 survey: 81.6% response rate, up from 79% in 2023), with local HR/management workshops to analyze results with employee representatives and build targeted action plans; an annual development dialogue (ADD), supplemented from late 2025 by a Year-End Review process tracking ADD-goal progress and performance ratings; and occupational health and safety committees/forums adapted to local regulation, meeting at a locally varying frequency.

Effectiveness is assessed via survey participation, survey-index results, action-plan implementation, and ADD completion share. Bulten also monitors staff turnover (see S1-5, S1-6). The company additionally states it "actively promotes meaningful social dialogue," respecting freedom of association; 65% of all Bulten employees are covered by collective bargaining agreements, mainly at European factories, with alternative dialogue forums used where unions are restricted or absent.

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

Reference: pages 55-56.

Employees can raise issues with managers, HR, or another designated management function, or use Bulten's Group-wide whistle-blower system, an electronic, independent and autonomous channel meeting the EU Whistle-blower Protection Directive, available in oral form and via www.bulten.com and the intranet.

Governance: all reports are documented and managed by an independent law firm; a parent-company Board member and the CFO receive information on all valid reports; the CFO coordinates internal investigations with external legal counsel and keeps the Board informed via its committees; the Remuneration Committee monitors process effectiveness. Reports are retained no longer than two years after case closure. If investigators face a conflict of interest, the case is reassigned.

Bulten states it "does however not currently assess whether employees trust the whistle-blower system as a way to report and have the issues addressed." Safety incidents/near-misses follow separate local procedures with Group- and cross-subsidiary reporting of accidents.

Taking action on material impacts on own workforce

Reference: pages 56-57.

Training and skills development: the enhanced annual development dialogue (ADD) now includes a role-gap assessment and forward-looking development plan; the Bulten Fastener Academy (e-learning on fastener technology) and Bulten Sales Academy provide structured training.

Occupational health and safety: an OHS management system certified to ISO 45001 covers ~95% of employees. 2025 actions: expanded safety walks (375 conducted, up from 267 in 2024, with 91% of identified risks resolved), a new contractor safety standard, cross-site internal audits, a Safety First rules launch, two safety campaigns, and a Group-wide Safety Week 2025. Results: work-related accidents reduced by roughly one-third, and accident frequency down 30%.

Harassment prevention: governed by the code of conduct, mandatory training, and the whistle-blower channel described under S1-3; managers hold particular responsibility to act promptly on suspected misconduct.

Targets related to own workforce

Reference: page 57.

Training: Bulten targets 100% ADD completion; 99.4% of employees completed their ADD in 2025. No target is set for total training hours, though hours are monitored (see S1-13).

Health and safety: targets are set on directly influenceable preventive measures rather than lagging outcomes. The 2025 target was at least 240 safety walks with 80% of identified risks/non-conformities resolved during the year; Bulten delivered 375 safety walks with 91% of risks resolved, exceeding both elements of the target.

Harassment: Bulten "has established policies that clearly express zero tolerance for harassment and other violations of human rights," tracked through incident data reported under S1-17 rather than a numeric target. Targets, action plans and results are followed up monthly by Group and local management and reported regularly to the Board.

Characteristics of the undertaking's employees

Reference: page 58 (tables); accounting policy same page.

Headcount at 31 December 2025: 1,777 (26% women / 74% men), average headcount 1,862 during the year. By country: China 278 (2024: 335), Poland 593 (658), Sweden 369 (385), Germany 188 (201).

By contract type/gender: permanent 1,668 total (men 1,220, women 448; 2024: 1,730); temporary 109 (men 91, women 18; 2024: 216); full-time 1,747 (men 1,306, women 441; 2024: 1,917); part-time 30 (men 5, women 25; 2024: 29).

Turnover: 379 employees left in 2025 (2024: 375), of which 18 due to retirement (17); turnover rate 20% (2024: 20%).

Code of Conduct training completion (newly hired): 84% (2024: 97%) - the decline attributed to "limited resources that caused delays."

Age diversity: under 30 years 12% (2024: 15%); 30-50 years 61% (58%); over 50 years 27% (27%).

Characteristics of non-employee workers

Reference: page 58 (table).

Bulten defines non-employees as agency workers, contractors and consultants - people without a legally binding employment contract who supply labor on a regular or longer-term basis, distinct from employees who hold a temporary or permanent contract with a Bulten facility.

Numbers are headcount at year-end, collected from local-site HR systems. Data is split between blue-collar and white-collar non-employees, and from 2025 also between self-employed and third-party-employed. Bulten states no further qualitative or quantitative characteristics of non-employees are collected as part of the reporting procedure.

Training and skills development metrics

Reference: page 58.

The annual development dialogue (ADD) - a minimum of two occasions per employee per year - is Bulten's key structured process for discussing performance, career development and development needs.

Bulten also cites two entity-specific metrics in this area beyond the tabulated figures above (see S1-4 for narrative detail on the Fastener Academy and Sales Academy training programs feeding into these hours).

Health and safety metrics

Reference: pages 58-59 (tables); methodology note same pages.

Methodology change: Bulten switched its accident-frequency-rate denominator from 200,000 to 1,000,000 hours worked for ESRS reporting.

All own production units and major logistics centers are ISO 45001 certified, covering ~95% of employees. Safety walks: 375 performed in 2025 (2024: 267), with 91% of identified risks resolved (2024: 88%).

Incidents, complaints and severe human rights impacts

Reference: page 59 (table).

Human rights incidents and complaints are handled per Bulten's Code of Conduct, with specific suspected impacts routed through the whistle-blower system (see S1-3).

No human-rights-related complaints, National Contact Point referrals, serious incidents or associated fines were recorded in either 2025 or 2024. (Note: a separate whistle-blower table under G1-4 records 43 total 2025 whistle-blower reports across all categories, of which 2 concerned suspected corruption/bribery and 41 concerned other departmental/leadership/work-environment complaints; none of the 43 are recorded here as confirmed human-rights violations.)

Policies related to value chain workers

Reference: page 60.

Bulten expects suppliers to align with the UN Guiding Principles on Business and Human Rights, OECD Guidelines on Responsible Business Conduct, the UN International Bill of Human Rights, and ILO core labor standards, set out through four instruments: the Code of Conduct for business partners, suppliers and service providers; the Statement Against Modern Slavery and Human Trafficking; and the conflict minerals policy.

The Business Partner Code of Conduct covers human rights, labor conditions, health and safety, climate/environmental management, business ethics, anti-corruption and fair competition, based on the UN Global Compact, ILO conventions, AIAG automotive-industry principles, OECD Guidelines and UNGPs. It requires suppliers to safeguard workers' human rights and dignity for all employee types (part-time, temporary, migrant, student intern), prohibits forced/child labor (no sub-minimum-age workers, no ID confiscation, no recruitment fees), and is signed by all suppliers during onboarding, managed via the SRM system.

The conflict minerals policy follows OECD Due Diligence Guidance for tin, tantalum, tungsten, gold (3TG), cobalt and mica, applying to all direct-material suppliers.

Processes for engaging with value chain workers about impacts

Reference: pages 60-61.

Bulten states it "does not currently have a dedicated, standalone process for engaging directly with value chain workers or their representatives"; engagement is embedded within supplier-management processes instead, with direct worker engagement occurring occasionally during on-site audits.

Supplier screening: initial evaluation covering commercial, quality, logistics, environmental, human-rights, social and governance criteria. Supplier audits: on-site verification of policies, management systems, financial status and purchasing/goods flow; may include direct worker engagement at prospective Tier 1 suppliers. Ongoing review: the Drive Sustainability Self-Assessment Questionnaire (SAQ) (human rights, child/forced labor, employment conditions, H&S, environment, business ethics) - Bulten "has currently started its second round" - and an annual Internal Supplier Assessment (ISA). Supplier scorecards and regular meetings provide continuous dialogue. Conflict minerals reporting is a yearly RMI-based exercise with Tier 1 suppliers of 3TG/cobalt/mica-containing materials. Effectiveness measurement "is not yet in place," though supplier-assessment and audit outcomes are monitored. Bulten "aims to review how to strengthen its monitoring and engagement with suppliers over the medium-term."

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

Reference: pages 61-62.

Bulten's Group-wide whistle-blower system is available to all relevant stakeholders including value chain workers, for reporting corruption, bribery, human-rights violations and other misconduct, under the same EU Whistle-blower-Directive-aligned process described under S1-3.

Under the supplier Code of Conduct, suppliers must take "diligent and reasonable steps to prevent human and labor rights violations" in their own supply chains, including conducting their own impact assessments. If a supplier identifies child or forced labor or trafficking, it must immediately ensure the affected employees' safety and wellbeing, remove them from the situation, engage local authorities/support organizations, and where feasible support recovery and reintegration including alternative employment.

The Drive Sustainability assessment includes a grievance-mechanism and non-retaliation commitment review. A supplier failing requirements may submit an improvement plan for reassessment. Reporting-channel availability is checked during on-site audits; worker awareness or trust in the channels is not currently assessed, nor the type of issues raised. In 2025, no whistle-blower cases reported concerned workers in the supply chain.

Taking action on material impacts on value chain workers

Reference: page 62.

Bulten's primary mitigation is supplier selection: prioritizing well-established suppliers in lower-risk geographies, and building long-term relationships that limit annual new-supplier onboarding. "The majority of Bulten's tier 1 supply chain is based in geographic regions where there is relatively strong compliance with human rights related legislation."

The supplier Code of Conduct sets labor, human-rights and environmental requirements for suppliers and their subcontractors, acknowledged and complied with as a contractual condition. New/prospective suppliers undergo ESG-risk screening before engagement and periodic screening thereafter (human rights, corruption, environmental harm), particularly in higher-risk geographies/sectors; existing suppliers are monitored via scorecards, the Drive Sustainability SAQ, and audits/internal assessments (S2-2). Non-compliant suppliers are asked for an improvement plan; Bulten "reserves the right to end a supplier relationship if a supplier shows a consistent or significant lack of commitment." The Purchasing function owns these processes and monitors their efficiency (results under S2-5).

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

Reference: page 62.

Bulten states: "Bulten has not, at this point in time, set any outcome-oriented and time-bound targets and metrics directly related to value chain workers." Effectiveness is instead tracked through process-coverage metrics:

Exim (acquired 2023) is reported separately as it begins Code of Conduct signing and SAQ assessments. No serious incidents or significant Code of Conduct violations were identified in 2025, and no contract terminations resulted from such a cause.

Business conduct policies and corporate culture

Reference: pages 63-64.

Bulten states operations are conducted "in an ethical manner, in compliance with legislation and the company's core values... the only option for Bulten." As a UN Global Compact member, Bulten works to its ten principles on human rights, labor, environment and anti-corruption.

Governing policies: the Code of Conduct (responsible trade/anti-corruption, fair competition, transparent accounting, personal-data protection, insider information, conflicts of interest, problem reporting - binding on the Executive Board, all managers and employees); the anti-corruption policy; the anti-competitive-behavior policy (zero tolerance, strict local-law compliance); and the Code of Conduct for business partners, suppliers and service providers. Supporting manuals include a finance manual and authorization rules.

Policies are reviewed regularly by Group Management, communicated to new employees, and the supplier code is signed by all new suppliers. Compliance training is mandatory at onboarding; an in-depth anti-corruption and business ethics e-learning is mandatory for white-collar employees in higher-risk functions (purchasing, sales). Training coverage of at-risk departments: 100% in 2025 (2024: 97%).

Prevention and detection of corruption and bribery

Reference: pages 64-65.

"Bulten does not tolerate any form of corruption or bribery." Prevention/detection tools: the Code of Conduct, Business Partner Code of Conduct, finance manual, anti-corruption policy, authorization rules, anti-competition policy and guidelines, supplemented by training, segregation of duties, and review/approval processes. Bulten "performs compliance checks/internal control to detect unusual transactions and investigate suspected violations," with remedial actions potentially including disciplinary measures or contract termination. Investigations run independently of management via the whistle-blower system (see S1-3); the CFO and one Board member receive all reported cases, informing the Remuneration Committee.

Employees must avoid dependence on suppliers/partners; offers such as board seats require pre-approval to avoid conflicts of interest. Training completion: 95% of new/temporary employees completed Code of Conduct training in 2025 (2024: 97%); 100% of newly hired white-collar employees completed business ethics training (2024: 97%). All Board members have signed the Code of Conduct. Business partners must comply with the Business Partner Code of Conduct; Bulten performs anti-corruption due diligence before engaging business relations and includes standard anti-corruption clauses in agreements.

Targets related to business conduct

Back-filled from the business conduct chapter, where effectiveness is tracked as part of the MDR-T disclosures rather than as a numbered disclosure requirement. G1-3 (Targets) became a standalone DR only in the 2025/2026 ESRS.

Bulten discloses no numeric, outcome-oriented business-conduct target (e.g. no target percentage for confirmed corruption incidents or investigation timelines). Consistent with MDR-T's alternative limb, effectiveness is tracked in the absence of an outcome target:

• Training-coverage tracking: "Share of at-risk departments covered by and having completed the training program" reached 100% in 2025 (2024: 97%) (G1-1, page 64); Code of Conduct training completion for new/temporary employees reached 95% and white-collar business-ethics training 100% (G1-3, page 64).
• Incident-handling effectiveness is explicitly assessed: after describing the 2025 whistle-blower incidents, Bulten concludes "the procedures described in section ESRS G1-3 to prevent, detect and manage allegations or incidents of corruption and bribery are considered effective. No additional measures are deemed necessary" (G1-4, page 65).

This training-coverage and effectiveness-assessment approach is the MDR-T "how effectiveness is tracked in the absence of a target" limb, applied here to business conduct.

Incidents of corruption or bribery

Reference: page 65 (table).

"During the reporting period, a total of 43 incidents were reported through the whistle-blower system. Two incidents concerning suspected corruption and/or bribery were reported during the year. These incidents were investigated but did not result in any confirmed cases and therefore no convictions, fines, or disciplinary actions." No incidents involved contracts with business partners, and no legal proceedings on corruption or bribery were initiated against Bulten or its employees. The remaining 41 reported incidents concerned various departments, leadership and work-environment complaints; all were investigated with corrective action taken where relevant and results communicated to the Board.

Bulten concludes the G1-3 procedures "are considered effective. No additional measures are deemed necessary."