Byggmax Group AB

Reference: page 22.

Byggmax's governance structure for sustainability sits within its ordinary governance bodies. The Board of Directors "has overall responsibility for sustainability governance and for integrating sustainability matters into the business plan, targets, risk management and policies," defines the double materiality assessment, and "monitors sustainability work quarterly through reports from the President and CEO and CFO and adopts the Sustainability Statement." The Audit Committee is "a preparatory body for the Board of Directors and is responsible for the review and quality assurance of the sustainability reporting," and reviews the Sustainability Statement before Board approval.

Day to day, the President and CEO is "responsible for the day-to-day administration and management of material IROs" and leads Group Management. The Finance Function coordinates and quality-assures the Sustainability Statement, with the CFO holding operational responsibility for reporting; the HR Function collects own-workforce data.

Composition: the Board has six non-executive members, 33% women / 66% men, with "no workers' representatives." Group Management has eight members, 38% women / 62% men. Members of both bodies "have attended training programmes related to CSRD and double materiality."

Reference: page 23.

Sustainability matters are handled "through decisions on strategy, risk management, double materiality assessment and reporting," with the Board "regularly informed about the status and development of the Group's sustainability targets, material sustainability-related risks and opportunities, and relevant regulatory changes" via reports from the CEO and CFO, mainly around the strategy/budget cycle and when adopting the Annual and Sustainability Report.

During 2025 the Board specifically: "established an updated double materiality assessment as a basis for reporting under CSRD and ESRS"; "addressed sustainability-related risks in the context of the double materiality assessment"; "addressed and established the Ethics Policy as part of the annual review of governing documents"; and "monitored the Group's sustainability targets and outcomes." The report states no other sustainability matter required special handling by the Board beyond these.

Reference: page 24.

Byggmax states plainly that it "does not have any incentive programmes linked to sustainability or climate-related targets or results." The Remuneration Committee of the Board is responsible for preparing and monitoring the Group's remuneration and incentive programmes generally, with further detail cross-referenced to Note 9 of the Annual Report and the Remuneration Report.

This is a clean nil disclosure: unlike some peers, Byggmax's executive incentive schemes carry no sustainability or climate metric for FY2025.

Reference: page 24.

"Due diligence is an integral part of Byggmax's governance and risk management, and its purpose is identifying, preventing, mitigating and managing actual and potential negative impacts on people, the environment and business ethics in own operations and in the value chain."

The statement carries a table mapping the ESRS due-diligence core elements to where they are addressed: embedding due diligence in governance/strategy/business model (GOV-1, GOV-2, SBM-3 general and per-topic, pp.22-52); engaging with affected stakeholders (SBM-2, IRO-1, E1-2, E5-1, S1-1, S1-2, pp.27-53); identifying and assessing adverse impacts (SBM-3, IRO-1, pp.28-52); taking action (E1-3, E5-3, S1-4, pp.36-54); and tracking effectiveness (E1-5, E1-6, E5-4, E5-5, S1-6, S1-9, S1-14, S1-16, S1-17, pp.38-58).

Reference: page 24.

"Byggmax's sustainability reporting is based on established processes for internal governance and control, which in the main follow the same principles as for financial reporting." The Board, through the Audit Committee, "monitors the Group's assessment of internal control, among other things through dialogue with auditors," while the CFO and Finance Function coordinate, quality-assure and consolidate sustainability data collected from HR/payroll and supplier/sales systems; climate and environment data compilation "takes place in proprietary templates, which involves manual handling."

Risk assessments are conducted annually, and the report names the two biggest risk areas explicitly: "the most material risks of inaccuracies or inadequate data quality are mainly linked to indirect GHG emissions and supplier data," citing standard figures, industry data, incomplete supplier input, limited traceability and variable supplier maturity. Controls include reasonableness assessments, reconciliation with historical data, and external-expert review before Audit Committee and Board sign-off.

Reference: pages 25-26.

Byggmax is described as "a leading Nordic retail chain in building materials and DIY products, operating in Sweden, Norway, Finland and Denmark with over 210 stores," combining an in-store range with online sales (18% of Group sales). As at 31 December 2025 the Group had 1,597 employees (1,105 Sweden, 379 Norway, 113 Finland/Denmark) and net sales of SEK 6,133 million. The Group sits in "Wholesale and Retail Trade" under NACE and reports as one IFRS 8 segment.

"Timber products, cement and concrete, as well as metal, are the largest material categories in terms of both net sales and environmental impact," and are flagged as the most significant materials for E1 and E5. The value chain runs from upstream raw-material and component suppliers, through direct suppliers and transport, to Byggmax's own stores/e-commerce, and downstream to home delivery, customer use and end-of-life management, with "most of Byggmax's climate impact" arising upstream from sourcing (timber, cement, concrete, metals).

Reference: page 27.

Byggmax "conducts ongoing dialogue with the Group's most important groups of stakeholders, who are customers, employees, suppliers, investors and society in general," mainly through existing forums (customer/market surveys, employee surveys and interviews, supplier days and audits, AGM/investor meetings, and industry bodies) rather than dedicated sustainability dialogues: "no separate, dedicated dialogues focusing on sustainability were therefore conducted" in 2025, though sustainability was folded into the employee survey and supplier reviews.

A stakeholder table lists key issues per group, e.g. customers (sustainable construction, product safety/labelling, end-of-life management), employees (health and safety, gender equality, skills development, industrial relations), suppliers (responsible sourcing, factory audits, the Paris Agreement, human rights, EPDs), investors (long-term value creation, green finance linked to Scope 1-3 targets, climate risk) and society, reached via the European DIY Retail Association (EDRA).

Reference: pages 28-29.

"Based on the double materiality assessment performed, a total of eleven IROs have been identified, resulting in four of the ten ESRS standards and eight of its sub-topics being assessed as material." The four material standards are E1, E5, S1 and S2, with S2 "Value chain workers" disclosed under a full-standard phase-in per ESRS 1 Appendix C (see BP-2). The impact/risk table records: E1 GHG emissions and energy use (negative impacts) plus a transition-cost risk; E5 virgin-material use and unrecoverable outflows (negative impacts); S1 work-related injury/ill health and equal-treatment/harassment risks in stores (negative impacts); and S2 poor working conditions, health and safety, and unfair treatment/human-rights risk in the upstream value chain (negative impacts).

On resilience: "the assessment of our resilience to climate-related risks is based on internal risk analyses... In the short and medium terms, the business model is considered robust, but long-term resilience needs to be analysed more systematically." In-depth scenario-based analysis and an updated resilience assessment are planned for the next reporting period. Note: the financial-effects sub-item of SBM-3 (paragraph 48e) is one of the disclosure requirements explicitly carried under the BP-2 phase-in list.

Reference: pages 30-32.

Byggmax first ran a double materiality assessment in 2023, "validated and updated in 2025 to ensure that all material aspects of our value chain have been included." The process covered the whole value chain upstream and downstream, drew on due diligence work, climate statements, supplier assessments, stakeholder dialogues, public market reports and business intelligence, with external sustainability specialists engaged throughout.

Impact materiality: scored on a five-point scale for scale, scope, irremediable character and likelihood. Financial materiality: scored for size of financial effect and likelihood, applied "regardless of whether Byggmax has control over the matter." Per-topic assessments follow: E1 used the IPCC SSP1-2.6 (Paris-consistent) and SSP3-7.0 (high-emissions) scenarios plus the IEA Net Zero by 2050 scenario as a "qualitative, science-based" reference, but "Byggmax has not carried out a climate scenario analysis at company level." E2, E3 and E4 (pollution, water, biodiversity) and G1 (business conduct) were each assessed and found to have "no significant sub-topics identified" at overview level, using external public-source data with acknowledged data limitations in the upstream value chain. E5 assessment identified Resource inflows and Resource outflows as material. Results were validated by Group Management and the Board adopted the updated assessment in 2025; no significant DMA process changes occurred during the year.

Reference: page 32.

Byggmax's own words: "A full list of the ESRS disclosure requirements applied in the preparation of the Byggmax Sustainability Statement is provided in the table of contents on page 19. Disclosures have been included where they are considered material to the reporting and relevant to describe the Group's policies, actions, metrics and targets related to identified material impacts, risks and opportunities. All disclosures in the Sustainability Statement comply with the applicable disclosure requirements in ESRS. The Sustainability Statement does not contain any entity-specific information."

The page-19 table of contents is the operative ESRS content index used throughout this file: it lists, by code, every disclosure requirement Byggmax reports against (ESRS 2 general disclosures in full; E1-1 through E1-6; E5-1 through E5-5; and a named subset of S1 codes), each with its page number. A disclosure requirement not printed in that index was treated here as not covered by the statement, consistent with the company's own statement that the index is the full list.

Reference: pages 33-34.

Byggmax has "adopted science-based climate targets validated by Science Based Targets initiative (SBTi) to reach net zero emissions throughout the value chain by 2040," guided by the Ethics Policy and Supplier Code of Conduct. Critically, though, the company is explicit that it has no formal transition plan: "Byggmax has not formally adopted a documented transition plan. Our climate targets serve as the basis for the Group's gradual transition efforts, and the focus is on implementing specific emission reduction actions within the framework of our existing business model and growth strategy."

It adds candidly: "We have made progress in our climate work but still have significant work ahead of us... We will also assess the possibility of developing a transition plan in future reporting periods." No locked-in-emissions assessment, no GHG-neutrality target date statement, and no disclosed CapEx/OpEx plan for the transition accompany this entry (see the audit file). No carbon offsetting is used: "No carbon offsetting has been implemented" (E1-6, page 39).

Reference: page 35.

Climate mitigation is governed by the Ethics Policy, the Group's overarching ethics document, which "addresses the areas of climate change mitigation and energy efficiency and emphasises that Byggmax should contribute to mitigating climate change both in its own operations and in the value chain through efficient use of energy, natural resources and raw materials," grounded in the UN Global Compact's ten principles and the Paris Agreement.

The Supplier Code of Conduct complements this with explicit supplier-facing environmental requirements: suppliers "must comply with applicable environmental legislation and make active efforts to reduce their climate impact," including reducing waste/emissions, reducing energy consumption, conserving natural resources and using environmentally friendly technologies. A supplementary travel and vehicle guideline states that "Group employees entitled to a leased car should if possible choose an electric car," with HR approval required for exceptions.

Reference: page 36.

Actions are grouped by decarbonisation lever. Electrification: "As of 31 December 2025, 75 percent (69) of the Group's forklifts were electrified," with a target to electrify the whole fleet by 2027; leased company cars are "majority... electric or hybrid." Renewable energy: "In all stores where Byggmax has its own electricity contracts, electricity is purchased from renewable sources," alongside a gradual switch to LED lighting and renewable heating as leases renew. Upstream value chain: shifting the product range to lower-emission alternatives, increasing supplier climate-data transparency, and following Fossil Free Sweden's cement/steel roadmaps. Transport transition: optimising fill rates via central warehouses, prioritising local suppliers and sea transport over long-haul road, and piloting a shift to rail transport in Northern Sweden.

On investment: "No current or future planned investments linked to the actions described above are of a material nature, nor do we have any significant investments linked to value chain actions."

Reference: page 37.

Byggmax has SBTi-validated targets against a 2020 base year: net zero across Scopes 1, 2 and 3 by 2040; a 90% absolute reduction in Scopes 1 and 2 by 2040 (interim: -75% already achieved by 2025, against 1,284 tCO2e vs. a 5,136 tCO2e base year); a 90% absolute Scope 3 reduction by 2040; and a Scope-3-intensity target of -52% per tonne of product sold, tracking at -8% in 2025 (0.29 vs. 0.32 base year). A separate transport target aims to cut emissions per transported tonne of goods by 70% by 2030, "in line with Sweden's target for domestic transport," with a 42% reduction already achieved versus 2010.

"No external stakeholders have been directly involved in the process of formulating the targets," though the company considers stakeholder perspectives indirectly reflected via SBTi validation and Paris Agreement alignment.

Reference: page 38.

Total energy consumption was 30,363 MWh in 2025 (all from rented stores, warehouses and offices), with a mix of "78 percent renewable energy, 22 percent fossil energy and 0 percent from nuclear energy sources." The renewable total is 23,580 MWh (77% by the detailed table), split between 4,126 MWh of renewable fuel and 19,454 MWh of purchased renewable electricity/heat/steam/cooling. Fossil energy totals 6,743 MWh: 6,498 MWh purchased fossil electricity/heat/steam/cooling, 155 MWh crude oil/petroleum, and 90 MWh natural gas. No 2024 comparatives are given for this table ("–"), and no energy-intensity figure for high-climate-impact-sector operations is populated in the extracted text.

Reference: pages 39-41.

Total GHG emissions were 165,789 tCO2e (market-based) in 2025, down 37% from the 263,831 tCO2e 2020 base year; Scope 3 is "over 99 percent of the Group's total greenhouse gas emissions." Scope 1 was 253 tCO2e (down from 482 in 2020); Scope 2 market-based was 1,031 tCO2e; combined Scope 1+2 market-based fell 75% versus base year to 1,284 tCO2e. Scope 3 totalled 164,504 tCO2e, led by Category 1 Purchased goods and services (131,883 tCO2e), Category 4 Upstream transport and distribution (12,002 tCO2e), Category 11 Use of sold products (8,212 tCO2e) and Category 12 End-of-life treatment (6,060 tCO2e). Categories 8, 10, 13, 14 and 15 are excluded as immaterial to the business.

Methodology follows the GHG Protocol under operational control; primary data covers 46% of indirect emissions, with the remainder estimated via distance-, weight- or cost-based proxies and named emission-factor sources (Swedish Energy Agency, DEFRA, NTM, VMK, IVL). Biogenic emissions totalled 51,115 tCO2e, almost all in Scope 3.

Back-filled from ESRS 2 IRO-1 (Assessment of E1 Climate change, pages 30-31) and SBM-3 (page 28), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Byggmax classifies its material climate IROs by physical/transition nature implicitly through its GHG-emissions, energy and transition-cost IRO rows (SBM-3, page 28-29) rather than a dedicated ¶15 table. On methodology and scenarios: "Byggmax has not carried out a climate scenario analysis at company level. Instead, a qualitative, science-based assessment has been carried out using the IPCC climate scenarios SSP1-2.6 (Paris-consistent) and SSP3-7.0 (high emissions) as well as the IEA Net Zero by 2050 scenario as a reference for climate change adaptation and transition risks in the Nordic building trade sector, including timber, cement and metal products" (page 30). This names one high-emission scenario (SSP3-7.0) and references a 1.5C-aligned reference (IEA NZE 2050), but no global-average-temperature projection per scenario, no explicit scope-of-operations statement, and no assumptions list (policy, macroeconomic, technology) are given; the analysis is stated to be qualitative and company-wide rather than dated to a specific exercise, and "in-depth climate analyses based on scientific scenarios are planned for the next reporting period."

Back-filled from ESRS 2 SBM-3, where this content is disclosed in the FY2025 report (page 28). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Byggmax states: "The assessment of our resilience to climate-related risks is based on internal risk analyses, experience-based knowledge of the operations, the company's strategic strengths and an overall qualitative analysis based on the IPCC climate scenarios SSP1-2.6... and SSP3-7.0... as well as the IEA Net Zero by 2050 scenario as a qualitative reference for climate change adaptation and transition risks... In the short and medium terms, the business model is considered robust, but long-term resilience needs to be analysed more systematically to provide a comprehensive picture and understanding of our impacts and the effects of risks." No ESRS-defined resilience analysis (covering strategy implications, financial-resource flexibility, or asset redeployment per AR 10) has been performed; the company commits only to updating "our current resilience assessment" alongside planned scenario work "in the next reporting period."

Reference: page 43.

The Ethics Policy "states that our products and processes should be designed in a way that makes efficient use of energy, natural resources and raw materials and minimises waste and residues," and Byggmax frames its greatest resource-use opportunity as sitting in "the sourcing of goods and materials." The report is candid about scope: "While our Ethics Policy does not explicitly address virgin materials, Byggmax strives for resource efficiency in all aspects of our sourcing, including for virgin materials such as timber," and explicitly notes the policy gap: "Our Ethics Policy or Code of Conduct does not at present include the transition from the use of new resources, including relative increase in the use of secondary (recoverable) resources, or the sustainable sourcing and use of renewable resources."

The Supplier Code of Conduct requires suppliers to reduce waste/emissions, reduce energy use, conserve natural resources and use environmentally friendly methods.

Reference: page 44.

"Resource efficiency is a natural and integral part of our operations," but the company is explicit that "working more systematically on these issues is at an early stage." Concrete actions: reviewing the PEFC-certified timber option "in every purchase," continuously reviewing the product range for lower-climate-impact alternatives, and prioritising local sourcing to cut transport-related resource use: "For 92 percent of the sales made during the year, the related goods were purchased from suppliers based in the EU," with the remaining 8% from outside the EU. Central-warehouse routing is also used to optimise truck fill factor.

Reference: page 44.

Byggmax's own voluntary target: at least 75% of purchased timber certified to PEFC or equivalent from 2027, up from roughly 50% in 2020, explicitly not statutory or science-based: "This is a voluntary target set by the Group and is therefore not statutory or based on scientific guidance." The company reports it "was achieved in 2025," while noting that as an uncertified company itself, "other certified companies will generally be prioritised ahead of Byggmax in the event of very high demand." The target is scoped to certified sourcing and "currently does not cover circular product design or minimising the use of primary resources."

Reference: page 44.

Timber is Byggmax's largest resource inflow by both volume and climate impact, "around 37 percent of our total purchases," entirely sourced from the Nordic countries, with "over 94 percent of the timber... certified according to PEFC or equivalent." Treated timber is about 40% of the timber range and complies with Nordic Wood Preservation Council classification. Total combined weight of products and technical/biological materials purchased was 533,293 tonnes in 2025, of which 22% was biological material of sustainable origin (i.e., certified timber). The company states plainly: "For 2025 reporting, we do not have access to sufficiently reliable data on reused or recycled materials."

Reference: page 45.

Byggmax argues durability as its main circularity lever: most products sold are "timber-based and therefore reusable materials with a long product life," citing timber structure lifespans of 30-60 years, concrete/cement 50-120 years, and steel products described as "highly recoverable." Packaging is limited (most goods sold in bulk/large units); e-commerce transport packaging "is recovered in partnership with recycling centres, and pallets are reused in the pallet exchange system of the major hauliers."

On quantification, the company is explicit about the gap: "For 2025 reporting, we do not have access to sufficiently reliable data to quantify resource outflows, such as the proportion of recyclable material in products and packaging. Work to strengthen data collection and traceability in the value chain is ongoing."

Reference: page 52.

Own-workforce policy runs through the Ethics Policy plus country-level Working Environment Policies: "All companies in the Group also have a Working Environment Policy adapted to each country's regulations," covering systematic work-environment management, victimisation/sexual-harassment guidelines, pay mapping and recruitment guidelines. "All forms of discrimination and harassment are prohibited, and we actively promote diversity and equality," applying to "all employees, regardless of gender, age, ethnicity, religion, sexual orientation, gender identity, disability or other personal characteristics." Policies are made available on the intranet, communicated at onboarding, and read annually by all employees; compliance is tracked via training, the employee survey and the whistleblowing system.

Reference: page 53.

Engagement channels include daily line-manager dialogue, twice-yearly employee interviews for permanent staff, trade-union cooperation, and an annual employee survey with a six-month pulse follow-up, coordinated by the HR Manager under Group Management oversight. For vulnerable groups specifically, Byggmax "prioritises dialogue with employees in more vulnerable roles," conducted through regular safety/fire/working-environment rounds and workplace meetings, with issues followed up and fed back to employees. Trade-union dialogue under current collective agreements addresses working-environment issues; effectiveness is evaluated via survey response rates, interview outcomes and union dialogue.

Reference: page 54.

Employees can raise concerns via line managers, another responsible function, HR, or "the Group's external independent whistleblowing service, which enables anonymous and secure reporting of suspected breaches, including victimisation or other irregularities." The service is run by an external, independent provider, is encrypted and password-protected, and cases are handled confidentially by a limited HR group with legal support where needed. "People who report in good faith will be protected against retaliation." Confirmed remediation cases are handled "in accordance with applicable national legislation, collective agreements and through dialogue with relevant trade unions," and the process also covers possible human-rights breaches.

Reference: pages 54-55.

Actions target the identified material risks: systematic work-environment management (continuous risk assessment, safety rounds, manager training, a health-and-safety training plan) and equal-treatment/diversity work (victimisation/harassment guidelines, competency-based recruitment training, annual pay mapping). 2025 initiatives named specifically: a Group-wide leadership programme on diversity/inclusion/anti-discrimination (running 2025-2026); an AI-supported recruitment step to reduce discrimination risk; and a new mobile internal training system. The report states plainly: "None of these actions have involved significant financial resources for implementation."

Effectiveness is tracked via workplace accidents, sickness absence, turnover and survey indices; the 2025 engagement index was 84 (up from 82) and the leadership index 86 (flat).

Reference: page 55.

Byggmax's own-workforce target is a zero-vision on occupational injuries: "an absolute target, meaning that no accidents should occur," deliberately not framed as a time- or percentage-reduction target "as such a structure would implicitly accept a certain level of accidents over time." The report states this is "currently the Group's only absolute target regarding its own workforce, and no further timed targets have been set." Monitoring is via Group-wide incident/accident reporting with root-cause analysis and employee feedback after each event; outcomes are reported under S1-14.

Reference: page 56.

Total headcount at 31 December 2025 was 1,597 (2024: 1,537): 1,115 men and 482 women (2024: 1,122 men, 415 women), by country 1,105 in Sweden and 379 in Norway (Denmark/Finland reported in the Group total only, below the 50-employee/10% country-disclosure threshold). Employee turnover was 17% in 2025 (297 departures), down from 23% (327) in 2024. Age distribution: 44% under 30, 44% aged 30-50, 12% over 50 (2024: 43%/46%/11%). Contract-type breakdown by gender is given for permanent, temporary and casual employees, though several 2024 comparatives are marked unavailable in the source tables.

Reference: page 56.

The diversity-metrics table covers the gender ratio of senior executives (defined as members of Group Management) but the underlying figures are flagged in the source as "Data not available" for the metric as extracted here; board- and management-level gender composition (33%/66% Board, 38%/62% Group Management) is instead carried under GOV-1 (page 22). Given the extraction gap on the S1-9-specific table, this entry should be checked against the original PDF page 56 layout before republishing the exact figures.

Reference: page 57.

"Proportion of employees in own workforce covered by certified health and safety system" was 100% in both 2025 and 2024. Zero work-related fatalities in either year. Recordable work-related accidents: 36 in 2025 (39 in 2024); accident rate 16% (17% in 2024, defined per million hours worked). Days lost to injuries/ill-health/fatalities: 283 in 2025, versus 24 in 2024.

Note the BP-2 phase-in: the datapoint "S1-14 88d and AR 94: The number of cases of recordable work-related ill health" is separately listed among the disclosure requirements to which Appendix C relief applies (page 21), so that specific sub-metric (distinct from the accident figures above) is not quantified this year.

Reference: page 57.

"The gender pay gap in 2025 was -1.2 percent, which means that on average women had marginally higher pay than men," calculated as the difference in average gross hourly earnings between genders, expressed as a percentage of male average pay. The annual total remuneration ratio (highest-paid individual's total remuneration versus the median of all other employees, pro-rated for part-year/part-time employment) was 24 in 2025; no 2024 comparative is given.

Reference: page 58.

"In 2025, a limited number of cases related to potential adverse human rights impacts were reported within the Group," mainly discrimination, harassment and grievances via internal mechanisms; "no cases were deemed to constitute serious breaches of human rights," no OECD National Contact Point grievances were filed, and no fines/penalties/damages were paid. Figures: 3 reported discrimination/harassment cases (1 confirmed); 7 non-governmental-mechanism complaints reported (6 confirmed); 0 OECD NCP complaints; SEK 0 in fines, penalties or compensation. No 2024 comparatives are populated in the source table.