Comer Industries S.p.A.

Reference: page 35; pages 35-38.

Comer Industries has a traditional governance model: the Board of Directors ("responsible for strategic direction and the overall management of the Group"), the Board of Statutory Auditors ("tasked with overseeing the BoD's activities"), the Supervisory Body and Internal Auditor ("internal control and monitoring functions"), and the Audit Firm (page 9; restated page 35).

The BoD composition by gender: 1 executive / 8 non-executive members, 2 women / 7 men (29% women) (page 36). The Board is supported by the Control, Risks, Sustainability and Related Parties Committee (CRSRPC), "a board committee with advisory and consultative functions," which links the BoD to operational functions (page 36). The BoD "delegates responsibility for managing the Group's impacts, risks, and opportunities... to the Quality, Sustainability & Compliance function" (page 36). "Currently there are no active employee representatives who are members of the governing and control bodies" (page 35).

Reference: page 38; pages 38-39.

"The results of the sustainability development program are monitored by the Quality, Sustainability & Compliance function and communicated to management via an information flow... which includes specific quarterly reporting to the CRSRPC about the performance of key sustainability indicators against targets" (page 38). "In accordance with applicable provisions, the BoD is informed annually regarding impacts, risks, and opportunities included in the double materiality assessment and is responsible for approving the results" (page 38).

The CRSRPC met five times in 2025 and twice in Q1 2026 (page 39), covering topics such as the 2024 Sustainability Report, the 2035 Sustainable Development Plan, the climate risk assessment update, the double materiality study, and the whistleblowing procedure (page 39).

Reference: page 39.

"The remuneration system for the Chair of the BoD and executives with strategic responsibilities includes a sustainability performance parameter in the variable remuneration component with a weight of 10%. This parameter assesses achievement (on/off) of the greenhouse gas emissions reduction target, calculated as the ratio between Scope 1 and Scope 2 market-based emissions and the total number of hours worked" (page 39). The same parameter "is extended to the variable incentive system for Executive, Manager, and Professional personnel who benefit from it" (page 39). The Remuneration Policy is approved by the BoD following consultation with the Appointment and Remuneration Committee, per Legislative Decree 58/1998 (page 39).

Reference: page 39.

Comer Industries provides "a mapping of the points in the Sustainability Reporting where information about this process is provided" (page 39) against the six ESRS due diligence elements:

• (a) Embedding in governance/strategy: GOV-1, GOV-2, GOV-3, SBM-3
• (b) Stakeholder engagement: GOV-2, SBM-2
• (c) Identifying/assessing adverse impacts: SBM-3, IRO-1
• (d)/(e) Taking action and monitoring effectiveness: "Disclosures are provided in the specific ESRS topical standards, where the set of measures - including actions and targets - through which impacts and risks are managed is disclosed" (page 39).

Reference: page 40.

"Comer Industries has adopted a risk management model inspired by the 'Risk Management' ISO 31000 standard... coordinated by the CRSRPC, while the Risk Management function is entrusted with the task of translating the BoD's guidelines on risk management into operation" (page 40).

The Sustainability function "conducts audits on the accuracy of the data and information collection processes" via a multilevel check system: automated system alerts on data entry, monthly completeness checks, quarterly reviews of local-unit data with documentary audits, annual verification during final consolidation, and periodic external partner review of methodology (page 41). Findings go quarterly to the Global Integrated System, Sustainability and Compliance Manager and the CRSRPC (page 41); Internal Audit also tests the control system as part of its annual audit plan (page 41).

Reference: page 41; pages 41-47.

"Comer Industries is a global leader in the design and manufacture of advanced power transmission systems and mechatronic solutions" for agricultural, industrial, and renewable-energy applications, with 11 manufacturing sites and 3,226 people including 2,806 employees as of December 31, 2025 (page 41). Consolidated turnover was 893.7 million euros (page 41).

The value chain runs from upstream suppliers of "steel and cast iron" and other raw materials, through own operations (R&D, machining, painting, heat treatment, assembly, aftermarket), to a downstream network of "more than 130 distribution partners" and OEM customers (pages 44-46). The 2035 Sustainable Development Plan, approved by the BoD on February 17, 2025, sets the strategic framework, mapping four pillars (Climate change / ESRS E1, Circularity / ESRS E5, Human capital / ESRS S1-S2, ESG Governance / ESRS G1) to material topics (page 47-49).

Reference: page 52; pages 52-55.

Comer Industries maps engagement activities and purposes for shareholders/investors, banks, employees, trade unions/workers' representatives, suppliers, customers, public administration, and community/territory (pages 52-53). For suppliers: "Sustainability performance assessment survey... Adherence to the Supplier Code of Ethics... Whistleblowing system" (page 52). For workers in the value chain, engagement is indirect: "the involvement of workers in the value chain is through engagement with key suppliers and not directly" (page 53, fn.9).

"An analysis of the inputs collected confirmed alignment between stakeholder expectations, the Group's business model, and the strategic direction already defined" and did not reveal the need for strategic repositioning (page 54).

Reference: page 56; pages 56-62.

The double materiality assessment identified "23 impacts, of which 14 were negative and 9 positive" and, on financial materiality, "5 material topics were identified based on 16 risks and 9 opportunities" (page 67). Material topics are ESRS 2, E1, E2, E3, E5, S1, S2 and G1; sub-threshold topics are E4 (biodiversity), S3 (affected communities) and S4 (consumers and end-users) (page 67).

IROs span climate change (GHG emissions, physical/transition risks), pollution (value-chain only), water, circularity/waste, own workforce (health and safety, DEI, skills, data security, human rights), workers in the value chain, and business conduct (corruption, whistleblowing, supplier relations) (pages 56-61). "All risks and opportunities identified have a financial impact. However, for the year under review, no significant financial effects were identified" (page 61, taking advantage of the ESRS 1 phase-in for financial-effects disclosure).

Reference: page 63; pages 62-68.

The double materiality assessment follows ESRS 1's two perspectives: "Impact materiality (inside-out)... Financial materiality (outside-in)" (page 62), coordinated by the Quality, Sustainability & Compliance function and approved by the CRSRPC and BoD (page 62). Compared with FY2024, "four negative impacts related to the topic of pollution in the upstream and downstream value chain were considered material," and the risk of "supplier non-compliance with company policies and the Supplier Code of Ethics" was added; "No impacts, risks, or opportunities considered material in fiscal year 2024 were deemed non-material in this analysis" (page 62).

Sub-threshold topics (E4, S3, S4) are explained individually: e.g. for E4, "Comer Industries does not conduct its business in areas exposed to risk of biodiversity loss, nor do its products affect the health and integrity of ecosystems" except the Lohmar site, which is "duly authorized" (page 66); for S4, "the business model of Comer Industries, which operates entirely within B2B markets," means no interaction with consumers or end-users (page 67).

Reference: page 68.

"Comer Industries submitted a Sustainability Statement in accordance with the ESRS Standards for the period January 1, 2025 - December 31, 2025," applying ESRS 1 (July 31, 2023) with no pertinent industry standard (page 68). "All relevant and applicable ESRS disclosure requirements and related datapoints are included in this Statement... The detailed list of reported indicators is provided in the index presented in chapter IRO-2" (page 30).

The index (pages 68-71) lists each disclosure requirement against a page reference, "Not material," or "The Group is taking advantage of the phase-in period" (citing Commission Delegated Regulation (EU) 2025/1416 and Appendix C of ESRS 1) for the anticipated-financial-effects disclosures (E1-9, E2-6, E3-5, E5-6).

Reference: page 95; pages 94-96.

Comer Industries discloses a Decarbonization Plan rather than a formal ESRS transition plan: "The Group currently has not formalized a climate transition plan aligned with ESRS definitions and requirements (ESRS E1 RA 1)," though its targets are "consistent with the emission reduction trajectory set by the Net-Zero 2050 initiative" (page 95, fn.50). The Plan "calls for reducing Scope 1 and Scope 2 market-based and Scope 3 absolute greenhouse gas emissions by 63% by 2035 compared to 2023" (page 94), via six levers: efficient production, efficient buildings, renewable energy, electrification, procurement policies, and ecodesign (page 95).

The BoD "approved the goals, actions, and related financial resources"; for 2025-2035 the Company planned "6.5 million euros," of which FY2025 budgeted 325 thousand euros but actual spend was "100 thousand euros" (page 95). Locked-in emissions are tied mainly to natural-gas steam production and long-lived capital goods (page 95).

Reference: back-filled from ESRS 2 IRO-1 / E1 SBM-3, pages 90-93. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

In 2024 Comer Industries conducted a Climate Change Risk Assessment (CCRA) "to evaluate potential risks the Group is exposed to and to assess business resilience... Based on what is defined in IFRS S2" (page 90); "the analysis remains valid for the current fiscal year" (page 90, fn.47). Physical risk used three IPCC RCP scenarios including the high-emission "RCP 8.5 - Assumes high emission levels and a significant temperature increase" (page 90); transition risk used IEA STEPS, APS and "Net Zero by 2050" (page 90).

Scope: "the entire Organization, including all production plants, sales offices, and Aftermarket sites" for own operations only - "Risk analyses only covered the Group's own operations. No analysis of physical and transition risks was conducted on the upstream and downstream value chain" (page 90, fn.47). Timing: the assessment dates to 2024 and was not refreshed with a new scenario run in 2025.

Reference: back-filled from ESRS 2 IRO-1 and E1 SBM-3/IRO-1, pages 62, 90-93. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"The Group has accrued a high degree of resilience to external events, which ensures a propensity to adapt, and to mitigate significant impacts/risks... This assessment is expressed in detail in the chapter on climate change, in which a resilience analysis was conducted, through which the ability of the business model to adapt and respond to both physical and transitional climate risks was assessed" (page 62).

Chronic physical risk (2030/2050/2080 horizons) found "chronic physical risks were not considered significant for the 33 sites analyzed," so "no specific mitigation measures were planned" (page 91). For acute risk, "no site presents acute physical risks deemed material," though mitigations are already in place: "flood barriers, evacuation devices, emergency power systems... air conditioning systems... breaks and flexible schedules" and a Rockford tornado emergency plan (page 92).

Reference: page 97; pages 96-97.

The Integrated Quality, Sustainability and Product Responsibility Policy promotes "reduction of greenhouse gas emissions and strengthening resilience to climate risks across the entire value chain," in line with "the Paris Agreement objective of limiting the increase in global average temperature to 1.5°C" (page 96). Scope extends upstream (supplier involvement on quality/health/safety/environment) and, for extremely hazardous substances, downstream (page 96).

Responsibility sits with the "President and CEO," with operational oversight by the "Quality, Sustainability, and Compliance function" (page 97). The Policy is based on ISO 9001, ISO 14001, ISO 45001 and ISO 31000 (page 97). One gap is disclosed: "The Quality, Sustainability, and Product Responsibility Policy does not include processes to manage impacts, risks, and opportunities related to climate change adaptation, but only processes related to mitigation" (page 96, fn.58).

Reference: page 99; pages 98-99.

2025 decarbonization projects totaled "just over 100,000 euros" (page 98): compressed-air system upgrades at Reggiolo and Sohland ("a reduction in emissions of 12 tCO2eq"), building-efficiency measures at Reggiolo, Rockford, Monguelfo, Irxleben and Bangalore ("16 tCO2eq" reduction), and renewable electricity certificates at five plants ("9,830 tCO2eq" reduction) (page 98).

"No major climate change adaptation initiatives were carried out in 2025" (page 98, fn.60). Implementation "does not depend on external preconditions such as grants of financial support... but depends solely on the availability of internal resources"; the Decarbonization Plan envisages a total commitment of "6.5 million euros" over 2025-2035 (page 98).

Reference: page 100; pages 99-101.

Three measurable, 1.5°C-aligned targets set with the SBTi Science Based Target Setting Tool: "Reduce Scope 1 and Scope 2 market-based greenhouse gas emissions per hours worked by 30%," "Reduce absolute Scope 1 and Scope 2 market-based greenhouse gas emissions by 63%," and "Reduce absolute Scope 3 greenhouse gas emissions by 63%," both by 2035 from a 2023 baseline (page 100).

FY2025 progress: Scope 1+2 market-based emission intensity fell from a 2022 baseline of 100.3 to a 2025 performance of 70.2 tCO2eq/machine hours (2030 target 85.0) (page 101); absolute Scope 1+2 fell to 19,365 tCO2eq against a 2023 baseline of 29,274 (2035 target 10,831) (page 101); absolute Scope 3 fell to 300,687 tCO2eq against a 2023 baseline of 375,739 (2035 target 139,023) (page 101). Targets "were developed without direct and structured stakeholder involvement" though expectations of customers, banks and investors were considered (page 101).

Reference: page 102; pages 101-103.

Total energy consumption was "87,974" MWh in 2025 versus "85,960" MWh in 2024, of which "75.52%" came from fossil sources and "24.48%" from renewable sources (page 101), up from 22.01% renewable in 2024. "Electricity accounted for 50% of total consumption, followed by district heating with 3%," with natural gas "92% of total fuels" (page 102). Energy intensity was "0.098" MWh per unit of turnover, versus 0.091 in 2024 (page 101).

Total electricity consumption was "43,890 MWh, of which 44% came from renewable sources," including self-generation from "five photovoltaic installations" with "a total capacity of 2,172 kWp," covering "5% of the Group's total electricity needs" (page 103).

Reference: page 105; pages 104-107.

"Gross Scope 1 GHG emissions" were 8,131 tCO2eq in 2025 versus 7,968 in 2024 (+2%) (page 104). Scope 2: "Gross Scope 2 market-based GHG emissions" fell 15% to 11,234 tCO2eq (page 105), driven by the renewable-electricity share increase. Scope 3 totaled 300,687 tCO2eq (down from 375,739 in the targets table), dominated by "Purchase of goods and services" at 262,308 tCO2eq (page 106).

"Total GHG emissions (market-based)" were "320,052" tCO2eq in 2025 versus "277,075" in 2024 (page 107); market-based emissions intensity rose to 0.3581 from 0.2940 (page 107). Scope 3 is calculated "in accordance with the GHG Protocol Corporate Standard and the GHG Protocol Corporate Value Chain (Scope 3) Accounting and Reporting Standard," using mainly average-data and spend-based methods, since "primary data from the value chain was not used" (page 105, fn.70).

Reference: page 109.

"Comer Industries does not purchase certificates in the EU ETS market or in similar markets because its companies and factories are not among those required to participate in such schemes, as they do not meet the regulatory criteria for inclusion. The Group has no GHG emissions removed or stored within its operations or along the value chain. There are also no initiatives to reduce greenhouse gas emissions financed through carbon credits, as these were not purchased in 2025" (page 109). The company's own ESRS content index lists this as reported (page 109), rather than not material, and the nil position is stated directly rather than inferred.

Reference: page 109.

"As of December 31, 2025, Comer Industries has not adopted a carbon pricing scheme" (page 109). This sits alongside a breakdown of Scope 1, Scope 2 location-based and Scope 2 market-based emissions by individual Group company (pages 108-109), none of which is linked to an internal carbon price. The ESRS content index lists the disclosure as reported with a page reference rather than marking it not material, consistent with a nil return being a complete answer to the requirement.

Reference: page 110.

Pollution is managed through the Integrated Quality, Sustainability and Product Responsibility Policy and the Supplier Code of Ethics, which "requires each supplier to ensure full compliance with European REACH and RoHS regulations" (page 110), though it does not set "commitments or provisions for substitution and reduction of substances of concern" beyond the phase-out of substances of very high concern (page 110). The Policy "expresses the Company's commitment to reducing negative impacts associated with its products throughout their life cycle... avoiding use of substances of very high concern for health or the environment" and mitigating air, water and soil pollution (page 111).

A footnote records a gap: "The Group has not currently formalized a specific policy dedicated to managing negative impacts along the downstream value chain, which are indirectly overseen through" the Integrated Policy (page 110, fn.72).

Reference: page 110.

Comer Industries integrates "the principles of the Corporate Sustainability Due Diligence Directive (CSDDD) and the German Supply Chain Act" into supplier due diligence, using "an environmental due diligence questionnaire" covering "waste management, air emissions, accidental spills, water consumption and discharge, use of hazardous substances" (page 110). The Group "plans to allocate additional financial resources between 2026 and 2035 for the purchase of performance and risk assessment tools linked to suppliers," not detailed because it falls "below the materiality threshold set at 3,500,000 euros" for the decade (page 110, fn.75).

"Note that in 2025 the Group did not implement actions aimed at mitigating downstream value chain impacts related to pollution" (page 110).

Reference: page 112.

"Due to its limited ability to influence the more distant parts of the supply chain and challenges related to data accessibility, Comer Industries does not currently have measurable, time-bound targets for reducing pollution in the upstream and downstream value chain" (page 112). Instead, it requires supplier compliance via the Supplier Code of Ethics, covering "the Minamata Convention, POPs Convention, Rotterdam Convention Annex 3, Basel Convention, Montreal Protocol" (page 112); "During fiscal year 2025, the Supplier Code of Ethics was signed by 96% of suppliers" (page 112).

"Given the absence of material impacts from its operations and no material risks or opportunities identified, Comer Industries does not currently plan to set additional targets related to pollution" (page 112).

Reference: page 113.

"The main policy of reference with regard to the management of impacts of water resources is the Integrated Quality, Sustainability, and Product Responsibility Policy, which expresses the Group's commitment to minimize the withdrawal of natural resources, with particular attention to withdrawals in water-stressed areas, and to reduce water consumption through process efficiency" (page 113). Suppliers must comply with the Supplier Code of Ethics on water use (page 113).

"The Policy does not directly refer to the downstream value chain, as Comer Industries products do not include characteristics specifically related to water use. Therefore, water efficiency is only a concern with respect to production" (page 113). "The Group has not adopted policies or practices related to the sustainability of oceans and seas, as the issue of 'marine resources' was not found to be material" (page 114).

Reference: page 114.

2025 actions focused on "optimizing production processes, recovering and reusing water resources, and adopting advanced technologies to monitor and control consumption," with new projects at "Lohmar (Germany), Welsberg (Italy), and Jiaxing (China)" (page 114). At Jiaxing, "a project to treat wastewater from production processes has been implemented, enabling the recovery and reuse of water resources"; at Welsberg, water dispensers were replaced; at Lohmar, a sewer-system upgrade is underway, due to complete "in 2026" (page 114).

Spend was "not significant in amount," funded through "ordinary corporate cash flows," with no use of "green bonds, social bonds, or green loans" (page 114).

Reference: page 114; page 115.

Two voluntary, intensity-based targets: globally, "a 10% reduction in water consumption intensity" by 2030 from a 2022 baseline of 20 m3/machine hours (performance 2025: 18.10) (page 115); locally, in nine high-water-stress plants (Sohland, Nuremberg, Hasselroth, Matera, Bangalore, Cachoeirinha, Charlotte, Rockford, Woodridge and Jiaxing), "a plan to reduce consumption by 15%" by 2030 from a 2023 baseline of 14.3 m3/machine hours (performance 2025: 16.4) (page 115).

Both were "set on a voluntary basis, as they are not mandatory by law or regulation," and "developed without direct stakeholder involvement," though "stakeholder expectations were considered during the definition phase" (page 115).

Reference: page 116.

In 2025 the Group generated total water withdrawal of 704,113 m3 (of which 20,673 m3 in water-stress areas), and total water consumed of 41,830 m3 (of which 20,673 m3 in water-stress areas) (page 116); the remainder, withdrawn at Lohmar and Monguelfo for cooling in a "continuous, closed circuit," is discharged without consumption or contamination (page 116). Water consumption intensity was 18.11 m3 per machine hours worked overall (17.89 in water-stress areas) (page 116).

"The main method of supplying water to the Group's sites is extraction from surface aquifers (94%)," with 99.5% classified as fresh water (page 116). "The Company does not store representative volumes of water and does not recycle or reuse water," though it treats and reuses degreasing/oily mixtures (page 116).

Reference: page 118.

"According to the Integrated Quality, Sustainability, and Product Responsibility Policy the Group's priority is the pursuit of a circular development model, favoring the use of sustainable materials and optimizing the use of natural resources in production processes, thereby reducing the waste generated and the negative environmental impacts of its products" (page 118). The Policy extends to the supply chain through the Supplier Code of Ethics (page 118).

Three vectors: "Implementing technological and management solutions... aimed at reducing the use of resources per unit processed, as well as reusing them"; "Integrating eco-design criteria into product design"; and "Implementing procurement policies that encourage cooperation with component and service suppliers with better performance in terms of recycled material and recyclability" (page 118).

Reference: page 118; page 124.

"Throughout 2025, Comer Industries implemented a series of initiatives aimed at strengthening its commitment to the circular economy, with actions focused on the efficient management of raw material inputs, waste reduction, and improved sustainability throughout the supply chain" (page 118). At Jiaxing "a wastewater treatment system was installed, significantly reducing volumes"; at Reggiolo, new ferrous-waste collection systems were installed to maximize recovery; at Lohmar, a project replaced solvents in the painting area; and at Rockford, reusable packaging was introduced to cut single-use cardboard and wood (page 117).

"The initiatives implemented in 2025 did not require significant capital investments, nor were operating costs recognized, being mainly included in ordinary personnel costs" (page 118).

Reference: page 119.

Two goals: "20% reduction in the intensity of hazardous waste" (tonnes/machine hours), baseline 2022 at 8.6, 2025 performance 7.8, target 2030 (page 119); and "Estimate the effective quantity of recycled materials inside the product," with a project in progress in 2025 against a target year of 2026 (page 119). "A scenario analysis was not used to define the circularity targets. However, the targets were defined with the help of scientific evidence showing trends on waste and recycled materials over time, including Eurostat data and special waste reports issued by Ispra. The definition of the targets related to circularity did not involve stakeholders" (page 119, fn.88).

Reference: page 120.

Total raw materials consumed were "94,469" tonnes in 2025 versus "91,633" in 2024 (page 119), dominated by ferrous materials ("84,583" tonnes, of which steel 76,753 and cast iron 7,619) (page 119). "Weight recycled raw materials" was 49,073 tonnes, or "51.95%" of total raw materials, down from 55.55% in 2024 (page 120).

Main inputs are "steel, cast iron, aluminum alloys, plastics, and electronic components, as well as lubricating oils, auxiliary raw materials, and packaging" (page 120). "Comer Industries has a limited consumption of rare earths... The Group ensures responsible, tracked sourcing of these materials" (page 120). Packaging is "mainly composed of wood, steel, and a small amount of plastic" (page 120).

Reference: page 122; pages 122-125.

Product circularity: average "recyclable content" across studied product families (wind turbines, double joints, drive shafts, electric motors, axles, gearboxes) is "93%," and average "recycled content" is "44%" (page 122). Gearboxes, PTO shafts, axles, planetary drives, tractor attachment systems, drive shafts and fan clutches have "a high degree of recyclability," while hydrostatic traction drives and electric motors "contain a small portion of materials subject to product and supply chain constraints" (page 122).

Waste: in 2025 the Group generated "a total of 11,577 tons of waste, 15% of which was classified as hazardous... equal to 1,787 tons" (page 124). "More than 90% of the waste generated was recovered, while the remaining 10% was sent for disposal, with less than half of the latter going to landfills" (page 125).

Reference: page 124; pages 124-125.

"Comer Industries' production generates different types of waste," including metal/machining scrap (generally recoverable through remelting), WEEE, packaging, hazardous waste ("spent oils, solvents, paints"), plastic waste, and generic/municipal waste (page 124). "The waste management procedure defines how to handle and dispose of all types of waste... take into consideration the principles of the waste hierarchy, thus prioritizing prevention, reuse and recycling, recovery, and finally landfilling" (page 124).

Total waste was "11,577 tons," of which "15%... equal to 1,787 tons" was hazardous (page 124, excluding radioactive waste, which the Group does not produce, fn.99). "More than 90% of the waste generated was recovered" (page 125).

Reference: page 130.

The Group manages workforce IROs through four policies: the Integrated Human Rights Policy ("core principles regarding the protection of people's fundamental rights, both within the organization and throughout the supply chain"), the Integrated Diversity and Inclusion Policy, the Integrated Information Security Policy, and the Integrated Quality, Sustainability and Product Responsibility Policy for occupational health and safety (page 130). Responsibility rests with the "President and CEO," operational oversight with "HR & Organization" (page 130).

"The Group safeguards the physical and moral integrity of its personnel, ensuring dignified, safe, and healthy working conditions. All forms of coercion, intimidation, threats... as are any practices related to human trafficking or forced, compulsory, or child labor" are "strictly prohibited" (page 130). Policies are aligned to the UN Universal Declaration of Human Rights, ILO conventions, the OECD Guidelines, and the CSDDD (page 131).

Reference: page 132.

"Comer Industries takes a systematic and inclusive approach to employee engagement, ensuring clear, transparent communication through the use of tools such as the company intranet and regular meetings," and where worker representatives exist the Company "ensures that they are informed of and involved in issues envisaged by regulations or collective agreements" (page 132). "While there is no global framework agreement, Comer Industries strictly complies with the human rights regulations applicable in each country" (page 132).

A gap is disclosed directly: "The Group has not put in place procedures for evaluating the effectiveness of its workforce engagement actions" (page 132, fn.104).

Reference: page 134.

"Comer Industries adopts corrective measures based on an analysis of the specific cases, verifying the effectiveness of their resolution." The Company has "a whistleblowing channel managed by an independent external company, which has a mandate to protect the identity of all who use it," available through the website (page 134). "All reports received are digitally tracked throughout the entire process, from receipt to all stages of investigation, and examined by qualified personnel to ensure maximum confidentiality and protect the whistleblower against any kind of retaliation" (page 134).

Reference: page 135; pages 134-135.

"Once an impact is identified, it is assessed to determine its severity and likelihood. Corrective or preventive actions are then defined" (page 134). FY2025 actions span centralized hazard/injury-reporting software across Group plants, continued Policies and Regulations training (targeting full workforce coverage "by the end of 2026"), flexible-work and international-mobility initiatives, and a Rule Book update "to incorporate industry best practices" for data protection (pages 134-135). 2025 capital investment for these projects was "about 225,000 euros" (page 135).

"The Group has not taken measures to mitigate negative impacts on its workforce deriving from the transition to a greener and climate-neutral economy, as such transitions do not have dependencies on negative impacts or risks to the workforce" (page 135, fn.107).

Reference: page 136; pages 136-137.

DEI targets: female workforce representation to "at least 30%" by 2030 (2022 baseline 11.0%, 2025 performance 11.2%) (page 136); women in positions of responsibility to 25% increase by 2030 (2022 baseline 12.2%, 2025 performance 11.9%) (page 136). Training targets: maintain ">93%" training coverage (2025 performance 93%); "20% increase" in ESG training hours per employee (2025 performance 3.5 against a 2022 baseline of 5.3); "95%" of employees trained on the Code of Ethics by 2026 (2025 performance 24%, 2024 baseline 4%) (page 136). Health, safety and environment: full digitization of HSE reporting by 2035, and a 50% faster HSE-report closing time by 2035 (page 137).

"In defining targets, monitoring performance, and identifying areas of improvement, Comer Industries did not directly involve its workforce or worker representatives" (page 137).

Reference: page 138.

"As of December 31, 2025, Comer Industries' total workforce consists of 3,226 people, including 420 outsourced workers" (page 138). Employees: 2,806 (2,492 men, 314 women), down from 2,924 in 2024 (page 138). By country: Italy 1,021, Germany 1,090, United States 273, China 222, rest of world 200 (page 137). Permanent employees: 2,489; fixed-term: 317; full-time: 2,752; reduced-hour: 54 (page 138). "The Group has no workers who are on call" (page 138). During 2025, "220 employees were hired and 338 left," a net reduction of 118, with "203" of leavers resigning voluntarily (60%) (page 139).

Reference: page 139.

Non-employee workers in the own workforce totaled 420 in 2025 (392 men, 28 women), up from 247 in 2024 (page 139). "The Group uses non-employee workers whose work is nonetheless controlled by the organization in order to handle production peaks that do not require an increase in staffing levels. This category is represented in its entirety by temporary workers" (page 140).

Reference: page 140.

"90% of workers are covered by collective labor agreements. The percentage is 97% if only EEA countries are considered and 65% if only non-EEA countries are considered. As far as worker representatives are concerned, these cover 83% of the company's population" (page 140). "There is no representation by a European Works Council (EWC), a European Company (SE) Works Council or a European Cooperative Society Works Council" (page 140). Workplace representation by country band ranges 0-19% (India) up to 80-100% (Italy, Germany) (page 140-141).

Reference: page 140; page 141.

Women in top management: "one employee in seven top managers, or 14%" (page 140). Age distribution: "468 employees are aged 30 or under (16.7% of the workforce); 1,328 fall within the 31-50 age range (47.3%); and 1,010 employees are over 51, representing 36.0% of the total" (page 140). Employees with disabilities: "87 employees... or 3% of the total" (page 141). Overall female share of the workforce is 11.2% (314 of 2,806) (page 138).

Reference: page 141.

"Comer Industries sets the benchmark for adequate wages based on the legal minimum wage in each country," using the minimum of an economically comparable country or collective-bargaining minimums where no statutory minimum applies (page 141, fn.119). "During the year, no Group employees were identified as being paid below the benchmark for adequate wages as defined above" (page 141). In Italy, Sweden, Denmark and Austria, which have no statutory minimum, "collective bargaining agreements are respected in terms of minimum wages" (page 141, fn.119).

Reference: page 141.

"All Group employees are covered by social protection - through public programs or benefits offered by the Company - against loss of income due to illness, unemployment, occupational injury and acquired disability, parental leave, and retirement" (page 141).

Reference: page 141.

"There are 87 employees in the Group's workforce with disabilities, or 3% of the total" (page 141), using definitions consistent "with the legal definitions of disability in the various countries where the data was collected," covering "enduring physical, mental, intellectual, or sensory impairments whose interactions with environmental and social barriers may hinder full, effective participation in society and work on an equal basis with others" (page 141, fn.120).

Reference: page 142.

"In 2025 the Company maintained its high level of commitment to the development of people's skills and expertise, providing a total of 34,283 hours of training, equal to 12.2 hours per person" (page 142), down from 36,621 hours (12.5 per capita) in 2024 (page 142). Men received 31,563 hours (12.7 per capita); women 2,720 hours (8.7 per capita) (page 142). The Performance Management process covered "25%" of the workforce, 712 employees, of whom 22% were women (50% of the female population) and 78% men (22% of male employees) (page 142); "100%" of planned reviews were conducted (page 142).

Reference: page 143; pages 143-144.

"Occupational health and safety is managed through a proactive approach and an ISO 45001:2018 compliant Health and Safety Management System," covering "86% of workers" (2,425 of 2,806) (page 143). "A total of 48 injuries were recorded during more than 5 million hours worked. Thanks to a constant preventive approach, no cases of occupational diseases were reported... No workplace fatalities were recorded in 2025" (page 144). Rate of recordable injuries in the workplace was 9.6 per million hours worked, down from 10.7 in 2024 (page 144). Hours worked: 5,025,729 (page 144).

Reference: page 145.

"In 2025, 98% of employees were eligible for parental leave. Of these, 9% took advantage of it during the year" (page 145): 95% of women eligible (13% took leave) and 99% of men eligible (9% took leave) (page 145). "Whenever possible the Group has accommodated all employees' requests for part-time work, temporary schedule flexibility... as well as guaranteeing all leave as envisaged in the regulations and collective bargaining" (page 145). "Remote working was available to Group employees again in 2025" (page 145).

Reference: page 145.

"At Comer Industries, the gender pay gap - defined as the difference between the average pay of male employees and female employees, expressed as a percentage of the average pay of male employees - stands at -6.03% at the Group level," meaning "on average female employees receive annual pay that is 6% higher than that of male colleagues" (page 145). The total annual remuneration ratio - highest-paid individual to median employee pay, excluding the highest-paid individual - "was equal to 9.82" in 2025 (page 145).

Reference: page 146.

"In 2025 Comer Industries did not record any incidents of discrimination, harassment, or serious human rights violations. During the year two reports were received through the whistleblowing channels... none were classifiable as violations of the United Nations Guiding Principles on Human Rights, the International Labour Organization Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines for Multinational Enterprises" (page 146). "The Group did not receive any penalties, fines, or claims for damages against the Company," nor any complaints through the OECD National Contact Points (page 146).

Reference: page 149.

"The main tools for mitigating the negative impacts and risks related to workers in the value chain are the Code of Ethics, the Supplier Code of Ethics... and the Integrated Human Rights Policy" (page 149). "The Code of Ethics prohibits any form of discrimination, labor exploitation, and the use of forced or child labor" (page 149). The Supplier Code of Ethics "extends the principles set out in the Code of Ethics to suppliers and their subcontractors," is "a binding condition for establishing or maintaining contractual relationships," and "includes periodic audit mechanisms" (page 149); responsibility for it sits with the "President and CEO," operational oversight with the "Purchasing function" (page 149).

Reference: page 150.

"The Group does not directly survey the views of workers in the value chain except through their representatives," instead monitoring impacts through "compliance requirements aligned with its ethical standards and annual supplier assessment processes" (page 150), with the Purchasing Director responsible for supplier engagement and the Sales Director for customers (page 150). "At this time the Group does not have any global framework agreements or understandings in place with international labor unions related to the rights of workers in the value chain" (page 150), and "downstream value chain monitoring has not yet been fully implemented" (page 150, fn.135).

Reference: page 150.

The same whistleblowing channel available to own-workforce employees "is also available to workers in the value chain, allowing them to report violations in a secure, confidential manner" (page 150), governed by "a whistleblowing procedure applicable to all Group Companies" (page 150). "The effectiveness of measures is assessed through direct dialogue with the reporting party and related follow-up" (page 150). A gap is noted directly: "The Group has not established a process to verify that workers in the value chain are aware of the whistleblowing channel" (page 150, fn.136).

Reference: page 151.

Three pillars: supply-chain due diligence (risk-based supplier classification plus a CSDDD/German Supply Chain Act self-assessment questionnaire), acceptance of the Supplier Code of Conduct, and the whistleblowing channel (page 151). "The Company assessed that none of the negative impacts are directly caused by its own operations, but rather are attributable to upstream and downstream value chain activities. As no actual impacts on workers in the value chain occurred, no remedial measures were required" (page 151). "The double materiality process did not identify material positive impacts or opportunities" for value chain workers (page 151).

Reference: page 153.

Two targets: "more than 95% of tier 1 suppliers comply with the Supplier Code of Conduct" by 2026 (2025 performance 96%) (page 153); "Due diligence of 75% of the supply chain (tier 1) using ESG criteria" by 2026 (2025 performance 77%) (page 153). "During 2025 no issues or incidents related to human rights in the upstream or downstream value chain were reported. Therefore, no contract terminations were required with business partners due to human rights violations" (page 153). "The process of setting targets did not involve value chain workers" (page 153, fn.138).

Reference: page 156; pages 156-158.

"The guide and reference for conducting company activities for all employees, partners, and third parties having dealings with Comer Industries is the Code of Ethics... the foundation of the control model," underscoring "integrity, transparency, respect, legality, and confidentiality" (page 156). It was "approved by the Board of Directors," applies Group-wide including to "members of the Board of Directors," and is reinforced by the 231 Model (page 156).

The whistleblowing channel, compliant with "European Directive 2019/1937," is handled by the Internal Auditor function and "can also be used by partners outside the Group," including anonymously; "Comer Industries protects good-faith whistleblowers from any kind of retaliation" (page 158). "During the reporting year, no incidents occurred and no proceedings or legal action were initiated against the Company regarding violations of free competition, monopolistic practices, antitrust" (page 157).

Reference: page 159.

"Comer Industries has built a network of suppliers based on a logic of long-term collaboration," combining a global supply base with local presence for "lead times, flexibility, and competitiveness" (page 159). "Each week Comer Industries' administration checks pending payments... scheduling their execution according to the deadlines" to prevent delayed payments, "especially with respect to small and medium-sized enterprises" (page 159). "Acceptance of the Supplier Code of Ethics is mandatory in order to initiate the relationship," with subsequent supplier qualification via audits of "quality management systems, environmental, social, and health and safety aspects" and technological capacity (page 159-160).

Reference: page 160.

Comer Industries has "adopted Anti-Corruption Regulations" consistent with the UN Convention Against Corruption, informed by a corruption risk assessment under its Enterprise Risk Management process; "the business areas that have emerged as most exposed to corruption risks... appear to be the administration and control, human resources, and purchasing functions" (page 160). Controls cover "(1) relations with authorities, (2) donations and sponsorships, (3) political contributions, (4) gifts and hospitality, (5) relations with suppliers and partners, (6) acquisitions, disposals, and joint ventures" (page 160).

A digital training course on anti-corruption was delivered in H1 2025 "with 100% coverage" of the three at-risk functions plus some top Executives; "to date there are no plans to deliver the course to administrative and control bodies" (page 160).

Reference: back-filled from the S1-5 targets table (page 136) and the G1-1/G1-3 business-conduct chapter (pages 156, 160). G1-3 became a standalone DR only in the 2025/2026 ESRS; this report is prepared under the 2023 ESRS, where business-conduct targets fall under MDR-T.

Comer Industries discloses a measurable, time-bound business-conduct target: "Involvement of 95% of employees in training on the Code of Ethics," with a 2024 baseline of "4%," 2025 performance of "24%," and a 2026 target year (page 136). "The objective aims to ensure that almost all of the company population has been exposed to the principles of the Code of Ethics at least once through a training activity" (page 136, fn.111).

Consistent with MDR-T's effectiveness-tracking limb, the anti-corruption training programme reports "100%" coverage of the three functions identified as most exposed to corruption risk (page 160), and G1-1 describes ongoing whistleblowing-channel monitoring as its measure of effectiveness (page 158).

Reference: page 161.

"In 2025, as in previous years, there were no documented incidents related to corruption issues. Therefore there were no convictions or fines imposed for violations of laws against bribery and corruption or along the value chain that directly involved Comer Industries personnel" (page 161). Any reports or confirmed cases would be "investigated within the whistleblowing process by the Internal Auditor function and... periodically reported to the oversight bodies, specifically the Board of Statutory Auditors and the Supervisory Body" (page 160-161).

Reference: page 161.

"Procurement processes are governed by contractual terms... payment deadlines that in value terms are 12% within 30 days and 60% between 30 and 120 days" (page 161, based on Comer Industries S.p.A. and Comer Industries Components S.r.l., "representing 46% of the total payments made by the Group") (page 161, fn.143). "The average payment days in 2025 was 96.6 days," versus "96.5" in 2024 (page 161, fn.144). "Comer Industries was not involved in any legal proceedings for late payments during the reporting year" (page 161).