Componenta Oyj

Reference: page 16.

Componenta's Board of Directors is the administrative and supervisory body for sustainability matters; the Annual General Meeting elects it annually, and under the Articles of Association it has three to seven members. At the end of 2025 the Board had four members, 25% women and 75% men, none with an operational role, no employee representation, and 100% independent of the company and its significant shareholders. The Board has not established a separate sustainability committee.

The Board's sustainability duties include monitoring and controlling the sustainability reporting process, approving the sustainability reporting assurance plan and its budget, meeting the sustainability auditor as necessary, and assessing the auditor's independence.

The Corporate Executive Team (four people in 2025, 25% women) is chaired by the President and CEO and also includes the CFO, the COO and the Director responsible for legal affairs and sustainability; no employee representation. The President and CEO is responsible for lawful and reliable sustainability reporting; day-to-day responsibility sits with the Director responsible for legal affairs and sustainability, who reports to the CEO, supported by a dedicated sustainability expert. Per the EU-legislation datapoint table (p.16), board gender diversity is 25% and 100% of Board members are independent.

Reference: pages 17-18.

The Corporate Executive Team (CET) discusses material impacts, risks and opportunities at least in connection with the annual review of the double materiality assessment (DMA), usually presented by the Director responsible for legal affairs and sustainability. The CET also receives input from subject-matter experts on individual IROs, approves short-term Group-level sustainability targets, and monitors target achievement regularly.

During the reporting period the CET addressed all impacts, risks and opportunities identified as material in the 2025 DMA. The Board of Directors specifically addressed: energy consumption, climate change mitigation, resource inflows, occupational health and safety, corporate culture, cybersecurity, and increasing environmental legislation — i.e. the full set of Componenta's material topics.

Sustainability matters are incorporated into strategy in connection with strategy updates, and both governing bodies weigh sustainability factors in decision-making.

Reference: page 18.

Componenta does not have incentive schemes linking Board remuneration to sustainability performance, and Corporate Executive Team (CET) remuneration is not currently linked to sustainability matters. The remuneration policy for governing bodies adopted at the 2024 Annual General Meeting built in the possibility for the President and CEO's short- and long-term incentive schemes to be based on sustainability matters in the future, and the same optionality extends to other CET members' incentive schemes.

Climate considerations are explicitly not currently taken into account in the CET's short- and long-term incentive schemes. The Board of Directors decides the terms and conditions of the company's short- and long-term incentive schemes.

Reference: page 29.

Componenta's statement on due diligence is presented as a table mapping the five core elements of due diligence (per ESRS 1 AR 15-16) to where each is covered in the sustainability statement:

• (a) Embedding due diligence in governance, strategy and business model — pages 17, 58, 59, 65
• (b) Engaging with affected stakeholders in all key steps of the due diligence process — pages 19, 20, 59
• (c) Identifying and assessing adverse impacts — pages 21, 42, 49, 52, 57
• (d) Taking actions to address those adverse impacts — pages 44, 50, 52, 60
• (e) Tracking the effectiveness of these efforts and communication — pages 44, 50, 53, 61, 62

No separate narrative is added beyond the cross-reference table; the underlying content sits in the governance, IRO and topical chapters referenced.

Reference: page 18.

Componenta's risk management model for the sustainability reporting process identifies the most significant risks to the reporting process and defines internal controls (controls) to address them. Risks were identified through discussions among a working group of sustainability, legal and financial management experts; no formal risk-prioritisation method was used, and the assessment instead focused on the risks judged qualitatively most significant.

The most significant identified risk is errors in the collection and reporting of numerical data. Mitigating controls include review-type controls (correctness of collected data assessed at least twice during the reporting process), the four-eye principle for computational data, and a preference for data collected directly from source systems rather than manual compilation. Resources and expertise for the reporting process are ensured internally, supplemented by external specialists as necessary. Material internal-control findings are reported to the Corporate Executive Team and the Board of Directors at least once a year.

Reference: pages 18-19, 29-30.

Componenta is a contract manufacturer with a broad offering; it has no products of its own — products are manufactured to customers' specifications (business model detailed in Note 1 to the consolidated financial statements; employee count on page 63). Its most significant production inputs are personnel, financial capital and assets, raw materials and the subcontracting network, and energy. Tier-1 suppliers are mostly Finnish and European; customers are mainly global machinery and equipment manufacturers with Finnish assembly operations.

For its 2024-2026 strategy period, Componenta selected five focus areas: in-depth customer knowledge, sustainability, operative reform, personnel, and inorganic growth. Of these, sustainability and personnel are directly tied to Componenta's material sustainability topics; the others affect those topics indirectly (e.g. through headcount growth and production-process development). The company is exploring automation and robotics to address competitiveness and labour shortages. At the end of 2025 Componenta had no sustainability-linked targets for product/service groups, customer categories, geographic areas or stakeholder relationships.

The EU-legislation datapoint table (SBM-1, paragraph 40(d), pp.29-30) confirms Componenta is not involved in activities related to fossil fuels, chemical production, controversial weapons, or tobacco cultivation/production — all marked "Not material".

Reference: pages 19-20.

Componenta's key stakeholders are personnel, customers, suppliers (including contractors and subcontractors), shareholders, financiers, the authorities, and local communities near production units. Regular discussion with all key stakeholders is part of standard business operations; operationally significant matters reach the Corporate Executive Team, and Board-relevant matters reach the Board of Directors.

Stakeholder views feed into the strategy process — sustainability was chosen as a new focus area for 2024-2026 partly on this basis, covering long-term climate targets, GHG reduction, occupational safety, well-being, competence, diversity, non-discrimination and equality. A detailed table (p.20) sets out, per stakeholder group, the engagement channels used (e.g. daily management and surveys for personnel; factory visits and trade fairs for customers; cooperation meetings and audits for suppliers; AGM and investor meetings for shareholders; permit-related communication for authorities and local communities) and the benefits Componenta seeks to provide each group.

Reference: pages 24-26.

Componenta's material impacts, risks and opportunities, by topic:

• Climate change (E1): energy consumption and climate change mitigation — both actual negative impacts, own operations and upstream value chain (energy-intensive foundry/forge processes and metal raw material production). No material climate risks or opportunities identified.
• Pollution (E2): air pollution — actual negative impact, own operations (foundry emissions affecting local air quality).
• Resource use and circular economy (E5): resource inflows — actual negative impact, own operations (raw-material-intensive processes); waste and resource outflows related to products/services — actual positive impacts, own operations (recycled metal use, return scrap iron reuse, product recyclability).
• Own workforce (S1): gender equality/equal pay and training & skills development — actual positive impacts; health and safety — actual negative impact (production work's higher accident risk) — all own operations.
• Business conduct (G1): corporate culture — potential positive impact, own operations.
• Entity-specific: cybersecurity (financial risk, own operations and up/downstream value chain) and increasing environmental legislation (financial risk, own operations).

Explicitly excluded from the material-topics list after DMA review: the positive impact on social dialogue/collective bargaining (S1), the financial opportunity on resource outflows related to products and services (E5), and the financial risk on raw-material availability/price (entity-specific).

Reference: pages 21-23.

Componenta's first DMA was carried out for 2024 reporting under the CSRD; it was reviewed in H1 2025, and the need for a further update is assessed annually. The review first looked at the general-level impact of 2024-2025 operational changes on the topics already assessed, then analysed in more detail the topics previously found material or that had fallen just below threshold.

Scoring: 1-5 scale. Actual impacts always receive the maximum likelihood score (5) to allow comparison with potential impacts. Negative-impact severity = (scale + scope + irremediability) x 0.33 each; positive-impact significance = (scale + scope) x 0.5 each; total impact score = severity/significance + likelihood (max 10). Risks/opportunities score = financial-impact magnitude (1-5, against euro-denominated thresholds from the risk management policy) + likelihood, unweighted, assessed after the impact assessment so impacts/dependencies inform it.

Materiality thresholds: an impact is material if severity/significance ≥3 and the severity/significance-plus-likelihood sum exceeds 5; a risk/opportunity is material if magnitude >2 and the magnitude-plus-likelihood sum exceeds 4.

Coverage: the entire value chain, with upstream focus on the most significant tier-1 suppliers and downstream assessed only at a general level (not possible to fully assess given the diversity of end uses). No separate stakeholder survey was run for the DMA; existing stakeholder information was used. Geography: mainly Finland and Europe (excluding global climate impacts). Key assumption: where only one of the two foundries had been separately monitored for certain impacts, both were assumed similar.

Reference: page 27 (table spans pp.27-29); EU-legislation datapoints table pp.29-31.

IRO-2 is Componenta's "List of Disclosure Requirements complied with", a table naming each disclosure requirement and the page where it is covered. It lists: BP-1, BP-2; ESRS 2 GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2; E1-1 through E1-6 (plus the ESRS 2 SBM-3/IRO-1 climate cross-references); E2-1 through E2-4 (plus the climate-adjacent IRO-1 cross-reference, and the water/biodiversity IRO-1 process-description cross-references at pages 24 and 23 respectively); E5-1 through E5-5; S1-1 through S1-7 and S1-14, with S1-13 and S1-16 explicitly flagged "Not reported under Phase-In provisions"; and G1-1.

A companion table, "List of required datapoints incorporated by reference to information outside of the sustainability statement" (the due diligence core-elements table) and a further "List of datapoints derived from other EU legislation" table (pp.29-31) catalogue additional mandatory datapoints and mark many as "Not material" (e.g. fossil fuel/chemicals/weapons/tobacco involvement, water and biodiversity datapoints, S2/S3/S4 human-rights datapoints, G1-4 corruption-incident datapoints) or "Not reported under Phase-In provisions" (S1-16 pay gap and CEO pay ratio datapoints). No DR outside this set carries a page reference or datapoint entry anywhere in the index.

Reference: page 44.

Componenta's transition-plan disclosure is a direct statement of absence: "Componenta is not planning to prepare a transition plan for its business regarding climate change mitigation in the near future."

The company nonetheless discloses adjacent content that speaks to transition-relevant activity elsewhere in the E1 chapter: a Board-approved Scope 1 & 2 emission-reduction target compatible with a 1.5°C pathway (E1-4), named decarbonisation levers and 2025 actions (E1-3), and a climate resilience analysis (backfilled under E1-3-Resilience). But as a distinct Disclosure Requirement, E1-1 is answered in the negative, consistent with ESRS 1's position that a complete "no" is itself a valid disclosure.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 / SBM-3 (climate), where this content is disclosed in the FY2025 report on pages 42-44. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Two material climate-related topics were identified in the DMA — energy consumption and climate change mitigation — both actual negative impacts in own operations and the upstream value chain (energy-intensive foundry/forge operations and metal raw-material production); no material climate risks or opportunities were identified (p.42).

Resilience/scenario methodology (pp.42-43): a climate resilience analysis was carried out in 2024 and "updated in 2026 to include the company's largest business areas in 2025," using the IPCC science-based scenarios SSP1-2.6, SSP2-4.5 and SSP5-8.5, over medium-term (2025-2030) and long-term (2030-2050) horizons (short-term excluded as not expected to differ materially). SSP5-8.5 is the high-emission scenario; SSP1-2.6 is described as "global warming of just over 1.5°C." Physical risks were assessed across own operations, upstream metal production and the company's largest downstream business areas; transition events mainly in own operations, and in the value chain only where they would directly affect Componenta. Physical-hazard analysis used the World Bank Climate Change Knowledge Portal (rainfall/temperature) and Finnish Environment Institute open data (flood risk); transition events covered policy/legislation, technology, markets and reputation. No quantified global-average-temperature projection is given for SSP2 or SSP5.

Resilience in relation to climate change

Back-filled from ESRS 2 IRO-1 / SBM-3 (climate), where this content is disclosed in the FY2025 report on pages 42-44. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Results: no chronic or acute hazard or transition event was found to have a major impact on Componenta through own operations or the value chain. A moderate impact from floods was identified over the long term across all scenarios (own operations and upstream value chain); moderate impacts from heatwaves, heavy precipitation and landslides under SSP5-8.5 (mainly long term); and moderate impacts on production-process regulation/transition cost and on product substitution under SSP1-2.6 and SSP2-4.5 (medium to long term). Componenta states it can adapt via technology/equipment renewal and its extensive supplier portfolio (e.g. substituting the LPG used in cutting and as a production heat source). "Componenta does not consider it necessary to change its business model" in response (p.44).

Capacity to adjust (AR10): the report concludes "Componenta is able to carry out climate change mitigation and adaptation measures necessary for its business and strategy in the medium and long term, in order to secure business operations and, for example, access to financing" (p.43).

Uncertainty: "The current geopolitical developments increase the uncertainty related to the results of the resilience analysis" (p.44).

Timing (AR9): the analysis is not run annually — carried out in 2024 and updated, per the text, in 2026 to reflect 2025 business areas; non-annual refresh is compliant under AR9.

Reference: page 44.

Componenta's QEHS policy guides operations toward climate change mitigation and improved energy efficiency, through production-process development, energy efficiency of production units, and increasing the share of fossil-free energy procured. The Code of Conduct for suppliers and subcontractors addresses suppliers' and subcontractors' energy efficiency (and thereby climate mitigation); suppliers and subcontractors "must limit their energy consumption as much as possible." The QEHS policy is detailed on page 50, the supplier Code of Conduct on page 66.

The policies do not specifically address climate change adaptation or the adoption of renewable energy — "the topics have not been separately defined as material for the company." Consistent with E1-1, Componenta is not planning a transition plan.

Reference: pages 44-45.

Componenta continuously works to improve energy efficiency and reduce energy use, through quality/process development, investment in energy-efficient machinery, method design and energy audits; in iron foundries, production volume and load stability materially affect relative energy efficiency because keeping hot metal melted requires energy regardless of production-volume changes.

2025 actions: energy-efficiency improvements to buildings at certain production units (renewed lighting, enhanced insulation); electrification of operations, including replacing combustion-engine forklifts with electric forklifts; and the single most significant measure — acquiring certified nuclear electricity (guarantees of origin) covering 58% of the company's electricity consumption, with an emission-reduction impact of 10,953 tCO2eq in 2025. None of these individual measures involved significant operating or capital expenditure.

Reference: pages 44-45.

Componenta targets a 50% absolute reduction in market-based Scope 1 & 2 emissions (7,289 tCO2eq) by 2030 against a 2024 baseline (14,577 tCO2eq, of which Scope 2 was 85%). In 2025, Scope 1 & 2 emissions were 9,534 tCO2eq, 34.6% below the 2024 baseline. The target covers 100% of Scope 1 & 2 emissions, is aligned with the QEHS policy, and implements the 2024-2026 strategy's sustainability focus area.

1.5°C alignment: set using the SBTi calculation tool and the cross-sector Absolute Contraction Approach pathway; Componenta states that the SBTi-implied minimum reduction for 1.5°C compatibility is 42% (6,122 tCO2eq) by 2030, and that its own target of 50% (7,289 tCO2eq) is 1,167 tCO2eq more than that minimum — i.e. its target exceeds the SBTi floor. Scope 1 & 2 represented 19% of 2024 market-based GHG emissions; no absolute Scope 3 target is set. The target was set in 2025 with production units and the Corporate Executive Team, approved by the Board of Directors, and has not been assured by a third party. Componenta states growth (net sales over MEUR 150 by 2027) could raise absolute emissions absent further reduction measures, but views the target as achievable regardless.

Reference: page 46.

Total energy consumption: 79,535 MWh in 2025 (77,173 MWh in 2024). Mix shifted markedly away from fossil sources: fossil share fell to 31.7% (from 67.7%); the share from nuclear sources rose to 61.6% (from 32.2%) — 48,965 MWh versus 24,855 MWh, reflecting the 2025 nuclear-electricity guarantees-of-origin purchase; and the renewable share rose to 6.7% (from 0.1%) — 5,379 MWh versus 80 MWh. Energy intensity improved to 0.69 MWh/tEUR (from 0.79). Componenta's operations fall under NACE code C – Manufacturing, a sector with significant climate impact.

Methodology notes: fuels used are light fuel oil, wood pellets, LPG, plus small amounts of diesel and gasoline; purchased energy is electricity and district heat. Only the Vantaa office and the entire Karkkila foundry had certified renewable electricity/heat via guarantees of origin in 2025; all other district heat is conservatively reported as fossil-sourced, even though producers report much of it as renewable, because it lacks certification. Componenta separately acquired guarantees of origin for nuclear-based electricity covering part of production electricity consumption.

Reference: pages 47-48.

2025 GHG emissions (base year 2024 in brackets), tCO2eq: Scope 1: 2,011 (2,204), -8.7%. Scope 2 location-based: 5,577 (6,895), -19.1%; market-based: 7,523 (12,374), -39.2%. Scope 3 total: 57,098 (63,622), -10.3% — largest categories purchased goods & services 43,510, end-of-life treatment of sold products 5,331, upstream transportation & distribution 3,429, downstream transportation 620, downstream leased assets 678, capital goods 407, waste generated in operations 651, employee commuting 947, business travel 92. Total GHG: location-based 64,686 (72,721), -11.0%; market-based 66,632 (78,199), -14.8%.

Biogenic CO2: 3,982 tCO2 total in 2025 (3,085 in 2024). GHG intensity per net sales: location-based 0.56 tCO2eq/tEUR (0.66); market-based 0.58 (0.71).

Methodology: GHG Protocol Corporate and Scope 3 (Corporate Value Chain) standards, operational-control approach, covering all production units and the Vantaa office. Scope 3 category 10 (processing of sold products) is excluded as not realistically assessable given the broad product range; categories 8, 11, 14 and 15 do not apply to Componenta's activities. Roughly 25% of Scope 3 emissions were calculated using supplier-specific emission factors.

Reference: pages 49-50.

The QEHS policy frames the management of foundry air emissions. Both foundries operate under authority-approved environmental-permit monitoring plans specifying measurement points for air emissions, responsible parties for measuring-device inspection, third-party measurement schedules, substances measured (particles and metals) and emission limits, plus calculation-based emissions. Continuous particulate-measurement systems in the filter plants support ongoing monitoring; filter plants are checked at least weekly under preventive maintenance, with Business Unit Managers and the COO responsible for implementation.

Componenta holds third-party certified ISO 9001 (quality), ISO 14001 (environment) and ISO 45001 (occupational safety) systems at all production units under the QEHS policy, approved by the President and CEO. Componenta has no policies on water/soil pollution or on substances of concern/very high concern — "the topics have not been defined as material for the company."

Reference: page 50.

Emissions management is embedded in the foundries' continuous operations under their environmental permits: filter-plant inspections, preventive maintenance, emissions measurement/calculation and reporting to environmental authorities, and ongoing monitoring with response to deviations.

In 2025, a filter plant was overhauled at the Karkkila foundry, reducing particulate emissions and improving local air quality; the investment was approximately EUR 0.3 million, financed through operating cash flow and capitalised as an addition to machinery and equipment. Both foundries also carried out air-emission measurements in 2025 under their environmental permits, to confirm the filtration equipment functions properly and emissions stay within permitted limits.

Reference: page 50.

At the end of 2025 Componenta had no long-term pollution targets; the general objective is to comply with the emission limit values set in foundries' environmental permits. Effectiveness of pollution-mitigation measures and policies is monitored through regular emission measurements, with data reported annually to the environmental authorities, alongside regular monitoring of filtration-equipment operation as part of normal production.

Reference: pages 50-51.

Material air emissions arise only from foundry operations — mainly particulate matter and volatile organic compounds — and the E-PRTR reporting thresholds are not exceeded for any pollutant, consistent with 2024. Componenta has no material emissions to water or soil in normal operations, and there were no exceptional 2025 situations causing material water or soil emissions.

Substances potentially present in foundry off-gases, per the E-PRTR Regulation: particulate matter, arsenic, cadmium, chromium, copper, nickel, lead, zinc, carbon monoxide, non-methane VOCs, nitrogen oxides, sulphur oxides, dioxins/furans, benzene, anthracene, naphthalene, PAHs, and chlorine/fluorine compounds (as HCl/HF). In 2025 both foundries underwent accredited third-party air-emission measurements, including additional measurements tied to the 2024 BAT conclusions for foundries and smitheries.

Reference: page 52.

Under the QEHS policy, Componenta seeks to minimise environmental impact through continuous development of high-quality operations and management of recyclable side streams. Under the Code of Conduct, Componenta seeks to increase the environmental friendliness of its production methods and processes and minimise products' life-cycle environmental impact (detailed p.66). The policies do not specifically address moving away from virgin resources, or sustainable sourcing and use of renewable resources.

Reference: pages 52-53.

Componenta optimises raw-material use in daily operations; simulation is used in the casting design of all new products. The main cast-component raw material is steel scrap (recycled); foundries also reuse return scrap iron and recycle most production sand. Waste sorting promotes recovery of metals, slag, sand and dust; Componenta is exploring new reuse options for moulding sand, and always seeks the lowest possible reject rate (fewer rejects = less raw material, energy and resource consumption).

2025: Componenta enhanced the reuse of used machining tools in its own operations, so sharpened tools return to service faster — reducing both new-tool purchases and tool waste.

Reference: page 53.

At the end of 2025 Componenta had no long-term targets for resource use and circular economy. Effectiveness of related measures and policies is assessed via quantitative indicators — the share of recycled metal among the foundries' main raw materials, and the share of generated production waste that is recovered — with the aim of improving relative performance year over year.

Reference: pages 53-54.

Main raw materials are metals (steel scrap and virgin pig iron for foundries; various steels, cast iron, aluminium, copper for machining), plus sand, additives, inoculants, alloying elements, auxiliary materials, gases, and packaging (mainly wooden pallets/collars/boxes, mostly purchased used, plus smaller amounts of plastic and cardboard). Of the EU's critical raw materials, Componenta uses copper (a strategic raw material), silicon, magnesium, manganese and phosphorus, plus small amounts of bismuth, strontium, cerium and lanthanum.

2025 inflows (2024 in brackets), tonnes: total material inflows 47,565 (42,818) — main metals 29,905 (25,550), other raw materials 15,161 (15,102), packaging 2,499 (2,166). Recycled materials 14,132 (13,698) — steel scrap 12,465 (12,013), copper 80 (72), recycled packaging 1,587 (1,613) — a recycled share of 30% (32%). The share of sustainably sourced materials (FSC/PEFC-certified wood packaging) was 1% (1%) of all inflows.

Reference: page 55.

As a contract manufacturer with no products of its own, Componenta manufactures cast and machined metal components, forged blanks, welded structures, pipe products and metal sheet cuttings to customer specification; product reusability/reparability depends on customer requirements and is outside Componenta's control. Products are made from metal and are therefore, in principle, recyclable and durable.

Recyclable content: 100% (100%) in products, and 99% (99%) in packaging materials used. Some components undergo in-house assembly (e.g. added seals/filters), but the added weight is small relative to total product weight.

Reference: pages 55-56 (datapoints 37(d) non-recycled waste and 39 hazardous/radioactive waste, both referenced to page 55).

Componenta's main waste streams: metal waste (generally non-hazardous), foundry sand (non-hazardous), filter dust (hazardous and non-hazardous, contains metals), furnace slag (non-hazardous, contains metals), and spent cutting emulsion/wash water from machining (hazardous). Metal and sand by-products from the foundries are largely reused as raw materials in-house; metal waste from machining/materials-service units is mostly sold as industrial raw material. Waste fractions containing metals contain small amounts of critical raw materials — mainly magnesium, manganese and copper.

2025 (2024 in brackets), tonnes: total waste 16,269 (16,464); total waste recovered 10,467 (13,660); radioactive waste: none identified in the disclosed fractions. Approximately 3,200 tonnes of waste sand generated at the Karkkila foundry in 2025 are stored on-site pending a recovery decision; this sand is included in "total waste" but, since its final treatment is undetermined, excluded from the recovered/disposal/non-recycled figures.

Reference: page 58.

Componenta's Code of Conduct commits to local labour law, collective agreements and human-rights/equality legislation; recruitment, remuneration and career decisions are based solely on competence and achievement, with no tolerance for discrimination. Finland's legislation prohibits discrimination on gender, gender identity, age, origin, nationality, language, religion, belief, opinion, political/trade-union activity, family relations, health, disability or sexual orientation. The Code aligns broadly with the UN Guiding Principles on Business and Human Rights (and, per p.66, the UN Universal Declaration of Human Rights, OECD Guidelines, ILO core conventions, and UN Convention on the Rights of the Child). It does not specifically address human trafficking, forced labour or child labour — Componenta operates only in Finland, where these are prohibited by law — and there is no specific policy on inclusion or positive action for vulnerable groups.

The Group-wide HR policy (CEO-approved) covers resource allocation, competence development, salaries/incentives and well-being, committing to equal treatment, fair pay, training, respect for freedom of association/collective agreements, continuous employee-representative dialogue, and proactive safety. The QEHS policy commits to safe working conditions under a Zero Accidents principle, with risk observation/identification/minimisation. A harassment and inappropriate-behaviour guideline (CEO and OHS-manager approved) is part of new-employee induction. A third-party-hosted whistleblowing channel covers human-rights-violation reports.

Reference: page 59.

Channels include daily management, annual personnel surveys and performance reviews (feeding site/function development plans with assigned owners and timeframes), quarterly dialogue with shop stewards, regular reviews by the President and CEO and unit heads, a whistleblowing channel, an occupational-safety-observation channel (open to visiting stakeholder representatives too), and the intranet/info-TV/newsletters.

Each production unit has an occupational health and safety group, feeding the Group-level OHS committee, which meets quarterly with employee OHS representatives present. Componenta is bound by collective agreements through Technology Industries of Finland (workers, salaried and senior salaried employees) and dialogue with shop stewards under the Cooperation Act. The President and CEO holds ultimate operational responsibility for ensuring personnel interaction occurs and that its findings inform operating methods.

Reference: page 60.

Personnel can raise concerns directly with a supervisor, through the occupational-safety-observation/accident/near-miss reporting platform, or via an anonymous third-party whistleblowing channel. Separate procedures exist for whistleblowing reports, OHS observations/accidents, and harassment/inappropriate-behaviour reports; reported cases are investigated under the relevant procedure, with corrective measures taken promptly and effectiveness reviewed after implementation. These channels are uniform and available Group-wide via internal/external websites.

New employees and non-employees are briefed on reporting practices at the start of their engagement, and whistleblowing-channel use is covered in annual Code of Conduct training for all employees (and non-employees, where applicable). Whistleblower protection is described on page 66.

Reference: pages 60-62.

Table of the most significant 2025 measures: (1) converting safety training/induction/work-guidance materials into e-learning (2024-2026, own operations/production; tracked via accident numbers — a decrease in injury frequency observed particularly in units with a multinational workforce); (2) a continuous-improvement OHS model, including a 2025 HSE alert mechanism for learning from accidents/near misses across units (continuous; tracked via number of proactive safety observations and processed-vs-pending observations); (3) personnel benefits for sports, culture and well-being (continuous; tracked via benefit-usage statistics); (4) extended occupational healthcare under the occupational health-care action plan (continuous; tracked via number/duration of sickness absences).

Governance: a Group-level QHS manager, supported by unit OHS officers; Business Unit Managers and supervisors implement day-to-day OHS; an HR manager oversees well-being and competence development. Beyond the table, Componenta takes corrective measures following accident/OHS-observation investigations, assigning resources and implementation timelines as needed.

Reference: pages 62-63.

Target 1: Lost Time Injury Frequency (LTIF) below the industry average (23.2 in 2024) by 2030; 2025 performance: 35 (all personnel; LTIF = lost-time injuries x 1,000,000 / hours worked). Target 2: 100% coverage of performance reviews (employees only) by 2030, then continuous; 2025 performance: 72%.

Both targets were developed with the OHS and HR functions and discussed with production units and the Corporate Executive Team; no external stakeholders were separately consulted. Targets were set in 2025. Effectiveness of related measures is also tracked via proactive safety observations (quantitative), sickness absences (quantitative), and occupational-health-care enquiries/visits (qualitative and quantitative).

Reference: page 63.

2025 (2024 in brackets): total employees 663 (681) — 87 female / 576 male (90F/591M in 2024); permanent 649 (666) — 86F/563M (89F/577M); temporary 14 (15) — 1F/13M (1F/14M); non-guaranteed-hours 22 (17) — 1F/21M (4F/13M). 72 employees left in 2025 (43 in 2024); average turnover rate 11% (7%). Componenta had employees only in Finland in 2025. Figures are head counts as of 31 December.

Reference: page 63.

Agency-hired labour is used for short-term/urgent needs and where seasonal customer-demand fluctuations make work continuity hard to predict, and also as a recruitment channel; mainly for production tasks. Non-employees also include self-employed contractors. On 31 December 2025, 15 (head count) agency-hired/self-employed workers were engaged, versus 10 a year earlier; numbers vary through the year with workload.

Reference: page 64.

A third-party certified ISO 45001 occupational health and safety management system covers all of Componenta Castings Oy and Componenta Manufacturing Oy (100% of their personnel); the parent, Componenta Corporation, is not covered. Overall, 97% (97%) of personnel are covered by a certified OHS system.

2025 (2024 in brackets): recordable work-related accidents 35 (32); Lost Time Injury Frequency 35 (34); recordable work-related ill-health cases 0 (0); days lost to work-related injuries/fatalities 376 (226); work-related fatalities 0 (0).

Reference: pages 65-67.

Componenta's values — openness, honesty, respect — anchor its corporate culture, identified in the DMA as a potential positive impact in own operations (p.65). Governance instruments: a Code of Conduct (compliance with laws; working life and human rights; corruption, bribery, conflicts of interest and political activities; environment; exchange of information between competitors; confidential/insider information; company assets; suppliers and subcontractors; whistleblowing); a Code of Conduct for suppliers and subcontractors (legal compliance, employee/human rights, environmental responsibility, responsible business practices, reporting violations — signed at contracting, or an equivalent supplier code accepted); and a risk management policy built on the COSO ERM framework, covering operational, financial, strategic and accident risk. Annual Code of Conduct training is given to all employees.

Componenta has a third-party-hosted whistleblowing channel, open to all stakeholders and not only personnel, built on GDPR, the EU Whistleblower Directive and national law, with documented investigation guidelines and explicit protection against retaliation for genuine reports; reports are reviewed by legal/HR staff independent of the reported issue. No separate corruption-investigation procedure exists beyond the whistleblowing guidelines, and Componenta judges corruption/bribery risk as not significant given operations are mainly in Finland, despite flagging procurement, sales and unit management as the most exposed functions.

Targets and metrics (p.67): 100% employee Code of Conduct training participation (continuous target) — 90% in 2025; "work vibe" score ≥4 on a 1-5 scale, target 2030 — 3.7 in 2025; 100% of the TOP100 suppliers (by procurement value) signed on Componenta's Supplier Code of Conduct or an equivalent, target 2028 — 96% in 2025.

Targets related to business conduct

Back-filled from the business conduct chapter (pp.65-67), where targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

Componenta's "Targets and metrics" table for business conduct (p.67) sets out three outcome-oriented targets with 2025 performance:

• 100% of employees participate in annual Code of Conduct training (continuous target) — 90% achieved in 2025.
• Work vibe of 4 or higher on a 1-5 scale (target year 2030) — 3.7 in 2025.
• 100% of TOP100 suppliers (by procurement value) have signed Componenta's Supplier Code of Conduct, or hold an equivalent own code (target year 2028) — 96% in 2025.

The targets were developed with the legal affairs, procurement and HR functions, discussed with production units and the Corporate Executive Team, and set in 2025. Work vibe is tracked via the annual employee survey as a well-being/corporate-culture indicator; the Code of Conduct training rate via HR digital systems; the supplier signature rate against the 100 largest suppliers by annual procurement value.