Consti Oyj

Reference: page 26.

Sustainability is part of business management, led by the CEO with the Management Team. The Board of Consti Plc is "the highest authority responsible for sustainability in the company" and approves the key plans and guidelines that steer operations (ethical guidelines, insider guidelines, disclosure policy, environmental principles, occupational safety principles, competition-law compliance, equality and non-discrimination plan). The Board approves sustainability goals as part of strategy and monitors achievement; it is informed of sustainability deviations and misconduct such as serious accidents and corruption suspicions.

Sustainability development is coordinated by the Corporate Sustainability Steering Group (CEO plus representatives of support functions and Business Areas), chaired by the Director of Legal and Compliance. The Board has a Nomination and Remuneration Committee. At end-2025 the Board had six members, 33.3% women and 66.6% men, all independent of the company and its significant shareholders.

Reference: pages 26-27.

The Board met 10 times during 2025 and addressed sustainability topics including: approving the 2024 sustainability report; actions related to sustainability in 2025; changes to the disclosure policy and insider instructions; tasks of the Corporate Responsibility Steering Group; and it "reviewed and approved the 2025 double materiality assessment, including the changes made compared to 2024." The Board also reviewed and approved the corporate security policy and the risk-management process description, and discussed occupational safety and HR issues monthly.

The CEO reports to the Board on material impacts, risks and opportunities and on the progress of sustainability goals, "alone or together with the company's sustainability experts," and presents an occupational safety review at every Board meeting. The Management Team prepares sustainability matters for the Board and receives a sustainability review from Consti's corporate responsibility experts twice a year.

Reference: page 27.

The CEO's incentive system (STI) can pay a bonus of up to 60% of annual base salary; sustainability-related goals made up 24% of the annual base salary in 2025, including "the promotion of sustainability and green transition, improving accident frequency rates, and promoting an occupational safety culture." Other Management Team members had sustainability goals worth 14-22% of base salary, covering the same themes plus CSRD reporting.

For other personnel, individual reward targets relate mainly to quality assurance and occupational safety; "sustainability objectives are not linked to the remuneration of the entire staff." The Board's own remuneration is not performance-linked. "Consti's climate aspects have not been taken into account in the remuneration of governance, management, and supervisory bodies, nor has their performance been evaluated in relation to the reported greenhouse gas emission reduction targets."

Reference: pages 29-30.

Consti's due diligence process has four elements, run through a decentralised, line-organisation model with group-level risk frameworks: identification, assessment and prioritisation; stopping, preventing and mitigating adverse impacts (continuing, suspending or terminating a business relationship); monitoring of the measures' implementation and effectiveness; and communication and transparency "as the situation requires." In 2025 the guidelines for applying due diligence in environment, HR management and good governance were clarified and made available to all employees on the intranet.

The process covers Consti's own operations and its value chain, "including the subcontracting and supply chain," and response options to a business relationship's adverse impacts range from continuing the relationship during mitigation to termination "due to the severity of the adverse impacts or after failed mitigation attempts."

Reference: page 25.

Sustainability reporting follows the Group's common risk-management and internal-control principles. Three risks are identified: (1) correctness, accuracy, completeness and timeliness of reported information; (2) division and reproducibility of reporting responsibility; (3) changes in legislation. A particular limitation is flagged: "in the reporting of Scope 3 emissions, data often has to be estimated on a cost basis, as sufficient emissions data is not yet available from material suppliers."

Responsibility for sustainability reporting sits with Consti's Director of Legal and Compliance, supported by the Finance Department and the Sustainability Manager. Internal controls are part of common business processes monitored through business-unit and Group Management Team reporting; accuracy is ensured "by providing clear instructions for data submission and by requesting additional clarifications on received information when necessary."

Reference: pages 28-29.

Consti is a Finnish renovation contractor and technical building services provider, organised into four business areas (Housing Companies, Corporations, Public Sector, Building Technology), with offices in Helsinki, Tampere, Turku, Lahti, Hämeenlinna, Oulu and Jyväskylä. At end-2025 the Group employed 981 (1,012) construction and building-technology professionals, about 98% permanent.

"Consti's business model emphasises mitigating climate change," mainly through improving energy efficiency in renovation as an alternative to demolition. The value chain runs from material manufacturers and suppliers/subcontractors through Consti to customers and end-users (property owners, residents); the report does not cover the upstream building-materials manufacturing chain, citing insufficient internal information and systems to track it.

Business resilience was assessed via two TCFD-aligned climate scenarios, IPCC SSP1-2.6 and SSP5-8.5, deepening the 2025 double materiality assessment.

Reference: page 30.

Key stakeholders are customers (housing companies, public-sector developers, real-estate investors), construction consultants, designers, property managers, subcontractors, suppliers, financiers, owners, and current/potential employees. In 2025 stakeholder views were surveyed through questionnaires and interviews covering customers, partners and suppliers.

Partners and customers rated prevention of environmental pollution, resource efficiency, health and safety, expertise, corporate culture, responsible business principles and equal treatment as significant or very significant; financiers emphasised reducing emissions, preventing pollution, resource efficiency, corporate culture and responsible business principles. Results were "in line with the double materiality assessment," except that stakeholders also flagged environmental-pollution prevention as important even though the DMA did not find it material. "Stakeholders have not directly participated in defining Consti's sustainability goals." Views are reported to the Board.

Reference: pages 34-35.

The table "Consti's material sustainability factors" lists disclosure requirements that are both impact-material and financially material: E1-5 energy consumption, E1-6 Scope 1/2/3 GHG emissions, seven named climate physical-risk hazards (storm, heavy rain, flood, heat load, temperature fluctuations, changes in wind/rainfall conditions, heat wave), E5-5 demolition/packaging/surplus waste, S1-13 training and skills, S1-14 health and safety at work, S2 health and safety at work, G1-1 corporate culture, G1-2 supplier relations, G1-3 corruption prevention and detection, and G1-4 confirmed corruption/bribery cases.

Materiality is scored on a 1-5 impact/probability/severity scale across 1-year, under-5-year and over-5-year horizons; "sustainability factors that received a high rating were defined as material," i.e. at least 14-16 for impact materiality and 15-16 for financial materiality.

Reference: pages 31-33.

Consti's risk management is "continuous, systematic, and preventive," built on the due diligence process in section 1.2.4. In 2025 Consti ran two workshops (CEO plus nine participants from Business Areas and support functions): one reviewing impact materiality, one reviewing financial materiality, each updating the 2024 analysis. Impacts were scored on scale, breadth and ability to correct; risk probability, severity and impact on the same 1-5 scale.

"Based on the analysis, no changes were made to Consti's material sustainability factors, except for... G1 Protection for Whistleblowers," which was found significant but did not reach the material threshold for 2025. The Board approved the 2025 double materiality assessment on 17 July 2025. E2 Pollution, E3 Water and marine resources, E4 Biodiversity, S3 Affected communities and S4 Consumers/end-users were each assessed and found not material (detailed under each topic). The next assessment is due during 2026.

Reference: page 24; Appendix 1 (pages 78-81) and Appendix 2 (pages 82+).

The basis of preparation states that "the data points reported in accordance with the ESRS standard and their locations within the sustainability report are presented in the indices published at the end of this report: 5.1 Appendix 1: Content index and 5.2 Appendix 2: Data points that derive from other EU legislation. The indices also outline any deviations and provide relevant clarifications."

Appendix 1 lists, per ESRS 2 and topical standard, each disclosure requirement with its report chapter reference, flagging items explicitly as "Not Material" (E1-7, E1-8, E5-4, E5-5) or "Reviewed later" (E5-6) where applicable. "Consti has not used the option under Articles 19a(3) and 29a(3) of Directive 2013/34/EU to omit information related to ongoing development or negotiations," and has used the option for internal cross-references within the report.

Reference: pages 56-57.

Consti's transition plan targets carbon neutrality for its own operations (Scope 1 and 2) by 2035, aligned with limiting warming to 1.5°C, using 2024 emissions as the baseline for Scope 1-3. The most significant 2030 reduction levers are: reducing construction-site energy emissions, requiring suppliers to provide emission data on significant material groups, mapping new low-carbon materials, and promoting circular economy and recycling. "Consti's climate targets are not science-based."

The plan "was integrated into the business strategy and financial planning and aligned with them during 2025-2027," approved by the Management Team and Board; implementation covering Scope 3 "will begin in 2025." "Consti does not include financed greenhouse gas removals in its transition plan, nor does it use them to offset its emissions." A footnote states Consti has not assessed investments/financing supporting the plan, nor embedded emissions in key assets, quantitatively.

Reference: Back-filled from section 1.2.3 (SBM-1), pages 28-29. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"In 2025 Consti's climate-related climate scenario and resilience analysis was updated in accordance with the TCFD recommendations. This was carried out by taking into account two different climate scenario analyses, which were based on the IPCC's SSP1-2.6 and SSP5-8.5 scenarios. In the SSP1-2.6 scenario, the increase in global temperatures is kept below two degrees, while in the SSP5-8.5 scenario, temperatures are projected to rise by over four degrees by the year 2100."

Consti names acute climate risks and regulatory issues (the Construction Act, EU Taxonomy, Energy Performance of Buildings Directive) as particularly significant. The risk/opportunity tables in section 2.2.2 (pages 49-52) classify each named hazard as transition or physical. No quantified exposure/sensitivity modelling or timing of the analysis is given beyond "2025 update."

Reference: Back-filled from section 1.2.3 (SBM-1), page 29, and the E1 transition/physical risk table, pages 50-52. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The resilience analysis (TCFD-aligned, pages 28-29) "helped identify weaknesses and strengths related to the business and assess potential adaptation measures for both business development and site operations," deepening the 2025 double materiality assessment over 1-year, under-5-year and over-5-year horizons.

On capacity to adjust, the report is explicit about a gap: "Consti has not assessed how the company's assets and business could be exposed to climate-related transition risks or benefit from transition-related opportunities. Consti has not assessed to what extent its assets and business may be exposed to identified transition events and to what extent they are sensitive to them" (page 52). Adaptation measures named elsewhere (heatwave work scheduling, rainwater/snow planning, material protection) are operational responses rather than a capital-reallocation analysis.

Reference: page 52.

"Consti is committed to continuously improving environmental and energy efficiency... and has set CO2eq emission reduction targets for its own operations. In addition, Consti has defined emission reduction targets for Scope 3 emissions." Environmental competence and culture are developed through staff and management training.

The transition plan (section 2.2.5) is the vehicle for the climate mitigation policy; the energy and GHG policy content is cross-referenced there rather than repeated. No separate standalone climate-adaptation policy document is named beyond the due-diligence environmental guideline referenced in section 1.2.4.

Reference: pages 52-53.

Key measures: systematic monitoring of construction-site energy consumption, efficiency guidelines for sites, use of the Group's electricity contract to obtain guarantees of origin, gradual transition of vehicles and company cars to electric, replacement of fossil fuels with emission-free alternatives at offices and worksites. "CO2eq emissions from Consti's own operations are calculated annually, and a statutory energy audit report is prepared every four years."

On adaptation: "Consti prepares for threats caused by extreme weather events at the organisational level as needed" - cooling work areas and scheduling around heat, monitoring forecasts and planning rainwater/snow removal, protecting materials. Consti also develops customer-facing energy-efficiency services such as Consti Optimi, a site-specific multi-energy system using waste heat from the building.

Reference: pages 47-48.

Target: "Consti aims for its own operations (Scope 1 and Scope 2) to be carbon neutral by 2035," supporting the Paris Agreement's 1.5°C goal. 2025 targets and results against the 2024 baseline: emission intensity 5.4 tCO2eq/net sales €M (2024: 7.8); Scope 3 calculation refinement - realised; worksite energy monitoring and emission-reduction targets established - realised; 8 energy-efficiency projects completed (2024: 7); taxonomy-aligned turnover share 0.0% (unchanged).

In 2024 Consti switched company cars and half of feasible production vehicles from fossil diesel to biodiesel; in 2025 emission-free electricity was procured for eight offices, and electricity supplied to construction sites by Consti's contract partner is emission-free.

Reference: pages 52-53.

2025 (2024 in brackets), MWh: fossil fuel/electricity-heat-steam-cooling 0.0 (280.3); crude oil/petroleum 2,398.8 (4,991.0); natural gas** 4,337.6 (349.9)**; coal 0.0 (478.1); other fossil 1,484.4 (0.0) - total fossil 8,220.8 (6,099.3), 70% (52%) of the mix. Nuclear-sourced 826.1 (2,087.1), 7% (18%). Renewable fuel 547.7 (316.8); renewable electricity/heat 2,084.3 (3,123.2) - total renewable 2,632.0 (3,440.0), 23% (30%).

Total energy consumption: 11,678.9 MWh (11,626.4); energy intensity 34.7 MWh/net sales €M (35.6). The fossil share rose year-on-year even as total consumption held broadly flat, driven by higher natural-gas use at construction sites.

Reference: pages 53-55.

Scope 1: 1,390.0 tCO2-eq (2024: 2,038.3), from vehicle fuel and direct site energy use; 0.0% covered by emissions trading. Scope 2 location-based: 244.4 (2,651.1); market-based: 428.4 (509.7). Scope 3: 45,980 tCO2-eq (76,480), led by purchased goods and services (39,501; 2024: 68,732), operational waste (3,881), employee commuting (1,559) and business travel (363); use-of-sold-products and end-of-life categories reported zero in 2025 versus 2,253 and 166 tCO2-eq in 2024.

Total GHG, location-based: 47,614 tCO2-eq (81,169); market-based: 47,798 (79,028). GHG intensity fell to 141.6 tCO2-eq/€M (location-based) from 248.5. Calculated per the GHG Protocol Corporate and Scope 3 Standards; Scope 1, 2 and 3 calculations were externally assured by KPMG Oy Ab.

Reference: pages 49-52, 56-57.

Consti's IRO tables (pages 49-52) set out named transition risks (policy/legislation, technology, market, reputation) and physical risks (storm, heavy rain, flood, heat stress, temperature/wind/rainfall changes) with qualitative financial-effect descriptions for each - e.g. "increase in operating and production costs," "increased insurance premiums," "decreased turnover due to reduced demand." Climate opportunities (resource efficiency, new low-emission products, market access, financing diversification) are listed qualitatively in the same tables.

No figure is put on any of these effects. The report is explicit about the limitation: "Consti has not assessed how the company's assets and business could be exposed to climate-related transition risks or benefit from transition-related opportunities" (page 52), and the transition-plan footnote records that investment/financing needs to implement the plan have not been assessed or quantified.

Reference: pages 59-60.

Consti complies with recycling/disposal legislation and EU energy/emissions targets, and is "committed to reducing waste and recycling efficiently" per its environmental principles. Material efficiency is pursued through planning, reuse of existing building components where the customer agrees, and designing systems so repairs avoid extensive demolition. "Consti has not yet identified an appropriate method for measuring the amount of surplus material, nor a method for measuring the utilisation of surplus material."

Consti monitors circular-economy practice as a member of the Helsinki Circular Economy Cluster; both Consti Korjausrakentaminen Ltd and Consti Talotekniikka Ltd hold RALA Environmental and Safety Certificates. Responsibility sits with business-unit directors and the CEO.

Reference: page 61.

"Reducing the harmful environmental impacts of construction sites means minimising energy consumption and minimising noise, dust, and waste generated from site traffic, demolition work, and construction, as well as careful handling of environmentally harmful substances." Site-specific environmental plans identify risks and set out prevention measures; staff competence development is a further stated lever for reducing harm. Partners commit to environmental requirements in subcontracting agreements, and Consti's transition plan (section 2.2.5) sets a 2030 circular-economy target: waste recycling rate 80%, rising to 85% by 2035 and 90% by 2050.

Reference: pages 57-59.

2025 target: 70% construction-site waste recycling rate; achieved 64% (2024: 70%). The figure is weight-based and inflated by the large share of mass demolitions, where stone-based materials are efficiently recycled; the 2025 decline reflects a lower share of demolition contracts in total waste, while the circular-economy suppliers' own recycling rate held at about 60%.

Longer-term goals: 2030 - 80% recycling rate, exploring circular-economy potential; 2035 - 85%, setting circular-economy targets and leveraging opportunities in service offerings; 2050 - 90%, "utilising circular economy as part of the offered services."

Reference: pages 58-60.

Waste generated, 2025: 14,258.5 t total (13,861.4 t non-hazardous, 397.1 t hazardous), versus 15,953.1 t in 2024. Diverted from disposal: 13,188.8 t in 2025 (14,732.1 t in 2024), split prepared-for-reuse / recycling / other recovery operations. Directed to disposal: 1,069.7 t in 2025 (1,221.0 t in 2024) via incineration, landfilling and other disposal.

Recycling rate 64% in 2025, down from 70% in 2024, against a 70% target; amount diverted for disposal 5,095.0 t (2025) vs 4,723.0 t (2024). Waste data is sourced from transfer documents and the SIIRTO register compiled by demolition and waste-management contractors; hazardous-waste handling follows the Waste Act's sort-at-source requirement.

Reference: pages 63-64.

Consti's workforce principles rest on human-rights principles, ethical guidelines, HR processes and the "Consti Way" operating model (cooperation and openness, common operating models, performance management, understanding the customer, continuous improvement), applied to the entire workforce including orientation for subcontractors on occupational safety. Equal treatment policy prohibits discrimination on grounds including gender, age, origin, disability, health status and sexual orientation, and covers permanent, fixed-term and part-time staff as well as subcontractors.

Social protection: all employees have statutory accident insurance, occupational healthcare beyond the statutory minimum, statutory pensions, unemployment benefits and parental leave. Consti "operates in accordance with the UN Guiding Principles on Business and Human Rights" and ILO fundamental principles.

Reference: pages 64-65.

Consti complies with the Employment Contracts Act and applicable collective agreements, and negotiates local agreements with employee representatives. Cooperation events are held four times a year at Consti Plc and twice a year at the two subsidiaries with personnel-group and Group personnel representatives (exceptionally two events in 2025). An employee survey runs every two years; the autumn-2024 round had a 68% response rate, with strengths in role clarity and adequate skills, and improvement areas around recognition and well-being support.

Occupational safety is discussed regularly within personnel groups, and the cross-business-area Safety Group meets at least five times a year.

Reference: page 65.

"Consti's own workforce can report any ethical issues or legal violations they observe to their supervisor, local management, HR, or through the electronic reporting channel (whistleblowing channel)... Reports can also be made anonymously if desired." Consti "does not tolerate retaliation against whistleblowers."

For safety specifically, all employees can submit notifications recorded in the Congrid system (safety observations, accidents, near misses, corrective actions). The reporting channel's handling process (investigation by the Director of HR and Finance and the Director of Legal and Compliance, reporting of serious violations to the Board) is described in full under G1-3/section 4.1.5.

Reference: pages 65-67.

Equality actions: Consti aims to increase the proportion of women in every employee group; the share rose slightly in 2025 to 12.9% (2024: 12.7%). Training and skills: office staff get individual development plans via annual development discussions; Consti Academy provides qualification and leadership training, with heavier investment in leadership training in 2025.

Health and safety: HR uses a common system group-wide; mandatory ePerehdytys general safety training plus task-specific qualifications for all site workers; safety observations recorded electronically; accident investigations completed within two weeks. Accident frequency was 8 in 2025 (7 in 2024); the main focus areas in 2025 were "improving the quality of accident investigation and the development of safety skills."

Reference: pages 61-62.

Social responsibility goals target health and safety, equality/human rights, and skills development, with indicators: more women across staff groups, fixed-term contracts below 5%, falling sick leave, accident frequency below 10, skills/leadership development, and staff turnover below 10%.

2025 results against target: share of women 12.9% (target: increase); fixed-term employment 2.0% (target <5%, met); sick-leave absences 4.25% and accident frequency 8 (target <10 for frequency, met; sick leave target not separately quantified); leadership-development programme - realised; employee turnover 13.0% (target <10%, not met, 2024: 12.6%); age distribution "balanced."

Reference: pages 66-67.

Total employees 2025: 981 (2024: 1,012) - women 131 (128), men 850 (884). Permanent staff: 961 (992) - women 128 (124), men 833 (868). Temporary staff: 20 (20) - women 3 (4), men 17 (16). Full-time: 962 (983); part-time: 11 (12). Employees on variable working hours: women 3 (6), men 5 (11).

Operations are in Finland only. Data is drawn from the Group HR system as of 31 December 2025; the share of women in total staff is calculated on a monthly-average basis.

Reference: page 61 (scope definition); chapter 3.1.6 per the content index.

Consti defines its own workforce under ESRS as covering "personnel employed by Consti and those working for Consti through temporary employment agencies or through their own company" (page 24). The accident-frequency metric (S1-14) is explicitly widened to include "persons working through temporary employment agencies and self-employed persons, as well as employees of subcontractors working at Consti's construction sites" (page 68).

No separate headcount, gender or age breakdown is given for non-employee workers distinct from the employee figures reported under S1-6; the report does not quantify how many people in its own workforce fall outside a direct employment contract.

Reference: page 66.

Employees covered by collective agreements: 89.1% in 2025 (90.1% in 2024). Operations are "only in Finland." Total percentage of employees covered by employee representation: 89.0% (81.4% in 2024). Consti has no agreements with employees on representation managed by a European Works Council, SE works council, or SCE works council (not applicable given its Finland-only footprint).

Reference: page 67.

Proportion of men and women in management, by headcount 2025: women 1, men 7 (2024: 1 and 7) - i.e. women 14%, men 86% of management, unchanged year-on-year. Age distribution of senior management, 2025: under 30s - 0; ages 30-50 - 2; over 50 - 6 (unchanged from 2024).

Reference: page 67.

"The pay is based on the generally applicable collective agreement for the sector." Consti does not present a separate minimum-wage benchmark or a quantified adequacy assessment beyond confirming collective-agreement coverage; the disclosure is a single confirming statement rather than a wage-level analysis.

Reference: page 64.

"All Consti employees are covered by statutory accident insurance and occupational health care that exceeds the statutory minimum, as well as statutory pension schemes, unemployment benefits, and parental leave." Information on health services is available to all employees with a contract of employment via the intranet. No figure is given for coverage outside statutory/occupational schemes (e.g. in the event of major life events) beyond this confirming statement.

Reference: pages 65-66.

"The safety requirements in construction industry limit opportunities for employing persons with disabilities in certain production roles. Nevertheless, Consti is committed to responsibility and equality in all actions and seeks ways to promote accessibility and inclusion in all positions where it is possible." No headcount of employees with disabilities is disclosed; the statement is qualitative, acknowledging a structural limitation specific to construction-site roles.

Reference: page 68.

Average training hours per person, 2025: women 3.8, men 5.3 (total 5.1); 2024: women 2.0, men 2.4 (total 2.4). Completed performance appraisals: 58% in 2025 (59% in 2024). Training delivery channels are described under S1-4/section 3.1.5: Consti Academy qualification and special-competence training, online learning paths, and 2025's expanded leadership-training investment.

Reference: pages 66-68.

Accident frequency: 8 in 2025 (7 in 2024). OSH management system coverage: 95% of own workforce (93% in 2024); 100% of employees with employment contracts (both years). Fatalities: 0 (0). Work-related health issues identified (e.g. occupational diseases): 3 (1). Lost days from accidents, fatalities and work-related health issues: 0 (0) as reported. Accident-frequency scope is widened to cover temporary-agency and self-employed workers and subcontractors' employees on Consti's sites, not just direct employees.

Reference: page 68.

Percentage of persons entitled to family leave: 100% in both 2025 and 2024. Percentage of persons on family leave, by gender: 2025 - women 3.8%, men 6.4%; 2024 - women 5.5%, men 6.1%. No separate disclosure of working-time arrangements (e.g. flexible/hybrid working) is quantified here, though flexible and hybrid arrangements are described qualitatively under S1-4.

Reference: pages 67-68.

Gender pay gap: 6.5% in 2025 (5.6% in 2024). Ratio of highest to median earned income: 9.9 in 2025 (9.5 in 2024). No CEO-to-median pay ratio distinct from this "highest earner" ratio is separately disclosed, and no excessive-CEO-pay-ratio datapoint is flagged as phase-in (unlike some peers' Appendix disclosures).

Reference: page 68.

Discrimination cases (including harassment) reported: 0 in 2025 (2 in 2024). Complaints submitted through workforce channels: 4 in 2025 (1 in 2024). Fines/penalties/compensation paid for the above: 0 (0) in both years. Serious human-rights cases related to the company's workforce: 0 (0). Total fines/penalties/damages from incidents: 0 (0). Figures are drawn from the electronic whistleblowing/reporting channel and internal case records.

Reference: pages 69-70.

Consti's human-rights principles are grounded in the UN Universal Declaration of Human Rights, its implementing covenants, and the ILO Declaration on Fundamental Principles and Rights at Work. Partners commit via the Code of Conduct / Ethical Guidelines for Partners, which covers human rights and equal treatment, freedom of association, prohibition of harassment/discrimination, prohibition of child and forced labour and protection of young workers, lawful wages and working hours, health and safety, privacy, and remedy of human-rights impacts.

Suppliers must be members of the Reliable Partner service (Vastuu Group Ltd) or provide equivalent documentation; subcontractors may have only one further level of their own subcontractors. A partner breaching the guidelines must correct its actions and report deficiencies to Consti; the Procurement Director escalates unresolved deviations to the CEO.

Reference: page 70.

"Dialogue is regularly conducted with value chain employees on construction sites," with meetings at project start, during and at close. Consti "takes into account the views of value chain workers involved in its projects regarding key areas of responsibility, including occupational safety, employee wellbeing, and the environment." Workers are encouraged to raise observed issues immediately, through the Congrid system, their direct supervisor, or the site safety manager; these observations feed into project-level decisions on safety and environmental measures.

Reference: page 70.

Reports of inappropriate behaviour, corruption, or other concerns from value-chain workers "can be made to the supervisor, the supervisor's supervisor, or a representative of Consti's HR function, or anonymously through the electronic reporting channel (whistleblowing channel)" - the same mechanism described under G1-3/4.1.5. Working-condition, health and safety violations on Consti's sites are addressed immediately on-site; human-rights violations follow the general risk-management process, with suppliers first given the opportunity to correct their conduct. "If the service provider is unwilling or unable to correct its actions, cooperation with the provider will not continue." The most serious cases go to top management and the Board.

Reference: pages 70-71.

Before tendering, subcontractors' social-obligation status (tax and pension payments, applicable collective agreements, sanctions-list checks) is verified via a Vastuu Group report. Subcontractors' employees complete general (ePerehdytys) and site-specific safety training before starting work, in local-language versions, and make safety observations on the same basis as Consti's own staff; deviations trigger monthly-monitored corrective action. Accidents are investigated jointly with service providers, with authorities involved for serious cases.

"In 2025, no cases related to the working conditions, health or safety of value-chain employees were brought to the attention of top management or reported to the Board." Observed issues (occupational-safety negligence, client-responsibility information gaps) were handled by the line organisation and suppliers were required to correct them immediately.

Reference: pages 68-69.

Target: all value-chain actors "operate sustainably and in accordance with Consti's sustainability factors," with zero tolerance for child or forced labour, human trafficking or modern slavery. "At present, workers in the value chain do not directly participate in setting Consti's sustainability targets, but the company continuously evaluates opportunities to improve its processes and increase their engagement in the future."

2025 indicator: mapping and describing human-rights processes - realised (also realised in 2024). No quantified numeric target (e.g. a percentage coverage or incident-rate goal) specific to value-chain workers is set beyond this process-completion indicator; the health-and-safety indicators applying equally to value-chain workers are the S1 targets described under S1-5.

Reference: pages 72-75.

Corporate culture is guided by "Consti Way - Our Way of Working" (collaboration and openness, common operating models, performance management, understanding the customer, continuous improvement), reinforced through orientation, supervisor training and staff events, and monitored via regular employee surveys. Consti's stated values are grouped as "You can trust us," "Focus on the customer," "Responsibility is action" and "Professionalism is an attitude."

Operating principles rest on Finnish company/securities law, the Act on the Contractor's Obligations and Liability, Consti's articles of association, Board-approved ethical guidelines (Code of Conduct), and Nasdaq Helsinki's listed-company rules. Board-approved policies include ethical guidelines for employees and partners, human-rights principles, anti-corruption guidelines, competition-law compliance, disclosure policy, insider guidelines, the equality and non-discrimination plan, occupational safety and environmental principles, risk-management procedures and (new in 2025) a corporate security policy. All office staff and management complete business-principles training on orientation and renew the "Business Fundamentals" course every two years.

Reference: page 76.

Material goods procurement is mainly from Finnish wholesalers and established manufacturers "committed to the principles of sustainable business in their own operations." Procurement follows open and honest competition, with internal competition-law guidelines to prevent favouritism, and written contracts for all procurement. Sustainability themes are discussed in annual-contract follow-up meetings, with a goal of developing a corporate-wide follow-up practice; project-specific sustainability issues are handled in project-level follow-ups.

Subcontractors must hold Reliable Partner (Vastuu Group) status or equivalent documentation under the Contractor's Obligations and Liability Act, and commit to Consti's ethical guidelines; the Valtti Card controls site access, and employee tax numbers are reported to the construction-industry tax-number register. Compliance is monitored by procurement staff, site personnel, the Head of Procurement and business-area procurement leads, with deviations escalated through the Procurement Director.

Reference: pages 76-77.

Identified shadow-economy risks in construction include "invoice trading, corruption, bribery, and avoidance of public obligations," amplified by project uniqueness, large sums and the number of subcontracting layers. Preventive measures: training on ethical principles; a defined process for reporting and assessing suspected financial misconduct; anonymous whistleblowing; requiring Reliable Partner membership or equivalent from suppliers; defined decision-making authorities; and a corporate culture supporting misconduct prevention.

The whistleblowing channel is externally hosted and accessible via Consti's public website; reports route to the Director of HR and Finance and the Director of Legal and Compliance, who lead investigations with restricted access to materials; serious violations go to the Management Team and Board; "Consti does not tolerate any retaliation against whistleblowers." "In 2025, Consti did not become aware of any confirmed cases of bribery or corruption. There were also no known violations of competition law or breaches of customer data protection."

Reference: Back-filled from the G1 targets table, section 4.1.1, pages 72-73. G1-3 as a standalone Targets DR did not exist under the 2023 ESRS the report was prepared against; in that framework these targets sit under MDR-T.

Consti's business-conduct targets for 2024-2027 and their 2025 results: development plan for supplier ESG sustainability assessment methods - not realised (2024: realised); identification of main value-chain actors - realised; subcontractors committed to Consti's Code of Conduct - estimated 90% (2024: 90%); no incidents violating the Code of Conduct in own operations - 0 incidents (target met); confirmed cases of corruption or bribery - 0 cases, against a target of 0 - not realised as a completed process step in 2025 versus realised in 2024 (the cases figure itself was 0 in both years).

These are tracked, quantified year-on-year targets against named indicators, satisfying the effectiveness-tracking limb of MDR-T even where a given year's process target (e.g. the supplier ESG assessment development plan) was not met.

Reference: page 77.

Corruption and bribery cases: 0 in 2025 (0 in 2024). Convictions for violations of anti-corruption/bribery laws: 0 (0). Fines for such convictions: 0 (0). Figures are based on reports through the electronic reporting channel and cases reported by business areas.

Reference: page 77.

"Consti does not seek to directly influence political parties and did not provide financial support to political parties in 2025." Consti is not registered in the EU or Finnish transparency registers; influence is exercised through industry-association membership, including the Confederation of Finnish Construction Industries RT, HVAC Contractors LVI-TU, the Electrical and Telecommunications Contractors Association STUL, Green Building Council Finland, and the Helsinki Circular Economy Cluster.

"In 2025, no individuals who had worked in a similar position in public administration or regulatory authorities in the previous two years were appointed to the management or governance bodies of Consti Plc or its subsidiaries."

Reference: page 76.

Standard payment term: 30 days net, not differentiated by supplier group; case-by-case assessment is possible. Proportion of 2025 payments made on standard terms: 46.5% (2024: 48.8%). Average realised payment term: 31 days (2024: 32 days). "Consti has no ongoing legal proceedings related to payment delays." Payment-practice indicators "have not been verified or validated by any external party other than the report assurer or auditor."