Dedicare AB (publ)

The role of the administrative, management and supervisory bodies

Reference: page 57.

Of the Board's six members, one is an executive member (HR Director) and five are non-executive; the Board includes no employee representatives. The gender distribution "amounted to 50 percent men and 50 percent women, on average." Three of six members (50%) are deemed independent in relation to the company and its major shareholders; Björn Örås, Jenny Pizzignacco and Krister Widström are each named as not independent, with the stated reasons (ownership influence, Group management role and family relationship, and prior management role respectively).

Responsibilities: the Board has overall responsibility for sustainability governance and approves the double materiality analysis, and decides Group-wide sustainability targets on management's proposal. The Board also has overall responsibility for oversight of business ethics, the Code of Conduct and compliance (ESRS G1); the Audit Committee monitors internal control, compliance and reporting. Operational management, supported by the Head of Sustainability, HR and finance, integrates sustainability into risk management and internal control and monitors material IROs.

Competence: during the period, Board members "have undergone FAR's digital training 'CSRD – ESRS 1 General Requirements and ESRS 2 General Disclosures'." A central sustainability function (Head of Sustainability plus a group-wide working group) exists, supplemented by external consultants where needed.

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

Reference: page 58.

The central sustainability function reports to Group management on an ongoing basis, to the Audit Committee at its regular meetings, and to the Board at predetermined occasions, covering "the implementation of the company's due diligence process, the double materiality analysis, and material sustainability-related impacts, risks and opportunities (IROs)."

During the period the Board's and management's handling included "the establishment and revision of relevant policies, approval of the company's double materiality analysis, and follow-up of ongoing activities and processes." The Audit Committee separately follows up the reporting process, materiality assessments and quality assurance of the sustainability information.

Matters addressed during the year, by the Board and Audit Committee, covered all IROs identified as material: climate-related risks and opportunities linked to travel and accommodation for consultants (E1); risks and opportunities linked to own workforce, skills, work environment and staff turnover (S1); governance-related risks in responsible business conduct, ethics, whistleblowing, compliance and internal control (G1); and social risks tied to end-user safety and continuity in client assignments (S4). "During the period, no major transactions have been carried out that required special Board decisions where sustainability-related trade-offs were decisive."

Integration of sustainability-related performance in incentive schemes

Reference: page 58.

"During the reporting period, the company has not had any incentive or remuneration programmes where the outcome is directly or indirectly linked to achieved sustainability-related targets or results. Sustainability-related performance does not therefore constitute a formal performance criterion when determining variable remuneration for senior executives."

Remuneration guidelines for senior executives, adopted by the general meeting, may include fixed and variable elements in support of the company's business strategy and long-term value creation. Decisions on remuneration guidelines are made by the general meeting and applied by the Board. The company states it "continuously evaluates remuneration structures and incentive models in relation to the company's strategy and long-term value creation, including an overall assessment of whether and how sustainability aspects may be taken into account in future remuneration structures" - i.e. a stated nil position for 2025 rather than an omission.

Statement on due diligence

Reference: page 59; pages 66-69 (IRO-1 process).

Due diligence is integrated into governance, strategy and business model: the Board has overall responsibility for sustainability matters and monitors material risks and outcomes, while operational management applies the due diligence process through governing documents, internal routines and monitoring. Because Dedicare "conducts staffing and recruitment activities without its own production, the methodology is particularly focused on issues relating to its own workforce, quality and safety in customer assignments, business ethics and compliance, and climate-related aspects linked to the company's value chain."

The report maps the five core due diligence elements to specific disclosures and pages: embedding in governance/strategy (GOV-1/2/3, SBM-3, pp.57-58, 70-72), engaging with stakeholders (GOV-2, SBM-2, IRO-1, S1-2; pp.58, 65-69, 88), identifying and assessing negative impacts (IRO-1, SBM-3, E1/S1/S4/G1; pp.66-82, 85-102), taking action (SBM-3 and topical chapters, pp.70-101), and tracking effectiveness (E1-4, S1-5/6/9/10, G1; pp.79, 91-93, 102). When negative impacts are identified, "proportionate measures are taken, adapted to the nature and severity of the risks," monitored through KPIs, internal follow-up and reporting to management and the Board.

Risk management and internal control over sustainability reporting

Reference: page 60.

The central finance function is the first level of control (collection, compilation, initial quality assurance of subsidiary data); the central sustainability function is the next level, defining, implementing, following up and evaluating group-wide controls, with reporting centralised at group level. Controls include preventive measures (common definitions, standardised templates, instructions), investigative controls (analytical reviews, reasonableness assessments, the four-eyes principle across "environmental data, social data, and during consolidation at Group level"), and corrective controls.

Three main risk areas are named: "manual data processing, uncertainty within subsidiaries regarding which data to report, and lack of documentation and formalisation of processes." "Since 2025 constitutes Dedicare's first year of sustainability reporting in accordance with ESRS, work has been initiated during the year to identify, document and evaluate internal controls... The work continues during 2026." An additional level of control is the external review (the limited assurance engagement), reported annually to the Board and management via the Audit Committee.

Strategy, business model and value chain

Reference: pages 62-64; partially incorporated by reference to the Annual Report, "Market and strategy" section, pages 18-30 (per the index).

Dedicare is a staffing and recruitment group whose "staffed or recruited personnel perform their work within the customer's operations and work environment, in close contact with end-users," spanning healthcare, social care, education and life science across Sweden, Norway, Denmark and the UK. 2025 revenue by geography: Sweden MSEK 295 (20%), Norway MSEK 922 (63%), Denmark MSEK 208 (14%), UK MSEK 48 (3%); total MSEK 1,473. Average FTEs: Sweden 219, Norway 747, Denmark 62, UK 39; total 1,067.

The sustainability strategy rests on three focus areas - "Sustainable services (E), Safe and developing work environment (S) and Mature leadership (G)" - and material issues link to "human capital, quality of delivery, safety and quality for end users in customer environments, and climate impact in the value chain, particularly through travel, procurement of services and energy use in premises." The value chain diagram identifies upstream suppliers of IT, training, premises, travel and accommodation; own operations (9 offices, recruitment and staffing); and downstream public/private healthcare, social care, education and life-science customers and their end-users. "As 2025 is the company's first reporting year according to ESRS, no quantitative climate targets have yet been established"; targets are intended for 2026.

Interests and views of stakeholders

Reference: page 65.

Key stakeholder groups are "employees and consultants, customers, candidates, suppliers, investors, as well as public actors and other social stakeholders," plus end-users (patients, service users, students) engaged indirectly via customer organisations. Dialogue channels and key issues are tabulated by group: employees/consultants (surveys, eNPS, ongoing dialogue - work environment, conditions, skills); customers (meetings, satisfaction surveys, procurements - quality, reliability, transparency); suppliers (procurements, requirements - ethics, conditions, quality assurance); investors/banks (meetings, credit assessments - financial performance, ESG risk); authorities (consultations, supervision - compliance, transparency).

Stakeholder perspectives were "of particular importance as a basis for the assessment of social impacts within the... double materiality assessment," with dialogue making clear that "quality of deliveries, safety for end users and correct matching of expertise are central" to the business model. "During the 2025 financial year, the stakeholder dialogues have not resulted in any material changes to Dedicare's business model or overall strategy."

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

Reference: pages 70-72 (consolidated list); topical detail at pages 74-76 (E1), 85-86 (S1), 96-97 (S4), 99 (G1).

The DMA identified nine material IROs across four topics: E1 - an actual negative impact (GHG emissions from travel, accommodation, purchased services and energy use, upstream/own operations/downstream, short-medium-long term) and a financial risk (increased energy costs and limited access to purchased energy, upstream/own operations, medium-long term). S1 - an actual negative impact (work environment and health/safety risks), a potential negative impact (privacy risks in personal data handling) and a financial risk (incorrect handling of personal information), all own operations, short-medium-long term. S4 - an actual negative impact (risks to health/safety of patients, service users and students) and a financial risk (changed conditions for public-sector staffing affecting demand and revenue), both downstream. G1 - a potential negative impact and a financial risk, both tied to "deficiencies in corporate culture" affecting quality, governance and compliance, own operations and relevant business relationships.

"As of the 2025 reporting year, no material direct financial effects have been identified... that affect the Group's financial position, performance or cash flows in such a way that separate monetary disclosure is provided." "2025 is the Group's first year of reporting in accordance with ESRS. No comparison with previous periods is therefore provided." The report also states that "all IROs in the final list are covered by disclosure requirements according to ESRS. No additional entity-specific IROs have been identified."

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

Reference: pages 66-69.

The DMA "for the reporting year 2025 has been conducted without applying transitional provisions," covering impact materiality (severity: scale, scope, irremediable character, plus likelihood for potential impacts) and financial materiality (likelihood and size/scale of financial effect on revenue, costs, earnings, cash flow, asset values and capital requirements). A quantitative model was used with internally set thresholds - "no external standard thresholds were applied" - developed by the cross-functional sustainability working group, supported by management and approved by the Board.

Process steps: (1) identification of potential issues via business-context and value-chain mapping, with focus on work environment/safety in assignments, public-sector customers, travel/accommodation emissions, and supplier/data-protection relationships; (2) stakeholder dialogue (customers, consultants, employees, subsidiary management, capital-market participants); (3) assessment and prioritisation of impact and financial materiality by value-chain location and time horizon. E2-E5 were each assessed and found not material (see below). For climate, Dedicare "conducted a qualitative, scenario-inspired analysis" using two scenario logics - (A) a stricter-policy transition pathway and (B) a high-emission physical-risk scenario - informed by IPCC AR6 and the GHG Protocol, "without quantitative modelling or financial quantification."

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

Reference: page 73; full content index at Appendix I (pages 103-110).

"This section constitutes a summary of the disclosure requirements (DR) in the European Sustainability Reporting Standards (ESRS) covered by Dedicare's statutory sustainability report for the 2025 financial year, in accordance with ESRS 2 IRO-2 §56," based on the DMA results in IRO-1. The Appendix I content index (Parts A-C) lists, per disclosure requirement, its materiality status, location, page and any external reference or phase-in comment; Part D lists datapoints derived from other EU legislation (SFDR/Benchmark/Climate Law references), most marked "Not material" where applicable.

Material standards are ESRS 2, E1, S1, S4 and G1. Part C records that "E2 Pollution," "E3 Water and marine resources," "E4 Biodiversity and ecosystems," "E5 Resource use and circular economy," "S2 Workers in the value chain" and "S3 Affected communities" were each "Assessed within DMA but not identified as material." Phase-in is applied to E1-9, S1-7 and the whole of S4 under the ESRS 1 transitional provisions and the ESRS Quick Fix delegated act of 11 July 2025.

Transition plan for climate change mitigation

Reference: page 77; pages 60-63 (EU Taxonomy context, pages 83-84).

"As of the 2025 financial year, Dedicare has no formally established transition plan for climate change mitigation in accordance with ESRS E1-1." The company has instead done "initial and preparatory work... with a focus on strengthening data quality, methodology, and internal processes for climate reporting," explicitly stating that existing practices - route/assignment planning for geographical proximity, digital working methods, dialogue with selected travel/accommodation/support suppliers - "do not... constitute a transition plan according to the ESRS definition," since they are not "gathered in a structured plan with established targets, timelines, or decided action packages."

"In 2025, Dedicare carried out its first compilation of greenhouse gas emissions in Scope 1, Scope 2, and Scope 3 for the purpose of establishing a reliable base year for climate reporting." Once data quality and coverage are verified, the Group "intends... to evaluate the scope, direction, and schedule for a possible future transition plan." This is a stated nil/in-progress position for the first reporting year, not a silent gap.

Policies related to climate change mitigation and adaptation

Reference: pages 77-78.

In 2025 Dedicare "updated the Group-wide sustainability policy, which constitutes the overall governing document for the Group's sustainability work," addressing climate through: (i) climate change mitigation - monitoring GHG emissions, reducing the environmental impact of business travel, and developing the ISO 14001-certified environmental management system; (ii) climate change adaptation - handled within the Group's risk management and the DMA; (iii) energy efficiency - responsible and efficient use of resources in offices and support functions; (iv) renewable energy - "where possible and compatible with the conditions of the business, the origin of energy is considered when purchasing electricity," including choosing renewable electricity contracts where Dedicare has control.

"The policy does not contain any specific targets or transition plans for climate adaptation or renewable energy" as of 2025. The Board holds overall responsibility for the policy; the CEO and subsidiary CEOs are responsible for communication and application, monitored through the annual DMA. The GHG Protocol is the methodological basis applied, alongside the Paris Agreement and the EU's 2050 climate-neutrality target.

Actions and resources in relation to climate change policies

Reference: page 78.

"As of the 2025 financial year, Dedicare has not established any climate-related actions or action plans in accordance with ESRS E1-3. Consequently, the Group has no decided or formalised actions for climate change mitigation or adaptation in the sense referred to in the standard." Preparatory work during the year focused on building data-collection, calculation and monitoring processes for Scope 1-3 emissions.

Existing operational practices - assignment/geographic planning, digital working methods, dialogue with selected travel and accommodation providers - are explicitly described as not constituting ESRS E1-3 actions, since they are "part of the ongoing operational management and have not been formalised in action plans with established targets, timelines or allocated resources." Resources allocated in 2025 "primarily relate to internal administrative resources for building reporting processes, data collection, quality assurance and monitoring of climate data. No investments in specific emission-reducing actions or climate-related adaptation measures have been decided during the financial year."

Targets related to climate change mitigation and adaptation

Reference: page 79.

"As of the 2025 financial year, Dedicare has not established any group-wide quantitative targets for climate change mitigation or adaptation in accordance with ESRS E1-4." Work during the year centred on "establishing fundamental processes for data collection, selection of methodology and quality assurance of climate-related information," including mapping Scope 1, 2 and material Scope 3 emissions under the GHG Protocol.

"Work on analysing the Group's climate impact, climate-related risks and opportunities is ongoing, and in parallel, the conditions for establishing emission reduction and climate adaptation targets in the long term are being evaluated." Any future targets "will cover the Group's own operations and, where applicable, the value chain, and will take into account... the Paris Agreement." The Part D legislative datapoint table cross-references this absence at paragraph 34 (page 79). This is a disclosed nil position for the base year rather than a silent omission.

Energy consumption and mix

Reference: page 79.

Total energy consumption for 2025 was 397.47 MWh: fossil sources 352.10 MWh (88.6% of the total - all from purchased/acquired electricity, heating, steam and cooling; fuel consumption from fossil sources was 0 MWh) and renewable sources 45.36 MWh (11.4%, also purchased/acquired electricity, heating, steam and cooling; self-generated renewable non-fuel energy "-"). Fuel consumption from renewable sources was 0 MWh and nuclear-sourced consumption "-".

"Dedicare does not conduct any energy-intensive operations and has no self-produced energy. Energy consumption primarily relates to purchased electricity and heat in leased premises." Reporting covers office/support-function energy use and Group-owned or leased vehicles under the operational-control principle. "Dedicare does not operate in sectors with a high climate impact according to ESRS. The disclosure requirements within ESRS E1-5 relating to energy intensity and energy use in such sectors are therefore not applicable to the Group." Where the renewable origin of purchased energy could not be verified, consumption is left unclassified rather than assumed.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 80-82.

2025 base-year emissions (tCO2e): Scope 1 gross 2.81; Scope 2 location-based 22.33, market-based 17.21; Scope 3 total 1,482.56, of which Category 1 (purchased goods and services) 62.20, Category 4 (upstream transportation and distribution) 2.26, Category 6 (business travel) 906.51, Category 8 (upstream leased assets) 511.60. Total GHG emissions: location-based 1,507.70, market-based 1,502.59. GHG intensity on net sales of MSEK 1,455: 1.04 tCO2e/MSEK (location-based), 1.07 (market-based). "The Group has no climate targets as of 2025; columns for interim targets and targets are therefore not applicable."

Scope 1 covers fuel in owned/leased vehicles; Scope 2 covers purchased electricity and heating in leased premises plus electricity for charging leased vehicles, reported both location- and market-based; Scope 3 covers the four categories above, selected via the DMA, while "other Scope 3 categories have been analysed but have not been assessed as material or are not relevant." Biogenic CO2 emissions were 0 tCO2e. Share of primary data by Scope 3 category: Category 1 0%, Category 4 0%, Category 6 80%, Category 8 0%.

Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Reference: page 82 (status: "Material - phase-in" per the content index).

"In accordance with the transitional provisions, a phase-in is applied for disclosure requirements under ESRS E1-9 for the 2025 financial year. Dedicare has therefore not provided quantitative disclosures on the expected financial effects of material physical risks, transition risks or potential climate-related opportunities." The Application of phase-in provisions table (page 56) names the plan for full reporting as "gradual expansion of data coverage and precision in line with improved access to primary data."

This sits alongside SBM-3's qualitative statement that "no material direct financial effects have been identified" for 2025 and that, in the medium and long term, "changing climate-related costs, regulatory requirements and access to skilled labour may affect cost structure and margins," though these effects "have not been quantified for 2025" (pages 71-72). Part D of Appendix I marks the related physical-risk-exposure and real-estate energy-efficiency datapoints under E1-9 as "Not material."

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 climate DMA section, where this content is disclosed in the FY2025 report (pages 67-69, 75-76). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

As part of the DMA, Dedicare "conducted a qualitative, scenario-inspired analysis of climate-related transition risks and physical climate risks over the short, medium and long term," using two scenario logics: "(A) transition path with successively stricter policy- and market-driven requirements" and "(B) high-emission scenario with increased physical risk types," calibrated against "IPCC AR6 as an overall framework for risk types" and the GHG Protocol "for methodological logic and concepts. No quantitative modelling or scenario runs were conducted during the 2025 financial year."

Physical hazards identified were "heatwaves, torrential rain/extreme precipitation and storms," assessed as affecting Dedicare only indirectly via supplier dependence on transport and energy systems - "no separate material physical climate risks have been identified in its own operations." Transition exposure centres on energy-market conditions and tightening procurement/customer climate requirements, with the material transition risk being "increased energy costs and price volatility for purchased energy" (IRO-1, pp.67-69; E1 SBM-3, pp.74-76).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the E1 climate DMA section, where this content is disclosed in the FY2025 report (page 72, and pages 75-76). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"The Board of Directors and management have carried out a qualitative assessment of the resilience of the business model in relation to identified material risks," based on a diversified public-sector customer base, presence across several countries, a flexible cost structure, and established quality/compliance processes (SBM-3, p.72). "No quantitative scenario analysis has been carried out for 2025. The methodology and analysis framework will be further developed in the coming years."

In the climate-specific scenario-inspired analysis, the conclusion is that Dedicare's business model "has a good capacity to manage the identified climate-related risks," affecting mainly "cost structure, supplier relationships and administrative requirements rather than any need for fundamental changes to the business model," with adaptability resting on flexible travel/accommodation sourcing, the ability to renegotiate supplier agreements, and gradual development of climate reporting and compliance competence (pages 75-76). No uncertainty areas or investment-redeployment analysis are quantified for 2025.

Policies related to own workforce

Reference: page 87; policy table on page 61.

"Dedicare has established a policy framework that regulates responsibilities, expectations and rights for its own workforce," anchored in the Code of Conduct and HR Policy and supplemented by the Occupational Health and Safety Policy, Sustainability Policy, Anti-Corruption Policy, Whistleblowing Policy and Policy against harassment and discrimination (table, page 61), each reviewed and approved annually by Group Management and the Board. The Code of Conduct "states that the company does not tolerate modern slavery, human trafficking or other violations of human rights either in its own operations or in the supply chain."

The policy framework targets discrimination on "all statutory grounds," underpins equal opportunity in recruitment, development and pay-setting, and is complemented by a whistleblowing function following the EU Whistleblowing Directive, available to "all employees, suppliers, and other external stakeholders," with fully anonymous reporting. Policies draw on the UN Guiding Principles on Business and Human Rights, the UN Global Compact, OECD Guidelines and Due Diligence Guidance, and the ILO Tripartite Declaration.

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

Reference: page 88.

Dedicare "ensures that the perspective of its own workforce is taken into account through ongoing individual employee appraisals, department meetings, structured HR processes, and through dialogue with employee representatives," supplemented by annual performance reviews, target/KPI management in the budget cycle, induction/preboarding, and pre-, mid- and end-of-assignment reviews between consultant and consultant manager. "Employee satisfaction is measured quarterly through employee Net Promoter Score (eNPS)," followed up by management and the Board each quarter and by each department head with their team.

Employee-representative engagement varies by country: in Sweden via collective agreements and meetings with the Unionen branch and health-and-safety representatives; in Norway via four elected representatives (a shop steward and safety representative in Oslo and Trondheim); in Denmark via an ongoing dialogue with a health-and-safety representative; "in the UK, there are currently no employee representatives." "The company has no global framework agreements with employee representatives."

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

Reference: page 89.

Three channels are described: the line organisation (immediate manager, another manager, or HR; for consultants, primarily the consultant manager); work environment channels (representatives plus an ISO-certified non-conformance system for near-misses, deviations and incidents, with external expertise involved where necessary); and whistleblowing (a digital, anonymous function per country, with confirmation within seven days and feedback within three months; "the CFO is the appointed case officer" acting "independently, with confidentiality and sole access," and documentation "deleted no later than two years after the case has been closed").

"In the event of suspected harassment or discrimination, Dedicare has an obligation to investigate and take action," covering incidents connected to work even outside normal hours. "Dedicare strives for a culture of openness and integrity and clarifies that reporting should be possible without risk of retaliation." Remediation can include "support to affected persons, rehabilitation efforts, correction of terms or other measures," with effectiveness tracked through follow-up discussions, complaint-pattern analysis and survey results.

Taking action on material impacts on own workforce

Reference: page 90.

Measures follow an identify-analyse-plan-follow-up cycle: issues surface through "dialogue, safety inspections, employee surveys and deviation and whistleblower systems" (with a dedicated personal-data-incident category reported directly to the IT Manager); root-cause analysis is carried out for relevant cases; a responsible manager, with HR and IT support where needed, builds an action plan with ownership, timetable and follow-up; effects are tracked via eNPS, turnover, sick leave, incident statistics and HR reviews.

On health and safety, measures include structured induction, clear escalation routes, ongoing monitoring of assignment conditions, and - for consultants in higher-risk settings such as psychiatry and prison services - additional support or reassessment of assignment suitability. On privacy, measures include access management on a need basis, incident-reporting procedures, and involvement of IT, HR and an internal GDPR group. "All managers in the Nordic region undergo leadership training," and senior consultant managers in Sweden and Norway were trained during the year "in how to give and receive feedback."

Targets related to own workforce

Reference: page 91. Note: this disclosure requirement is not listed as a separate row in Appendix I Part B's material-DR table for S1 (which lists SBM-3, S1-1 to S1-4, S1-6, S1-7, S1-9, S1-14 and S1-17 only), but the report carries a full S1-5 section with named targets and 2025 outcomes - treated here as reported on the strength of that direct disclosure; a reviewer should confirm this against the source PDF.

Targets are set annually alongside the budget/business-planning cycle, evaluated by management and the Board and followed up quarterly: employee satisfaction target >4 (outcome 4.3, scale 1-5); eNPS target >50 (outcome 26, scale -100 to 100); consultant satisfaction target >9 (outcome 9.3, scale 1-10); sickness absence target <3% (outcome 1.5%); employee turnover target <15% (outcome 24%). "All targets follow the calendar year as the measurement period and are established annually, which is why no baseline value is applied... During 2025, no change has occurred regarding targets, metrics or calculation methods." On personal-data risk, "the company had no reported deviations or incidents related to personal data" during 2025.

Characteristics of the undertaking's employees

Reference: pages 91-95.

Average number of employees (FTE) 2025, by gender: Group total 754 women, 313 men (1,067 total); parent company 10 women, 3 men (13); subsidiaries 744 women, 310 men (1,054). By country: Sweden 219, Norway 747, Denmark 62, UK 39 (total 1,067). By contract type (headcount, not FTE): fixed-term 167, permanent 3,134, hourly 521 - total 3,822 individuals employed at some point during the year, reflecting that "a significant proportion of the company's assignment consultants are employed for parts of the year, particularly during the summer months." Employee turnover: 747 permanent employees left during the year, a turnover rate of 24%.

Data for office employees comes from HR systems and for consultants from business and payroll systems, consolidated in standardised Excel templates under the four-eyes principle; FTE is calculated as actual hours worked divided by country-specific normalised full-time hours (e.g. Sweden 8.0h/day field staff, 7.5h/day office staff; Norway 7.1h/day field, 7.5h/day office; Denmark 7.4h/day; UK 7.5h/day). Turnover excludes most assignment consultants, "as the nature of the employment makes the measure less relevant."

Characteristics of non-employee workers

Reference: page 92 (status: "Material - phase-in" per the content index, no specific page given there).

Phase-in is explicitly applied: "Dedicare has chosen to use the phase-in opportunity regarding the following area: S1-7 Characteristics of non-employees," with the stated plan for full reporting being "further development of system support and internal processes for more complete reporting" (page 56). "Non-employees refer to the workforce that does not have direct employment within the group. This may involve hired staffing personnel and consultants working at the company's offices. The most common group consists of contract consultants who are self-employed or working through their own limited companies and who perform work on behalf of Dedicare at the company's customers" (SBM-3, page 85).

The partial quantitative disclosure available for 2025 is the headcount-by-contract-type breakdown reported alongside S1-6: 167 fixed-term, 3,134 permanent and 521 hourly individuals (total headcount 3,822), against an average FTE base of 1,067 - consistent with a large non-employee/short-duration consultant population not yet broken out separately under the phase-in relief.

Diversity metrics

Reference: pages 91-95 (table, page 93).

"Dedicare has a majority of female employees, which is because the professional categories needed in the business... are traditionally female-dominated." Gender distribution at management level: all managers 28 women (68%) / 13 men (32%); Board of Directors 3/3 (50%/50%); Group Management 4 women (57%) / 3 men (43%); Management Team Sweden 3/3 (50%/50%); Management Team Norway 6 women (75%) / 2 men (25%); Management Team Denmark 1 woman (25%) / 3 men (75%); Management Team UK 1 woman (33%) / 2 men (67%).

Dedicare states it works "systematically with a standardised and competency-based recruitment process, from requirements profile to employment, to promote equality, diversity and to counter discrimination," and that "the general gender distribution in the company should also be reflected in senior positions," supported by a standardised, HR-led promotion process "which provides high integrity in the process." Data is drawn from the HR system and calculated by gender per manager group in Excel.

Training and skills development metrics

Reference: page 94. Note: Dedicare states this topic was not found material; it is disclosed voluntarily and is not listed in Appendix I Part B's material-DR table for S1 (which omits S1-13). Per CLAUDE.md's treatment of voluntary, DMA-immaterial disclosures, the actual reported content is recorded here as reported rather than not_material.

"Training and professional development have currently not been assessed as a material impact, risk, or opportunity in Dedicare's double materiality analysis. Dedicare nevertheless chooses to provide certain disclosures and key performance indicators in the area... to provide stakeholders with relevant information."

2025 training hours by category (internal employees / consultants): First Aid/Emergency Medicine 6h (1 employee) / 199h (49 consultants); Leadership 386h (47); Sales development 24h (3); Language course 842h (34); Medical course 653h (160); Compliance 83h (7); HR and Work environment 272h (184); Accounting and payroll 74h (46); Other 16h (3); consultants also logged 488h (33) separately tabulated. Total hours: 861 (internal employees) and 2,182 (consultants). Calculation basis: "Number of hours = Number of participants x length of training."

Health and safety metrics

Reference: pages 91-95 (text and metrics on page 95).

"All employees in the own workforce are covered by an occupational health and safety management system based on legal requirements. 80.6 percent are covered by ISO certification in Occupational Health and Safety." "In 2025, 8 minor work-related accidents occurred in Dedicare's Norwegian organisation. All involved contract consultants. In Sweden, one minor work-related accident occurred involving a contract consultant. In Denmark and the United Kingdom, no work-related accidents occurred during 2025. No fatalities occurred." "The accident frequency rate amounted to 4.67 recordable work-related accidents in its own workforce per 1 million hours worked. The number of lost workdays due to work-related injuries and work accidents was three days. No cases regarding work-related ill health or deaths linked to ill health among employees have been registered."

Sources: Norwegian data from NAV; Sweden/Denmark/UK data from the head of operations in each country, plus occupational-health-provider Falck data for Sweden. The Work Environment Policy stipulates the work environment "shall be good, safe, and developing," supported by systematic management of physical and psychosocial risk and ISO 45001 certification in Norway.

Incidents, complaints and severe human rights impacts

Reference: pages 91-95 (text on page 95).

"Dedicare monitors work-related incidents and matters via the Group's whistleblowing system, which enables anonymous reporting. For 2025, no serious human rights-related matters or incidents were reported in the company's whistleblowing system. A total of three cases were submitted through the whistleblowing system during the year, of which one case involved harassment, which was also investigated during 2025. Other matters concerned views that could be attributed to ongoing operations."

"No matters linked to the work environment were received via the company's ISO-certified deviation system during 2025. No cases of discrimination or misconduct were reported during the year. No fines, penalties, compensation or settlements have been paid as a result of complaints received as above." Appendix I Part D cross-references the incidents-of-discrimination (paragraph 103a) and non-respect-of-UNGP/OECD (paragraph 104a) datapoints to page 95.

Policies related to consumers and end-users

Reference: pages 96-98 (status: "Material - phase-in"; per the index, "disclosures are provided in accordance with ESRS 2 BP-2 §17").

"For the 2025 reporting year, Dedicare has not established any separate group-wide policy specifically for ESRS S4" (page 56). The topic is instead "considered within the framework of the business model, strategy, and quality management through existing selection, verification, matching, and follow-up processes" for staffing assignments. S4 is material "because the Group's consultants work in customers' operations and can thereby indirectly affect patients, users, and students" (page 56).

Management of the identified S4 impact and risk draws on "the Group's quality policy and verification procedures, which set requirements that IDs, authorisations and relevant qualifications must be checked before the start of an assignment," alongside structured matching and contractually regulated quality requirements (page 97). Phase-in is applied under ESRS 1 and the ESRS Quick Fix delegated act of 11 July 2025, with the stated plan for full reporting being "gradual implementation of processes and follow-up in accordance with transitional provisions" (page 56).

Processes for engaging with consumers and end-users about impacts

Reference: pages 96-98 ("Qualitative reporting, disclosures are provided in accordance with ESRS 2 BP-2 §17," per the index).

End-users (patients, service users, students) are engaged indirectly: "dialogue occurs mainly indirectly via customer organisations" (SBM-2, page 65), since the direct relationship with end-users is held by Dedicare's customers rather than Dedicare itself. Understanding of end-user impact "has been further developed through analysis of quality and incident data, as well as dialogue with operational management and business areas," where "quality and incident data refers to the follow-up of deviations and incidents reported in connection with assignments, as well as feedback in customer dialogues" (page 96).

"Dedicare has no separate direct channel for end users to submit complaints to the Group, as the relationship with end users is handled by the respective customer. Comments and deviations are followed up within the framework of the customer relationship and contract management" (page 97). No separate end-user survey or consultation process is disclosed beyond this indirect, customer-mediated engagement.

Processes to remediate negative impacts and channels for consumers and end-users to raise concerns

Reference: pages 96-98 ("Includes IROs and general governance, disclosures are provided in accordance with ESRS 2 BP-2 §17," per the index).

As above, "Dedicare has no separate direct channel for end users to submit complaints to the Group, as the relationship with end users is handled by the respective customer. Comments and deviations are followed up within the framework of the customer relationship and contract management" (page 97). Remediation instead operates through the assignment-management process: "during an ongoing assignment, follow-up takes place through customer dialogue and the management of any deviations or incidents. If necessary, actions may include supplementary verification, dialogue with the relevant consultant, reassignment, or termination of the assignment" (page 97).

"Dedicare works to ensure that its own operations do not cause or contribute to negative impacts through clear requirements in assignment contracts, documented control routines, and systematic follow-up of reported incidents. Responsibility for handling these issues is integrated into the business areas' operational structure and is covered by the Group's internal governance" (page 97).

Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions

Reference: pages 96-98 (index row title: "Actions, metrics and targets"; "no separate group-wide quantitative metrics or targets established in 2025, disclosures are provided in accordance with ESRS 2 BP-2 §17").

Prior to an assignment, "professional registrations and relevant qualifications in regulated professions are verified," and matching is "based on the requirement profile and the needs of the operations" (page 97). Company-specific follow-up metrics for 2025: "Proportion of assignments where credentials and authorisation were verified prior to the start of the assignment (%)" - outcome 100%; "Number of quality- or safety-related incidents reported to Dedicare" - outcome 6 incidents (page 98).

"Dedicare assesses that future relevant metrics may relate to, for example, quality- or safety-related incidents attributable to the execution of the assignment, customer-related deviations, complaints, or other indicators linked to continuity and quality in delivery to end-users. Such metrics have not been established as group-wide metrics for the 2025 reporting year" (page 56). Effectiveness is monitored through "incident follow-up and internal quality control" (page 97).

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

Reference: pages 96-98, and page 56 (Application of phase-in provisions). Note: Appendix I Part B folds S4 targets into the S4-4 row ("Actions, metrics and targets") rather than listing S4-5 separately; the statement itself does address the absence of group-wide S4 targets explicitly, so this is recorded here as reported on that direct textual basis.

"For the 2025 reporting year, the company has also not established separate group-wide targets or quantitative metrics specifically linked to ESRS S4, but provides a general qualitative report of materiality, IROs, and governance in accordance with applicable transitional provisions" (page 56). This sits alongside the same page's statement that "Dedicare assesses that future relevant metrics may relate to... quality- or safety-related incidents... Such metrics have not been established as group-wide metrics for the 2025 reporting year," and the S4-4 company-specific indicators (100% credential verification; 6 quality/safety incidents) that currently stand in place of a formal target. Phase-in is applied under the ESRS Quick Fix delegated act of 11 July 2025, with planned "gradual implementation of processes and follow-up."

Business conduct policies and corporate culture

Reference: page 100.

Policy work "is based on the Group's Code of Conduct, which forms the foundation for the business ethics framework," covering "integrity, professional conduct, respect for legislation, good business practice and responsible treatment" toward customers, candidates, consultants, colleagues and other business contacts, and applying to all employees. It is supplemented by the Anti-Corruption Policy, Whistleblowing Policy, HR Policy, Policy against Harassment and Discrimination, and a separate Supplier Code of Conduct "specifically" for suppliers.

"Overall responsibility for the implementation of the Code of Conduct... lies with the Group Management, with the Board of Directors being ultimately responsible for the company's governance and internal control." Reporting and handling of irregularities runs through the line organisation or a dedicated whistleblowing channel, "handled promptly, factually and objectively." On anti-corruption specifically: "the Code of Conduct includes a clear prohibition against bribery, improper benefits and conflicts of interest," and "no confirmed incidents related to corruption or bribery have been identified during the reporting period."

Prevention and detection of corruption and bribery

Reference: page 101.

"Within the framework of the double materiality analysis, Dedicare has not assessed corruption and bribery as a material sustainability area for the 2025 financial year" - a caveat worth reading alongside the Appendix I Part B index, which lists G1-3 with a "Material" status and a page-101 reference. Despite that caveat, substantive content is disclosed: "preventive work takes place within the framework of the Code of Conduct, the Anti-Corruption Policy, internal guidelines on conflicts of interest as well as established reporting and control procedures," while "Dedicare currently does not have a separate, dedicated training programme regarding corruption or bribery," an arrangement "reviewed on an ongoing basis."

On resourcing: 2025 actions "have not required any significant capital expenditure (CapEx)," with resource use limited to "ongoing operational and administrative efforts" expensed as OpEx, and "Dedicare does not currently separately report any specific CapEx or OpEx items for actions within ESRS G1."

Targets related to business conduct

This is a standalone disclosure requirement only from the 2025/2026 ESRS; under the 2023 ESRS the equivalent ground was covered by MDR-T. Dedicare's FY2025 statement is prepared under the 2023 ESRS (see BP-2), so no section is headed "G1-3 Targets," but the business conduct chapter directly addresses both limbs of MDR-T: a stated target, and how effectiveness is tracked in its absence.

Reference: pages 101-102.

"For the financial year 2025, Dedicare has not established separate group-wide quantitative targets specifically for ESRS G1." In place of a formal target, the Group reports an "entity-specific indicator for reporting culture and reporting channels" - the number of reports received via whistleblowing and other reporting routes - "used during 2025 as a follow-up measure to track the development of reporting culture and functioning reporting routes, rather than as a measure with a set quantitative target level." Outcome 2025: one (1) report, "handled in accordance with established routines and... closed during the year. No significant breaches of law or the Code of Conduct were identified."

"The reason why Dedicare has not yet established separate targets... is that 2025 is the company's first reporting year according to ESRS G1 and that the indicator therefore still lacks sufficient history to form the basis for an appropriate target level." "For sub-areas within ESRS G1 that have not been assessed as material..., the Group has not established separate policies, action plans, or targets beyond the overall framework provided by the Code of Conduct."