Diasorin S.p.A.

Governance roles

Reference: pages 145-149.

The Board of Directors has 12 members, 10 non-executive, 4 independent (33% of the Board). The Board of Statutory Auditors has 3 Statutory Auditors and 2 Alternate Auditors.

The Control, Risk and Sustainability Committee (CRS Committee) was assigned, by Board resolution of 28 April 2025, the task of "supervising sustainability issues, including material IROs, connected to the corporate activities and to interactions with its stakeholders" (p.147).

Board members' professional skills: 66.66% business/management, 8% scientific, 16.66% dual economics/science, 25% legal. Gender diversity on the Board (average male/female ratio) is 0.89 (p.147). No employee representation is provided for in the governance model or Articles of Association (p.145).

Information and matters addressed by governance bodies

Reference: page 150.

"The Board of Directors of the Company tasked the CSR Committee with supervising the Group's sustainability strategy." Annually the Committee "receives information on the impacts, risks, and opportunities arising from the double materiality analysis, as well as updates on policies, actions, metrics, and targets", mainly during the review of the Sustainability Statement. The Board of Directors approves the IROs and the Sustainability Statement on an annual basis.

The Group's annual Enterprise Risk Assessment (ERA), run with external consultants, is a "preliminary reference, complemented by additional and dedicated analyses conducted within the double materiality process." During the year the CRS Committee "examined the double materiality methodology and process implemented to identify material Impacts, Risks, and Opportunities."no extraordinary strategic transactions were carried out during the year.

Integration of sustainability performance in incentive schemes

Reference: pages 150-151.

"10% of the 2025 MBO for the CEO and General Manager is based on the '2025 Sustainability Goals'", requiring cumulative achievement of all listed objectives. The sole environmental goal is quantitative: "Continuing the reduction of emissions through ongoing energy efficiency initiatives", KPI "Insulation of the Saluggia offices." The remaining goals are social/qualitative (STEM education funding and reach targets, volunteering hours, awareness campaigns, bias-training for leaders, an Engagement Survey).

Separately, for ESRS E1 the report states: "In the current reporting period, members of the administrative bodies have no incentive schemes (MBOs) linked to GHG emission reduction goals" (p.189) — so climate-specific remuneration linkage is explicitly absent even though one energy-efficiency KPI exists.

Statement on due diligence

Reference: pages 151-153.

Due diligence draws on the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. The report maps the five due-diligence elements to statement sections in a table (p.153): governance/strategy embedding to Governance information (G1) and the CRS Committee; stakeholder engagement to the DMA and engagement sections; impact identification/action/tracking to the DMA, E1/E2/E3/E5 chapters, G1-1/G1-3, and S2 supply-chain actions.

The process "will be further refined in the coming years" (p.152) — the Company frames its due diligence as a foundation still being built, drawing on existing tools (Code of Ethics, Enterprise Risk Assessment, supplier risk-based investigation using the WWF Biodiversity Risk Filter, Water Risk Atlas, Corruption Perception Index and Human Rights Risk Assessment).

Risk management and internal controls over sustainability reporting

Reference: page 153.

The process follows the EFRAG "IG 1: Materiality Assessment Implementation Guidance" and integrates with the Enterprise Risk Assessment. A validated Sustainability Statement goes to the Board of Directors for final approval.

2025 development: the Group "prepared risk matrices for the most material indicators (E1.5 – Energy and consumption / E1.6 – Scope 1 and Scope 2 emissions / S1.14 – Occupational health and safety metrics)". The main identified risk is "the potential for incomplete or inaccurate collection of the data to be reported"; key controls are an annual review by the relevant Corporate lead for completeness and consistency. No formal substantive testing was performed in 2025 on these matrices (scheduled to begin in 2026); for 2026 the Group intends to expand the indicators covered and formalize the procedure.

Strategy, business model and value chain

Reference: pages 154-157.

Diasorin is an in-vitro diagnostics group (Immunodiagnostics, Molecular Diagnostics, and Licensed Technologies via the Luminex acquisition), with 2025 revenue mix of 68.7% ex-COVID Immunodiagnostics, 16.4% ex-COVID Molecular Diagnostics, 13.8% Licensed Technologies and 1.1% COVID (p.157). Mission: "improving public health outcomes by delivering diagnostic tests that enable more effective and informed medical decision-making."

"The Company does not operate in the fossil fuel, controversial weapons, or tobacco farming and production. Furthermore, it does not produce chemical products" (p.157). Workforce is concentrated in Italy (859 employees) and the USA (1,525 employees) (p.157). Largest manufacturing sites: Saluggia (Italy), Dartford (UK), Stillwater (US), Dietzenbach (Germany), plus Chicago/Cypress (US, molecular).

Interests and views of stakeholders

Reference: pages 159-161.

Key stakeholder groups: Institutional stakeholders (Shareholders, Regulators, Government), Partners, Customers and medical community, Employees, Suppliers, Local communities (p.159). Engagement channels include industry conferences (Euromedlab, ECCMID, ASM), a dedicated Investor Relations office, customer satisfaction surveys, and dialogue with local communities via Fondazione Diasorin.

"In light of the interests expressed by stakeholders, to date, there is no perceived need to make changes to the Group's strategy or its business model" (p.159). Supplier selection and monitoring "are not structured according to sustainability parameters" currently, though new suppliers undergo due diligence on governance, financial status, quality and health/security (p.160).

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

Reference: pages 161-166.

The 2025 DMA identified 17 material impacts (down from 21 in 2024), plus 2 risks and 1 opportunity — 20 IRO rows in total across E1, E2, E3, E5, S1, S2, S3, S4, G1 and the entity-specific Research & Innovation topic. "There are no material impacts arising from the company's strategy or business model" (p.164). Financial effects "are limited compared to the economic and financial flows. No asset impairments associated with these risks were registered" (p.161).

Four impacts were dropped as no longer material in 2025: upstream water consumption, low-recyclability device manufacturing, an H&S-system impact, and a corporate-culture impact (p.166).

Phase-in note: per the ESRS content index, the Company has omitted the ESRS 2 SBM-3 paragraph 48(e) datapoint (general resilience statement) under the Appendix C transitional relief (p.172).

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

Reference: pages 163-164.

2025 was the Company's second double materiality analysis, following EFRAG's IG1 and IG2 guidance. It assesses impact materiality (severity x likelihood, 1-4 scale, human-rights severity weighted over likelihood) and financial materiality (using EBITDA and qualitative factors). The materiality threshold is a severity-times-likelihood score greater than 8 ("major").

IROs were assessed by internal Subject Matter Experts; "In 2025, no external stakeholders and experts were engaged. The Group intends to reintroduce the engagement of specific stakeholder categories for the double materiality analysis in 2026" (p.164). The list of material IROs was validated by the Board of Directors on 20 March 2026.

Disclosure requirements in ESRS covered by the undertaking's Sustainability Statement

Reference: pages 167-178.

The report contains a full ESRS content index (Annex B datapoint table, pages 167-171, plus the disclosure-requirement/chapter map, pages 172-178) identifying, for every disclosure requirement, whether it is reported (with a chapter reference), not material, or omitted under an Appendix C phase-in.

Topics found not material: all of ESRS E4 (biodiversity and ecosystems) is absent from the index entirely. Within E2, the substances-of-concern and own-operations air/water/soil sub-topics are marked "Not material, ESRS materiality limited to the value chain." G1-2 (supplier relationships), G1-5 (political influence) and G1-6 (payment practices) are marked "Not material." S1-10 (adequate wages) is marked "Not material."

Explicit Appendix C phase-ins cover ESRS 2 SBM-3 §48(e), E1-9, E2-6, E3-5, E5-6, S1-7, S1-8, S1-11, S1-12, S1-13, S1-14 (value-chain workers' metrics) and S1-15 (p.144, 172-178).

Transition plan for climate change mitigation

Reference: page 189.

"The Company has neither implemented an energy transition plan nor performed an in-depth analysis of the resilience of its strategy and business model regarding climate change." IROs were identified from current GHG sources and actions already taken (EV charging stations, photovoltaic panels). "The Company has not registered significant negative climate-related events, and therefore no relevant physical risks were identified," and no climate-related transition opportunities or risks were found.

"In the coming years, the Company will assess the opportunity to conduct a scenario analysis." Diasorin states it complies with EU Paris-aligned benchmark requirements and is not subject to the Article 12 exclusion criteria of Regulation (EU) 2020/1818. Administrative-body incentive schemes carry no GHG-linked MBOs.

Policies related to climate change mitigation and adaptation

Reference: pages 189-190.

"To date, the Diasorin Group has not implemented specific policies related to climate change mitigation and adaptation, energy efficiency, and the diffusion of renewable energies. While the topic is considered material, implementing a policy in this regard is not a current priority for the Group."

The Company states its key intervention areas "continue to be those strictly related to the business model (focused on the needs of the healthcare sector) and to personnel management, which are the areas where the Company has the most significant impact" — i.e. the absence of a dedicated climate policy is explained rather than left unaddressed.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS E1 IRO-1, where this content is disclosed in the FY2025 report (page 189). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Climate-related IROs were identified from current GHG sources and past actions (EV charging, photovoltaics), supplier document reviews, and the countries/activities the Group operates in. "The identification and evaluation process carried out by internal referents highlighted that, over the years, the Company has not registered significant negative climate-related events, and therefore no relevant physical risks were identified. The mapping of material IROs showed no climate-related transition opportunities or risks affecting its operations."

No scenario analysis has been performed: "In the coming years, the Company will assess the opportunity to conduct a scenario analysis that thoroughly and prospectively examines the effects of potential physical and transition risks on its operations and value chain" (p.189). Per ESRS, absence of paragraph 17 content is not a gap where no scenario analysis was used.

Actions and resources in relation to climate change policies

Reference: pages 190-191.

Actions focus on electrification and energy efficiency in own operations. "Despite the expected results, the CO2 reduction is not currently connected to defined future objectives or activities and is not monitored in relation to individual climate change mitigation actions."

Action 1 "Charging stations for electric vehicles": installed since 2020 in Italy, extended to Germany (5 new stations at Dietzenbach in 2024); Saluggia stations connect to the on-site photovoltaic system.

Action 2 "Energy-efficiency equipment": a 2025 site-by-site table of initiatives — window replacement and HVAC/refrigeration upgrades at Diasorin Italia, steam-system and lighting upgrades at Diasorin UK, freezer and LED upgrades at Diasorin USA and Germany. None required significant CapEx/OpEx or a structured plan.

Resilience in relation to climate change

Back-filled from ESRS E1 IRO-1, where this content is disclosed in the FY2025 report (page 189). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"The Company has neither implemented an energy transition plan nor performed an in-depth analysis of the resilience of its strategy and business model regarding climate change." The double materiality analysis "has not identified any climate change-related dependencies or risks that would cause the Diasorin Group to consider its business model to be critically vulnerable to climate change" (p.189).

No quantified or scenario-based resilience assessment exists; the Company's position is a plain statement that no such analysis as defined under the ESRS has been carried out, consistent with its broader absence of a climate transition plan.

Targets related to climate change mitigation and adaptation

Reference: page 192.

The Group's 2023-2025 ESG Sustainability Plan lists qualitative environmental commitments — "Reducing GHG emissions", "Improving Diasorin's energy efficiency worldwide", and keeping the HSE Management System aligned with ISO 14001/45001. "The aforementioned public commitments, completing in the 2025 reporting year, are not compliant with the requirements of ESRS 2-MDR-T."

"It should be noted that the Company has not implemented a system to monitor the effectiveness of the aforementioned actions." No quantified GHG reduction target, baseline year, or target date is disclosed; the Plan is described elsewhere (SBM-3) as having "met all its targets" by its 2025 close, ahead of a planned 2026-2030 ESG Plan.

Energy consumption and mix

Reference: pages 192-193.

Total 2025 energy consumption: 58,937 MWh (54,867 MWh in 2024). Fossil sources: 50,629 MWh, 86% of the total (80% in 2024), concentrated at manufacturing sites in China, Germany, Italy (Saluggia), North America (Luminex/Diasorin Molecular), the UK and the US. Nuclear-sourced consumption: 909 MWh (2%), exclusively at the Stillwater (US) facility. Renewable consumption: 7,398 MWh (13%), recorded only for sites in the US, Italy (Saluggia), Germany and China; a further 3,664 MWh of non-certified renewable-origin electricity/heat/steam/cooling is added to the total for lack of guarantee-of-origin certificates.

Energy intensity: 0.05 (MWh per €'000 net revenue, manufacturing). Not subject to third-party certification.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 194-195.

Scope 1: 4,184 tCO2eq (3,513 in 2024). Scope 2 location-based: 14,447 tCO2eq (13,546); market-based: 12,807 tCO2eq (12,132). Scope 3: 96,847 tCO2eq (136,702), 84% of gross emissions; material categories are 1, 2, 3, 4, 5, 6, 7, 8 and 11 (incorporating category 13). Total location-based: 115,447 tCO2eq (153,761); market-based: 113,838 tCO2eq (152,347). Emission intensity: 0.0966 tCO2eq per €'000 revenue.

A Scope 3 Category 11 restatement corrected a methodology error: the 2024 figure moved from 113,217 to 23,664 tCO2eq. Diasorin is outside the EU ETS and does not purchase, sell or use carbon credits or GHG removals; biogenic CO2 is not applicable to its operations.

Policies related to pollution

Reference: page 198.

"The Group did not adopt policies, actions, or objectives with reference to pollution-related IROs. Although the topic [is] identified material in the value chain, the implementation of a policy and actions, as well as the definition of objectives, are not currently a priority for the Group."

The single material E2 IRO is air pollution from value-chain activities (NOx, SOx, PM), positioned upstream and downstream rather than in Diasorin's own operations. The Company again points to its business-model and personnel-management priorities as the current focus of intervention (p.198).

Actions and resources related to pollution

Reference: page 198.

"To date, the Group has not implemented policies, actions, or defined objectives regarding air pollution management along the value chain." No dedicated pollution-mitigation actions, programs or resource allocations are described. The disclosure is a direct nil return: the Company states plainly that no actions have been taken on this material value-chain impact, rather than describing unrelated activity as if it addressed the topic.

Targets related to pollution

Reference: page 198.

"The Group did not adopt policies, actions, or objectives with reference to pollution-related IROs." No pollution-reduction target, whether qualitative or quantitative, is disclosed for the air-pollution impact identified in the value chain. As with E2-1 and E2-2, the Company frames this as a deliberate prioritization choice rather than an omission it is silent about.

Policies related to water and marine resources

Reference: page 199.

"The Group did not adopt policies, actions, or targets with reference to water and marine resources-related IROs. Although the topic has been identified as material, the Group currently does not prioritize implementing a policy and actions, or defining objectives in this regard."

The material E3 impact is water withdrawal and consumption contributing to depletion "especially in water-stressed areas" for Diasorin's own operations (p.165, p.199). Water is used for product formulation (reagents) and manufacturing (washing/cooling fermenters); there is no recycled or stored water.

Actions and resources related to water and marine resources

Reference: page 199.

No water-specific actions or dedicated resources are described; the nil-policy statement at E3-1 covers actions too: "The Group did not adopt policies, actions, or targets with reference to water and marine resources-related IROs." The Company states it nonetheless "undertakes to monitor its water consumption and withdrawal in relation to its operations," and that "all wastewater discharges are carried out in full compliance with local regulations and standards" (p.199).

Targets related to water and marine resources

Reference: page 199.

No water consumption or withdrawal reduction target is disclosed. The Company's single consolidated statement covering E3-1 through E3-3 — "The Group did not adopt policies, actions, or targets with reference to water and marine resources-related IROs" — applies equally here; the stated reason is that, although material, the topic is not currently a priority relative to business-model and personnel-management intervention areas (p.199).

Water consumption

Reference: pages 199-200.

2025 estimated water consumption: 588 m3 (256 m3 in 2024), all of it in water-stressed areas (Belgium, China, India, Israel, Italy, Spain, the US and Mexico, per the WRI Aqueduct Water Risk Atlas). The figure estimates the water content of 8,773,434 testing cartridges distributed (3.9 million immunodiagnostics, 4.9 million molecular), each containing 67 ml of water from the supply network, produced at Saluggia, Dartford, Stillwater, Dietzenbach, Chicago and Cypress.

The year-on-year increase reflects the first-time inclusion of Cypress and Chicago (molecular) output. Water intensity: 0.49 m3 per million euros of net revenue. Not subject to third-party certification.

Policies related to resource use and circular economy

Reference: page 201.

"The Group did not adopt specific policies regarding resource use and circular economy. Despite the relevance of this topic, the Group does not currently prioritize implementing a policy on this matter." Material IROs are non-renewable material use (plastics, iron) contributing to resource depletion, and waste generation (p.165, 200). Regulatory restrictions on recycled materials in diagnostic devices limit Diasorin's ability to raise recycled-content shares, so the Group "uses new and certified materials to ensure quality and compliance" (p.200).

Actions and resources in relation to resource use and circular economy

Reference: pages 201-202.

Action 1 "Plastic free project" (since 2020): eliminates single-use plastic at the Saluggia office via water dispensers, reusable bottles and compostable cups. Action 2 "Packaging optimization" (from March 2024): reduces spare-parts packaging volume to cut material use and transport emissions. Action 3 "Waste disposal and segregation": systematic tracking and country-compliant classification of all waste. Action 4 "Equipment regeneration project": 72 diagnostic/analytical instruments reconditioned in 2025 via a specialized supplier, mostly resold into developing-country markets, with a customer pick-up service for outdated units. None of the actions required significant CapEx/OpEx.

Targets related to resource use and circular economy

Reference: page 202.

"The Group did not adopt specific objectives regarding resource use and circular economy. Despite the relevance of this topic, the Group does not currently prioritize implementing a policy on this matter." No quantified recycling, waste-reduction or circularity target is disclosed. As elsewhere, the Company's stated reason is that business-model and personnel-management areas remain the current intervention priority rather than resource use and circular economy objectives.

Resource inflows

Reference: pages 202-203.

Total resource inflows, 2025: 3,790.88 tonnes (3,880.21 in 2024), comprising technical/biological materials and products used (3,213.97 t: electronic/metal parts 301.93 t, glass 179.50 t, products used 998.38 t, plastic 1,523.01 t, other 211.15 t) plus biological materials used (576.91 t: reagents/serums 28.78 t, paper/cardboard 548.13 t) and chemicals. Recycled content in packaging: 52.3 tonnes (1.4% of packaging weight), unchanged in share from 2024's 74.36 t (1.9%); recycled content in products is 0. Biological materials are 15% of total inflows. Not subject to third-party certification.

Resource outflows

Reference: pages 203-204.

"The Diasorin Group prioritizes, when possible, the development of repairable and refurbishable immunodiagnostic equipment. Once the end consumers have finished using the diagnostic kits, they become hazardous materials and cannot be recycled." Reconditioning (see E5-2 Action 4) extends equipment life. "Regarding product packaging, the Group is currently unable to disclose specific data concerning the recyclable content of its packaging."

Waste diverted from disposal totalled 1,081.68 tonnes in 2025 (927.91 in 2024); waste directed to disposal totalled 1,113.69 tonnes (1,000.02 in 2024). Full figures are under the companion E5-5-Waste entry.

Waste

Reference: pages 203-204.

Total waste generated, 2025: 2,195.37 tonnes (1,927.93 in 2024) — 750.03 t hazardous (671.37 in 2024) and 1,445.21 t non-hazardous (1,256.56). Non-recycled waste: 1,351.82 tonnes, 62% of total (unchanged from 2024's 62%). No radioactive waste is generated. Hazardous waste directed to disposal (687.43 t) is mostly "other operations" (565.47 t); non-hazardous directed to disposal (426.26 t) is mostly landfilling (311.23 t).

Hazardous waste arises from chemical reagents and biological materials (blood, tissues, cultures); recyclable items include light bulbs, batteries, computers and WEEE. Data come from HSE Site Managers (production) and Finance Managers using third-party supplier data (commercial sites); not subject to third-party certification.

Policies related to own workforce

Reference: pages 207-208, 212, 215, 218.

Diasorin recognizes people as one of its most important assets. In 2025 it introduced three new Global Policies: Equal Opportunity, Anti-discrimination/Anti-harassment/Anti-bullying, and Human Rights, each rolled out to all staff with dedicated manager training (p.207).

Sub-topic policies: an Environmental, Health & Safety Policy Statement (updated 2022) and, for Saluggia (extended to Bresso in 2025), an Integrated HSE Policy under ISO 45001/14001 (p.212). A hybrid-work "Ways of Working" policy governs work-life balance (p.215). "The Diasorin Group does not have specific policies for managing and organizing the 'Safe Employment' topic" — i.e. income-loss social protection (p.225).

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

Reference: page 208.

Engagement varies by geography: Global Town Halls; "Change Ambassadors" for organizational shifts; monthly dialogue with employee representatives in Italy plus periodic Workers' Health and Safety Representative (WSR) meetings; the "Magic Box" suggestion scheme in China; quarterly manager forums in the UK; and periodic topic-specific meetings and seminars in the US.

"Based on the suggestions or feedback provided and the concerns or needs reported, the Diasorin Group, through the Human Resources or Legal functions, is committed to constantly updating its existing policies."

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

Reference: pages 208-209.

An online whistleblowing system, active since 2019 and updated in 2023 per Legislative Decree 24/2023 implementing Directive (EU) 2019/1937, is accessible via the "EQS Integrity Line" web platform and handled by a dedicated Whistleblowing Committee. In the US and Canada a separate "compliance and information reporting line" exists.

"Every report is handled by the Whistleblowing Committee, which assesses its validity for the adoption of any potential disciplinary measures." The Company also maintains dedicated channels for discrimination, harassment and bullying complaints (p.209).

Taking action on material impacts on own workforce

Reference: pages 212-225.

Actions are organized by sub-topic. Health and safety: Minimum EHS Requirements, HSE audits, and EHS training (ongoing, p.212-215). Work-life balance: welfare and benefit initiatives by region — EAP and family-adoption support (North America), supplementary medical/dental insurance (UK), supplementary health insurance (China), welfare-plan extension and canteen (Italy) (p.216-217). Gender equality/diversity: "Merit Mindset" unconscious-bias training for all leaders, UNI/PdR 125:2022 gender-equality certification for Italian subsidiaries (December 2025), extra paid parental/paternity leave in Italy (p.218-219). Safe employment: no specific actions — "The Diasorin Group does not currently have specific policies for managing and organizing the 'Safe employment' topic" (p.225).

Targets related to own workforce

Reference: pages 209-210.

The 2023-2025 ESG Sustainability Plan's social commitments include equipping the Group with talent-promotion/fair-opportunity policies, a Global Engagement Survey, and aligning local social-responsibility initiatives with Group policy. "Please note that the public commitments due for completion in 2025 do not comply with the requirements of ESRS 2-MDR-T."

Both named targets were met: the Global Policy on Equal Opportunity launched alongside "The Merit Mindset" training, and "The first Global Engagement Survey was launched in November 2025." The Group is now developing a 2026-2030 ESG Plan alongside its new Strategic Plan.

Characteristics of the undertaking's employees

Reference: pages 210-212.

Total employees, 2025: 3,272 (1,438 female, 1,833 male, 1 other) vs. 3,271 in 2024. By country: Italy 859 (415 F / 444 M), United States 1,525 (641 F / 883 M / 1 other). Permanent contracts: 3,245 (99% of the workforce); fixed-term 27; full-time 3,212; part-time 60. Average headcount 2025: 3,281 (3,227 in 2024).

Employee turnover: 392 departures, an 11.95% turnover rate — "a significant improvement... compared to 13% in 2024 and 19% in 2023." Data validated by local HR teams and the Group's SAP SuccessFactors HRMS.

Diversity metrics

Reference: pages 220-221.

Top management gender split, 2025: 165 male (71%), 67 female (29%) of 232 total (160 M / 62 F, 72%/28%, in 2024). Age distribution, 2025 (3,272 total): under 30 — 375 (11%); 30-50 — 1,964 (60%); over 50 — 933 (29%). Blue-collar, white-collar and executive breakdowns are tabulated separately by gender and age band.

"The company employs over 3,000 people worldwide, with 90% of them having a degree, primarily in STEM fields." The Group notes EU STEM graduates are "around 25%" of young graduates, with men outnumbering women roughly two to one, and cites Fondazione Diasorin's STEM outreach as a mitigation.

Health and safety metrics

Reference: page 215.

Employees covered by the H&S management system: 100% (94% in 2024). Deaths from work-related injuries/illness: 0. Workplace accidents: 16 (14 in 2024); recordable injury rate: 2.6% (2.5% in 2024). Days lost to accidents: 146 (201 in 2024); no fatality-related days lost.

"The majority of accidents are caused by business-related car travel." Figures are not subject to third-party certification. Note: the value-chain-workers' portion of S1-14 (non-employee H&S metrics) is separately listed among the Appendix C phase-ins applied (p.144); this entry covers Diasorin's own workforce, for which data is fully reported.

Compensation metrics (pay gap and total compensation)

Reference: page 221.

Gender pay gap, 2025: 15.17% on total compensation (12.81% base salary, 29.49% variable/complementary), restated 2024 comparative 15.18%. Average gross hourly wage: men €44.68 total (€38.35 base), women €37.90 total (€33.44 base).

Total annual compensation ratio: 43:1 (39:1 in 2024) — highest-paid individual's total compensation of €2,898,612 against a median employee compensation of €67,790. A footnote flags that the 2024 comparative pay-gap figures were restated after a prior calculation-methodology error.

Incidents, complaints and severe human rights impacts

Reference: page 222.

Discrimination incidents, 2025: 2 (7 in 2024); reports submitted through internal concern channels: 29 (13 in 2024); 0 reports to OECD National Contact Points; €0 in related fines. "Increased reporting demonstrates that the company's feedback channels are working effectively."

Serious human rights incidents for company personnel: 0, with zero cases of non-compliance with the UN Guiding Principles, the ILO Declaration, or the OECD Guidelines, and zero related fines or damages. Data are supplied by HR Business Partners managing employee-relations investigations.

Policies related to value chain workers

Reference: pages 226-228.

Policy 1 "Policy on Sustainability and respect of Human Rights of the Diasorin Group" (Board-approved): covers own operations and the entire supply chain; "the Group specifically refuses to engage in or maintain business relationships with suppliers who engage in irregular, forced, compulsory, or child labour practices." Policy 2 "Modern Slavery Statement" (voluntary, Board-approved by Diasorin S.p.A., Diasorin Italia and Diasorin Limited in March 2023): adopts zero tolerance for slavery, servitude, forced/compulsory labour and trafficking.

"At present, the Group has not developed a specific assessment process regarding the risk exposure of workers across the value chain" — there is no dedicated supplier Code of Conduct, though every supplier must sign the Group Code of Ethics.

Processes for engaging with value chain workers about impacts

Reference: page 228.

"At the date of this report, the Group has not implemented structured processes to engage workers in the value chain." This is a direct, disclosed nil return for S2-2, distinct from the remediation channels described under S2-3, which are accessible to value-chain workers even without a dedicated structured engagement process.

Processes to remediate negative impacts and channels for value chain workers to raise concerns

Reference: page 229.

Official communication channels, including the Whistleblowing system, are open to third parties along the value chain, not only to Diasorin employees. "Reports received through these official channels are handled with a confidentiality-focused approach, shielding reporters from potential retaliation, just as the Company does for reports from Group employees." The same Whistleblowing Committee established for own-workforce reports handles investigations and, where warranted, disciplinary or legal escalation.

Taking action on material impacts on value chain workers

Reference: pages 229-230.

Action "Supplier Management" and "Procurement Portal: Supplier Qualification" (ongoing): formal guidelines for selection, qualification, monitoring and management of suppliers, requiring Code of Ethics compliance clauses and risk-based classification. "To date, the Group has not established any sustainability criteria for selecting suppliers" — monitoring instead covers acceptance testing, product-certification verification and supplier-site audits.

"No serious human rights issues or incidents have been reported in connection with its upstream and downstream value chain" during 2025; the projects required no significant CapEx/OpEx.

Targets related to managing material impacts, risks and opportunities for value chain workers

Reference: page 176 (ESRS content index).

"No value chain workers-related targets have been identified" is the index's stated answer for S2-5. No quantified target for reducing value-chain health-and-safety or forced-labour impacts is disclosed; the Company's supplier-management actions (S2-4) are not linked to a numeric objective or monitoring system for effectiveness.

Policies related to affected communities

Reference: page 231.

"The Diasorin Group has not yet implemented policies regarding the impacts associated with the affected communities. This decision stems from the fact that these topics are not closely related to the Group's priority areas," which remain the healthcare business model and personnel management. The material S3 impact is a positive one: supporting local communities through targeted well-being initiatives, delivered mainly via Fondazione Diasorin (p.165, 231).

Processes for engaging with affected communities about impacts

Reference: pages 231-232.

Local communities are engaged through Fondazione Diasorin and corporate communications (press releases, newsletters, and sustainability content on diasorin.com and fondazionediasorin.com). The Foundation runs a Technical-Scientific Committee of science teachers, university professors and teacher-training specialists who maintain ongoing dialogue with stakeholders on strategic areas for intervention.

Processes to remediate negative impacts and channels for affected communities to raise concerns

Reference: page 232.

The Whistleblowing system is accessible to affected communities as well as to internal stakeholders. "Diasorin provides direct access to these channels, fostering a transparent and inclusive dialogue," and has "implemented policies to safeguard individuals who utilize these channels, aiming to prevent any form of retaliation," cross-referenced to the G1-1 business-conduct policies.

Taking action on material impacts on affected communities

Reference: pages 232-236.

Delivered mainly through Fondazione Diasorin (established July 2020; average annual operating expense €1 million): "Mad for Science" (STEM competition for Italian high schools; 2025 prize pool €200,000; 143 projects from 15 regions); "Mad for Science for Teachers" webinars and lab courses; "Up Close with Research" with Fondazione Telethon (17 scientists, 1,702 students, 2024/25). Sports-inclusion sponsorships: FISIP Paralympic winter sports (€35,000), EDGA Paralympic Golf (€6,000), Diasorin Cup sitting volleyball. The Diagnosis and Prevention Campaign reached audiences via 66 web releases, 69 TV releases and 7 print releases (€122,000 cost). "For the current reporting period, no significant human rights issues or incidents concerning affected communities have been identified or recorded."

Targets related to managing material impacts, risks and opportunities for affected communities

Reference: page 236.

The 2023-2025 ESG Sustainability Plan's single named community commitment is "Aligning local social responsibility initiatives with the Group's existing policy, which outlines the types of actions that can be implemented in local communities." No quantified community-impact target (e.g. beneficiary counts, funding levels) is set as a formal objective, though Fondazione Diasorin's activities are tracked by attendance and prize figures each year.

Policies related to consumers and end-users

Reference: page 238.

"The Diasorin Group has not yet implemented policies regarding the impacts, risks, and opportunities associated with Consumers and End Users. Despite the topic [being] identified as material, the Group does not prioritize implementing a policy at this time." The material S4 impact is positive: developing innovative diagnostic products and ensuring a consistent supply to support diagnostic activity and safeguard patient health and safety (p.166, 237).

Processes for engaging with consumers and end-users about impacts

Reference: pages 238-239.

The "Diasorin Group Customer Satisfaction Survey," run with partner TP Infinity, is conducted in two half-yearly waves (Relational: telephone interviews; Transactional: post-intervention email questionnaires), extended to all Luminex companies since 2022. "The portal is designed to automatically initiate a 'hot case' procedure if a rating falls below the required threshold," triggering a branch-level recovery plan. Results are tracked on a country-differentiated web portal with biannual management reporting.

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

Reference: page 239.

The Customer Satisfaction Survey doubles as a feedback-and-issue channel, supplemented by a technical-support channel on Diasorin's website, managed internally except for the TP Infinity survey collaboration. "During the reporting period, there were no reported cases of significant human rights violations or incidents related to consumers and end-users." Whistleblowing protections against retaliation apply per ESRS G1-1.

Taking action on material impacts on consumers and end-users

Reference: pages 239-241.

Action 1 "Quality Management System" under ISO 9001:2015, ISO 13485:2016/A11:2021 and 21CFR Part 820. Action 2 "Diasorin Group Customer Satisfaction Survey": 2024 wave covered ~1,200 Diasorin customers across 20 countries plus ~1,200 Luminex customers (~30% sampling); overall satisfaction 8.81/10 (Diasorin) and 8.55/10 (Luminex), both steady year-on-year. Action 3 "Laboratory staff training": 2025 outreach reached over 160 critical-care centres via Clinical Specialists on antimicrobial resistance and sepsis markers, plus a diagnostic-clinical integration with ~60 national care centres on hypertensive-risk and bone/nephrological testing.

Targets related to managing material impacts, risks and opportunities for consumers and end-users

Reference: page 241.

"The Group has not set any objectives regarding end-users and consumers, as this initiative is not part of the company's primary business plans," and "has not implemented a system for monitoring the effectiveness of the actions listed above." The Company states it is "leveraging the evolving European regulatory landscape to redefine its sustainability objectives" over the medium term, without committing to a specific target or date.

Business conduct policies and corporate culture

Reference: pages 245-247.

Policy 1 "Group Code of Ethics", applicable to all Group companies, suppliers, consultants, agents and distributors, sets rules against active and passive corruption and anti-competitive conduct. A Whistleblowing Committee has operated an online reporting platform ("EQS Integrity Line") since 2019, formalized under a July 2023 Report Management Procedure (Legislative Decree 24/2023). "Throughout 2025, no reports were received regarding situations that could have involved corrupt conduct."

Highest-bribery-risk functions identified: Sales, Marketing and Scientific Affairs. "The Company does not currently plan to adopt a specific anti-corruption policy aligned with the United Nations Convention" (consistent with the index's "Not material" marking for that SFDR datapoint).

Prevention and detection of corruption and bribery

Reference: pages 247-248.

Oversight sits with the Supervisory Bodies (SB) of Diasorin S.p.A. and Diasorin Italia S.p.A., supported by the Whistleblowing Committee; SB findings go into a semi-annual report to the Control, Risk and Sustainability Committee and the Board, with urgent escalation for critical incidents. Internal Audit runs annual sample checks on Code of Ethics acceptance (digitized via the Smart Solve system since 2022) and on gift/benefit expense reports. Training on the Code of Ethics and Model 231 is mandatory for at-risk functions, with the last refresher held 1 February 2025; "the administrative, management, and supervisory bodies do not receive specific anti-corruption training."

Targets related to business conduct

(part of MDR-T/GDR-T disclosures)

Reference: pages 247-248.

No numeric business-conduct target is set: "The Group did not set any objectives for managing the aforementioned impacts" (corruption/bribery, p.248). Effectiveness is instead tracked through recurring monitoring: semi-annual Supervisory Body reports to the CRS Committee and Board, annual Internal Audit sample checks on Code of Ethics acceptance and gift/benefit expenses, and mandatory at-least-biennial anti-corruption training for at-risk functions (Sales, Marketing, Scientific Affairs) — the alternate MDR-T limb of tracking effectiveness in the absence of a formal target.

Incidents of corruption or bribery

Reference: page 248.

Convictions for corruption/bribery law violations, 2025: 0 (0 in 2024). Fines for corruption/bribery violations: €0 (€0 in 2024). "No episodes of corruption or bribery occurred during the reporting year, nor were any related sanctions or fines imposed." Metrics are not subject to third-party certification.