Digia

Responsibility for Digia's operations is held by the Shareholders' Meeting, Board of Directors, and the President & CEO assisted by the Group Management Team. Digia's highest decision-making body is the Shareholders' Meeting at which shareholders exercise their voting rights on company matters.

Board of Directors and Committees

The Board of Directors is elected by the Shareholders' Meeting, and is in charge of Digia's administration and the appropriate organisation of the company's operations. Under the Articles of Association, the Board of Directors must consist of a minimum of four and a maximum of eight members. Neither the CEO nor other company employees working under the CEO's direction may be elected members of the Board.

The Board of Directors has defined a Board diversity policy. It states that the requirements of the company's size, market position and industry should be duly reflected in the Board's composition. Both genders should be represented on the Board. It should be ensured that the Board as a whole will always have sufficient expertise in the following areas in particular:

• the company's field of business • managing a company of similar size • the nature of a listed company's business operations • management accounting • risk management • corporate sustainability statement • mergers and acquisitions • board work.

The members of Digia's Board of Directors have extensive and relevant expertise in these areas on the basis of their primary work experience and other positions of trust.

The majority of Board members must be independent of the company and a minimum of two of those members must also be independent of the company's major shareholders. Of the current members of the Board, Martti Ala-Härkönen, Santtu Elsinen, Sari Leppänen, Henry Nieminen and Outi Taivainen are independent of the company and its major shareholders. Robert Ingman is independent of the company. Robert Ingman is not independent of the company's major shareholders due to his holdings in related parties.

During the 2024 reporting year, Digia's Board of Directors had three (3) committees: the Audit Committee, the Compensation Committee, and the Nomination Committee. It is the Audit Committee's role to monitor impacts and risks. These committees do not hold powers of decision or execution unless separately authorised by the Board; their role is to assist the Board in decision-making concerning their areas of expertise. The committees report regularly on their work to the Board, which has decision-making and collegial responsibility over their actions.

Gender Distribution

Gender distribution of Board of Directors 2024: Women 33% (2), Men 67% (4)

Gender distribution of Management Team 2024: Women 20% (2), Men 80% (8)

CEO and the Management Team

The company's Chief Executive Officer is appointed by the Board of Directors. The CEO is in charge of Digia's business operations and administration in accordance with the instructions and regulations issued by the Board of Directors, and as defined by the Finnish Limited Liability Companies Act. The CEO chairs the Group Management Team's meetings. The CEO is not a member of the Board of Directors, but attends Board meetings. The Management Team assists the CEO in the preparation and implementation of strategy, routine management, and preparing items for consideration by the Board of Directors. The CEO is responsible for the Management Team's decisions. Members of the Management Team are tasked with implementing these decisions within their own areas of responsibility.

Digia's Management Team consists of ten people: the CEO, CFO, General Counsel, CTO and HR Director, as well as the SVP of Sales and Marketing and the SVPs of four business areas. All members of the Management Team have lengthy experience in the company's sector or their own area of expertise.

Under the authorisation of the Board of Directors, the Remuneration Committee approves the appointments of the members of the Group Management Team and decides on the terms and conditions of their service contracts on the basis of the CEO's proposal. There were no employees or employee representatives in Digia's Management Team during the 2024 reporting year.

Sustainability-related expertise and skills

The Board of Directors, its committees and the Management Team regularly discuss reviews of various aspects of sustainability, which are presented by the Group's experts and operational management. Through these reviews, Digia's senior executives learn about the most material impacts, risks and opportunities associated with the company's sustainability, as well as the company's progress towards its sustainability targets and its sustainability-related projects. These reviews ensure that Digia's management has up-to-date information and competence with regard to sustainability issues. The need for any follow-up measures or external expertise is also decided upon.

The Board of Directors, its committees and the Management Team regularly discuss reviews of various aspects of sustainability, which are presented by the Group's experts and operational management. Through these reviews, Digia's senior executives learn about the most material impacts, risks and opportunities associated with the company's sustainability, as well as the company's progress towards its sustainability targets and its sustainability-related projects. The Board discussed sustainability at five of its meetings in 2024. At Audit Committee meetings, experts and senior executives present information for the committee to review: sustainability themes, target attainment, development plans, and development measures and their implementation. The outcomes of the Group's risk management (including sustainability risks) are presented to the Audit Committee twice a year, along with any reports of potential misconduct that have been made through the Whistleblowing channel.

During 2024, the following sustainability-related material risks, impacts and opportunities were reviewed at meetings of the Board of Directors and its Committees:

Impacts • Trends in Digia's CO2 emission targets and measures to achieve them. • Value chain emissions: the accuracy of Scope 3 data and a development plan. • The competencies and resources required to meet stakeholder requirements and carry out actions arising from sustainability regulation. • An overview of challenges facing the workplace community and any necessary development measures (mental health, equal treatment).

In the 2024 fiscal year, Digia had a long-term share-based incentive scheme for senior executives. The earning period in the incentive scheme is 2023–2025. The scheme's target group consists of the CEO and the company's senior executives. The scheme may also cover other individual key personnel. The scheme is designed to align the goals of the company's shareholders and management in order to increase the company's value, and to commit executive management to the company and its long-term objectives. It offers participants the chance to earn company shares if the targets set by the Board of Directors for the three-year bonus period are met.

These targets are based on the company's net sales, cumulative earnings per share (EPS) for 2023–2025, and sustainability objective. The earnings period for indicators is three years (2023–2025), and the targets for all indicators have been set for the final date of the earnings period. During the bonus period, the company's CEO and other scheme participants are entitled to a bonus equivalent to a maximum of 480,000 new Digia Plc shares. If the terms are met, the bonuses for all indicators based on the new scheme will be paid at the end of the reward period in spring 2026. All bonuses under this scheme will be paid as a combination of shares and cash. The cash component of the bonus will primarily be used to cover taxes and other comparable costs arising from the scheme.

As a rule, the bonus will not be paid if a member resigns or if a member's employment or post is terminated prior to the bonus payment date specified in the incentive scheme. Under certain conditions, the Board may, at its discretion, decide on possible bonuses in accordance with the pro-rata principle.

EUR 0.6 million in expenses were incurred by the scheme during the 2024 fiscal year. EUR 0.4 million in expenses were incurred by incentive schemes during the previous fiscal year.

The company has a finance business partner function that reports to the CFO and is tasked with ensuring the accuracy of monthly financial reporting. The CFO reports on the financial performance of the company and its divisions to Management, the Board of Directors, and the Board's Audit Committee.

The company uses a reporting system that compiles subsidiaries' reports into consolidated financial statements. There are also written directives for completing the financial reports of subsidiaries. The company's CFO monitors compliance with these instructions. The company also has the separate reporting facilities required for monitoring business operations and asset management.

The Group's financial administration unit prepares management's interim reports, consolidated interim reports and consolidated Financial Statements. This financial administration unit has centralised control over the Group's funding and asset management, and is in charge of managing financial risks.

Internal control helps to ensure the reliability of the Digia Group's financial reporting. Digia's financial administration unit provides guidance on financial reporting matters. The Group's business is divided into areas of responsibility led by Senior Vice Presidents (SVPs) reporting to the CEO. Reporting and supervision are based on annual budgets that are reviewed monthly, on monthly income reporting, and on updates of the latest forecasts.

The SVPs report to the Group Management Team on development matters, strategic and annual planning, business and income monitoring, investments, potential acquisition targets and internal organisation matters related to their areas of responsibility. Each area of responsibility also has its own management team.

Digia's operational management and supervision adhere to the corporate governance system described above.

Digia has not yet established a separate function responsible for internal auditing. The need for an internal audit function is regularly assessed. With the company's current business volume, its legal and financial management functions are able to handle internal auditing tasks.

Digia is a growing software and service company that combines technological possibilities and human capabilities to build smarter businesses and societies – and a sustainable future. Our mission is to keep our customers at the forefront of digital evolution by harnessing our well-rounded expertise, comprehensive offering and operational models that suit the customer's needs. Digia is a smart business partner with the most comprehensive IT service offering in Finland: we provide all the layers of digitalisation from business systems to integrations, digital services and 24/7 monitoring and service management. We operate internationally with our customers.

Strategy - "Unlock Your Intelligence"

We combine technological possibilities and human capabilities to build smarter businesses and societies – and a sustainable future. We ensure that our customers are at the forefront of digital evolution, with an operational model and rhythm that are right for them. We harness Digia's well-rounded expertise and comprehensive offering as well as operational models that suit the customer's needs. We constantly renew our own operations and expertise, and work with reliable partners. As a versatile company, Digia can offer its employees meaningful job tasks and things to learn. We are building a responsible society and a sustainable Digia.

We implement our strategy by tapping into our strengths and the specialist expertise of our service areas. As a unified company, we provide our customers with extensive solution packages and the expertise of our specialised service areas for their individual needs. We build long-term customer relationships and partnerships.

Main Strengths

• reliability and long-term customer relationships • diverse and constantly evolving top expertise • a well-rounded offering that can be combined to expand customer relationships • a strong financial position • a business model in which continuous services yield operational stability • the ability to carry out successful acquisitions and grow the acquirees as part of Digia.

Specialised Service Areas

Digital Solutions: Smart solutions for data utilisation and the customer experience. Digital Solutions provides our customers with comprehensive digital services for developing smart business and enhancing their customer experience. Key areas include data utilisation solutions, AI-based solutions, state-of-the-art customer relationship management, e-commerce solutions, versatile online and mobile services, digital marketing as well as service design and business services.

Business Platforms: Versatile and comprehensive ERP solutions. Business Platforms provides our customers with versatile and comprehensive solutions for smart financial management and ERP. Smart ERP integrates systems, data and processes into a data-driven solution, unlocking the power of automation, AI, and business development. Our offering comprises Microsoft Dynamics 365 solutions, Oracle NetSuite and our own Digia Envision ERP product.

Financial Platforms: Service and system packages for fund management companies, asset managers and stockbrokers. Financial Platforms provides versatile system packages for customers in the financial sector. Our business revolves around the Digia Financial Systems product family (DiFS), which is one of the most extensive financial systems for fund management companies, asset managers and brokers in the Nordic countries.

Managed Solutions: Service packages and outsourcing for maintenance, continuous development and security. Managed Solutions provides customers with the cornerstones of smart digital business, including cloud services, Finland's leading integration and API solutions, robotics and AI automation services, knowledge-based and change management services, information security, high-security solutions and continuous services (24/7 Managed Services).

Value Chain

Digia operates in ten locations in Finland. Abroad, we operate in Stockholm and Malmö in Sweden and in Hengelo in the Netherlands. Service for our Danish customers is provided from Sweden. Our headquarters are located in Helsinki. The Digia Hub brings together top freelance IT professionals in Northern Europe, and enables our customers to acquire versatile business, design and technology expertise to meet the varying needs of their projects.

Group Structure

On 31 December 2024, the Digia Group included the parent company Digia Plc and the following subsidiaries: • Digia Finland Oy and its subsidiary Most Digital Sweden AB • Productivity Leap Oy • Digia Sweden AB • Climber International AB and its subsidiaries Climber Finland Oy, Climber Benelux B.V., Climber Danmark ApS, Climber Holding AB, and its subsidiary Climber AB • Top of Minds AB

All subsidiaries are wholly owned by Digia.

Interests and views of stakeholders

Stakeholder identification and engagement approach

Digia's most important stakeholders are customers, personnel, investors, educational institutions, technology partners, subcontractors, organisations and communities. When identifying the material aspects of responsibility for each stakeholder, Digia has taken into account the most significant economic, social and environmental impacts of its operations and services, as well as other significant trends affecting the ICT sector. Digia builds up an understanding of materialities and stakeholders' expectations through a combination of routine management and regular meetings, surveys and analyses. Communication methods vary by stakeholder.

Both investors and customers have become increasingly active in areas relating to sustainable development. Taking stakeholders' interests and views into account is a key element of Digia's strategic planning and business development. Digia responds to changes in its stakeholders' needs and expectations by continually developing its operations and prioritising actions that will support both the company's own business and its collaboration with stakeholders.

Management engages in continuous dialogue with customers and other stakeholders through regular discussions, meetings, and by fostering partnerships via various channels. The Audit Committee receives biannual reports on developments in stakeholder-related risks, and sustainability risks are monitored during the Group's Management Team meetings.

Stakeholder engagement by group

Key stakeholder concerns and views

The document notes that both investors and customers have become increasingly active in areas relating to sustainable development. Specific concerns identified include:

Customer-related:

• Feedback on customer satisfaction (NPS) concerning Digia's status as a trusted partner
• Survey of customer needs with regard to sustainability themes
• New customer and business development needs that have arisen through increased regulation

Personnel-related:

• The adequacy of human resources: current status, personnel competence and turnover
• Digia's attractiveness as an employer: current resources and the company's ability to provide meaningful work that leads to personal development

Integration into strategy and business model

Taking stakeholders' interests and views into account is a key element of Digia's strategic planning and business development. Digia responds to changes in its stakeholders' needs and expectations by continually developing its operations and prioritising actions that will support both the company's own business and its collaboration with stakeholders.

The Audit Committee receives biannual reports on developments in stakeholder-related risks, and sustainability risks are monitored during the Group's Management Team meetings.

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

Overview

Six out of the ten sustainability themes mentioned in the directive emerged as material themes in Digia's double materiality assessment: climate change, resource use and circular economy, own workforce, workers in the value chain, consumers and end-users, and business conduct.

During the current reporting period, Digia did not identify any significant financial impacts relating to material risks or opportunities. There were no changes in the most significant impacts, risks or opportunities in comparison to the previous reporting period. When Digia's financial risks are taken into consideration, no significant changes in the company's financial performance, cash flows or financial position have been observed, and none are expected in the short term. Digia has no planned investments or divestments associated with the aforementioned. Customer demand and needs determine the realization of economic opportunities and the resulting environmental impacts in the short, medium, and long term.

Digia has not identified any business risks or opportunities that would not be covered by the ESRS disclosure requirements.

Material impacts, risks and opportunities by topic

Managing impacts, risks and opportunities

The key themes identified in the double materiality assessment have been included in current risk management and are handled in accordance with normal risk management processes. Impacts and opportunities are addressed in each business area, and also by the senior executive in charge of the function in question. They are assessed and prioritised as part of the annual calendar. Sustainability and a sustainable business model are key elements in Digia's strategy and approach. Digia revises its strategy and priorities for each strategy period, and thereby also the impacts and opportunities associated with sustainability topics.

Topic-specific details

E1 Climate change mitigation

Digia's own operations and procurement generate emissions. However, Digia can significantly improve its customers' energy and carbon dioxide efficiency through a variety of IT solutions, which will play a key role in reducing our society's emissions.

E5 Resource use and circular economy

Customers need to reduce their resource usage, and the green transition will create business opportunities for solutions that harness green coding and the circular economy.

S1 Own workforce

Digia is heavily dependent on its experts, which underlines the importance of employee wellbeing, workload management and flexible working hours. The potential negative impacts on Digia's own workforce include experiences of discrimination or inappropriate treatment, workload issues, and challenges related to wellbeing and not being able to be oneself at work.

The positive impacts on Digia's own workforce include providing meaningful and challenging work for employees and supporting their wellbeing at work and continuous personal development.

The crux of Digia's personnel strategy is that sustainable growth is created by people who enjoy their work. An appealing workplace community is an important enabler for Digia's growth, and being an attractive employer is also a business opportunity.

S2 Workers in the value chain

The Digia Hub subcontracting network is an integral part of Digia's operating model. Digia is strongly dependent on its skilled workforce, which is why the company also needs to source experts through subcontracting. Digia is aware that it has subcontractors in countries in which there is a higher risk of human rights violations.

S4 Consumers and end-users

Digia handles and develops solutions that make extensive use of data. The company aims to promote the digitalisation of society by providing everyone with secure and easy-to-use services. End-users may be exposed to a variety of privacy risks. Digia's most significant business risks are associated with privacy and security issues that could damage its reputation or potentially lead to major compensation claims.

G1 Business conduct

Digia operates in regions in which negative impacts on business practices are comparatively low on a global scale. The company is considered to be a reliable business partner. Fulfilling regulatory requirements can be a potential risk factor and requires investments. However, sustainability and reliability can also constitute a competitive edge and generate new business opportunities.

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

Overview

Digia conducted its double materiality assessment in 2023, and refined it in 2024 with regard to material sustainability impacts. The assessment identified the most significant sustainability themes for Digia's business, taking the entire value chain into account. It covered the company's own operations, as well as all upstream and downstream operations from direct and indirect suppliers to customers and solution end-users.

The assessment was based on the EU Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS). It determined the themes on which Digia's business has significant positive and/or negative impacts and the themes that create the most significant business risks and/or opportunities for Digia. The assessment was carried out in collaboration with an expert partner.

Methodology

Step-by-step process

1. Initial list development: The list of sustainability issues covered in the ESRS Application Requirements (ESRS 1 AR 16) was utilised both in the assessment and to draw up an initial list of material topics.

2. Preliminary analysis: The process utilised existing data on Digia's sustainability themes, as well as plans and external sources of information about typical sustainability themes within the sector. Stakeholder-related background material included customer interviews, online customer surveys, a reputation survey and an employer image survey. This preliminary list formed hypotheses on potentially material topics.

3. Impact assessment: A more accurate impact assessment was performed that identified Digia's actual and potential impacts. The assessment was performed separately for impacts and financial materiality.

4. Scoring: Impacts were assessed on the basis of a scoring system in which each topic was individually assessed in terms of its scale, scope, remediation and probability. Risks, dependencies and opportunities were scored on the basis of their financial significance and probability.

5. Analysis: All topics were analysed from the perspective of their impacts and financial significance, with particular attention being paid to the relationships between them.

6. Value chain and time frame consideration: As part of the assessment, Digia considered which section of the value chain has the greatest impact and over what time frame. The value chain was separated into upstream and downstream, and Digia's own operations. The time frame was divided into short-, medium- and long-term.

7. Prioritization: Prioritisation assessed the probability and scope of impacts, risks or opportunities. Topics with a score above a predetermined threshold were defined as material. This threshold was defined as topics with a score of moderate or higher.

8. Sub-theme aggregation: The assessment was carried out at a sub-theme level. At sub-sub-theme level, topics were aggregated when they were of a similar nature, had impacts on the same stakeholders, or received the same score.

Inputs to the assessment

• ESRS guidance: List of sustainability issues covered in ESRS 1 AR 16
• Sector benchmarks: External sources of information about typical sustainability themes within the sector
• Internal experts: Some of Digia's internal experts took part in the assessment, for example, via interviews and workshops
• Management involvement: Digia's Management Team was actively involved throughout the assessment process
• Board oversight: The Board of Directors' Audit Committee discussed topic definitions
• External stakeholders: Surveys and interviews were used to take external stakeholders' views into consideration, including:
  • Customer interviews
  • Online customer surveys
  • Reputation survey
  • Employer image survey
  • Financial institution interview to gain insights into its views on important sustainability themes
• Expert partner: The assessment was carried out in collaboration with an expert partner

Scoring criteria

Impact materiality

Impacts were assessed on the basis of a scoring system in which each topic was individually assessed in terms of:

• Scale
• Scope
• Remediation (irremediable character)
• Probability (likelihood)

Financial materiality

Risks, dependencies and opportunities were scored on the basis of:

• Financial significance (size of effect)
• Probability (likelihood)

Threshold for materiality

Topics with a score above a predetermined threshold were defined as material. This threshold was defined as topics with a score of moderate or higher.

On this basis, there are a total of ten material topics:

1. Climate change mitigation (E1)
2. Energy (E1)
3. Resource use and circular economy (E5)
4. Working conditions - own workforce (S1)
5. Equal opportunities and opportunities for all - own workforce (S1)
6. Working conditions - value chain workers (S2)
7. Privacy - consumers and end-users (S4)
8. Data security - consumers and end-users (S4)
9. Social inclusion - consumers and end-users (S4)
10. Business conduct (G1)

Value chain mapping

As part of the assessment, Digia considered which section of the value chain has the greatest impact. The value chain was separated into:

• Upstream: Direct and indirect suppliers
• Own operations: Digia's own business activities
• Downstream: Customers and solution end-users

During the assessment, Digia noted that the material impacts of upstream operations only cover direct suppliers, while downstream operations include customers and solution end-users.

Time horizons

In both its double materiality assessment and the identification of risks and opportunities, Digia has used the short-term (one year), medium-term (1–5 years) and long-term (more than five years) definitions given in ESRS 1.

Frequency and review

Digia reviews its materiality assessment at least once per strategy period and, if necessary, also at more frequent intervals if there are significant changes in the company's operating environment or business.

Digia's current strategy period covers the calendar years 2023–2025, and the process has not changed during this time. The company will also monitor changes in legislation and market practices in case any updates are required.

Digia will update its double materiality assessment at least once per strategy period, or when significant changes occur in the company's business. At the same time, the company will also review the need for any changes in the management of sustainability risks.

Approval and governance

On the basis of preparatory work carried out by the Management Team, the Audit Committee assessed and approved the materiality assessment.

As part of its double materiality assessment, (double materiality has the same meaning as the term double materiality in the ESRS standards and the term two-way information in the Accounting Act) Digia has analysed those sustainability themes that are most material to the company's business, taking the entire value chain into account. Based on this assessment, the Sustainability Statement covers upstream operations for direct suppliers and downstream operations for Digia's customers and the solutions delivered to its customers' end-users.

A list of reported disclosure requirements and references to other content can be found on pages 63–65 of this statement.

Transition plan for climate change mitigation

Overview and scope

Digia set climate targets in conjunction with the publication of its strategy for 2023–2025: by 2025, Digia will reduce the entire value chain's CO2 emissions by 60 per cent (compared to the 2019 baseline). However, the alignment of the strategy period's emissions reduction target with the Paris Agreement has not been separately verified.

Digia joined the Science Based Targets initiative in 2024 and will define its science-based climate targets during 2025. The baseline for the updated climate targets will be Digia's 2023 carbon footprint calculation. A more detailed transition plan for climate change adaptation will also be drawn up during 2025 in conjunction with the setting of science-based targets, and this will be reported on in the 2025 Sustainability Statement.

Due to the nature of Digia's business, the company has not identified any risk of potential locked-in GHG emissions in its operations. Digia is not excluded from the EU's Paris-aligned Benchmarks.

Target year and reduction milestones

2023–2025 Strategy period target:

• Reduce entire value chain CO2 emissions (Scope 1–3) by 60% by 2025 (baseline: 2019)
• 2019 baseline: 3,055 tCO2eq

Baseline year details: In 2019, Digia's carbon footprint was 3,055 tCO2eq. It covered the Scope 1 and Scope 2 emissions of the company's then-current Finnish operations, as well as selected procurements and other Scope 3 emissions. Scope 2 was calculated using the market-based method and scope 3 emissions accounted for approximately 89 per cent of total emissions in 2019. The baseline year for the target was chosen as 2019 because it was Digia's first year of CO2 calculations, and its emissions reflected typical operational activities within the chosen scope.

Progress monitoring: The target is monitored on an annual basis, and individual actions are implemented continuously throughout the year. The target has been pursued systematically, with the largest reduction planned to be achieved in the final year.

Digia's carbon footprint, 2019–2024, using the 2019 calculation boundary

Alignment with 1.5°C / SBTi validation status

• Digia joined the Science Based Targets initiative in 2024
• Science-based climate targets will be defined during 2025
• Baseline for updated targets: 2023 carbon footprint
• The alignment of the strategy period's emission reduction target with the Paris Agreement has not been separately verified

Key decarbonization levers and actions

In accordance with Digia's environmental policy, the company aims for its own operations (including travel and procurement) to be conducted in an energy- and material-efficient manner that generates the lowest possible emissions. Digia uses renewable energy whenever possible.

Vehicles

Digia's company car benefit is a discretionary benefit that may be given to employees who need a vehicle for their job or otherwise. The cars are owned by a leasing or financing company. In accordance with Digia's vehicle policy, the company favours low-emission vehicles and sets a maximum emission limit for acquired vehicles on an annual basis.

Purchased energy

Digia aims to use zero-emission or renewable energy in its premises. As Digia leases its premises, the company is largely dependent on its landlords' efforts to transition to zero-emission or renewable energy.

At the end of 2024, Digia operated out of 11 locations in Finland, three permanent in Sweden and one in the Netherlands. In 2024, Digia decided to make changes in Helsinki: the company will reduce the size of its current headquarters, give up its lease on another set of smaller premises in Helsinki and move into new premises in central Helsinki in early 2025. In addition to being smaller in size, the new premises will use carbon-neutral electricity. The combined effect will have a significant positive impact on reducing the carbon footprint of Digia's own operations. According to Digia's assessment, this change will result in an around 50 per cent reduction in emissions from business premises in Helsinki, which equates to a reduction of approximately 138 tCO2eq.

The need for changes at other locations will be examined when existing leases are nearing their end. Digia actively seeks to influence its landlords, so as to ensure the use of zero-emission energy (electricity, heating and cooling) on its premises. Thanks to an increase in hybrid work, the company has already been able to reduce the size of its premises and renovate the remainder to better serve the requirements of hybrid work and creating a sense of community.

Purchased goods and services

In order to reduce emissions from procurement, Digia is developing its supplier management to enable the collection of primary emissions data from suppliers. The company's goal is to maintain active dialogue with its major suppliers in order to ensure that they are committed to reducing emissions in their own operations. At the same time, Digia is seeking other opportunities to reduce emissions through either a reduction in purchases or changes in suppliers.

To support supplier management, Digia has developed a Supplier Code of Conduct that is based on its own Code of Conduct and includes an environmental perspective. Subcontractors are contractually obliged to adhere to the Supplier Code of Conduct, and the company's goal is to extend the code to all procurements throughout Digia's value chain.

Capital goods and upstream leased assets

For IT equipment and phones, Digia aims to ensure that devices are properly recycled after the leasing period, so that either the equipment itself or its raw materials are reused.

Fuel and energy-related activities

Digia's indirect energy-related emissions will decrease as the company transitions to broader use of zero-emission or renewable energy at its premises. The electrification of the company's leasing fleet will also reduce indirect emissions related to fuel.

Business travel and employee commuting

Digia personnel are encouraged to favour public transport and avoid unnecessary travel. Emissions from commuting have decreased in tandem with the rising popularity of remote work. When selecting new premises, Digia also aims to ensure that its locations are easily accessible by public transport. The company also offers company bicycles as personnel benefits.

CapEx / investment commitments

The aforementioned actions do not require significant operating or capital expenditure, and the company's ability to implement such actions is not therefore dependent on the availability and allocation of resources.

Locked-in emissions and stranded asset analysis

Due to the nature of Digia's business, the company has not identified any risk of potential locked-in GHG emissions in its operations. Digia is not excluded from the EU's Paris-aligned Benchmarks.

Policy framework

Digia's environmental policy is the company's most important policy for climate change mitigation and adaptation. This policy helps to ensure that the environment is taken into account in all of the company's operations, and thereby supports the achievement and fulfilment of environmental targets and requirements. The environmental policy sets out Digia's policies on climate change mitigation, energy efficiency and the transition to renewable energy. The company's own operations, including travel and procurement, are conducted in an energy- and material-efficient manner that generates the lowest possible emissions.

The environmental policy is supported by Digia's Code of Conduct, which encourages environmentally friendly solutions both in business operations and the workplace environment, and expects contractors and partners to do the same.

Future development

These actions and their actual impacts will be updated during 2025 as the company prepares its transition plan.

Policies related to climate change mitigation and adaptation

Environmental Policy

Digia's environmental policy is the company's most important policy for climate change mitigation and adaptation. This policy helps to ensure that the environment is taken into account in all of the company's operations, and thereby supports the achievement and fulfilment of environmental targets and requirements.

Key content and principles:

• The environmental policy sets out Digia's policies on climate change mitigation, energy efficiency and the transition to renewable energy
• The company's own operations, including travel and procurement, are conducted in an energy- and material-efficient manner that generates the lowest possible emissions
• Digia uses renewable energy whenever possible

Scope: The environmental policy covers Digia's own operations (including travel and procurement).

Governance: The Management Team is responsible for supervising the policy.

Public availability: Digia's environmental policy is publicly available on the company's website.

Code of Conduct

The environmental policy is supported by Digia's Code of Conduct, which encourages environmentally friendly solutions both in business operations and the workplace environment, and expects contractors and partners to do the same.

Scope: The Code of Conduct applies to all of Digia's employees, subcontractors and network, and extends to contractors and partners.

Public availability: The Code of Conduct is publicly available in both Finnish and English. It is described in more detail in Disclosure Requirement G1-1 Corporate culture and business conduct policies.

Supplier Code of Conduct and Sustainable Supplier Programme

Digia's ethical guidelines for its supply chain are contained in its Supplier Code of Conduct and Sustainable Supplier programme.

Scope: These policies cover Digia's supply chain and value chain workers.

Further information: These are covered in more detail in Disclosure Requirement S2-1 Policies related to value chain workers.

Monitoring and Implementation

The company has not yet drawn up a transition plan for climate change mitigation and adaptation. A more detailed transition plan for climate change adaptation will be drawn up during 2025 in conjunction with the setting of science-based targets, and this will be reported on in the 2025 Sustainability Statement.

While the policies do not require significant operating or capital expenditure, the company's ability to implement actions is not dependent on the availability and allocation of resources. Actions and their actual impacts will be updated during 2025 as the company prepares its transition plan.

Actions and resources in relation to climate change policies

Digia's environmental policy guides the company to conduct its own operations (including travel and procurement) in an energy- and material-efficient manner that generates the lowest possible emissions. The company uses renewable energy whenever possible. These actions and their actual impacts will be updated during 2025 as the company prepares its transition plan.

Vehicles

Scope: Own operations

Action: Digia's vehicle policy favours low-emission vehicles and sets a maximum emission limit for acquired vehicles on an annual basis. The company car benefit is discretionary, given to employees who need a vehicle for their job. Cars are owned by leasing or financing companies.

Expected outcome: Reduction in Scope 1 emissions from company vehicles.

Purchased energy

Scope: Own operations

Action: Digia aims to use zero-emission or renewable energy in its premises. The company actively seeks to influence its landlords to ensure the use of zero-emission energy (electricity, heating and cooling) on its premises.

Specific 2024 action - Helsinki premises consolidation:

• Reduce the size of current headquarters
• Give up lease on smaller premises in Helsinki
• Move into new premises in central Helsinki in early 2025
• New premises will use carbon-neutral electricity

Expected outcome: Approximately 50% reduction in emissions from business premises in Helsinki, equating to a reduction of approximately 138 tCO2eq.

Timeline: The need for changes at other locations will be examined when existing leases are nearing their end.

Limitation: As Digia leases its premises, the company is largely dependent on its landlords' efforts to transition to zero-emission or renewable energy.

Capital goods and upstream leased assets

Scope: Upstream value chain

Action: For IT equipment and phones, Digia aims to ensure that devices are properly recycled after the leasing period, so that either the equipment itself or its raw materials are reused.

Link: More information available in section E5 – Resource use and circular economy.

Fuel and energy-related activities

Scope: Own operations and upstream

Action: Digia's indirect energy-related emissions will decrease as the company transitions to broader use of zero-emission or renewable energy at its premises. The electrification of the company's leasing fleet will also reduce indirect emissions related to fuel.

Business travel and employee commuting

Scope: Own operations

Action: Digia personnel are encouraged to favour public transport and avoid unnecessary travel.

Expected outcome: Emissions from commuting have decreased in tandem with the rising popularity of remote work. Hybrid work has enabled the company to reduce the size of its premises.

Supplier engagement

Scope: Upstream value chain

Action: Digia's goal is to maintain active dialogue with its major suppliers to ensure they are committed to reducing emissions in their own operations. The company is seeking other opportunities to reduce emissions through either a reduction in purchases or changes in suppliers.

Resources: Digia has developed a Supplier Code of Conduct based on its own Code of Conduct and includes an environmental perspective. Subcontractors are contractually obliged to adhere to the Supplier Code of Conduct.

Target: The company's goal is to extend the code to all procurements throughout Digia's value chain.

Link to targets

All actions support Digia's climate target for the 2023–2025 strategy period: to reduce CO2 emissions (Scope 1–3) by 60% by 2025 (compared to the 2019 baseline). The target has been pursued systematically, with the largest reduction planned to be achieved in the final year. Individual actions are implemented continuously throughout the year.

Future planning

Digia joined the Science Based Targets initiative in 2024 and will define its science-based climate targets during 2025. A more detailed transition plan for climate change adaptation will also be drawn up during 2025 in conjunction with the setting of science-based targets.

Targets related to climate change mitigation and adaptation

Climate change mitigation target

Target metric: CO₂ emissions reduction (Scope 1–3)

Target value: -60% reduction

Target year: 2025

Baseline year: 2019

Baseline value: 3,055 tCO₂eq (total value chain emissions, Scope 1–3)

Scope: Entire value chain (Scope 1–3). The 2019 baseline covered Scope 1 and Scope 2 emissions of the company's then-current Finnish operations, as well as selected procurements and other Scope 3 emissions. Scope 3 emissions accounted for approximately 89% of total emissions in 2019.

Type: Absolute target

Science-based / validation status: Not validated against Paris Agreement during strategy period 2023-2025. Digia joined the Science Based Targets initiative in 2024 and will define science-based climate targets during 2025 based on 2023 baseline.

Progress to date:

Note: Progress data shown uses the 2019 calculation boundary.

Management incentive link

The CO₂ emission reduction target has a weighting of 20% within the overall sustainability target component (10% weighting) in both:

• Long-term share-based incentive scheme for 2023–2025
• Short-term target bonus scheme for 2024

Future targets

Digia will define science-based climate targets during 2025 based on 2023 baseline. A more detailed transition plan for climate change adaptation will also be drawn up during 2025.

Energy consumption and mix

Digia reports energy consumption covering fuel consumption from leased company cars and total energy consumption of offices. The energy producer and production method have been identified by landlords. Fuel consumption from leased cars is non-renewable. Energy from renewable sources includes electricity for offices and district heating and cooling. Where information about the energy source was unavailable, the division was made based on the same principle as in Scope 1 and Scope 2 calculations, meaning the energy was allocated by default among different energy sources.

28% of market-based energy consumption in 2024 is verified with guarantees of origin or renewable energy certificates.

Energy consumption and sources have not been verified by anyone other than the assurance provider.

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1 GHG emissions

Scope 1 emissions include fuel-related emissions from leasing vehicles used by Digia in its discretionary company car benefit. 2024 emissions have been calculated using the emissions factor provided by the Department for Environment, Food and Rural Affairs (DEFRA).

No sub-breakdown by stationary combustion, mobile combustion, process emissions, or fugitive emissions is provided.

Scope 2 GHG emissions

Scope 2 emissions consist of the energy consumption (heating, cooling and electricity) of Digia's premises. For market-based emissions, Digia collected data from landlords concerning the total amount of energy consumed, as well as data about energy companies and their products. The emissions factors used are specific emissions factors provided by energy companies. When necessary, the district heating emissions calculations for premises in Finland used the energy method value provided by Local Power's publicly available district heating emissions calculator. 28% of market-based energy consumption is verified with guarantees of origin or renewable energy certificates. The calculation of location-based emissions used country-specific average emission factors for the energy consumed.

Scope 3 GHG emissions

Digia reported Scope 3 emissions for upstream emissions in categories 1–3 and 5–8. The calculations employed both consumption-based and activity-based methods.

Category 1 (Purchased goods and services): Consumption-based emissions factors utilised the WWF's climate calculator, DEFRA, the report "Carbon footprint and raw material requirement of public procurement and household consumption in Finland – results from the ENVIMAT model" (15/2019), and the Julia 2030 project's publications (Dahlbo et al. 2011). For selected suppliers, Digia also utilised the latest publicly available emissions data for that supplier, such as an annual report or sustainability statement. The emissions reported by a supplier for their entire value chain are divided by total net sales in order to obtain a supplier-specific consumption-based emissions factor. Digia has also collected data on emissions from cloud and datacentre services and phone subscriptions using primary data obtained from suppliers.

Category 2 (Capital goods): Digia collected data on the emissions generated by the equipment it uses (laptops, docks, monitors and phones) directly from its suppliers. A consumption-based emissions factor has been used for other equipment purchases.

Category 3 (Fuel and energy-related activities): Emissions calculations utilise emissions factors published by the DEFRA and IPCC, while activity-based emissions have been calculated on the basis of the amount of energy consumed and the amount of fuel in litres.

Category 5 (Waste): Digia utilised an estimate of municipal solid waste published by Helsinki Region Environmental Services in 2019. This publication contains an estimate of the amount of waste generated by public administration offices per kilo per person-work-year. The emissions factors used in waste calculations are taken from a 2011 study carried out as part of the Julia 2030 project.

Category 6 (Business travel): Emissions have been calculated on an activity basis for specific modes of travel. Emissions from business-related road, rail and air journeys have been calculated using reported kilometres. DEFRA emissions factors have been used for all modes of transport except trains. VR's emissions factor for passenger traffic has been used for train travel in Finland. Other travel-related emissions have been calculated on a consumption basis.

Category 7 (Employee commuting): Emissions are based on emission factors that have been customised for Digia. Category 7 includes both emissions from Digia employees' commuting and emissions from remote work. Emissions from commuting have been estimated with the aid of surveys carried out in 2020 and 2023, which asked Digia employees about the average length of their commute and their means of travel. This data was used to calculate the average emissions from commuting, using the emission factors published by DEFRA for various modes of transport. Emissions from remote work were based on a 2023 personnel survey that determined how often employees worked remotely or at the office. The results of this survey were used to estimate the ratio of office days to remote-work days in relation to the total number of working days per year. Emissions from remote work were calculated using DEFRA's emissions factor, which includes emissions from lighting, heating and the energy consumption of equipment.

Category 8 (Upstream leased assets): The data for emissions includes Digia's leasing phones, for which emission data has been obtained directly from the supplier.

6% of Digia's Scope 3 emissions in 2024 have been calculated using primary data obtained from either the actual suppliers or other suppliers in the value chain.

The calculations omit Scope 3 emissions in Category 4 (Upstream transportation and distribution), as the company has not identified any significant emission sources in this category. Downstream categories 9–15 have also been omitted, as the company has not identified any significant downstream emissions in its operations.

Total GHG emissions

GHG intensity

Digia's net sales totalled EUR 205.7 million in 2024.

Biogenic CO2 emissions

Digia's emissions calculations contain CO2 emissions reported as carbon dioxide equivalents. The company has not identified any other types of GHGs in its calculations or any biogenic carbon dioxide emissions in its value chain.

Multi-year trend (2019–2024, using 2019 calculation boundary)

Digia has used two parallel boundaries for calculating its carbon emissions. The first boundary is based on that of the 2019 calculation, while the second boundary has expanded the calculation to cover all of Digia's locations and all material procurements at Group level. The multi-year trend table above uses the 2019 calculation boundary. In 2019, Digia's carbon footprint was 3,055 tCO2eq and covered the Scope 1 and Scope 2 emissions of the company's then-current Finnish operations, as well as selected procurements and other Scope 3 emissions. Scope 2 was calculated using the market-based method and Scope 3 emissions accounted for approximately 89% of total emissions in 2019.

2023 adjustments

Digia has retrospectively refined some of the emission factors used in the calculation of its 2023 carbon footprint, and has also expanded its 2023 carbon footprint calculation to better cover the Group's most material emissions in order to provide a reliable comparison year. These corrections and expansions apply to Scope 3 emissions.

Methodology notes

Digia calculates its GHG emissions in accordance with the GHG Protocol. The emissions calculations cover Scopes 1–3 as per the GHG Protocol, and the operational control criterion has been employed. Since 2023, Digia's emissions calculations have covered the entire Group. The company has retroactively revised its 2023 emissions calculations.

Digia has used indirect sources in the calculation of its upstream greenhouse gases. Indirect sources have mainly been used in Scope 3 emission categories 1, 3, 6 and 7, for which general factors have been used to calculate emissions. Estimation has therefore been used in the calculation of emissions, as these general factors are derived from widely used emission factor libraries.

There is no significant uncertainty associated with the metrics or monetary values used in Digia's emission calculations. However, as general emission factors are often averages that ignore variations in operations or conditions, this may increase the uncertainty of the calculation. The company is continuously developing its emissions calculation process, and aims to increase its use of direct sources through improved supplier management.

Digia's scope 1–3 emissions have not been verified by anyone other than the assurance provider.

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

Use of Phase-In Exemption

Digia has decided to omit the information specified in E1-9 from its first Sustainability Statement, as per ESRS 1 Appendix C: List of phased-in Disclosure Requirements.

Policies related to own workforce

Digia has established several policies governing its own workforce, primarily based on internationally recognized human rights, labour rights and standards (UN Universal Declaration of Human Rights, UN Global Compact, and ILO Declaration on Fundamental Principles and Rights at Work).

Code of Conduct

• Scope: All Digia personnel, including senior executives and the Board of Directors, as well as subcontractors and network
• Governance: Approved by the Management Team and Board of Directors; updated as necessary (last updated 2022)
• Key content: The Code of Conduct is the most important policy governing Digia's own workforce. Compliance is essential to business success. It prohibits the use of child or forced labour and is based on compliance with internationally-recognised human rights, labour rights and standards.
• Public availability: Publicly available in Finnish and English
• International standards: Based on UN Universal Declaration of Human Rights, UN Global Compact, and ILO Declaration on Fundamental Principles and Rights at Work
• Implementation: All employees, including senior executives and Board of Directors, are responsible for compliance
• Monitoring: Covered during onboarding and in mandatory annual Code of Conduct training (90% target completion rate; 84% achieved in 2024)

Cultural principles

• Scope: Group-level policy, implemented on practical and individual level
• Governance: Approved by the Management Team
• Key content: Four principles - learning, sharing, courage and professional pride - created in collaboration with Digia personnel to help individuals and the workplace community succeed and evolve in their work
• Purpose: Promote wellbeing and reduce potential negative impacts

Human rights commitment

• Scope: All of Digia's stakeholders
• Governance: Approved by Management Team; implemented by HR team; supervised by HR Director and General Counsel
• Key content: Based on human rights survey results. Commitment to respecting human rights in accordance with UN Universal Declaration of Human Rights, International Covenant on Civil and Political Rights, International Covenant on Economic, Social and Cultural Rights, and ILO Declaration on Fundamental Principles and Rights at Work
• Public availability: Published on company website
• International standards: UN Universal Declaration of Human Rights, UN Global Compact, ILO Declaration on Fundamental Principles and Rights at Work
• Identified risks: Right to health and safety, right to non-discrimination, right to decent work, elimination of labour exploitation and forced labour, right to organise and collective bargaining, right to privacy

Equality and non-discrimination plan

• Scope: Digia personnel
• Governance: Drawn up by equality and non-discrimination team; approved by Management Team; updated at least once per strategy period (last updated 2023); supervised by Management Team; implemented by equality and non-discrimination team
• Key content: Actions to make Digia an increasingly inclusive workplace where everyone can be themselves. Addresses various forms of discrimination and reasons behind them. Current focus areas (2023-2025): inclusive culture and psychological safety, making use of English commonplace, increasing proportion of women, increasing inclusivity and career opportunities for women
• Basis: Results of equality and non-discrimination survey of Digia personnel
• Monitoring: Diversity tribe handles and discusses the topic, shares information and learns

Leadership principles

• Scope: All management at Digia
• Governance: Approved by Management Team; supervised by HR Director; implemented by supervisors and HR team
• Key content: Support and guide everyday management and promote wellbeing. Ensure management is consistent and supports company values and goals

Early intervention model

• Scope: All employees
• Governance: Approved by HR Director; implemented by supervisors and HR team; supervised by HR Director
• Key content: Ensures employees receive support when encountering problems at work (increased absenteeism, difficulty carrying out work, interaction problems). Provides support for long sick leave or family leave and creates harmonised return-to-work practices

Guidelines on inappropriate behaviour

• Scope: All Digia employees
• Governance: Approved by HR Director; implemented by supervisors and HR team; supervised by HR Director
• Key content: Internal policy for addressing inappropriate behaviour and harassment. Primary means is discussion between parties involved, facilitated by HR if necessary. Supervisors and employee representatives have received training. Alternative reporting via Whistleblowing channel available

Collective agreement

• Scope: Digia employees in Finland (entered into force May 2023)
• Governance: Approved by Management Team; implemented by supervisors and HR team; supervised by HR Director and employee representatives
• Key content: Own collective agreement for Finland. Limitations reported in S1-8

Salary and remuneration manual

• Scope: All personnel
• Governance: Approved by Compensation Committee and Management Team; implemented by supervisors and HR team; supervised by HR Director
• Key content: General principles governing remuneration and total compensation, salary models, competence levels, salary review process and salary management. Aims to increase transparency and understanding, support good salary management. Openly describes career paths, task families and competence levels to support competence and salary structure development. Standardised salary review process aims to increase fairness, equality and non-discrimination. Salary management guidelines for supervisors

Hybrid work model

• Scope: Digia employees
• Governance: Approved by Management Team; implemented by HR and Office teams; remote work permits controlled by HR team and CSO Office
• Key content: Working should be smooth and flexible and nurture sense of community. Most work is site-independent, but employees separately agree on remote working methods with supervisor

Workplace accident prevention policies

• Scope: All workplace locations
• Governance: Operations planned based on regular workplace surveys by occupational healthcare and annually approved occupational health and safety action plans; monitored by HR team
• Key content: Covers identified health risks, measures related to health checks, ergonomics and early intervention. Location-specific workplace surveys include analyses of risks and problems with working environments, methods and conditions. Emergency first aid training ensures sufficient people with first aid skills at each site

Policies on equal employment opportunities

• Scope: Recruitment, training and promotion of employees
• Governance: Covered in salary and remuneration manual
• Key content: Based on qualifications, skills and experience. Ensures all employees have chance to develop and advance without disadvantage based on age or gender. Support for employment at different ages and career stages (trainees, recent graduates, career changers, those without extensive IT experience). Clear career path towards most demanding expert tasks for IT sector newcomers. Programmes for employees at different career stages (e.g., Konkarit-programme for approaching retirement age)
• International standards: Women's Empowerment Principles (WEPs) - seven principles from UN Women and UN Global Compact providing guidance to promote gender equality. Pride partnership demonstrating support for sexual and gender minorities

Taking action on material impacts on own workforce

Digia's measures to manage personnel-related material impacts, risks and opportunities are part of its broader HR strategy and sustainability programme. The company has conducted a comprehensive human rights survey to identify any human rights risks and impacts throughout its value chain, including on its own workforce. A human rights commitment has been published on the basis of the results.

General approach

Digia takes a broad range of measures to prevent negative material impacts on the company's own workforce and to promote positive ones. The company focuses on maintaining the working capacity of its employees through day-to-day management and personalised measures and flexibility.

Key actions and programmes

Working culture, operating methods and leadership development

• Enhancing and developing Digia's working culture, operating methods and leadership creates wellbeing, which in turn helps to maintain working capacity
• Systematic support of employee wellbeing by developing everyday management skills, self-direction and personal competence in the spirit of continuous improvement
• Increase employees' capacity to meet the evolving expectations of working life through clear objectives

Wellbeing and working capacity support

• Comprehensive occupational healthcare services
• Flexible working hours and arrangements
• Early intervention process
• Variety of mental health services and support methods
• Training sessions and discussions organised in cooperation with experts from occupational healthcare and pension companies
• Employee-wellbeing theme broadly considered, with wellbeing issues communicated in a diverse manner

Community building and meaningful work

• Strengthening sense of community as a main theme in 2024
• Creating a sense of community as both a significant success factor and an important part of providing meaningful work

Recruitment and retention

• Investment in collaboration with universities and active participation in a variety of events
• Thorough review of every job application
• Improved collaboration with subcontractor network to improve employee retention

Cultural principles and sustainability goals

• Support for UN Sustainable Development Goals: 4 Quality education, 5 Gender equality, 8 Decent work and economic growth, and 10 Reduced inequalities
• Cultural principles as the foundation for everything the company does, supported by other policies, procedures and objectives
• Integration of experts directly into business units, where they are part of the unit's management team

Link to policy

The human rights analysis and commitment are covered in Disclosure Requirement S1-1 Policies related to own workforce.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities (S1-5)

During the 2023–2025 strategy period, Digia will achieve the goals of its HR strategy through four selected focus areas: learning, goal-orientedness, wellbeing and a sense of community. The objectives described below have been set for the strategy period to promote positive impacts on employees. They have been set for the end of 2025, and their progress will be actively monitored throughout the strategy period.

Target 1: Employee Net Promoter Score (eNPS)

Target 2: Proportion of Women in Executive Positions

Additional diversity metric (not a formal target): Digia is also aiming to increase the number of women in architectural roles, which was 7% in 2024 (3% in prior year). Data covers companies in Finland.

Target 3: Mental Health Absences

Management Incentive Scheme Sustainability Targets

Both the long-term share-based incentive scheme (2023–2025) and the short-term target bonus scheme (2024) include the same sustainability targets:

• CO2 emissions reduction (weighting 20%)
• eNPS (weighting 40%)
• NPS (weighting 40%)

These sustainability targets have a 10% weighting in the overall incentive schemes.

At the end of the period, the total number of Group personnel was 1,576 (1,527), representing an increase of 49 employees or 3.2 per cent since the end of the 2023 fiscal period. The average number of employees was 1,553 (1,465), an increase of 89 employees, or 6.1 per cent, on the 2023 average.

Digia personnel by location:

Characteristics of non-employees in the undertaking's own workforce

Digia reports on its non-employee workforce, specifically subcontractors who work on company projects.

Number of non-employee workers

An average of 374 people per month worked as subcontractors in Digia's projects during 2024.

Methodology

The figure represents the average monthly count of subcontractors working on Digia's projects. The company notes that this is measured as headcount (number of people) rather than FTE.

Breakdown by type

No detailed breakdown by specific contractor categories (agency workers, self-employed, etc.) is provided. The company uses the general term "subcontractors" to describe its non-employee workforce.

Scope and coverage

The subcontracting occurs primarily through the Digia Hub network, which consists of:

• More than 5,000 freelance professionals in Finland
• Hundreds of subcontracting companies in Finland
• Nearshore subcontracting companies operating in the Baltic countries and Central and Eastern Europe
• International talent through Fulcrum Digital (with teams located in India)

Subcontractors are not directly employed by Digia and are therefore not covered by the company's collective agreements or employee benefits. However, they are contractually required to comply with Digia's Supplier Code of Conduct.

Multi-year comparison

No comparative data for previous years (2023 or 2022) is disclosed for the number of subcontractors.

Collective bargaining coverage and social dialogue

Overall coverage

85 per cent of the Digia Group's employees are covered by collective bargaining agreements.

Collective agreements by entity

Digia has its own collective agreement in Finland, which entered into force in May 2023. This collective agreement covers employees of Digia Plc and Digia Finland Ltd. Digia Plc's subsidiary Productivity Leap Ltd uses the Collective Agreement for the IT Service Sector as an unorganised employer. Digia Sweden AB, Top of Minds AB, and Climber International AB and its subsidiaries are not covered by a collective agreement. Most Digital Sweden AB does not have any employees. Subcontractors are not covered by Digia's collective agreements, as they are not employed by Digia.

Regional breakdown

Governance and implementation

The collective agreement has been approved by the Management Team. It is implemented by supervisors and the HR team, and supervised by the HR Director and employee representatives.

Diversity metrics

Gender distribution at top management level

Board of Directors 2024:

Board members by name (2024):

Management Team 2024:

Management Team members by name (2024):

Age band distribution of total workforce

Distribution of employees by age group:

Total workforce: 1,576 employees

Adequate wages

Digia always pays at least the minimum wage specified in the collective agreement. If a company is not covered by the collective agreement, the minimum wage is based on the salary specified in the industry's general collective agreement.

As part of the human rights survey conducted in 2023, Digia also reviewed the remuneration practices of its subcontractors' nearshore and offshore operations to ensure that adequate wages were being paid.

Benchmark: Collective agreements and industry-wide general collective agreements (minimum wage standards). No living wage benchmark disclosed.

Coverage: Not specified for own workforce assessment. Subcontractor nearshore and offshore operations were reviewed in 2023.

Methodology: The review was conducted as part of a human rights survey in 2023. No details on living wage calculation methodology, frequency of reassessment, or specific benchmarks used for the subcontractor review.

Social protection

Digia wants to be a family-friendly employer that understands diverse life situations. All companies within the Group have a right to family-related leave. Digia supports the varying life situations, working capacity and care responsibilities of its employees by offering flexible, location-independent working hours and providing occupational healthcare services. These services may vary from country to country and company to company.

In addition to statutory occupational accident, life and pension insurance, Digia also offers additional insurances, such as medical expense insurance and travel insurance for both working hours and leisure time.

Occupational healthcare coverage:

• 100% of the Digia Group's own workforce is covered by occupational healthcare
• The scope of occupational healthcare services may vary between companies

Work-related accidents and health:

• 6 work-related accidents in 2024
• 0 fatalities as a result of work-related injuries and work-related ill health

Training and skills development metrics

Performance and career development reviews

Percentage of employees that participated in regular performance and career development reviews:

Average training hours

Average number of training hours per person for employees, by employee category and by gender:

Learning objectives

The percentage of employees with a learning objective is measured and monitored annually as part of competence development. The goal is to set a learning target for 75 per cent of personnel. Learning targets were set for employees during 2024 (specific achievement percentage not disclosed).

Health and safety metrics

Coverage of health and safety management system

100 per cent of the Digia Group's own workforce is covered by occupational healthcare. The scope of occupational healthcare services may vary between companies.

Work-related accidents and fatalities

There were 6 work-related accidents in 2024. There were no fatalities as a result of work-related injuries and work-related ill health at Digia.

Recordable work-related injury rate

Not disclosed.

Days lost to work-related injuries and ill health

The number of absences in 2024 was 1.3 (1.3) days of absence per person for mental health reasons. The data covers Digia companies in Finland.

Note: The company monitors sickness absences with particular attention paid to absences related to mental health, which can be caused by a variety of psychological and emotional challenges, such as stress, fatigue or other problems that affect mental wellbeing. However, comprehensive days lost metrics (total days lost to injuries, fatalities and work-related ill health) are not disclosed in the format specified by ESRS S1-14.

Work-life balance metrics

All of the Digia Group's employees (100%) are entitled to take family-related leave.

6.0 per cent of Digia personnel took family-related leave in 2024.

Breakdown by gender

• 6.4 per cent of all women took family-related leave
• 5.8 per cent of all men took family-related leave

Supporting policies

Digia wants to be a family-friendly employer that understands diverse life situations. All companies within the Group have a right to family-related leave. Digia supports the varying life situations, working capacity and care responsibilities of its employees by offering flexible, location-independent working hours and providing occupational healthcare services. These services may vary from country to country and company to company.

The company has an early intervention model that involves providing long periods of sick leave or family leave when necessary, and creating harmonised practices that lower the threshold for returning to work.

Compensation metrics (S1-16)

Pay gap

Digia discloses gender pay gap by country:

The company states: "Digia analyses the realisation of pay equality also from different perspectives (such as the competence classification of positions, and task profiles)."

Remuneration ratio

Digia discloses annual total remuneration ratio (CEO-to-median):

Methodology

No detailed methodology or scope notes are provided for how the pay gap or remuneration ratios were calculated. The metrics are presented in tabular form without additional explanation of calculation methods, employee populations included, or time periods covered.

Incidents, complaints and severe human rights impacts

Digia references disclosure requirement S1-17 in its sustainability statement (page 55 in the index), but the excerpts provided do not contain the actual quantitative disclosures for this requirement.

The index indicates that S1-17 should cover:

• Data point 103 (a): Incidents of discrimination (page 55)
• Data point 104 (a): Non-respect of UNGPs on Business and Human Rights and OECD (page 55)

However, the specific metrics regarding:

• Number of incidents of discrimination, including harassment
• Number of complaints filed through grievance mechanisms
• Number of severe human rights impacts
• Total amount of fines, penalties or compensation
• Status of complaints (open/resolved/under investigation)

are not included in the provided excerpts. The excerpts reference grievance/complaints handling mechanisms at pages 51 and 62, but those pages are not included in the extract.

The excerpts do mention that monitoring of social responsibility risks includes "experiences of overwork, occupational wellbeing, discrimination and unequal treatment" and that "potential human rights risks such as the use of forced labour in the manufacture of equipment and the sourcing of raw materials" are monitored in procurement, but no actual incident data is disclosed in the provided text.

Digia's corporate governance principles are integrity, accountability, fairness, and transparency. This means that: • The company complies with applicable legislation and regulations. • When organising, planning, managing and running its business operations, the company abides by the applicable professional requirements that have been generally approved by its Board members, who demonstrate due care and responsibility in performing their duties. • The company is prudent in the management of its capital and assets. • The company's policy is to keep all parties in the market actively, openly and equitably informed of its businesses and operations. • The company's management, administration and personnel are subject to the appropriate internal and external audits and supervision.

Quality and information security are an integral part of Digia's reliable operations. During the fiscal period, we completed the recertification of our ISO 9001 quality certificate without any deviations. In addition, we conducted a follow-up assessment of ISO 27001 information security certification covering previously certified business areas without any deviations.

Digia has been awarded an ISO 9001 quality certificate, which covers Digia Finland Ltd and the Group's shared services. Digia has also been awarded an ISO 27001 security certificate, which covers some of Digia's business areas and locations.

Digia Plc has a whistleblowing channel for reporting suspected cases of bribery and corruption, market abuse, and violation of Digia's insider guidelines. This channel seeks to promote compliance with good governance in the company's routine activities, and to prevent and detect misconduct. It can be used to report market abuse and the violation of operating principles, regulations and instructions, either confirmed or suspected.

Anyone can make an anonymous report using a form that is available on both Digia's intranet and its public website. All reports are directed to Digia's legal unit and the chair of the Audit Committee of the Board of Directors. All reports will be processed confidentially and professionally in accordance with the Personal Data Act, with regard to both the informant and suspect.

The Audit Committee also reviews reports on notifications received through the Whistleblowing channel.

Incidents of corruption or bribery

Confirmed incidents

Digia had no confirmed cases of bribery or corruption in 2024.

Convictions and fines

No convictions or fines for violations of anti-corruption / anti-bribery laws were reported for 2024.

Disciplinary actions

No employees were dismissed or disciplined due to corruption or bribery during the reporting period.

Contracts terminated

No contracts with business partners were terminated or not renewed due to corruption or bribery issues in 2024.

Investigation procedures and speak-up mechanisms

Digia operates a Whistleblowing channel through which employees and external parties can report suspected cases of bribery and corruption, market abuse, and violations of Digia's insider guidelines. The channel is available both anonymously and under the reporter's own name. Digia is committed to ensuring that no retaliatory measures will be taken against whistleblowers. The channel is accessible at https://whistleblower.digia.com.

Reports are handled by a dedicated processing team consisting of the Chair of the Board of Directors' Audit Committee, the General Counsel, and a lawyer. The General Counsel informs the Audit Committee twice a year of any reports received via the whistleblowing channel and how they have been handled.

The company has introduced mandatory Code of Conduct training that must be refreshed annually for all employees. The goal is for 90% of personnel to complete this training. In 2024, 84% of Digia personnel completed this training (employees with long absences excluded; the figure does not include Top of Minds' employees).

Digia applies the Whistleblower Act, which provides protection for whistleblowers. The company has not identified any internal activities that would be particularly vulnerable to corruption and bribery.

Public legal cases

No public legal cases related to corruption or bribery were reported for 2024.

Additional context

During 2024, Digia received 4 reports through the Whistleblowing channel, none of which were found to require further action after investigation. None of these reports were related to corruption or bribery specifically.

Political influence and lobbying activities

Political engagement approach

Digia does not participate in any political or other lobbying activities through donations or sponsorship. The Company also has no legal obligation to be a member of any lobbying organisation.

Board member positions in public administration

During the reporting period, no members appointed to administrative, management or supervisory bodies had held a similar position in public administration during the preceding two years.

Political contributions

Digia does not make political contributions.

Lobbying activities

Digia does not engage in lobbying activities.

Trade association memberships

The Company has no legal obligation to be a member of any lobbying organisation.

Payment practices

The average time that Digia takes to pay an invoice, its average payment terms, and a breakdown by main categories of suppliers are shown in the table below. Digia has not defined any category-specific standard payment terms for its suppliers.

The category All supplier groups contains information about all of the invoices paid by the Group.

Average payment time and terms by supplier category

Legal proceedings for late payment

Digia is not currently involved in any ongoing legal proceedings for late payments.

Invoice payment process

Digia treats all of its suppliers equally, and has processes and guidelines in place to ensure that invoices are processed in accordance with payment terms.

Upon receipt of an invoice, the Group's financial administration will process the invoice and forward it to the recipient of the invoice for registration and approval. The invoice processing system will automatically remind the invoice handler of any unpaid invoices. The Group's financial administration will also send reminders about unpaid invoices as necessary.