Dynavox Group

The role of the administrative, management and supervisory bodies

Reference: page 51.

The Annual General Meeting is the highest administrative body. Below it sits the Board of Directors (six members, including the Chair) and the Executive Management Team (EMT) (nine executives, including the CEO). There is no formal representation of employees or other workers on the Board or EMT.

Board and management composition (page 51):

Several board members have backgrounds in medical technology, consumer electronics and software development, and prior board or executive roles in North America and Europe, Dynavox Group's primary markets. The Board holds ultimate responsibility for sustainability oversight, approves the Group's sustainability strategy and reviews the annual Sustainability Statement; the Audit Committee monitors ESG-related risks and internal control effectiveness.

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

Reference: page 52.

Sustainability is a standing topic at Board meetings twice a year. Representatives from the Sustainability Steering Committee (comprising EMT members) present updates on key sustainability matters at these sessions.

During the reporting period the Board and EMT focused on material impacts, risks and opportunities identified through the Double Materiality Assessment (DMA), which were formalized through approval of the DMA results. Social sustainability was a primary focus, "reflecting Dynavox Group's core business model and purpose" - social inclusion through communication solutions, and diversity, equity and inclusion as factors for attracting and retaining talent. From an environmental perspective, leadership reviewed supply-chain resilience and logistics risk, and packaging/shipping strategies balancing sustainability and cost. Data privacy and information security were also discussed, including the business case for further certifications.

Integration of sustainability-related performance in incentive schemes

Reference: page 52.

"Sustainability-related performance metrics are not currently formally embedded in the incentive structure." Dynavox Group states it "continues to monitor developments in sustainability reporting and remuneration practices" and "may consider integrating explicit sustainability metrics into future remuneration policies to align incentives more directly with sustainability goals."

No further detail on incentive design, or on any existing link between pay and sustainability performance, is given.

Statement on due diligence

Reference: page 52.

Dynavox Group maps the ESRS core elements of due diligence to where they are addressed in the Sustainability Statement:

Risk management and internal controls over sustainability reporting

Reference: pages 52-53.

Sustainability reporting "is built on the same principles that guide our financial reporting, risk management, and internal controls." Controls include a third-party data-collection system supervised by the Sustainability Working Group, standardized definitions, separation of duties, analytical reviews, and a "four-eyes principle" applied at multiple stages of data collection and consolidation.

The Group manages sustainability-related risk through an integrated framework aligned with ISO 13485:2016 and medical-device regulation (EU MDR, FDA QMSR). Climate risk is addressed through the Supplier Code of Conduct; supply-chain risk through supplier qualification, audits and quality agreements; social/compliance risk (equal treatment, discrimination, data privacy) through the Code of Conduct and Data Privacy Policy; anti-corruption risk through a dedicated policy, training and the WhistleB whistleblowing system. All policies are reviewed annually within the quality management system.

Strategy, business model and value chain

Reference: pages 54-56.

Dynavox Group provides comprehensive communication solutions (hardware, software/language systems, financing support and after-sales service) for people with conditions such as ALS, autism and cerebral palsy. In 2025 it served 65 markets (11 direct, the rest through resellers), had 1,063 employees, mainly in North America and Sweden, and total revenue of 2,467 MSEK (page 54).

Sustainability strategy pillars (page 54): (1) Delivering voices, (2) Empowering people, (3) Respect for the planet, (4) Acting with integrity.

Value chain (page 55-56): Upstream - sourcing of electronic components, batteries and materials via a managed supplier base, plus raw materials for the Kassel, Germany mounting-solutions facility. Own operations - R&D, an assembly facility in China, an aluminum-mounts manufacturing facility in Kassel, quality assurance, funding support and administration. Downstream - distribution via direct sales and reseller/distributor partners, customer support, and end-of-life handling (reduce/reuse/refurbish) via waste-management partners. A value chain diagram is presented on page 56.

Interests and views of stakeholders

Reference: pages 56-57.

Key stakeholder groups and engagement channels (page 57 table): employees (surveys, team meetings); prescribers/HCPs (training, advisory boards); customers/users/families (support, feedback, workshops); suppliers (Code of Conduct, audits); investors/analysts (reports, meetings); communities/advocacy groups (partnerships, public consultations).

The DMA is conducted and updated annually, including workshops and validation sessions with the EMT, refined through board-member and investor interviews. Leadership is informed via the CFO presenting to the Audit Committee and formal board discussion twice a year. "No changes were made to our overall strategy during the reporting period specifically to address stakeholder interests and views", though stakeholder input shaped operational improvements (product accessibility, well-being initiatives, the Sustainable Supplier Management Program). Dynavox Group plans to strengthen direct engagement with affected stakeholders in future DMA cycles.

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

Reference: pages 58-61 (per-topic IRO table); page 57 (narrative).

The DMA identified 12 material impacts, risks and opportunities across E1, E5, S1, S2, S4 and G1 (no explicit total IRO count is stated by the company; see iro_counts notes for the derivation). Topics assessed and found not material: E2 (Pollution), E3 (Water and Marine Resources), E4 (Biodiversity and Ecosystems) and S3 (Affected communities) - "Accordingly, E2, E3, and E4 have been assessed as not material at this time" (IRO-1, page 63).

Named material impacts/risks by topic (pages 58-61): E1 - a financial risk of operational disruption from climate/weather events, and negative impacts from Scope 1-3 emissions and from energy use; E5 - negative impacts from resource inflows (sourcing) and from waste handling; S1 - a negative impact of potential discrimination in the own workforce; S2 - negative impacts on personal integrity, other work-related rights and working conditions in the value chain; S4 - a negative impact on data privacy and a positive impact from social inclusion; G1 - a negative impact (risk) of corruption and bribery. "The analysis indicates that the strategy and business model are resilient in the short to medium term across the identified topics" (page 57).

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

Reference: pages 62-63.

The 2025 DMA was run through workshops led by the Sustainability Working Group, covering impact and financial materiality separately, validated by the EMT and refined through stakeholder interviews with Board members (including the Chair) and an investor. "We have not conducted direct consultations with affected stakeholder groups, such as individuals with communication disabilities"; the company considers their perspective represented by internal functions (Product, Quality, Regulatory, Clinical, Customer Support, Sales) that interact with users daily.

Methodology steps: defining scope (full value chain; suppliers currently limited to tier 1); stakeholder identification; value chain mapping; impact materiality assessment (severity/likelihood scored 1-5, human-rights impacts given precedence to severity); financial materiality assessment (size of effect 1-5, likelihood 1-3); business-conduct-specific criteria (location, activity nature, sector, transaction structure).

Screening of E2/E3/E4 (page 63): "...no significant direct impacts were identified... Accordingly, E2, E3, and E4 have been assessed as not material at this time."

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

Reference: pages 64-66 (content index).

Dynavox Group's content index lists, with page references, the disclosure requirements covered under ESRS 2 (BP-1/BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2), ESRS E1 (Climate change: IRO-1, SBM-3, E1-1 through E1-6) and ESRS E5 (Resource use and circular economy: IRO-1, E5-1 through E5-5), ESRS S1 (SBM-3, S1-1 through S1-6, S1-9, S1-16, S1-17), ESRS S4 (SBM-3, S4-1 through S4-5) and ESRS G1 (IRO-1, G1-1, G1-3, G1-4), plus related SFDR, Pillar 3, Benchmark Regulation and EU Climate Law datapoints (page 64, introductory note: identified "through a structured assessment, conducted in alignment with ESRS 1 section 3.2... including Appendix E, and supported by current guidance from EFRAG").

Not in the index: E2, E3, E4 and S3 (assessed not material, IRO-1 p.63); S2 (material but exempted as a whole standard under the ESRS "quick fix"); S1-7, S1-8, S1-10, S1-11, S1-14, S1-15 (not addressed in the statement); S1-12 and S1-13 (exempted sub-topics under the quick fix); G1-2, G1-5, G1-6 (not addressed); E1-7, E1-8 (not addressed); E1-9 and E5-6 (no dedicated financial-effects disclosure, despite a "Financial Risk" row under E1 in the SBM-3 IRO table, page 58).

Transition plan for climate change mitigation

Reference: page 69.

"Dynavox Group is fully committed to achieving net-zero emissions by 2050, in alignment with the Paris Agreement." The Group has built a comprehensive 2024 emissions profile as the baseline for its emission-reduction plan, and from it has identified key impact areas and long-term reduction targets with milestones (detailed under E1-4).

Important caveat the company states itself: "Using this information, we will prepare and implement our Climate Transition Plan in the year 2026." As of FY2025 the formal, ESRS-structured Climate Transition Plan document does not yet exist; what is disclosed here are the targets, baseline and decarbonization levers that will feed into it. No CapEx/OpEx figures are allocated to this work in 2025 (see E1-3/E1-4).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS E1 IRO-1 and E1 SBM-3, where this content is disclosed in the FY2025 report (pages 68-69). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Dynavox Group evaluated climate-related physical and transition risks across its own operations and value chain using two IPCC scenarios: the high-emission RCP8.5 (physical risk) and the low-emission, 1.5degC-aligned RCP2.6 (transition risk) (pages 68-69).

Only one material climate risk was identified: supply-chain disruption, "given that most of our component manufacturers are based in the Asian region, including China and Taiwan" (page 69). Under RCP8.5, impacts were assessed across short (0-1yr), medium (1-5yr) and long term (5+yr): delivery delays and freight-cost increases, escalating to structural shifts in sourcing and logistics. Under RCP2.6 (transition), "climate-related transition risks have been identified and their potential impact is assessed as low to moderate" (page 68), driven by regulation, carbon pricing and market shifts. The assessment screened facility locations, key supplier sites and logistics pathways, supported by cross-functional input and industry benchmarks; findings were incorporated into the Enterprise Risk Register (page 69).

Resilience in relation to climate change

Back-filled from ESRS E1 SBM-3, where this content is disclosed in the FY2025 report (page 69, drawing on the scenario work at pages 68-69). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

A climate resilience analysis was performed concurrently with the scenario assessment, using the same two scenarios (RCP2.6 low-emission, RCP8.5 high-emission) across short/medium/long-term horizons, covering the full value chain - global locations, critical supplier sites and logistics pathways (page 69).

Under the high-emission scenario, resilience and mitigation actions are: short term - maintaining stock of critical materials and monitoring inventory; medium term - geographical supplier diversification, strategic stock management and climate-risk screening of suppliers; long term - buffer/contingency planning through Business Continuity Plans and evaluation of nearshoring. "Based on the analysis of each scenario across the short, medium, and long-term horizons, we consider our business model to be resilient" (page 69). No quantified cost impact of the resilience measures is given.

Policies related to climate change mitigation and adaptation

Reference: page 70.

Environmental Policy - applies globally across the full value chain (suppliers, operations, product use). The Chief Operations Officer holds ultimate accountability. It sets commitments on climate mitigation and adaptation, pollution prevention, carbon-emission reduction and continuous improvement, and provides the foundation for the Group's GHG reduction targets and operational action plans. Oversight runs from the Board of Directors through the Audit Committee, EMT and Sustainability Steering Committee.

Supplier Code of Conduct - also owned by the COO, requires suppliers to minimize GHG emissions and energy consumption, demonstrate continuous improvement, set their own corporate-wide GHG reduction targets, track and publicly report Scope 1 and 2 emissions, and maintain climate-related business-continuity and emergency-preparedness measures. "Nearly 70% of Dynavox Group's total emissions originate from purchased goods and services under Scope 3 emissions, making supplier performance a central element" of the Group's reduction objectives.

Actions and resources in relation to climate change policies

Reference: pages 69-70.

"The Group's ability to implement the described actions is primarily dependent on the availability and allocation of internal financial and human resources, as well as external factors such as market availability of low-emission technologies, access to renewable electricity solutions, and supplier engagement across the value chain" (page 70).

2025 actions: vehicle fleet - 15 fully electric and 22 hybrid vehicles, together approximately 34% of the Group's total fleet, under a Global Car Policy mandating electric/hybrid for new purchases and long-term leases. Renewable electricity - the Sweden head office ran on 100% renewable electricity (~51.5 MWh), and the Link Assistive office in Adelaide, Australia fully on renewable sources (~22.08 MWh). "In year 2025, no specific CapEx or OpEx budget was allocated to the Global Car Policy or energy efficiency initiatives."

Targets related to climate change mitigation and adaptation

Reference: page 71.

Target: reduce overall GHG emissions by 35% by 2030 versus a 2024 baseline, aligned with limiting warming to 1.5degC. SBTi verification is planned for 2026.

Five decarbonization levers, each with its own 2030 target (page 71): (1) vehicle fleet electrification - 20% cut in Scope 1 fleet emissions; (2) renewable electricity for own operations - 25% cut in Scope 2 (market-based) emissions; (3) sustainable business travel - 15% cut in travel-related emissions; (4) sustainable transport and logistics - 15% cut in transport-related emissions; (5) sustainable supplier management - 44% cut in purchased-goods-and-services emissions.

Contribution to the 35% target: Scope 1 ~0.13%, Scope 2 (market-based) ~0.75%, Scope 3 ~34.12% - "the majority of Dynavox Group's emissions (nearly 95%) are from Scope 3 sources." All targets are stated as voluntary and internally defined rather than legally mandated.

Energy consumption and mix

Reference: page 72.

Dynavox Group is not a high climate impact sector reporter, so no energy-intensity-by-sector disaggregation is presented. No comparative 2024 figures are shown in this table.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 72-75.

Total emissions rose year-on-year against a target trajectory that requires reduction - driven mainly by Scope 1 more than doubling (leased/acquired vehicles) and Scope 3 growth in purchased goods and services (68% of Scope 3), downstream transportation (15%) and business travel (8%). GHG intensity per net revenue nonetheless improved, from 8.83 to 8.08 tCO2eq/SEK million (location-based, -8.5%), as revenue grew faster than emissions. Methodology follows the GHG Protocol with operational control consolidation; Scope 1/2 are activity-based, Scope 3 mixes activity-, spend- and supplier-specific data (Position Green platform); Categories 2, 8, 10, 13, 14 and 15 are excluded as not applicable or not separately reported.

Policies related to resource use and circular economy

Reference: page 77.

Environmental Policy (COO accountable) requires products designed for durability, recyclability and reuse, prioritizing recycled materials and reduced hazardous substances; it also promotes optimizing energy use, production efficiency and minimizing waste.

Supplier Code of Conduct (also COO-owned) applies to all suppliers and sub-suppliers worldwide and cross-references the Environmental Policy; suppliers must sign a declaration of compliance. It mandates conservation of natural resources through material substitution, greater use of recycled/recyclable materials, resource-efficient low-impact production, avoidance of unrecyclable/problematic materials, and durable, easy-to-disassemble components to support end-of-life recovery.

Actions and resources related to resource use and circular economy

Reference: pages 77-78.

2025 actions: a continuous device-reuse trial program (devices used a minimum of eight times per year before retirement, inspected/cleaned/repaired by in-house Repairs Teams); durability-focused design for the TD I-110 speech device using high-strength, lightweight materials; component standardization across product generations (the I-110/I-110.2 speaker system, most Navio-series electronics) to cut material development and waste; a 5-year Battery Eco-Design and Prevention Plan developed with battery manufacturers to reduce non-renewable resource use and increase recyclability; and a 5-year Packaging Eco-Design and Prevention Plan to move all packaging toward more recyclable, lower-impact materials. No CapEx/OpEx figures are given for these initiatives.

Targets related to resource use and circular economy

Reference: page 78.

Three voluntary, entity-specific 2030 targets, reporting to commence in 2026: product durability - 100% of new products compliant with internal durability standards and recognized testing protocols; plastic packaging - 100% made from recyclable materials by 2030; cardboard packaging - 80% made from recycled materials by 2030.

"All targets established by Dynavox Group under ESRS E5 are voluntary. They are internally defined and not mandated by legislation." A stated assumption for the packaging targets is reliance on supplier certifications for secondary raw material content and recyclability, mitigated by prioritizing certified suppliers.

Resource inflows

Reference: page 79.

Dynavox Group does not manufacture components itself; finished/semi-finished parts are sourced upstream and assembled in-house. Main inflow categories: electronic components (circuit boards, displays, sensors, speakers), rechargeable lithium-based batteries, packaging (cardboard, plastics) and accessories (cables, chargers).

The company notes a data limitation: only product-related material inflows are reported for the current year; IT equipment, machinery and other capital-asset inflows are excluded "due to constraints in collecting and processing detailed weight measurement data."

Resource outflows

Reference: page 79.

Dynavox Group's main operations are assembly rather than manufacturing, so "no significant manufacturing waste is generated"; defective components identified during assembly are returned to manufacturers rather than disposed of. Outflow-relevant waste arises mainly from repair/service activities at global repair centers, covering electronic parts, packaging waste and general operational waste, handled via contracted waste partners under local regulation. See E5-5-Waste for the full quantified breakdown (diversion, disposal, recycled-component share) presented on the same page.

Waste

Reference: page 79.

Percent of recycled/reused components: 0.00% (hazardous), 56.69% (non-hazardous). Non-recycled waste: 55.18% of total. No radioactive waste is generated (0 tonnes throughout).

Policies related to own workforce

Reference: pages 86-87.

Global Code of Conduct, Employee Handbook and Whistleblower Policy apply to all roles and regions, extended to acquired entities as integration progresses. A zero-tolerance policy on discrimination, harassment and unfair treatment covers hiring, remuneration, advancement and termination, grounded in the UN Guiding Principles, OECD Guidelines and ILO Conventions 100 and 111; it prohibits discrimination on race, ethnicity, gender, sexual orientation, gender identity, religion, political opinion, national/social origin, disability or age. "There are no other specific policy commitments relating to vulnerable groups." Physical accommodations (ramps, ergonomic workstations, accessible restrooms) are provided but "not yet formalized in a written accessibility policy." Human rights commitments (prohibition of child labor, forced labor, trafficking) are embedded in the Code of Conduct, aligned with the Universal Declaration of Human Rights and ILO core conventions.

Processes for engaging with own workforce and workers' representatives

Reference: page 88.

Engagement combines country-specific formal processes (e.g. Swedish union engagement during reorganizations; US OFCCP-audited equal-opportunity compliance) with lifecycle-wide channels: onboarding check-ins (weeks 2, 4, 8, 12, 20), a bi-annual engagement survey from day 90 (analyzed by company/department/team, tracked via Employee Satisfaction Scores and participation rates), annual Growth Talks and mid-year check-ins, monthly all-hands and bi-weekly regional stand-ups, and a DEI Committee running lunch-and-learns and fireside chats. International assignees receive relocation and integration support.

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

Reference: page 89.

Formal grievance processes operate globally with country-specific additions (e.g. UK appeal rights with trade-union representation). A strict non-retaliation policy and confidentiality guarantee apply, with anonymous reporting always available through the third-party WhistleB platform. Employees may also speak to a manager, People Business Partner, or use the global People portal (Halo), which logs and tracks cases. Awareness is reinforced through onboarding and mandatory Code of Conduct training. Effectiveness is monitored via survey participation rates and feedback review at company/department/team level.

Taking action on material impacts on own workforce

Reference: page 90.

Actions addressing the identified discrimination impact: standardized onboarding compliance training plus Manager 101 (inclusive leadership) and the Leadership Voice program for acquired-entity leaders; bias-reduction measures in recruitment (structured interviews, gender-neutral job descriptions); accessibility adaptations (ergonomic equipment, wheelchair-accessible facilities); a bi-annual anonymous engagement survey covering inclusion and harassment experience; and positive initiatives such as flexible work, upskilling and a North America job-shadowing program. "We have robust processes... [but] do not relying on short-term outcome targets" - monitoring runs through survey results, case tracking and external compensation/benefits audits (cross-referencing S1-17).

Targets related to own workforce

Reference: page 90.

Dynavox Group has not set timebound, outcome-oriented targets for equal treatment and discrimination. "We do not consider fixed short-term targets to be the most effective mechanism for managing this material impact," citing no incidents of serious harm recorded and a workforce "diverse across multiple dimensions." Effectiveness is instead tracked through the bi-annual engagement survey (inclusion/discrimination questions), monitoring of People-portal and WhistleB reports, training completion/participation rates, and review of case outcomes and feedback.

Characteristics of the undertaking's employees

Reference: pages 91-92.

Headcount at 31 December 2025: 1,063 (male 386, female 631, choose not to disclose 17, not reported 29). Permanent 1,049 / temporary 14; full-time 995 / part-time 68; board of directors 6. By region: Europe 519, North America 544. By country: Sweden 238, US 539, Germany 120, other 166 (average headcount in countries with >10% of workforce: 299). Turnover: 146 permanent employees left in 2025, a 15.28% turnover rate. Workforce grew 22% year-on-year, driven by acquisitions (Cenomy, France; RehaMedia, Germany) and a central development hub in Stockholm. No formal co-creation process with the workforce exists for these actions, though informal forums (S1-2) provide input channels.

Diversity metrics

Reference: page 93.

*Board/EMT age distribution is also given by bracket (under 20 through >65); total headcount reconciles to S1-6. Metrics are based on head count at year-end from the employment system, with no significant assumptions or limitations and no external validation beyond the audit assurance process.

Compensation metrics (pay gap and total compensation)

Reference: page 93.

Limitation stated by the company: figures are "based on fixed base salary only," excluding bonuses, wellness contributions, company-car benefits and long-term incentive programmes. The company assesses this exclusion as not materially affecting the gender pay gap (these components applied comparably to women and men), but acknowledges it understates the CEO-to-median pay ratio, since variable/LTI pay is more prevalent at senior levels, and states it is "developing an improved methodology" for future periods.

Incidents, complaints and severe human rights impacts

Reference: page 94.

"There is an inherent risk that not all incidents are captured in these metrics", as unreported cases will not appear in the data. Severe human rights incidents are monitored via quarterly litigation reviews and annual senior-management compliance surveys; none were reported in 2025.

Policies related to consumers and end-users

Reference: page 97.

Data Privacy Policy and Data Privacy Notice govern lawful, fair and transparent processing of personal data, applied company-wide and reviewed annually, grounded in GDPR, HIPAA and other applicable law. "There are no publicly available policies for consumers and end-users" (only the Privacy Notice is public); other policies are intranet-only. The company follows the UN Guiding Principles and OECD Guidelines, and aligns its medical-device and digital-health work with EU MDR, FDA Quality System Regulation and HIPAA. Privacy and security follow CIS Controls, with risk-based supplier due diligence, targeted staff training and a whistleblower channel.

Processes for engaging with consumers and end-users about impacts

Reference: page 97.

Engagement channels: Net Promoter Score surveys after each customer case, a formal complaints-tracking process run by the Quality team, and daily interaction with users, care circles and prescribers by phone, email and in person. Feature requests feed into product development. Privacy-related feedback is escalated to Quality and Compliance teams and has informed consent-management improvements, clearer privacy notices and enhanced security features. Oversight roles: Customer Service and Support Manager (daily interactions), Quality team (complaints), Marketing (NPS), and a Customer Journey Lead integrating insights into strategy. Effectiveness is evaluated via NPS response rates and complaints tracking.

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

Reference: pages 97-98.

Governed by the Incident & Crisis Management Policy and Instruction, distinguishing localized "incidents" (handled by the Incident Response Team) from major "crises" (escalated to the Crisis Management Team and, where required, the Board). Regulatory frameworks observed: GDPR, HIPAA, PIPL. Channels: customer-service hotlines, online forms, dedicated email, in-person support; partners/resellers must escalate incidents to Dynavox Group internally. "Although our current policies do not include an explicit anti-retaliation clause for consumers and end-users," established practice is to treat feedback confidentially and assure no denial of service results from raising a concern. Each case closes with root-cause analysis; oversight sits with the Corporate Communications Director supported by HR, Privacy, Quality and Regulatory.

Taking action on material impacts on consumers and end-users

Reference: pages 98-99.

Actions: Data Protection Impact Assessments for new products/features/services (privacy-by-design, overseen by the Privacy Manager, Privacy Specialist, Quality/Regulatory and an external DPO); mandatory privacy training toward a 95% completion target; quality/safety/accessibility work under EU MDR and ISO 13485 (risk management, post-market surveillance, corrective/preventive actions). "During the period, there have not been any incidents relating to data privacy or human rights issues, so the actions and remedies described below are stated as examples or processes we have in our policies." Planned future work: formalized vendor risk assessments, privacy safeguards in business-continuity planning, expanded DPIAs/Transfer Impact Assessments, a unified consent-management platform, and quarterly privacy KPIs from 2026.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities (consumers and end-users)

Reference: pages 99-100.

Privacy target: 95% participation rate in mandatory data-privacy training by end-Q2 2026 (2025 outcome: 85%). Societal-impact target: by 2030, contribute to improving the lives of at least 400,000 individuals, tracked via number of communication solutions sold, targeting 25% year-on-year growth (2025: 27,518 solutions sold in-year / 145,689 cumulative, 28% growth, against a 2025 target of 25%/145,137 cumulative). Both targets were developed by EMT working groups and formally approved by the EMT; **"no direct involvement of consumers or end-users has taken place in the target-setting process."

Business conduct policies and corporate culture

Reference: pages 103-104.

Employee Code of Conduct sets a zero-tolerance stance on corruption, bribery, extortion and money laundering; no employee may offer, give, request or accept anything of value that could influence professional judgment, with heightened care around government customers. Anti-Corruption Policy applies to all employees including short-term consultants, covering financial and non-financial benefits (gifts, hospitality, travel, charitable contributions). Whistleblower Policy provides confidential/anonymous reporting via the third-party WhistleB platform; retaliation against good-faith reporters is explicitly prohibited, investigations are restricted to uninvolved investigators, and cases concerning senior staff escalate to the Board. Mandatory Code of Conduct training (onboarding plus bi-annual e-learning) covers anti-corruption; "we have not yet identified high-risk areas for bribery and corruption," with targeted training for high-risk categories planned for next year.

Prevention and detection of corruption and bribery

Reference: pages 104-105.

Multiple reporting channels: the anonymous external WhistleB service, plus direct access to the CFO and the Audit Committee Chairman. All suppliers must sign and comply with the Supplier Code of Conduct, extending anti-corruption expectations across the value chain. Detection: all reports logged in the secure third-party system; Whistleblower Investigators (external People partners/generalists, independent of the matter under review) apply standardized assessment criteria, with serious/sensitive cases escalated to the Audit Committee. "During the year Dynavox Group has not been convicted for breaking anti-corruption and bribery laws and no amount of fines for such cases has been paid during the year" (this conviction/fines statement is presented under the G1-4 heading on page 106, but is substantively relevant here). Investigators log cases and report aggregated statistics annually to the Board.

Targets related to business conduct

Reference: page 106 (presented under the "Legal convictions and fines | G1-4" heading in the source document, but substantively a G1-3/anti-corruption target).

"We have set a target of achieving a 95% participation rate in anti-corruption and bribery training by 2030... This target supports the objectives of our Code of Conduct and Anti-Corruption Policy by ensuring that all employees and consultants understand their responsibilities and can identify and prevent misconduct." 2025 outcome: 83% participation (target 95% by 2030, elsewhere stated as "by the end of Q2 2026" in the methodology paragraph - the report is internally inconsistent on the target date). The target was developed by an EMT working group, based on current participation levels and assumed platform/support-structure capacity, with no historical baseline year used; progress is evaluated annually against the stated ambition rather than a baseline trend.

Incidents of corruption or bribery

Reference: page 106.

"We follow up legal convictions and fines annually, no baseline year or value is used in this follow-up... During the year Dynavox Group has not been convicted for breaking anti-corruption and bribery laws and no amount of fines for such cases has been paid during the year." No significant assumptions are stated, and no external body beyond the assurance provider validated the metric. (See G1-3-Targets for the 95%-by-2030 anti-corruption training target disclosed in the same section.)