Eesti Energia As

Reference: page 80

Eesti Energia AS has a two-tier governance system under the Estonian Commercial Code and State Assets Act: a management board (up to six members) responsible for day-to-day management, and a supervisory board (six to eight members, appointed by the Ministry of Finance as representative of the sole shareholder, the Republic of Estonia) which "conducts strategic oversight, approves major investments and monitors the functioning of the risk management and control systems."

A central sustainability unit provides methodological support, and a sustainability steering group is "headed by the CFO, who is a member of the management board and bears ultimate responsibility for sustainability." At 31 December 2025 the supervisory board comprised three women and two men, and the management board three men and two women. There are no elected employee representatives on the supervisory board; employee views are gathered through surveys and management reviews instead.

Reference: page 81

"The supervisory board and the audit committee are informed at least annually about the Group's material sustainability-related impacts, risks and opportunities, and the implementation and effectiveness of sustainability-related due diligence measures, policies, actions, metrics and targets." Reviews are provided by the management board or the sustainability manager.

When overseeing strategy, major investment decisions and risk management, "the supervisory board takes into account sustainability-related factors alongside financial and operational indicators." The management board integrates material sustainability impacts, risks and opportunities into the Group's risk management system and development processes, supported by the finance, risk management, organisation and culture, and environment units.

Reference: page 81

"The variable remuneration of employees is linked to the achievement of the Group's strategic objectives, including sustainability-related goals and targets." All employees and management board members participate in one variable remuneration system combining financial and non-financial indicators.

In 2025 the sustainability-related metrics were "GHG intensity (clean energy transition), the lost time injury frequency rate (LTIFR, occupational safety) and the net promoter score (NPS, customer satisfaction)." Maximum variable remuneration is up to four times basic monthly pay, and "the proportion of sustainability-related targets in the maximum variable remuneration ranged from 38% to 60%, depending on the entity." Members of the supervisory board receive only fixed remuneration.

Reference: page 81

"The Group's due diligence actions are based on the OECD Due Diligence Guidance and the United Nations (UN) Guiding Principles on Business and Human Rights. Relevant processes are embedded in the Group's governance, risk management and compliance assurance systems." This is intended to ensure that "material sustainability-related impacts, risks and opportunities within the Group's activities and value chain are identified, assessed and managed in the same way as other business impacts."

"Information on the management, scope and implementation of the Group's due diligence process is provided in various chapters of this sustainability statement. A summary table is provided in Annex 3 'Due diligence'."

Reference: page 81

"The Group operates an internal control and risk management system covering financial, operational and sustainability information. This framework is based on the three lines of defence model", using the same principles and policies for internal control, risk management and compliance set out in the Risk Management chapter of the management report, "employed for sustainability-related reporting controls."

"The sustainability steering group coordinates the preparation of the sustainability statement, including data collection and validation, in cooperation with data administrators. An external assurance engagement on the sustainability statement ensures that the reporting standards are applied correctly." This is the Group's first statement prepared under the CSRD, so data and reporting processes have been enhanced during the year to support accuracy, completeness and reliability.

Reference: pages 82-83

"The Group is an integrated energy and industrial company that operates across the entire electricity and heat value chain." It "operates in the fossil fuel sector, producing oil shale-based electricity, heat and liquid fuels in the eastern part of Estonia," activities being "progressively aligned with the Group's clean energy transition plan." The Group "does not generate revenue from the extraction, processing or sale of crude oil."

The value chain diagram (p.83) sets out upstream inputs (energy and material inputs, industrial materials), the Group's own operations (renewable and dispatchable generation, distribution grid, industry, liquid fuels, energy technologies, construction and engineering, e-mobility), and downstream customers, municipalities, utilities and affected communities. Strategic sustainability metrics are GHG intensity, occupational safety and customer satisfaction. On SBM-1 paragraphs 40(b)-(c), "the Group is not in a position to provide this information as the European Commission has not yet adopted the sector-specific ESRS and related sector classifications."

Reference: page 84

Stakeholders include "employees, customers, suppliers, investors, regulators, government agencies, local communities, civil society organisations and other partners." Engagement is "mostly continuous and carried out as part of the core business activities and central management processes," complemented by surveys and needs-based initiatives; "channels and topics of engagement depend on the counterparty and are not centralised at Group level."

Cross-cutting topics raised include "energy transition, climate risks and progress towards renewable energy and climate neutrality; protection of the environment and biodiversity...; energy availability, fair prices and remuneration; occupational safety, employee well-being and community development, including a just transition in Ida-Viru County; transparency and ethical business conduct." Stakeholder input feeds strategy, risk management, investment decisions and the annual double materiality assessment; the management and supervisory bodies "obtain a consolidated view of stakeholders' opinions on sustainability issues from the Group's sustainability statement."

Reference: pages 85-86

"The Group's material sustainability-related impacts, risks and opportunities disclosed in this statement were identified in 2025 based on the Group's double materiality assessment." Key material impacts and risks relate to "climate change mitigation and adaptation, pollution reduction and control, occupational safety and employee well-being, and responsible business conduct"; opportunities mainly relate to "renewable energy development, power grid modernisation and the circular economy."

Table 2 lists 18 material impacts, risks and opportunities across E1, E2, E3, E4, E5, S1, S3, S4 and G1 (full breakdown in the IRO count). "In this statement, the Group has applied the phase-in provisions designed for wave one reporting entities. Therefore, the estimated financial impact of sustainability matters is not disclosed for this reporting year."

Reference: page 87

The Group "identifies and assesses sustainability-related impacts, risks and opportunities in line with the ESRS, applying due diligence, stakeholder engagement and risk management." The 2025 process "covered the parent company Eesti Energia AS and all its subsidiaries," across own operations and the upstream/downstream value chain; "after the Group's restructuring, the materiality assessment will be updated."

Impact materiality is scored on scale, scope, irremediability and likelihood (0-5 each); "for human rights impacts, severity is given higher weighting than likelihood" (75%/25%). Risks and opportunities are scored on expected financial impact (percentage impact on EBITDA) and likelihood. "The materiality threshold is 3.5 for impacts and 2.85 for risks and opportunities." As "the Group's first comprehensive ESRS-compliant double materiality assessment," no comparative information from prior periods is presented.

Reference: page 88

"ESRS 2 IRO-2. A list of the covered Disclosure Requirements of the ESRS is presented in the 'Annexes' chapter of the sustainability statement" (Annex 1, Table 33), and "a list of EU datapoints is presented in the 'Annexes' chapter of the sustainability statement" (Annex 2, Table 34).

Annex 1 lists, with page references, every ESRS 2 cross-cutting disclosure and all material-topic disclosure requirements the statement covers: BP-1/BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2, MDR-P, MDR-A, and the E1, E2, E3, E5, S1 and G1 topical disclosures. E4, S3 and S4 disclosure requirements are absent from the index because the Group applies the phase-in disclosure option to those topics for the 2025 statement.

Reference: pages 93-94

"The Group's transition plan is guided by the actions necessary to meet the climate targets set by Estonia and the European Green Deal," reflecting the owner's (the Republic of Estonia's) expectation "to reduce the GHG intensity of its production portfolio... and to become a clean industry by 2050." "The current version of the transition plan was approved in December 2025 together with the Group's green finance framework"; owner expectations "were last updated in July 2025."

Central elements: "the systematic development of renewable energy, energy storage and the electricity distribution network, and the transformation of the fossil fuel-based industry into a circular economy-based one." In 2025 renewable electricity's share of production rose 11pp to 62%, renewable capacity reached 1,030 MW (134 MW under construction), €172 million was invested in the distribution network (weatherproof share up to 77%), and a 26.6 MW battery storage facility opened at Auvere. GHG intensity fell to 0.27 tCO2eq/MWh (energy) and 0.37 tCO2eq/MWh (electricity). Since 2015 Scope 1 emissions have fallen 12.6% CAGR; targets are a 7% further reduction by 2030 and 21% by 2035 versus 2024, reaching net zero "by 2050." The Group is exposed to GHG emissions lock-in risk from its oil shale-fired and oil plants, and "is not included in the EU Paris-aligned Benchmarks (PAB)." No CapEx plan is presented in the Taxonomy report; €50 million was invested in oil-related activities and none in coal or gas.

Identification of climate-related risks and scenario analysis

Back-filled from the ESRS 2 IRO-1/SBM-3 'Material climate-related impacts, risks and opportunities' chapter (pages 91-92), where this content is disclosed. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Material climate risks are classified as transition risks (competitiveness of fossil assets, financing costs) and physical risks (extreme weather raising O&M costs); "risks classified as climate risks in CSRD reporting are traditionally managed by the Group and its subsidiaries as part of other risk categories rather than as a distinct climate risk category," so relevant risks in existing risk categories were mapped into the DMA framework alongside scenario-based analysis.

Scenarios used: for wind energy assets, "both CMIP6 models and European Climate Risk Assessment (EUCRA) data based on SSP1.2-6 and SSP3-7.0 scenarios"; for Elektrilevi's distribution network, a Commission Notice (2021/C 373/01) methodology using the Estonian Environment Agency's "Estonian future climate scenarios until 2100"; industrial assets rely mainly on technical resilience and operational-continuity assessment rather than climate scenarios. No 1.5°C-aligned transition scenario or a stated global temperature projection is disclosed, and "scenario selection for the assessment of physical climate risks has not been harmonised across the Group... The Group is planning to harmonise the selection of climate scenarios."

Resilience in relation to climate change

Back-filled from the ESRS 2 IRO-1 'Material climate-related impacts, risks and opportunities' chapter (pages 91-92). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against; no separate, formal resilience analysis under the ESRS definition is presented.

"To assess the resilience of the business model, climate scenarios were used selectively to distinguish between transition and physical risks... providing a more comprehensive global perspective than the limited application of regulatory requirements." The report states that "together, they provide an overall picture of the resilience of the business model," while acknowledging "not all impact assessments of the described sustainability matters are currently based on the assumptions of a uniform climate scenario."

Adaptive capacity is described qualitatively through mitigation measures: "project design, environmental impact assessments, insurance, operational continuity and resilience analysis, backup systems, weatherproofing investments and regular reporting," and, for the distribution network, monitoring via the SAIDI metric. No quantified assessment of financial flexibility or asset redeployment capacity, and no significant areas of uncertainty, are disclosed.

Reference: page 95

"Although the Group does not have a separate climate policy document, the policy is incorporated into the Group's environmental policy," described under ESRS 2 MDR-P. The policy "is based on the owner's expectation of achieving climate impact reduction targets by reducing the impact of GHG emissions"; climate risk management itself is handled under the E1 IRO-1 chapter rather than in the policy document.

"The most important frameworks guiding the implementation of the climate policy are the Paris Agreement, the European Green Deal, the EU ETS, the GHG Protocol, the ISO 14001 standard, and reporting under the CSRD." Climate policy documents (strategy, environmental policy, GHG methodology) "are available to employees on the Group's intranet." The management board is responsible for implementation.

Reference: page 95

Climate actions "are described in the transition plan outlined in the chapter E1-1" and fall into three categories: climate change mitigation (increasing biofuel share, improving production efficiency, expanding renewables, and distribution-network preparation for renewables and small generators), climate change adaptation (regular climate-risk assessment and mitigation measures), and governance practices (integrating climate KPIs into performance management, regular GHG audit and methodology enhancement).

Table 4 sets three Scope 1 targets against 2025 results: gross Scope 1 emissions to 2.7 MtCO2eq by 2030 (2025 result: 2.60 MtCO2eq); GHG intensity of energy production to 0.19 tCO2eq/MWh by 2030 (2025 result: 0.27 tCO2e/MWh); and net-zero Scope 1 emissions by 2050 at the latest. "In line with the transitional provisions, the Group does not disclose comparative GHG data for the previous period."

Reference: page 96

Climate targets are "based on the owner's expectations (net zero emissions in Scope 1 by 2050), the interim targets set for this pathway and the requirements established by the integrated environmental permits." "No targets have been set for Scopes 2 and 3." 2025 was chosen as the base year "to represent normal conditions," using the same methodology and organisational boundaries as the GHG footprint in E1-6.

"All targets are based on absolute emission values," so "actions reducing GHG emissions such as carbon credits and the effects of emission reduction and avoidance technologies are not taken into account" in target-setting or assessment. To reach net zero by 2050, "carbon capture and storage technologies or nature-based approaches to reducing GHG emissions may also be required to eliminate residual emissions"; the Group "monitors advances in these options" and will decide the approach closer to implementation.

Reference: page 97

"The Group uses a variety of energy sources in its operations, including oil shale, retort gas, natural gas, biomass, liquid fuels, mixed municipal waste and purchased electricity and heat." Table 5 (2025 data, MWh): total fossil energy consumption 12,634,013 (fuel from crude oil/petroleum 134,903; natural gas 344,583; other fossil 11,790,143; purchased fossil electricity/heat/steam/cooling 363,636); nuclear-source consumption 60,443 (0.4%); total renewable energy consumption 1,241,740 (fuel from renewable sources including biomass 1,186,022; purchased renewable electricity/heat/steam/cooling 55,013; self-generated non-fuel renewable 706); total energy consumption 13,936,196 MWh, of which 8.9% renewable.

Energy production: non-renewable 6,270,806 MWh, renewable 2,231,968 MWh. Energy intensity in high climate impact sectors was "8,467 MWh per million euros of net revenue," calculated against Group net revenue as "all Group segments are classified as high climate impact sectors."

Reference: pages 97-98

Table 6 (2025, tCO2eq): gross Scope 1 emissions 2,596,253 (99% from regulated EU ETS installations); gross location-based Scope 2 289,047, market-based Scope 2 288,862; total gross Scope 3 1,751,595, across nine categories assessed as significant (capital goods 26,645; upstream transport/distribution 1,927; waste generated 1,598; business travel 135; employee commuting 605; upstream leased assets 1,821; downstream transport 2,630; use of sold products 1,172,119; investments 544,116 — largely the Attarat associate). Total GHG emissions: 4,636,894 tCO2eq (location-based), 4,636,709 tCO2eq (market-based); GHG intensity 2,816 and 2,815 tCO2eq/€m net revenue respectively. Emissions from direct incineration of biogenic fuels: 501,913 tCO2eq (beyond Scopes 1-3).

Methodology follows the GHG Protocol with organisational boundaries set on a financial-control basis, using DEFRA emission factors (AR6 GWPs) supplemented by Group-specific factors; location-based Scope 2 uses 2024 AIB residual-mix data because 2025 figures are not yet published, and market-based Scope 2 uses guarantees of origin for renewable electricity sold through Enefit Volt's charging network.

Reference: page 99

"The Group has no GHG removals or GHG mitigation projects financed through carbon credits." This is a complete nil disclosure for the requirement rather than an omission: no carbon-credit-financed removal or mitigation projects exist within the reporting boundary for 2025.

Reference: page 99

"The Group takes EU ETS prices into account separately for all activities covered by the system, as well as for strategic planning and operational activities at Group level. The EU ETS covers over 99% of the Group's Scope 1 emissions." Beyond the EU ETS, and "on top of the EU ETS price, it is considering the introduction of further pricing methods on a case-by-case basis, including to support management and investment decisions."

"While the Group does not apply an additional internal price for GHG emissions... No internal carbon pricing is applied to Scopes 2 and 3."

Reference: page 107

Pollution policies "are based on its environmental policies and standards," described under ESRS 2 MDR-P. Production activities require environmental, radiation-practice and integrated environmental permits which "require the subsidiaries to prevent pollution, carry out monitoring, prevent production and workplace accidents, and regularly report on their installations' compliance with the permit requirements, including emissions," and which "outline emission limit values, as well as monitoring and other obligations."

"The Group needs environmental permits for its day-to-day production activities... Integrated environmental permits also require the use of the best available techniques." "Hazardous substances and substances of very high concern are not addressed in the Group's environmental policy. Instead, these topics are regulated by the Group's environmental management standards and applicable legislation." Potential disasters and emergencies "have been identified, and the requirements for responding to them are set out in internal documents," including an emergency reporting procedure reviewed during internal and post-incident audits.

Reference: pages 108-109

"The Group is committed to continuously improving the resilience of its monitoring systems, reducing emissions and increasing energy efficiency." Actions differ by subsidiary: at Enefit Power's oil shale power plants, new dust monitors were installed at all three plants, urea dosing controls NOx at Auvere, retort gas combustion is capped at Auvere to protect the HCl limit, and the Eesti plant's pulverised combustion units moved to part-time operation (max. 1,500 hours/year) with ash field pipeline and spillway upgrades. At Enefit Industry, secondary-air system changes at the Enefit140 plants reduced several pollutant concentrations (H₂S, CO, NMVOC, CH₄, NH₃, COS, benzene) though SO₂ rose, prompting a three-solution SO₂ testing programme agreed with the Environmental Board. At Enefit Green's Iru plant, boiler-wall cleaning, activated-charcoal/lime-milk flue-gas scrubbing and SNCR reduce NOx, and mercury-containing lamps are being replaced.

"During the reporting period, there were 20 environmental incidents, including leaks, fires and an accidental overflow into the environment. All incidents were thoroughly analysed and the necessary corrective actions implemented."

Reference: page 110

"The Group-wide pollution-related goal for 2025 and beyond is to comply with all limit values specified in environmental permits," alongside the owner's objective "of becoming a clean industry by 2050," meaning net-zero GHG emissions from production processes by then. Subsidiary-level 2025 targets: Enefit Industry and Enefit Power targeted meeting all environmental requirements and resilient continuous monitoring; Enefit Green's Iru plant targeted improved emissions measurement certainty and a flue-gas condenser installation plan.

On compliance: "the Environmental Board... regularly inspects production units every one to three years." In 2025, Enefit Industry was fined €110,000 (paid) for unauthorised handling of phenolic water at Enefit140 (Jan-Apr 2024), and a further €70,000 fine (paid) for exceeding ambient-air emission limits (2023-2024). A fine against Enefit Power for the Eesti power plant was overturned by the Supreme Court on 9 January 2026. Several proceedings remained pending at the time of preparation, and two others were closed after calibration requirements were met.

Reference: pages 111-112

Air: "Air emissions mainly occur in the industry segment and constitute a material environmental impact," from power plant chimneys, tanks, fuel stations, boiler plants, blasting and the Iru waste-to-energy unit. Table 12 lists 2025 quantities in tonnes, e.g. nitrogen oxides (NOx/NO2) 1,747, sulphur oxides (SOx/SO2) 1,119, particulate matter (PM10) 1,078, non-methane VOCs 1,284, benzene 459.

Water: "In the worst case, emissions to water can affect the quality of water bodies in public use"; the main source is mine and quarry dewatering discharged via sedimentation basins. Table 13 (tonnes): sulphate 81,978; suspended matter 454; total nitrogen 275; chlorine/HCl 884; total phosphorus 2. "The water discharge limit values were exceeded once due to an accidental overflow in the ash field of the Eesti power plant," caused by extreme precipitation.

Soil: "Due to the nature of its operations, impacts related to soil pollution are not a material sustainability matter for the Group. Therefore continuous monitoring is not carried out. Soil samples are taken only in the event of an accident."

Reference: page 113

"The Group's production units use a wide range of materials, including chemicals. The most commonly used materials are various gases, acids, lime and paints. Flocculants are used in water preparation and wastewater treatment, and explosives are used in blasting operations in mines and quarries. Slaked and unslaked lime, hydrochloric acid, and activated carbon are used to clean flue gases."

"The Group does not use any substances classified as being of very high concern under Article 57 of Regulation (EC) No 1907/2006 (REACH), or identified under Article 59(1) of the same Regulation." Employees handling chemicals receive safety data sheets and instructions, and chemicals are stored "in accordance with applicable requirements, taking into account the specific nature of each product." No quantities of substances of concern generated, used, procured or leaving facilities are separately quantified.

Reference: page 114

Water policies "are based on the Group-wide environmental policies and standards" (ESRS 2 MDR-P). Production units require environmental permits for special water use and operate environmental management systems meeting ISO 14001 and the EMAS Regulation. "The double materiality assessment identified water use as the only material water-related impact at Group level": the extensive pumping needed to operate the oil shale mine and quarry in Ida-Viru County "affects the local groundwater regime by lowering the groundwater level in the region," an impact assessed as "actual and negative... long-term, expected to last for more than ten years."

Cooling-water reinjection also raises surface-water temperature within permitted ranges. "The Group's operations have no material impact on oceans and seas because the Group does not conduct any operations related to them," so "there are no plans to establish policies and targets in this area."

Reference: page 115

"The Group's activities have the greatest impact on water resources through the process of dewatering mines and quarries in Ida-Viru County"; groundwater-level drops "can affect areas extending from a few hundred metres to several kilometres from the mine or quarry," and "Enefit Industry is responsible for compensating for any damage caused by lowering the groundwater level." A water supply system was built for the village of Kurtna (affected by the Estonia mine) in 2021.

Environmental protection provisions "totalled €1.25 million at the present value" at the start of 2025, used for example for aftercare of the closed Balti ash field and Narva quarry recultivation. Monitoring includes automated groundwater sensors installed after a 2024/2025 inspection of monitoring wells found deficiencies, which have since been remedied; ditches at the Narva quarry were cleaned to control run-off, flooding and erosion risk, with the Estonia mine's ditches to follow in 2026.

Reference: page 116

"The Group has not set separate targets for reducing water consumption. The targets related to water use arise from the environmental permits held by its production units and the requirements of national and international legislation." Subsidiary-level 2025 targets (Enefit Industry, Enefit Power, Enefit Green's Iru plant) were to meet all environmental requirements including for water use, covering monitoring of surface and groundwater at Selisoo, the Muraka bog and Kurtna lakes (Estonia mine), groundwater/surface water at the Narva quarry, abstraction limits and record-keeping (Ida-Viru power and liquid fuel plants), and groundwater-level measurement at the Iru plant.

Office-level efforts include tracking water-consumption indicators through the green offices programme and replacing mixer-tap aerators where needed.

Reference: pages 116-117

Table 15 (2025): total water consumption 516,041,043 m³; consumption in areas at water risk, including high-water-stress areas, 0; total water recycled and reused 2,481,870 m³; total water stored 29,000 m³ (0 change in storage); water intensity 313,339 m³ per €m net revenue. 40% of the total is obtained by direct measurement and 60% by calculation.

"During the reporting period, 141 million m³ of water was pumped out, a significant increase compared to the previous year due to heavy rainfall," from the Narva quarry and Estonia mine dewatering. "The amount of cooling water used was 373 million m3, reflecting a downward trend compared to previous years," sourced from the Narva river, Narva reservoir, Mustajõgi river and, for the Iru plant, the Pirita river via a cooling tower and storage pools.

Reference: page 118

Resource use and circular economy policies "are based on the environmental policies, standards and responsibilities described in chapter ESRS 2 MDR-P," applying "the best available techniques" to minimise emissions and waste. "One material impact and one material opportunity relating to resource use and the circular economy were identified. Both relate to the industry segment": recycling ash and waste rock from the oil shale industry is "an actual positive impact" that reduces waste and primary-resource consumption downstream, and also "presents business opportunities for the Group, such as the processing, upcycling and sale of previously deposited ash and waste rock."

Production units that recover/dispose of waste or operate waste dumps and storage facilities hold the necessary permits; Ida-Viru power plants implement the SURE-EU biofuel sustainability certification scheme. "Currently, the Group's environmental policy does not include a detailed action plan or quantitative targets for resource use and the circular economy" at Group level.

Reference: page 119

At the Iru plant, "metals that are separated from the ash resulting from the incineration of mixed municipal waste... are recycled," and a commissioned study on recovering incineration ash continues into 2026. In 2024 the base structure of a new solar farm at the Estonia mine used "6.36 million tonnes of waste rock"; in 2025 further waste rock was used "to build an excavator assembly site and roads." Enefit Industry's railway unit delivered removed concrete sleepers to the Estonian Defence Forces "for blasting exercises during national defence exercises."

The environmental impact assessment of the Eesti power plant's ash field expansion continued in 2025, alongside research into ash properties to support safe, reliable operation. Green-office practices include reducing paper use, sorting waste, and analysing office resource and waste data to plan improvements; employees with significant waste-handling contact "receive regular training."

Reference: page 120

"No quantitative targets have been set at Group level for resource use, waste reduction or the circular economy. Instead, targets are set at subsidiary level." Enefit Industry's 2025 targets included "recycling 100% of waste rock, using at least 30% of waste rock and crushed stone in the construction sector, recycling ashes (including ≥45,000 tonnes of fly ash and ≤5,000 tonnes of mixed ash), and obtaining three declarations of performance for crushed stone and three CE markings for the circular economy." Enefit Power and Enefit Green targeted meeting resource-use/waste requirements and carrying out ash-recycling feasibility studies; Elektrilevi's distribution-network target was to maintain grid losses near the technical limit.

"All of the targets set for 2025 were met, except for Enefit Industry's target for the use of waste rock and crushed stone in the construction sector, which was 27.2% - slightly below the target of at least 30%."

Reference: page 120

Table 17 (2025, tonnes): overall total weight of products and technical/biological materials used 1,779,790, of which shale oil used 1,380,353, clean biomass used 390,627, and explosives used 8,810. "The Group does not purchase significant quantities of materials for the production of non-energy products," since crushed stone, waste rock and oil shale ash are by-products of energy production. Rare earth metals "are not used in the production process," though may occur in small quantities in permanent-magnet generators or cable components (e.g. indium, germanium); "the Group is not significantly dependent on the availability of critical raw materials for these developments."

Reference: pages 120-121

Products and materials: "The Group's main products are energy products (electricity, heat and liquid fuels)." By-products - ashes and waste rock - are upcycled: ash is used in construction (cement, concrete) and agriculture (fertiliser, the Enefix soil improver); waste rock is used to produce crushed stone, e.g. for the Narva magnet factory (2023), Rail Baltica (2024) and the Eastern Border Patrol Road project (2025).

Waste (Table 18, 2025, tonnes): total waste generated 3,627,698 (non-hazardous 3,617,620; hazardous 10,078); waste diverted from disposal 1,578,945 (recycling 1,578,422; preparation for reuse of hazardous waste 523); waste directed to disposal 2,125,529 (landfilling of non-hazardous waste 2,115,974; landfilling of hazardous waste 9,555); total radioactive waste 0.09 tonnes; percentage of waste not recycled 59%. Ash and waste rock are deposited at the Group's own waste storage sites; hazardous waste is transferred to licensed handlers, and 217 tonnes of packaging was generated.

Waste

Reference: pages 120-121 (Table 18)

Table 18 - Resource outflows: waste (2025, tonnes)

"The main waste product resulting from electricity generation and liquid fuel production is ash, which can be either non-hazardous or hazardous depending on the type. The mining process mainly produces waste from the extraction of non-ore mineral resources, known as waste rock." Bottom ash from the Iru waste-to-energy plant "is transferred to a waste handling company which uses it as an alternative to mineral material when closing landfill sites." Decommissioned wind turbine components are handled by the manufacturer or an outsourced contract partner. A total of "217 tonnes of packaging was generated during the reporting period," with packaging-company obligations outsourced to contract partners.

Reference: page 123

The general policy framework is under ESRS 2 MDR-P; sub-topic policies "are based on applicable labour laws, international labour standards and the Group's values." "The Group recognises its employees' right to organise and bargain collectively... in accordance with international labour standards (ILO principles). Collective bargaining agreements have been concluded with employees of the subsidiaries Enefit Industry, Enefit Solutions, Enefit Power and Narva Soojusvõrk," covering "remuneration, working conditions, working hours, leave, safety" for all covered employees regardless of union membership.

"In accordance with applicable labour laws and policies, the Group does not permit human trafficking, forced or compulsory labour, or the use of child labour." The Code of Ethics states "discrimination, harassment and degrading treatment are not tolerated, and that all employees have equal opportunities regardless of gender, age, nationality, religion, disability, sexual orientation or other personal characteristics." Remuneration is benchmarked so that "pay levels are at least at the market median for each job family," and "all employees' remuneration exceeds the legal minimum," in compliance with Directive (EU) 2022/2041 on adequate minimum wages.

Reference: page 124

"The Group regularly consults with its employees and their representatives on matters relating to working conditions, health and safety, remuneration and organisational culture," through "regular surveys, unit-level meetings and information days," working environment councils and feedback channels. "The main forms of engagement include the annual employee engagement survey, unit-level meetings, information days and thematic focus groups, as well as regular meetings with trade unions and employee representatives."

Survey results "are presented to the Group's management board and all teams" and used to draw up "annual, unit-based action plans." The organisation and culture unit, with the risk management unit, coordinates engagement, with additional attention to employees at higher risk of harm (mining, distribution-network maintenance, production).

Reference: page 124

"The Group has a multi-layer system that enables employees and third parties to submit reports and raise concerns about ethics, safety, equal treatment, corruption and other issues relating to employee rights," accessible via the intranet and website, "or the confidential whistleblowing system," which "ensures anonymity and protection against possible retaliation." Whistleblower protection detail is cross-referenced to chapter G1-3.

"Where the Group's activities have had a significant negative impact on employees, redress principles are applied in accordance with labour legislation, relevant agreements and internal procedures." Effectiveness "is assessed on a case-by-case basis during the handling of reports and investigations," considering timeliness, appropriateness of corrective action and recurrence, reviewed by the internal audit and ethics unit, the ethics committee and risk management.

Reference: pages 124-125

On the actual negative impact (health and safety): "the safety committee is responsible for developing the safety culture across the Group," chaired by an Eesti Energia management board member and the Enefit Industry chairman, with representatives from all subsidiaries. "A long-term action plan for improving safety is prepared for each subsidiary." In 2025, "ISO 45001 audits, which all subsidiaries successfully passed" were conducted along with a scheduled occupational safety audit at the Estonia mine and internal safety audits at eight Elektrilevi sites; forward-looking safety metrics (near-miss reporting, training-event counts) began development for 2026 reporting.

On the potential positive impact (adequate/motivating wages): "remuneration is regularly reviewed to ensure competitiveness in the labour market" via the annual salary survey. On the energy transition's workforce effects: "employees will be offered retraining and training programmes, which will be equally accessible to all, to support them in acquiring new skills and pursuing new career opportunities," with health and safety in new processes "systematically assessed."

Reference: pages 126-127

Table 20 sets 2025 targets against results: lost time injury frequency rate (LTIFR) target 0.8, 2025 result 0.9; management quality index target 81, result 81; NPS target 34, result 53. "The Group's objective is to promote the best possible safety culture by minimising accidents at work involving its own employees and those of its partners... The effectiveness of the safety culture is monitored using the lost time injury frequency rate (LTIFR)."

Employee-value-proposition targets cover "fair and competitive remuneration, employee well-being, and constructive social dialogue," aiming for "gender pay equity and high levels of employee engagement while supporting work-life balance and flexible working arrangements." Employees and trade unions contribute to target design via engagement surveys and the annual collective bargaining meeting; changes are approved by management-board resolution.

Reference: page 128

Table 21 (headcount by gender, year-end 2025): male 3,447; female 1,126; total 4,573. Table 23 (by contract type): permanent employees 4,486 (1,096 female, 3,390 male); temporary employees 87 (30 female, 57 male). Table 22 (by country): Estonia 4,311; Lithuania 96; Poland 82; Latvia 81; Finland 1; United States 1; Germany 1; total 4,573.

"Own workforce includes employees with permanent or fixed-term contracts, part-time employees, interns and trainees, and individuals working under service contracts... The Group has no employees with variable working hours." Gender is self-defined within the gender binary.

Reference: page 129

Table 25 (2025): collective bargaining coverage by country - Estonia 55% (employees represented 100%); Latvia, Lithuania, Poland, Finland, United States and Germany all 0%/0%. "On average in the undertaking," coverage is 52% and representation 92%. "Collective bargaining agreements have been established only in Estonia. There are no employees covered by collective bargaining agreements outside the European Economic Area."

"Reliable data on the trade union membership of individuals... are unavailable due to data protection restrictions," and "the Group companies have not entered into any agreements with their employees regarding representation by a European Works Council (EWC)."

Reference: page 129

Table 26 (top management gender distribution, 2025): supervisory board 2 male, 3 female (5 total; one member resigned in December 2025 with no replacement found by year-end); management board 3 male, 2 female (5 total); strategic managers 18 male, 3 female (21 total). Table 27 (age distribution): under 30, 493; 30-50, 2,317; over 50, 1,763; total 4,573.

"Diversity metrics include the gender distribution of the Group's management team and the age distribution of its workforce... Management categories are determined based on the Group's management structure," and members of the supervisory board are excluded from other workforce indicators "except for S1-S9 diversity metrics."

Reference: page 130

Table 28 (2025): 4,573 employees total (3,447 male, 1,126 female); 2,414 participated in regular performance and career development reviews (1,570 male, 844 female), a participation rate of 53% overall (46% male, 75% female); average training hours per employee 25.3 (the male/female split "is not known").

"The average number of hours per employee is calculated by dividing the total duration of registered training sessions by the average number of employees during the reporting period. Training data are collected on the basis of a central training register."

Reference: page 131

Table 29 (2025): employees covered by the occupational health and safety management system 83%; fatalities from work-related injuries and ill health 0 (own workforce and partners' employees alike); registered work-related accidents 12; work-related accidents with partners 16; registered occupational diseases 0; working days lost 155; LTIFR 0.9%.

"The lost time injury frequency rate (LTIFR) is calculated as the number of lost time injuries per million hours worked." All subsidiaries apply the ISO 45001 standard and passed their 2025 ISO 45001 audits.

Reference: page 131

Table 30 (2025): gender pay gap -3.2%; annual total remuneration ratio of the highest-paid individual to the median annual total remuneration of all other employees 10.1.

"The gender pay gap is calculated on the basis of the monthly basic remuneration set out in the contract. Variable remuneration, non-monetary benefits, and the employer's social security contributions are excluded." The remuneration ratio "is calculated on the basis of total employee remuneration, including payments made during the year based on workload."

Reference: page 131

Table 31 (2025): incidents of discrimination officially registered or initiated by the relevant authority 0; complaints filed through employee-concern channels 8; complaints to National Contact Points for OECD Multinational Enterprises 0; fines/penalties/compensation for discrimination and complaints 0; severe human rights issues and incidents 0 (including 0 cases of non-respect of the UN Guiding Principles/OECD Guidelines); fines/penalties/compensation for severe human rights incidents 0.

"The indicators for complaints and human rights incidents have been collected from the entire value chain and cover complaints received via all reporting channels... No serious human rights violations involving the Group's own workforce were identified."

Reference: page 132

"The Group's Code of Ethics establishes the principles of conduct for all employees and members of the management and supervisory bodies," based on "integrity, transparency, impartiality and responsible behaviour," with "a zero-tolerance approach to discrimination, harassment, corruption and conflicts of interest." It "applies to all Group employees, governing body members and cooperation partners."

The value-based management culture follows "the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, the ILO Conventions and the principles of the UN Global Compact." An ethics committee, chaired by the head of the organisation and culture unit and overseen by the management board, "supports the value-based management culture, reviews and updates ethics policies and advises employees on resolving ethical dilemmas," covering "internal rules and regulations, applicable legislation... labour disputes, contracts, employee inquiries and reported concerns, complaints and grievances." The Code of Ethics for Partners extends these standards to contractual partners.

Reference: page 133

"For the Group, active management of relationships with suppliers is a strategic activity that is guided by the Group's procurement policy and applicable legislation." Procurement is "planned centrally at Group level and managed by the procurement services unit"; under the Estonian Public Procurement Act, Group companies "conduct procurements via the public procurement register to ensure equal treatment of suppliers, clear selection criteria and transparency." "Around 80% of procurement contracts are awarded to local suppliers," with Latvia, Lithuania, Finland, Germany and Poland the next-largest supplier countries after Estonia.

"The Code of Ethics for Partners sets out the standards of responsible business conduct expected of all contractual partners... requires fair business practices and respect for labour laws and human rights, and prohibits human trafficking and forced labour." Where sanctioned-country links are indicated, partners "are excluded using the EU Sanctions Map website." Key suppliers "are surveyed annually on matters of compliance and sustainability," and the Group's objectives include "increasing the share of environmentally sustainable procurements and reducing the proportion of single-bid procurements."

Reference: page 134

"The framework for preventing corruption and bribery is based on, and forms part of, the core principles of the Code of Ethics," covering "risk-based oversight, whistleblowing hotlines, incident registration and investigation, and continuous employee training." Investigations are run by the internal audit and ethics unit independently of the business area involved, with escalation to the management board, audit committee and supervisory board for significant risks.

Potential violations "can be reported via a dedicated whistleblowing channel, which is accessible to both employees and external partners and enables anonymous reporting," with confidentiality and legal protection for whistleblowers. "In 2025, 87% of Group employees using computers completed the e-learning course on the Code of Ethics"; corruption-prevention training is given to managers and fraud-risk training to managers and senior specialists. "The internal audit and ethics unit assesses the effectiveness of the whistleblowing hotlines annually by reviewing response times, incident handling quality and recurring issue trends," reporting to the management board and audit committee.

Targets related to business conduct

Back-filled from the G1 Business Conduct chapter (pages 132-135), where targets are addressed as part of the MDR-T-style disclosures rather than as a numbered disclosure requirement. G1-3 as a standalone targets DR did not exist under the 2023 ESRS this report was prepared against.

No single measurable, outcome-oriented business-conduct target (e.g. a numeric corruption-incident reduction target) is stated. Instead, consistent with MDR-T's "effectiveness tracked" limb, the Group describes how it monitors the effectiveness of its business-conduct measures: "the internal audit and ethics unit assesses the effectiveness of the whistleblowing hotlines annually by reviewing response times, incident handling quality and recurring issue trends" (G1-3, p.134), and training completion is tracked ("In 2025, 87% of Group employees using computers completed the e-learning course on the Code of Ethics," p.134).

On suppliers, the Group states its "main objectives of supplier relationship management are to increase the share of environmentally sustainable procurements and to reduce the proportion of single-bid procurements and those where price is the primary award criterion" (G1-2, p.133), again a directional objective rather than a quantified target. No G1-5 (political influence) content is presented, as that topic is not material.

Reference: page 135

"During the reporting period, no convictions or violations that should be recorded in the criminal records database were identified in relation to corruption or bribery offences committed by the Group's employees or members of the Group's governing bodies." "No fines were imposed on the Group for breaching anti-corruption or anti-bribery legislation."

"The Group provides all employees with mandatory ethics and anti-corruption training... The Group has not identified any unfulfilled training obligations or deficiencies that would suggest unmanaged systemic risk." Fraud risk (covering "the misuse of assets, corruption and misrepresentations in reporting") is tracked through the Group's risk profile and reported quarterly to management boards, with the audit committee briefed at least annually.

Reference: page 135

"The Group's payment practices are set out in its policy on payment terms for procurement contracts. The payment term depends on the contract amount and whether the bidder chooses the standard payment term or factoring." Standard terms: 14 days (contracts up to €59,999), 35 days (up to €249,999), 45 days (over €250,000); 95 days where factoring is used, with CFO-approved exceptions in specific circumstances (e.g. foreign companies unable to use factoring).

"In 2025, the Group's average time from receipt of an invoice to payment was 30 days. The calculation covers all payments; no representative sample was used." "While there is no precise data on the proportion of payments made on standard terms, the procedure for processing purchase invoices and other expense documents ensures that payments are made on time. In the next reporting period, options for determining the exact proportion of payments made on standard terms will be considered."