Ekspress Grupp

The role of the administrative, management and supervisory bodies

Reference: pages 47-49.

Ekspress Grupp's administrative, management and supervisory bodies are the Management Board, the Supervisory Board and the Audit Committee. The general meeting is "the highest management body of AS Ekspress Grupp" (p.47). During 2025 the Supervisory Board had 3 non-executive members, all male (0% gender diversification, 67% independent): Priit Rohumaa (Chairman until 23.05.2025), Hans H. Luik and Triin Hertmann, succeeded from 23 May 2025 by Ülar Maapalu (Chairman), Argo Virkebau and Sami Seppänen (p.48).

The Management Board had 3 executive members in 2025, 2 male and 1 female (33% gender diversification, 0% independent), including CEO Mari-Liis Rüütsalu (until 31.12.2025) and a CFO role that changed hands three times during the year (p.48).

"The Group Chief Financial Officer (CFO) holds primary responsibility for leading the implementation of the Group's sustainability strategy," overseeing all material IROs (p.48). "While specific IRO responsibilities are not assigned at subsidiary level yet, sustainability reporting principles are in place, with plans to enhance governance" (p.49). Boards lack dedicated environmental specialists but "collectively possess relevant sustainability-related expertise"; for specialised ESG knowledge "the Group engages external experts and provides targeted training" (p.48).

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

Reference: page 49.

In 2025 Ekspress Grupp "strengthened its internal process for monitoring and managing sustainability impacts, risks and opportunities." The Group Business Controller was formally assigned responsibility for coordinating and consolidating sustainability performance across all subsidiaries, reporting "directly to senior executive management" (p.49).

A dedicated control procedure was introduced: subsidiary representatives are engaged quarterly to report on sustainability topics, progress against policies and targets, and material developments; the Group Business Controller consolidates this and presents results to the Management Board and Supervisory Board "as part of regular reporting cycles" (p.49).

Executive Management reviews the consolidated information quarterly with business unit heads. "Sustainability impacts, risks and opportunities are addressed at the Executive level on a situational basis." As of the statement date, "no material needs to change the overall business model or governance approach has been identified as a result of sustainability assessments" (p.49).

Integration of sustainability-related performance in incentive schemes

Reference: page 49.

"At present, the Group does not assess the performance of the Management Board or the Supervisory Board against sustainability-related targets." Sustainability-related performance metrics are not used as performance benchmarks and are not included in the Group's remuneration policies or incentive schemes.

"Accordingly, none of the variable remuneration of Management Board or Supervisory Board members is dependent on sustainability-related targets or sustainability-related impacts" (p.49). No proportion of remuneration tied to sustainability, and no percentage tied to climate specifically, is disclosed, consistent with there being no such link.

Statement on due diligence

Reference: pages 49-50.

Ekspress Grupp maps its due diligence practice against the ESRS core elements without a formalised process: "We don't have a formalised due diligence process in place yet, however we consciously embed sustainability in our strategy and business model" (embedding); continuous dialogue with suppliers, employees and clients (stakeholder engagement); the double materiality assessment (identifying and assessing adverse impacts); action taken via the Climate Change, Circular Economy, Our People and Our End-Users chapters (taking action); and a "comprehensive sustainability KPIs tracking system" communicated in the annual sustainability statement (tracking effectiveness) (p.49).

The Group "bases its activities on the Code of Corporate Governance of the Financial Supervision Authority of Estonia, the OECD Guidelines and the UN Guiding Principles on Human Rights." The Code of Ethics and Corporate Governance is "an integral part of the Group's contracts" for fulfilling due diligence obligations, and "the outcome of our due diligence process is incorporated in our double materiality assessment" (p.50).

Risk management and internal controls over sustainability reporting

Reference: page 50.

The system is "designed to ensure the completeness, accuracy, and auditability of data on a Group-wide, continuous basis," built around sustainability KPIs embedded in dedicated data systems rather than ad-hoc year-end collection. A proactive trial data collection exercise was conducted after nine months into the 2025 reporting year for the first time, to validate the data collection process and surface issues early.

"The primary risk identified is the potential for data errors or inconsistencies arising from disconnected processes." Two controls mitigate it: each reported data point must be directly linked to its source data, and a continuous, quarterly information flow requires subsidiary representatives to report on ESG progress, activities, KPIs and bottlenecks. Findings feed back into relevant internal functions, and "a description of the key findings, performance against KPIs, and any identified control issues are periodically reported to the administrative, management, and supervisory bodies" (p.50).

Strategy, business model and value chain

Reference: pages 50-53.

Ekspress Grupp operates across digital and printed media, advertising solutions, ticket sales and events creation in Estonia, Latvia and Lithuania (p.53). Its ESG strategy, set in 2022 and formally assessed via a first DMA in 2024, is "based on the international standards of a responsible enterprise (including the UN Sustainable Development Goals, UN Global Compact, OECD Guidelines for Multinational Enterprises, UN Guiding Principles on Business and Human Rights)" (p.50).

The value chain (p.51-52) spans upstream content creation, translation and printing; own operations across media, advertising and events (online/printed publications, digital screens, ticket allocation); and downstream product distribution, ad placement and post-event analysis.

Significant 2025 developments (p.53): Delfi UAB acquired conference businesses under the EBIT and HR Week brands; Lrytas hosted several large national events; AI-driven technologies and META algorithm changes "continued to affect audience behaviour and advertising dynamics." "Our ambition is to set the benchmark for sustainability topics in the media sector by reducing our environmental footprint, promoting responsible content creation, and driving positive change" (p.50).

Interests and views of stakeholders

Reference: pages 53-54.

Key stakeholder groups are employees, consumers, customers, suppliers, partners, investors, local communities, government bodies and society at large (p.53-54), engaged via performance dialogue and employee surveys (employees), feedback and public perception (customers), AGM and quarterly presentations (investors), contracts and due diligence plus an annual survey (suppliers/partners), and public/company reviews (communities) (p.54).

"Stakeholder opinions gathered across the group's subsidiaries were analysed and considered in relation to the group's strategy and business model," and "no contradictions between stakeholder interests and the group's strategic direction or business model were identified" (p.54). "During 2025, no dedicated stakeholder engagement activities were conducted beyond existing communication channels," and accordingly no changes to strategy or business model resulted from stakeholder views that year.

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

Reference: pages 56-58.

The 2025 DMA update confirmed E1 Climate change, S1 Own workforce, S4 Consumers and end-users and G1 Business conduct as double material (both impact and financially material); E5 Circular economy as impact material; and E4 Biodiversity and ecosystems as financially material (one identified risk), while E2 Pollution, E3 Water and marine resources, S2 Workers in the value chain and S3 Affected communities were assessed immaterial (p.56).

Named material IROs are set out per topic in a summary table: GHG emissions (E1), deforestation (E4), circular economy and waste (E5), and several G1/S1/S4 items (p.57). "As of 2025, there are no financial effects from material IROs anticipated to result in material adjustments to the carrying value of our assets and liabilities in the next annual reporting period" (p.58). Resilience "is deemed high within the time horizons," though the assessment "does not follow the ESRS requirements" and instead rests on "qualitative input by external subject-matter experts" (p.58).

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

Reference: pages 54-58.

Ekspress Grupp performed its inaugural DMA across all Group companies in 2024; 2025 is an annual review update on the same methodology, "further refined... by incorporating the latest EFRAG guidance" (p.54). The topic long-list derives from ESRS 1 Appendix A, AR16, business-activity analysis, industry reports and peer disclosures (p.55).

Impact materiality is scored 1-5 on scale, scope and (for negative impacts) irreversibility, averaged with probability; results at or above the arithmetic-average threshold are material (p.56). Financial materiality is scored 1-3 on scale and probability, same threshold logic. Final calibration was done by "the sustainability working group... and the Group CFO"; no dedicated stakeholder session was held in 2025 "as the results of the assessment did not change significantly" (p.56).

Climate scenario assessment (p.58): in 2025 the Group "initiated its inaugural climate change scenario assessment," aligned with TCFD, covering physical risk (moderate/high global warming scenarios) and transition risk/opportunity (Net Zero 2050 and Delayed Transition scenarios); full results are deferred to the next reporting cycle. A separate E2/E3/E4 screening "have not used any sophisticated frameworks... have not conducted consultations"; "None of our sites is located in or near biodiversity-sensitive areas" (p.58).

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

Reference: page 58; full index pages 89-91.

"A comprehensive list of the ESRS disclosure requirements we adhere to is found in the Reference table, starting on page 89," covering ESRS 2 general disclosures and the topical standards, each marked with a page number or "Non-material" (p.58). "Starting on page 92, a list of data points derived from other EU legislation is provided" (ESRS 2 Appendix B mapping to SFDR, Pillar 3 and the Benchmark Regulation).

The index confirms E1, E4, E5, S1, S4 and G1 as covered, with E2, E3, S2 and S3 marked "Non-material" throughout, consistent with the DMA in SBM-3. Within the covered standards several individual datapoints are still marked "Non-material" (e.g. E1-7 to E1-9, S1-8, S1-10, S1-11, S1-14 to S1-16, G1-5), reflecting sub-topic-level materiality decisions rather than blanket topic coverage.

Transition plan for climate change mitigation

Reference: page 60.

"Currently, we do not have a transition plan for climate change mitigation, which would ensure our strategy and business model are compatible with the transition to a sustainable economy and limiting global warming to 1.5 degrees in line with the Paris Agreement."

The company states only that it is "actively monitoring regulatory developments related to transition planning and continue[s] preparing to integrate these requirements into our strategy as they evolve" (p.60). No decarbonisation levers, locked-in emissions assessment, financial planning link or governance approval for a transition plan are described under this disclosure; related content (subsidiary-level actions, an unquantified 2030/2050 ambition) is captured separately under E1-3 and E1-4.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1, where this content is disclosed in the FY2025 report (page 58). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"In 2025, Ekspress Grupp initiated its inaugural climate change scenario assessment to identify key risks and opportunities. While the assessment commenced during the reporting year, the final results were undergoing internal review and approval at the time of this statement."

Methodology (p.58): aligned with TCFD recommendations, focused on hazards material to regional operations, business activities and key suppliers, evaluating both probability and severity. Physical risks were assessed across "two scenarios (moderate and high global warming)," covering floods, storms, heatwaves, heat stress and sea-level rise. Transition risks and opportunities were assessed across "two distinct scenarios: Net Zero 2050 and Delayed Transition," covering policy, legal, technological, market and reputational channels. No named scenario codes (e.g. RCP/SSP, IEA NZE) or temperature projections are given; the company states "full details regarding data methodologies and scenario outcomes will be disclosed in our next reporting cycle" (p.58).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and IRO-1, where this content is disclosed in the FY2025 report (pages 55, 58). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Ekspress Grupp does not report a resilience analysis meeting the ESRS definition. At Group level, "based on 2024 DMA results, our resilience is deemed high within the time horizons. Though the resilience assessment does not follow the ESRS requirements, we have based our opinion on qualitative input by external subject-matter experts, including an overall assessment of the mitigating factors in place across all IROs" (p.58).

Climate-specific context (p.55): the Group assesses physical climate risk as "low" because "most operations take place in office environments and on digital platforms," with potential exposure limited to "extreme weather conditions that can impact the operational reliability of the Group companies or the value chain (e.g. data centres)." "Results of the detailed quantitative risk assessment will be included in future reporting periods."

Policies related to climate change mitigation and adaptation

Reference: page 60.

"As of today, we don't have a dedicated policy related to climate change." The Group's ESG strategy "serves as a guiding framework for our sustainability efforts and outlines our commitment to environmental preservation, including the mitigation of climate change, use of renewable energy and optimised use of resources," but "it is not considered a separate policy document" (p.60).

No named accountable owner, scope (own operations vs. value chain) or third-party framework alignment is disclosed for a climate policy specifically; climate-related commitments instead sit within the general ESG strategy described under SBM-1.

Actions and resources in relation to climate change policies

Reference: pages 61-62.

"While Ekspress Grupp has not yet implemented a structured Group-level approach to climate actions, several subsidiaries have taken initiatives to reduce their environmental and climate impact." Actions are described at subsidiary level rather than as a coordinated Group programme (p.61):

• Print reduction: Geenius Meedia, Delfi Meedia and Hea Lugu reduced printing and distribution volumes; Hea Lugu "produces additional copies only based on confirmed demand."
• Energy efficiency: Lrytas increased remote work and operates from "a sustainability-certified building"; Geenius Meedia relocated to a "newer, more cost-efficient building"; Hea Lugu uses "air-to-air heat pumps instead of electric radiators."
• Renewables: Digital Matter transitioned all purchased electricity to renewable sources and began measuring advertising-related CO2 emissions.
• Green office and mobility: Delfi Elta supports "electric car rentals for business travel" and an annual walking challenge; several subsidiaries follow green office practices (waste sorting, reduced paper).

"The Group's current assessment is that no significant additional financial resources are needed to continue implementation" (p.61).

Targets related to climate change mitigation and adaptation

Reference: pages 60-61.

"As of now, we don't have a measurable, science-based target." Instead the Group states an ambition: "Our Digital companies of Ekspress Grupp will reduce the climate impact across the value chain by 2030, in compliance with Paris agreement, and reach climate neutrality by 2050" (p.60) — unquantified and without a defined baseline year.

The company explains it may "further reconsider and re-evaluate the previously disclosed base year and any methodologies... during 2026," citing "continuous enhancement of data availability... which has resulted [in] inaccurate baseline values," and states plainly: "we do not disclose the current progress towards the previously set goals" (p.60). It tracks "absolute emissions on an annual basis to establish a clear historical record" without a formal short-term target (p.61).

Energy consumption and mix

Reference: page 62; accounting policies page 61.

Total energy consumption fell 7% year-on-year, from 4,025.3 MWh (2024) to 3,772.0 MWh (2025). Fossil energy consumption was 2,801.8 MWh (74% of the total) versus 2,849.5 MWh (71%) in 2024; renewable energy consumption (purchased electricity/steam/cooling only, no self-generation or fuel from renewables) was 970.2 MWh (26%) versus 1,175.8 MWh (29%) in 2024. Nuclear and non-fossil non-renewable sources were 0 in both years.

"Ekspress Grupp's subsidiaries do not operate in sectors with a high climate impact within the meaning of ESRS" (NACE sections A-H and L), so intensity per revenue is not disclosed. The financial control consolidation approach was used, consistent with GHG accounting. "A certain limitation... is related to the level of detail for the data collected from our energy suppliers, which currently does not allow to disaggregate all relevant energy consumption by energy source" (p.61).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 62-65.

Total GHG emissions (market-based) fell 4.5% to 6,152.0 tCO2e in 2025 (2024: 6,441.3); location-based fell 10.6% to 5,616.9 tCO2e. Scope 1: 234.4 tCO2e (-11.9%, mainly company-owned vehicle fuel, 3.8% of the footprint). Scope 2 market-based: 1,104.3 tCO2e (+33.9%); location-based: 563.1 tCO2e (-15.4%). Scope 3 (nine categories reported): 4,813.3 tCO2e (-10.0%), led by purchased goods and services (3,209.9), employee commuting (556.5) and downstream transport (309.6).

By country: Estonia 4,005.1 tCO2e (market-based), Lithuania 1,326.4, Latvia 820.5. GHG intensity: 0.077 tCO2e per EUR '000 net revenue (market-based, -9.3% YoY), on net revenue of EUR 80.227m (p.65). The financial control consolidation approach was used; 73.2% of Scope 3 emissions used primary data, the remainder spend-based estimates (p.64). No internal carbon price or emissions trading participation. Comparative 2024 figures were restated for LNG, fuel and renewable-electricity data corrections (p.47).

Policies related to resource use and circular economy

Reference: page 69.

"At present, Ekspress Grupp does not have a standalone policy specifically dedicated to resource use and circular economy." Relevant principles are instead "already embedded in the Group's Sustainable Development Strategy, procurement guidelines and operational practices across subsidiaries," including recycling of unsold printed materials, reuse of event equipment and props, and compliance with local waste management regulations.

"The Group has initiated the development of a comprehensive Environmental Policy," not finalised in 2025 and "planned to be adopted in 2026," aligned with the Group's overall strategy update. It "will set out responsibilities, reporting procedures and group-wide standards for recyclability, material reuse and waste reduction" (p.69).

Actions and resources related to resource use and circular economy

Reference: pages 69-70.

Ekspress Grupp "outsources all printed media products" and has "not considered any of the resource inflows material to our activities"; paper volume used is not disclosed "due to unavailability of all relevant data" (p.70).

Unsold physical products (newspapers, magazines, books) "are collected and directed to Eesti Keskkonnateenused, the Group's waste management partner, which ensures that paper is returned to papermills for recycling into new products." The Group also "encourages reuse of event materials and props, the use of recyclable advertising formats, and the reduction of single-use plastics." Green office practices (energy/resource efficiency, waste sorting, employee awareness) are applied across all locations (p.70). During 2025, "several entities further reduced print volumes and initial print runs, contributing to lower amounts of unsold printed products." No CapEx/OpEx figures are attached to these actions.

Targets related to resource use and circular economy

Reference: page 69.

"At present, Ekspress Grupp has not set specific targets related to resource use and circular economy." The Group states only a qualitative direction: its "approach to circular economy is guided by the principles of resource efficiency, product reuse and sustainable waste management" (p.69). No quantified reduction, recycling-rate or reuse target with a baseline or target year is disclosed; page 86 separately notes the Group "has not yet established specific measurable or time-bound targets" across sustainability topics generally.

Resource outflows

Reference: page 70.

"Ekspress Grupp does not own production facilities, and all operations are focused on digital and printed media content creation and advertising." The Group tracks the number of newspapers and magazines produced, unsold copies, and the share directed to reuse or recycling.

Unsold printed products, 2025 vs 2024: Delfi Meedia AS 992,479 (2024: 962,278); Geenius Meedia OÜ 15,883 (2024: 108,320); total 1,008,362 copies (2024: 1,070,598), 100% directed to reuse in both years.

"Owing to their full recyclability, these products can be reprocessed by paper manufacturers, contributing to resource circularity," reducing waste sent to "landfilling or incineration." "Printed media generally requires no separate packaging, reducing the need for plastic." Data comes from downstream distribution/collection partners; "no additional methodological assumptions have been made, and the data have not been externally validated" (p.70).

Waste

Reference: page 70.

Ekspress Grupp does not publish a total-waste-generated table with hazardous/non-hazardous or radioactive breakdown. Its quantified waste-relevant disclosure covers unsold printed products, presented in the report under a section literally headed "Waste": 1,008,362 copies of unsold newspapers and magazines in 2025 (2024: 1,070,598), with 100% directed to reuse (recycling by papermills) in both years — Delfi Meedia AS 992,479 copies, Geenius Meedia OÜ 15,883 copies (p.70).

The 2025 DMA separately names "Waste" as a distinct material negative-impact IRO under E5, "material to selective entities due to high usage of plastics and waste generated from operations, e.g., from events, film ads" (p.69), but no tonnage, hazard classification or disposal-route data is given for that broader event/advertising waste stream — only the printed-product recycling figures above.

Policies related to own workforce

Reference: page 73.

Ekspress Grupp relies on its Code of Conduct and entity-specific guidelines rather than a single formal S1 policy suite. It applies "Ekspress Grupp's Code of Good Corporate Governance," based on the Estonian Financial Supervision and Resolution Authority's Code, OECD Guidelines, ILO standards, UN Guiding Principles on Business and Human Rights and the Estonian Equal Treatment Act (p.73).

The Code of Conduct addresses "human trafficking, forced labour, compulsory and child labour, discrimination based on age, gender, race, skin colour, nationality or ethnic origin." "We currently do not have a group-wide separate policy for working time, home-office policy, accident prevention policy, health and safety policy, policy for promoting equal opportunities for employees or policy against discrimination and harassment," unchanged in 2025 (p.73). For privacy and security the Group instead relies on its Security Policy and GDPR Policy (p.73).

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

Reference: pages 73-74.

Engagement runs through annual employee engagement surveys, managed centrally by the HR unit, and informal manager-level dialogue in smaller teams. "The employee feedback survey is conducted once per year and covers a wide range of topics" — team collaboration, goal clarity, work-life balance, company prospects and brand identity — sent to all Group employees to maximise response rate (p.73).

"We have not taken extra steps to gain insights into the perspectives of our people who may be particularly vulnerable but encourage our people to openly communicate their opinions" (p.73). Survey results are reviewed by team managers and coordinated organisation-wide by HR, alongside one-on-one meetings and performance reviews; issues requiring broader attention are escalated to responsible persons (p.74).

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

Reference: page 74.

Employees experiencing discrimination or harassment can report to their direct supervisor, the HR department, or the group whistleblower system, which "guarantees confidentiality and protection of the person notifying." Channels are communicated through onboarding and internal communications (p.74).

Whistleblower cases: 6 (2023), 5 (2024), 16 (2025). None of the 2025 cases were deemed to require additional steps under the Whistleblower Policy. "As the total number of incidents has been low over the years, we have not yet separately evaluated the effectiveness of said notification channels, mechanisms and processes" (p.74).

Taking action on material impacts on own workforce, and effectiveness of those actions

Reference: pages 74-75.

Actions rest on "policies, procedures and management processes" — annual engagement surveys, open dialogue and formal HR channels — with each entity's HR function monitoring effectiveness through annual Group-wide workplace wellbeing studies (p.74-75).

Concrete 2025 subsidiary-level actions: training across internal professional development, leadership, AI and cybersecurity, and journalism skills; continued access to the H. H. Luik scholarship; team meetings, strategy days and works councils for engagement; and wellbeing measures including health and wellness benefits, sports/wellbeing compensation, hybrid working, mental health support and team-building (p.75). Diversity, equity and inclusion are framed as "essential for long-term success and a key pillar of high-quality journalism" (p.75).

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

Reference: page 74.

Workforce targets are largely qualitative: personal and professional development ("personal learning and development plans are drawn up for all employees"); health and well-being (an enabling working environment, no quantified metric); and under diversity and engagement, "Ekspress Grupp has no gender wage gap" (explicitly flagged as "not a material topic") and a commitment "to achieve compliance with the European Union directive on gender balance in business leadership" (p.74). Progress is tracked "through a combination of qualitative assessments and KPIs," reviewed at relevant management levels, without disclosed baseline years or target dates.

Characteristics of the undertaking's employees

Reference: page 75.

Total employees: 889 in 2025 (2024: 963), a 6% decrease — Estonia 463 (2024: 506), Latvia 118 (141), Lithuania 308 (316). Gender split: 61% female, 39% male in 2025 (2024: 60%/40%). Self-employed people: 54 (2024: 34).

"Due to limitations in the accounting systems, it is currently not possible to distinguish between permanent and temporary employees; therefore, the figures are presented without this breakdown." Management is defined Group-wide as "positions that are two levels below the administrative management and supervisory bodies." Employee turnover: 188 departures in 2025, a turnover rate of 20.89%, covering all voluntary and non-voluntary departures (p.75).

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

Reference: pages 75-76.

Total non-employees: 72 in 2025 (2024: 105) — by country: Estonia 66 (2024: 87), Latvia 1 (0), Lithuania 5 (18); by gender, 37 male / 35 female (2024: 51/54). Non-employees include self-employed contributors ("journalists and authors who provide content on a freelance basis") and project-based specialists engaged for events, trainings and conferences (p.75-76). A separate self-employed count of 54 (2024: 34) and a trainee count of 94 (2024: 67) are also disclosed.

In 2025, workforce presentation was revised: "Individuals previously reported as temporary employees were reassessed based on their contractual arrangements and are now classified as non-employees," with 2024 comparatives adjusted accordingly (p.46).

Diversity metrics

Reference: page 76.

Age distribution, 2025: under 30 — 68 male / 129 female; 30-50 — 234 male / 348 female (63.60% of women); over 50 — 51 male / 52 female (14.30% of women), against 2024 figures of 78/142, 253/335 and 22.83%/n.d. respectively (raw figures per p.76 table).

Top management: 26 male / 16 female in 2025 (2024: 31/22). Employees with disabilities: self-declared at 4.70% (male) / 5.50% (female) in 2025, versus 11 (1.23%) / 5 (0.52%) in 2024, reported "due to legal restrictions under the EU General Data Protection Regulation (GDPR)." Average headcount: 894 FTEs in 2025 (2024: 963), per Note 25 of the Consolidated Financial Statements (p.76).

Persons with disabilities

Reference: page 76.

"Due to legal restrictions under the EU General Data Protection Regulation (GDPR) and equivalent national legislation across the Group's operating countries, Ekspress Grupp reports only those employees with disabilities who have voluntarily disclosed their disability."

Disclosed 2025 figures: 4.70% of male employees and 5.50% of female employees self-identified as having a disability, compared with 11 employees (1.23%) and 5 employees (0.52%) respectively in 2024 (p.76, disclosed jointly with S1-9 diversity metrics).

Training and skills development metrics

Reference: pages 77-78.

Training in 2025 focused on "editorial quality, digital competencies, ethical journalism, leadership and personal growth," including editorial ethics and fact-checking training (Delfi Lithuania, ELTA), digital skills and analytics (Geenius Meedia), and communication/management training (Lrytas). The Group supports the Hans H. Luik Scholarship for journalism students (p.77).

Training hours, 2025: 7,288 (male) + 11,731 (female) + 8,876 (not specified) = 27,895 total hours, averaging 20.63 hours per male employee and 21.20 per female employee, versus 2024 (13,186 total; 23.08/22.78 hours per employee). Performance-review participation: 35.31% (male), 40.15% (female), 37.17% (not specified) in 2025 versus 44.42% overall in 2024. "Going forward, Ekspress Grupp plans to establish a Group-wide framework for collecting and monitoring training data" (p.77).

Discrimination incidents, complaints and severe human rights impacts

Reference: page 78.

2025 metrics (2024 in brackets), all Group-wide: registered discrimination incidents through a formal process: 0 (0); complaints filed through own-workforce concern channels: 1 (0); complaints to OECD National Contact Points: 0 (0); material fines/penalties/compensation for social and human rights violations: EUR 0 (0); severe human rights issues/incidents connected to own workforce: 0 (0); cases of non-respect of UN Guiding Principles/OECD Guidelines: 0 (0).

"Given the sensitive nature of these matters, we do not disclose details about the incidents. Each report or complaint is handled with the highest level of confidentiality." Handling follows the Code of Conduct's discrimination principles, referencing UN Guiding Principles on Business and Human Rights and the Estonian Equal Treatment Act (p.78).

Policies related to consumers and end-users

Reference: page 79.

Consumer-related risk is managed through three existing policies rather than a dedicated consumer policy: the Code of Conduct, GDPR Policy (2021) and Security Policy (2023), which "outline the behavioural standards, data protection principles and information security measures that safeguard people, hardware, software and digital infrastructure" and "ensure a reasonable level of privacy, resilience and compliance across all operations." Oversight stays at the local level, with each company's top management responsible for its own customer needs (p.79).

Processes for engaging with consumers and end-users about impacts

Reference: pages 80-81.

Ekspress Grupp is still developing dedicated consumer-facing policies: adopting a GDPR-aligned data protection/usability policy, a user-safety policy, targeted-advertising principles, and a policy ensuring critical content stays freely available (p.80). Current practice includes data-protection audits of subsidiaries, regular data-protection training, and "providing users with simple and transparent ways to control how their data is being used" (p.80).

Feedback is gathered via content satisfaction monitoring (Delfi Meedia, Delfi Latvia, Geenius Meedia and reader surveys), daily customer-service satisfaction tracking, informal advertiser feedback, and product-development surveys (Delfi Meedia). "As we have not had any negative impacts to our clients with regards to security and data privacy or human rights, we have not had the need to develop nor currently have mitigation measures" beyond feedback collection (p.80). Accessibility is supported via digital solutions, public news blogs and availability measures for people with special needs (p.81).

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

Reference: pages 80-81.

Consumers can raise concerns via public contact forms and dedicated e-mail addresses on each company's website, plus the Group's anonymous third-party whistleblowing channel (WhistleB), open to "any individual, including external parties." Reports are reviewed by responsible persons and escalated to Group level "if necessary" (p.81).

"In 2025, no serious human rights or consumer-related incidents were reported, and no material negative impacts have been identified in recent years." Remediation is handled case-by-case, with integration into Group-wide risk management "under consideration for future reporting periods." In a GDPR-sensitive data incident, "the relevant activity is immediately stopped, access to exposed data restricted, and a root-cause analysis performed," overseen by the Group Data Protection Officer (p.81).

Taking action on material impacts on consumers and end-users, and effectiveness of those actions

Reference: page 81.

Data-protection metrics, 2025 vs 2024 vs 2026 target: inconsistencies in personal data protection rules: 0 / 0 / 0; fines for personal data protection violations: 0 / 0 / 0; total fines: EUR 0 / 0 / 0. Percentage of digital content covered with availability measures: 90-100% in both 2025 and 2024, targeting 100% by 2026 — the range describes Delfi's coverage in Estonia, Latvia and Lithuania specifically, as "all media publications of Ekspress Grupp have not evaluated the share of content covered by availability measures" (p.81-82).

Users "can manage cookies, opt out of targeted advertising and control their personal information at any time." Community initiatives cited as translating S4 IROs into action include Delfi Lithuania's (In)visible/(Ne)Matomi disability-inclusion platform and the Saugu national safety-awareness initiative (p.82).

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

Reference: page 81.

Two Group-level targets were set in 2025 for all companies, effective for 2026, benchmarked against a 2023 base year: "Zero violations of personal data protection requirements" and "Access is ensured to all our media content, taking also into consideration the needs of people with special needs."

The company states it is "further developing our approach to measuring the impacts, including a thorough internal reporting process on matters related to both customer privacy and data security and media accessibility" (p.81), without a numeric baseline for the accessibility target beyond the 90-100% figure disclosed under S4-4.

Business conduct policies and corporate culture

Reference: pages 84-85.

The Group's core instrument is its Code of Conduct, based on the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights, and the UN Universal Declaration of Human Rights, "publicly available and introduced to all employees during onboarding" and extended to partners and value-chain stakeholders. It "covers key topics such as media integrity and pluralism, anti-corruption, intellectual property protection, and responsible partnerships" (p.85). Oversight rests with Executive Management and the Board of Directors, who "review and update it as necessary," informed by due diligence and the DMA (p.85).

Editorial-specific principles of accountable journalism are also codified: independence from business/political interests, balanced coverage with a right of correction, source-confidentiality protection, and human/AI comment moderation (p.84-85). "As a large, listed enterprise, we have significant influence in the society, and thus the credibility and impeccable reputation of all group entities must be consistently upheld" (p.84).

Management of relationships with suppliers

Reference: page 85.

"Sustainability criteria were first integrated into purchasing principles in 2023" and have since expanded; by 2025 "ESG performance and commitment to responsible practices are core considerations in supplier relationships." In 2024, Delfi Meedia assessed the ESG performance of its key suppliers as a pilot; from 2025 the Group is extending this assessment "across all subsidiaries" (p.85).

"A dedicated supplier engagement and procurement policy is still being developed," intended to set minimum ESG standards, evaluation criteria and engagement procedures, and "expectations on environmental responsibility, human rights, labour practices and ethical conduct." Oversight rests with the Group Business Controller, who reports progress to Executive Management (p.85).

Prevention and detection of corruption and bribery

Reference: pages 86-87.

Zero-tolerance policy, reinforced through mandatory business ethics training for new employees, newsletters, and interactive sessions. Investigations of potential/confirmed cases follow the UN Convention against Corruption and the Estonian Anti-Corruption Act, run by "an independent committee of impartial members," with functions in management, journalism, marketing and procurement flagged as most exposed (p.86).

At-risk anti-corruption training coverage: 86.7% in 2025 (316 employees at risk, 274 trained), up from 52.2% in 2024 (452 at risk, 236 trained). "No separate or formalised anti-corruption training was provided to members of the administrative, management or supervisory bodies during 2025", though all reviewed the Code of Conduct. "In 2025, there were no cases of corruption identified at Ekspress Grupp." The externally managed WhistleB channel remained available Group-wide, with "a limited number of inquiries or complaints... in some entities" (p.86-87).

Targets related to business conduct

Back-filled from the G1 Business conduct chapter's "TARGETS RELATED TO GOVERNANCE" section (page 86). This disclosure requirement is a standalone DR only from the 2025/2026 ESRS; under the 2023 ESRS it fell under MDR-T, applied wherever the topic was material.

"As of 2025, Ekspress Grupp has not yet established specific measurable or time-bound targets related to governance topics." During the year the Group instead focused on "developing a consistent approach to supplier assessment and preparing the forthcoming Supplier Engagement and Procurement Policy," which will define expectations on environmental responsibility, human rights, labour practices and ethical conduct (p.86).

In the meantime, qualitative targets are in place on responsible publishing and ethics: "Publications of Ekspress Grupp do not publish unethical or irresponsible information" and "Zero violations of Ekspress Grupp's journalism code of ethics (in preparation)" (p.86).

Incidents of corruption or bribery

Reference: page 87.

Convictions for violation of anti-corruption and anti-bribery laws: 0 in both 2025 and 2024. Fines for violation of anti-corruption and anti-bribery laws: EUR 0 in both years.

Reports of misconduct are channelled through the group-wide anonymous whistleblower system, externally managed by WhistleB, using encrypted, password-protected notifications. "All reports of misconduct are handled with utmost confidentiality, and we do not condone any retaliation or countermeasures against individuals who submit a whistleblower report." Metrics are drawn from data gathered by "group data protection specialists" responsible for the whistleblower channel, plus court convictions and fines during the reporting year; no external validation was used (p.87).

Payment practices

Reference: pages 87-88.

Standard payment terms: 30 days, though "some subsidiaries [have] longer or shorter terms"; "we have not set a centralised group policy nor terms for the payment practices" given the range of sub-sectors and countries involved, and no centralised late-payment policy focused on SMEs exists.

Percentage of payments aligned with agreed terms: 92.5% in 2025 (2024: 91.5%). Average days of payment to suppliers: 23 (2024: 26). Fines for late payments: EUR 3,110 in 2025 (2024: EUR 3,799), from 31 cases of overdue payment in 2025. "We have not been involved in any legal proceedings related to late payments" (p.87-88).