Elica S.p.A.

Governance roles

Reference: pages 68-69.

Elica S.p.A. has adopted a traditional governance and control model: a Board of Directors, a Board of Statutory Auditors (supervisory function) and an Internal Board committee covering Control, Risks, Sustainability, and Appointments and Remuneration.

Board composition (p.68): seven Directors - five Non-Executive (Angelo Catapano, Alice Acciarri, Elio Cosimo Catania, Cristina Casoli, Susanna Zucchelli) and two Executive (Executive Chairperson Francesco Casoli, CEO Giulio Cocci). Four of seven members (57%) are declared independent. "There is no employee representation within the undertaking's administrative, management and supervisory bodies" (p.68).

Gender composition (p.69): Board of Directors 58% male / 42% female; Board of Statutory Auditors 60% male / 40% female.

The Chief Financial Officer has been appointed Corporate Sustainability Reporting Officer, confirmed following a By-Laws amendment approved April 29, 2025 (p.69).

Information flows to governance bodies

Reference: page 69.

"Sustainability is a topic that must be continuously discussed, particularly at the Top Management level, as it represents a fundamental component of the Group's mission" (p.69). Information on due diligence adoption, and on the results and effectiveness of policies, actions, metrics and targets, follows the same reporting process as for impacts, risks and opportunities (IROs), with further detail cross-referenced to GOV-1 and SBM-3.

Sustainability in remuneration

Reference: pages 70-71.

The MBO (annual variable incentive) system for the Chairperson and CEO provides for economic-financial Group targets and a sustainability-linked multiplier: "A +/- 10% multiplier linked to the achievement of annually established sustainability targets is applied to the final payout of the Chairperson of the Board of Directors, Chief Executive Officer, and Senior Executives, with an on/off trigger mechanism" (p.70). For the current financial year the target is geared toward reducing the emissions impact of the Polish plant - a footnote states "the reduction targets ... are not defined according to Science based criteria" (p.70).

The Group explicitly states: "At present the incentive systems applicable to members of the management, administrative and supervisory bodies are not linked to science-based GHG emissions reduction targets" (p.71).

Due diligence statement

Reference: pages 71-73.

"Although the ESRS do not impose specific conduct requirements in relation to due diligence, on February 13, 2025, the BoD approved a procedure with specific reference to human rights (see 'Human Rights Due Diligence Procedure') and the related policy" (p.71), referencing the OECD Guidelines and the UN Guiding Principles on Business and Human Rights.

Elica also points to its ISO 14001:2015, ISO 45001:2018 and ISO 9001:2015 management-system processes (all Group companies except Air Force) as instrumental to identifying and monitoring material IROs (pp.71-72). At December 31, 2025, 94% of employees and 99% of non-employees worked at sites certified to all three standards (p.72).

Risk management and internal controls

Reference: page 73.

"The Group has consolidated a non-financial reporting process designed to ensure full compliance with the CSRD and the ESRS," supported by a dedicated management system called Talentia for data flows between the Corporate Sustainability Team and Data Owners across Group companies (p.73).

The Enterprise Risk Management (ERM) model is integrated into the analysis and assessment methodology, "adopting a risk-based approach that provides for the definition and periodic review of risk matrices and specific controls relating to key sustainability indicators" (p.73).

Strategy, business model and value chain

Reference: pages 75-76.

Elica Group is a production platform of approximately 2,400 employees organised into two Business Units: Cooking (range hoods, extractor hobs, cooktops, ovens, wine coolers) and Motors (electric motors and fans for heating, ventilation and home appliances) (p.75).

"Specific sustainability targets are not currently defined for significant groups of products or services, categories of customers, or geographical areas" (p.75); sustainability considerations are nonetheless factored into strategy, e.g. orienting investment toward hydrogen and heat-pump product development (p.75).

The value chain is mapped upstream (raw material extraction and refinement, component manufacture, inbound logistics), through own operations (design, production, testing, packaging, warehousing) to downstream (outbound logistics, sell-out, product use, end-of-life/waste disposal) (pp.75-76). Upstream mapping used Tier 1, 2 and 3 supplier analysis, with Tier 1 "most relevant suppliers" defined as those accounting for at least 80% of procurement expenses (p.76).

Stakeholder engagement

Reference: pages 77-79.

The report maps stakeholder categories (Shareholders and Governance, Workers, Trade unions, Customers and consumers, Suppliers and partners, Investors, Certification bodies, Standardisation bodies, Planet and global community, Local communities, Media, Trade associations, Insurance companies, Science hubs/universities, ESG Rating Agencies) against dedicated engagement channels (pp.77-79).

"Though there is currently no structured process of direct stakeholder engagement as an input for the redefinition of corporate strategy, all the engagement methods adopted in the current reporting year are presented in the above table" (p.79). For FY2025, Elica incorporated the results of stakeholder engagement activities conducted in 2024 into the organisational context analysis, using the prior year's survey as the reference point (p.79). The internal Board committee and Board of Statutory Auditors are informed at least once a year on the double materiality process and stakeholder engagement, subject to final Board validation (p.79).

Material impacts, risks and opportunities

Reference: pages 80-84 (general); pages 94-96 (climate-specific).

The double materiality assessment identified 17 material impacts and 14 material risks, across E1, E5, S1, S2, S4 and G1; no material opportunities were identified for FY2025: "No material opportunities were found for the reporting year; instead, physical and transition risks were assessed as material" (climate section, p.94-95). Full topic-by-topic IRO counts are in the iro.json evidence file.

Representative impacts: climate emissions from own operations, value chain and transport (E1, negative); raw-material and manufacturing-waste impacts (E5, negative); work-related injuries, skill development, own-workforce human rights (S1, mixed); value-chain human rights and forced/child labour (S2, negative); consumer health/safety versus customer privacy (S4, mixed); supply-chain management versus payment practices (G1, mixed).

Representative risks: physical climate and supply-chain risk, credit-rating erosion, customer ESG requirements (E1); injuries, maintenance downtime, GDPR, workforce scandals (S1); third-party injury/human-rights and scandal risk (S2); customer GDPR (S4); business ethics, scandals, fraud (G1).

"We note that no significant financial effects occurred concerning the identified material risks in the current reporting year" (p.84).

Double materiality process

Reference: pages 85-87.

Methodology follows EFRAG IG 1 "Materiality Assessment Implementation Guidance" in three phases (p.85): (1) understanding the organisational context (benchmarking, Sustainalytics/S&P Global/MSCI/Euronext/WEF/UNEP/OECD sources, value-chain mapping by Tier 1-3); (2) identification of IROs using ESRS 1 AR 16 topic/sub-topic/sub-sub-topic list as the methodological reference; (3) assessment, validated by the internal Board committee (acting as Control, Risks and Sustainability Committee) and the full Board.

Impact severity is scored on three-level scales for scale, scope and irremediable character, multiplied by a four-level likelihood factor (p.86). Financial materiality uses economic-financial, operational and reputational dimensions with a four-level magnitude scale (Low/Medium/High/Critical) based on revenue/cost/EBIT impact, assessed over the long-term horizon for aggregated results (p.87).

"No changes were made to the process compared with 2024, and the next review of the materiality assessment ... will take place during 2026" (p.87).

ESRS content index

Reference: pages 88-93 (index); pages 88-90 (non-material topics).

The Statement carries a page-referenced ESRS content index covering ESRS 2 general disclosures and the material topical standards E1, E5, S1, S2, S4 and G1 (pp.91-93).

Topics assessed and found not material: E2 (pollution), E3 (water and marine resources), E4 (biodiversity) and S3 (affected communities). E.g. E2: "the issue does not present risks or opportunities that are likely to materially impact Group financial performance ... such as to make it a material ESRS reporting topic" (p.88); E4: "none of the plants considered in the reporting scope are located in protected zones" (p.89).

Phase-in / omitted rows (ESRS 1 Appendix C), by the company's own labelling: E1-9, E5-6 (anticipated financial effects); several S1 datapoints (social protection, training, non-employee elements of health and safety and work-life balance) (pp.91-93). "For FY 2025, Elica decided to gradually introduce certain disclosure requirements envisaged in Appendix C of ESRS 1" (p.88).

No entity-specific disclosures: "all the material sustainability impacts, risks and opportunities identified by the Group are attributable to ESRS standards" (p.93).

Transition plan

Reference: page 96.

"At the date of this statement, the Group has not adopted a formalised climate transition plan." Climate impacts, risks and opportunities are instead factored into strategic analysis and risk management, and the Group "will continue to actively monitor the climate transition, assessing the potential adoption of dedicated tools or initiatives in the medium term" (p.96).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 (climate-specific section), where this content is disclosed in the FY2025 report (pages 94-95). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risk classification and methodology (p.94): physical and transition risks are assessed for own operations and the upstream/downstream value chain. Physical risk exposure was analysed for Italy, Spain, Mexico, China, the USA and Germany over a long-term horizon to 2050, scored 1-3 for magnitude on a geospatial basis.

Scenarios used (pp.94-95): physical risk - IPCC Representative Concentration Pathway (RCP) 8.5 (a high-emissions scenario); transition risk - the Current Policies and Net-Zero scenarios, and separately IPCC RCP 8.5 alongside 1.5°C-aligned scenarios including the Network for Greening the Financial System and the AIA Climate Action Plan net-zero-by-2050 scenarios, over a 2030-2050 horizon.

No explicit statement of the global average temperature projection per scenario is given - that element of AR 6/¶17(a)(iii) is absent from the disclosure.

Scope: own operations and value chain, both upstream and downstream, covering suppliers (accounting for 80% of expenditure) and customers (80% of revenue) (p.96). Timing: the analysis was "updated" during 2025 (p.96).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 (climate-specific section), where this content is disclosed in the FY2025 report (pages 95-96). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"In 2025, Elica updated its analysis of the reaction capacity of its strategy and business model to climate change, which led to the identification of priority adaptation solutions" (p.95), covering all production sites plus major suppliers (80% of spend) and customers (80% of revenue).

For physical risk, identified adaptation solutions include technical/equipment measures (air-conditioning optimisation, climate sensor monitoring) and transversal measures (insurance coverage, extraordinary maintenance) (p.95). For transition risk: "further investments in R&D and eco-design, greater engagement of stakeholders ... and the adoption of new product certifications and management systems" (p.96).

On adaptive capacity: "the analysis confirmed that Elica has the ability to adapt itself and its strategy and business model to climate change, both over the short and medium to long-term," citing continuous access to competitive funding (short-term) and the ability to "adapt or dispose of assets in the transition to a more sustainable economy" (medium-to-long-term) (p.96).

No area of significant uncertainty in the assessment is separately identified, and no quantified financial-flexibility figures are given.

Climate policies

Reference: page 96.

"With regard to climate change, the Group does not currently possess any policies that are fully aligned with regulatory requirements, also in light of the continuously developing regulatory framework." Elica states it "is committed to issuing a policy as soon as the regulatory landscape is consolidated," to be formalised "alongside the adoption of a comprehensive and structured Transition Plan" (p.96).

Climate actions

Reference: page 97.

"Although the Elica Group has not yet formalised science-based actions and targets relating to climate change, during 2025 it initiated several operational initiatives designed to reduce greenhouse gas emissions," described as "first concrete steps" (p.97).

Main 2025 actions, concentrated at the Jelcz Laskowice, Poland site (the Group's largest facility): reduced operating pressure of compressed-air compressor systems used in fastening processes; replacement of traditional lighting with LED and automated sensor-based lighting management in production areas, warehouses and offices; and dedicated staff training on efficient energy use (p.97).

Climate targets

Reference: page 97.

"The Group has not yet defined specific, clear, measurable, and science-based targets for climate change mitigation and climate change adaptation, although relevant aspects emerged through the double materiality assessment." Elica states it is "committed to supplementing its strategy to focus on reducing its impact in terms of emissions and energy" through the initiatives described under E1-3 (p.97).

Energy consumption and mix

Reference: page 97.

Total company consumption in high-climate-impact sectors reached 41,224 MWh in 2025 (p.97), primarily electricity for production, auxiliary equipment and lighting. Elica sourced electricity from renewable sources certified by Guarantee of Origin at all Italian sites and the Polish facility. Three photovoltaic systems on Italian sites generated 1,106.33 MWh in 2025.

"In 2025 the Group's electricity mix included approximately 36.84% renewable energy" (p.97). All Group sectors are classified as high climate-impact sectors under Annex I of Regulation (EC) No 1893/2006 (p.97).

GHG emissions

Reference: pages 100-103.

Methodology follows the GHG Protocol, with reporting scope covering all consolidated subsidiaries including sales companies (p.100).

Scope 1 (direct): 4,143 tCO2e in 2025, down from 4,308 tCO2e in 2024 (-5.0%) (p.101).

Scope 2 (market-based): 2,356 tCO2e in 2025, up from 2,104 tCO2e in 2024 (+12.0%) (p.101).

Scope 3 categories reported include: Category 1 (Purchased goods and services) 70,886 tCO2e (down 16.3% from 84,697); Category 4 (Upstream transportation and distribution) 13,942 tCO2e (up 19.7% from 11,642); Category 5 (Waste generated during operations) 56 tCO2e (up from 14); Category 6 (Business trips) 372 tCO2e (down from 499); Category 7 (Employee commuting) 2,630 tCO2e (up from 1,796) (p.102).

Total emissions (location-based, all scopes): 622,600 tCO2e in 2025, down from 700,932 tCO2e in 2024 (-12.8%); against net revenue of €460,560k, this gives an emissions intensity of 1.352 tCO2e/k€ (down from 1.550) (p.103).

GHG removals and carbon credits

Reference: page 94.

"The Group will not report information regarding Disclosure Requirement E1-7 ... because it does not perform greenhouse gas removals or finance mitigation projects through carbon credits. There is therefore no data on GHG removals or mitigation projects financed through carbon credits in its transactions or value chain" (p.94). This is a nil disclosure with a stated reason, not an omission.

Internal carbon pricing

Reference: page 94.

"The Group will not report information regarding ... Disclosure Requirement E1-8 because it does not ... apply internal carbon pricing schemes in its transactions. As such, there are no data on internal carbon prices or GHG emissions covered by such schemes" (p.94). This is a nil disclosure with a stated reason, not an omission.

Circular economy policies

Reference: page 115.

"For this reporting year, the Group has not adopted specific policies on this issue, as it considered it a priority to conduct an in-depth analysis of its operations and value chain within the circular economy." Elica states it "is actively working to draw up a policy that meets the needs for a more systematic and integrated approach to circular economy" (p.115).

Circular economy actions

Reference: pages 115-116.

"In 2025, the Group did not take any specific actions to manage impacts risks and opportunities relating to the circular economy topic, as the priority was to consolidate a knowledge base and operational processes" (p.115). Elica cites initiatives already under way: "optimisation of production processes in order to reduce waste, the use of more recycled and recyclable materials in products, and improvements to the management of product life cycles" (p.115).

Circular economy targets

Reference: page 116.

"The Group has not yet defined specific, clear and measurable objectives related to the circular economy, although material aspects emerged through the double materiality assessment." Elica states it is "committed to supplementing its strategy to focus on reducing its impact in terms of materials and waste" (p.116).

Resource inflows

Reference: pages 116-117.

Elica "sources raw and semi-finished materials from various industries and, as a processing company, does not directly import minerals" (p.116), and conducts periodic supplier audits under a Due Diligence programme aligned with Regulation (EU) 2017/821 (Conflict Minerals) (p.116).

FY2025 raw material inflows (total company, both technical categories, tonnes) include: Steels and Metals 32,476.85; Plastic 399.59; Powder coatings 348.95; and semi-finished Carpentry and Other Components 1,669.69 (p.117), alongside limited process water use (degreasing/washing at approx. 45°C) and groundwater/mains withdrawal (p.116).

Resource outflows (product circularity)

Reference: page 118.

Elica has implemented "a system based on accurate data, calculations and estimates" to assess the material composition of finished products by category, type and weight, supporting circularity and end-of-life recyclability disclosure requirements (p.118). Marketed (non-own-brand) products, a minority of the portfolio, are excluded from these calculations.

Product durability is not currently measured for repairability directly, but "based on statistics and industry studies, the Group can state that its products have an average life span exceeding twelve years" (p.118). For the Cooking BU, expected durability is reported at 12 years, matching the stated average industry durability (100% performance versus industry) (p.118).

Waste

Reference: page 119.

"For FY 2025, Elica reports that approximately 11,621 tonnes of total waste was generated from its operations, of which approximately 61 tonnes was hazardous waste and 11,559 tonnes was non-hazardous waste." Of total waste, "11,314 tonnes (97.4%) were directed to recovery while about 307 tonnes (2.6%) were directed to disposal." Non-recycled waste totals 5,517 tonnes (47.48%); "the Group does not produce radioactive waste" (p.119).

Waste mainly derives from "ferrous or other metal scrap related to moulding works, mechanical blanking or laser cutting, die-casting swarf or residues; mixed packaging ...; and electrical and electronic components discarded during production processes" (p.119).

Own workforce policies

Reference: page 127.

Elica applies a "human rights due diligence procedure aimed at identifying, preventing, and addressing any risks along the entire value chain," aligned with the UN Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines (p.127).

The policy framework includes an Ethics Code and Privacy General Principles, and "applies to all employees, consultants, suppliers and commercial partners" (p.127). A Human Rights Due Diligence Procedure and Group Policy - Human Rights Policy were approved by the Board on February 13, 2025 (p.127).

Engagement with own workforce

Reference: page 128.

"For the moment, the Elica Group has decided not to adopt a formal process for engaging its own workers and worker representatives as stakeholders, but to use initiatives and opportunities for direct engagement of workers, through internal communication channels and Group initiatives" (p.128), including activities with the Ermanno Casoli Foundation (FEC).

Remediation channels

Reference: pages 127-128.

The Group's Ethics Code, Organisational Model (Legislative Decree No. 231/01) and Whistleblowing Policy provide the framework. "The Elica reporting system, which is available to employees on the company intranet, guarantees confidentiality and protection from retaliation for anyone reporting any violations" (p.128), with continuous monitoring of channel effectiveness. Further detail is cross-referenced to G1-1.

Actions on own-workforce impacts

Reference: pages 129-130.

2025 actions targeted work-related injuries: "continuous investments in safety training programmes for all employees, periodic updating of Personal Protective Equipment (PPE), improvements to monitoring systems, and certifications at production facilities," plus internal/external H&S audits and extraordinary infrastructure maintenance (p.130).

"The double materiality assessment carried out identified no actual negative impacts on the Company's own workforce; the actual impacts identified are exclusively positive in nature," citing gender-pay equity and adherence to ILO principles against forced/child labour (p.130).

Own-workforce targets

Reference: pages 128-129.

Target: a 50% decrease in the Injury Frequency Index (FI), excluding "on-commute" injuries, to an absolute value of ≤0.55, against an FY24 baseline Group FI of 1.10, over 2024-2027, linked to the Ethics Code and Human Rights Policy (p.129). "The decrease in the Group Frequency Index (FI) was monitored ... and showed a positive trend towards the 50% reduction target" (p.129).

Employee characteristics

Reference: pages 130-131.

At December 31, 2025 the Group had 2,434 employees (excluding 140 interns/trainees), of whom approximately 48% are women (p.130). The workforce spans more than ten countries across two Business Units. 268 temporary contracts were in place in 2025 (164 women, 104 men); 2,166 permanent contracts (996 women, 1,170 men) (p.131). The Group-wide turnover rate is 27% (p.131).

Collective bargaining coverage

Reference: page 136.

"59% of employees are covered by collective bargaining agreements, in line with the previous year's figure. Employees not covered by collective bargaining are granted the conditions provided for by locally applicable legislation" (p.136). Precisely: 1,430 of 2,434 employees (58.75%) in 2025, versus 1,467 of 2,459 (59.66%) in 2024.

Coverage by employee representatives is 87% Group-wide (p.136). Applicable Italian agreements: "Metal Mechanical Industry" (blue/white-collar/managers) and "Industry Executives" (top managers) (p.136).

Diversity metrics

Reference: page 137.

At December 31, 2025 the Group had 2,434 employees (excluding 140 interns/trainees), approximately 48% women (p.137). By category (2025 headcount): Top Manager 34 (7 women, 27 men); Manager 80 (23 women, 57 men); White Collar 672 (281 women, 391 men); Blue Collar 1,648 (849 women, 799 men) (p.137).

Adequate wages

Reference: page 140.

"Elica defines the remuneration of its workforce in accordance with the reference parameters applicable in the various countries in which it operates." In Italy, wages follow national collective bargaining agreements (CCNL); in EU countries without collective bargaining, minimum-salary legislation and Eurostat benchmarking apply; in non-EU countries, wages follow local legislation and local-standard adequacy checks (p.140).

Health and safety metrics

Reference: page 141.

"The following table reports metrics relating to health and safety within the Elica Group ... reflecting the Group's commitment to guaranteeing a safe and healthy work environment for all employees. For metrics regarding non-employees, the Company has chosen to adhere to the phase-in as prescribed by Appendix C of ESRS1" (p.141) - so the core employee data is reported, with a stated, scoped phase-in only for the non-employee-worker portion.

"The Frequency Index (FI) figure for work-related injuries (excluding commuting injuries) shows a slight increase (+2.1%), essentially due to the reduction in the total number of hours worked, as the number of injuries that occurred in 2025 (5) shows no change in relation to the 2024 figure" (p.141). The Severity Index reflects two injuries at two Italian sites causing absence days.

Remuneration metrics

Reference: page 141.

"For 2025, the male-female gender pay gap reported by the Group is 28%, calculated using the standard methodology, down from 2024." The report notes the methodology "groups Blue Collar, White Collar, Managers and Executives who operate in completely different regions of the world" and does not control for role weighting, local wage levels or exchange rates (p.141).

Total annual pay ratio: highest-paid individual's annual remuneration €1,268,032 versus median employee compensation (excluding the highest-paid individual) of €20,435, giving an annual pay ratio of 62 in 2025 (down from 70 in 2024) (p.141).

Incidents and complaints

Reference: page 141.

"For the reporting period, the Group declares that no work-related accidents, episodes of discrimination, harassment or other severe human rights impacts on the workforce occurred. Furthermore, no complaints, fines, sanctions or compensation for damages were recorded regarding such issues" (p.141).

One exception is disclosed: "a report was received through the dedicated portal regarding non-compliance with an internal procedure at the Elicamex plant. The incident, which was minor and limited in scope, led to the immediate activation of the internal processes provided for under current policies and procedures" (p.141).

Value chain worker policies

Reference: pages 144-145.

Policies covering value chain workers - Ethics Code, Human Rights Policy and Supplier Code of Conduct - "establish guidelines to ensure compliance with workers' rights and promote ethical corporate practices" and apply to "all actors in the value chain, including suppliers and their workers" (p.145), referencing UN Guiding Principles, ILO Declaration and OECD Guidelines.

"Value chain workers" are defined as suppliers'/subcontractors' workers, downstream (distribution, logistics, after-sales) workers, and joint-venture/vehicle-company workers, with attention to particularly vulnerable groups (migrant workers, trade unionists, women, young people, remote workers) (p.144).

Engagement with value chain workers

Reference: page 145.

"To date the Group has not adopted a structured process for engaging with these stakeholders, but as part of future initiatives, it plans to increase opportunities and occasions for engagement" (p.145). Upstream, Elica engages with supplier workforces through periodic audits and direct dialogue; downstream, through direct communication with customer and distributor unions on working conditions (pp.144-145).

Remediation channels for value chain workers

Reference: page 145.

"Currently, Elica does not have a dedicated reporting channel exclusively for value chain workers to express concerns. However, the Group has established a public whistleblowing channel, accessible to everyone involved in its business activities," and "undertakes to ensure that value chain workers are adequately informed about this channel" (p.145). Further detail is cross-referenced to G1-1.

Actions on value-chain-worker impacts

Reference: pages 146-147.

Elica operates an "ESG Supplier Audit programme, which uses surveys and on-site visits to monitor and promote improvements in environmental, social and governance (ESG) standards along the supply chain" (p.146).

"The double materiality assessment carried out identified no current negative impacts and no actual or potential positive impacts and relevant opportunities; potential impacts and risks identified are managed through preventive and control measures" (p.146). "In the reporting year, there were no reports of incidents of human rights violations" (p.147).

Value-chain-worker targets

Reference: page 146.

2024-2027 targets, against an FY2024 baseline: Supplier Code of Conduct signed by over 90% of suppliers (baseline 78%); more than 70% of suppliers surveyed (baseline 49%); more than 20% of suppliers underwent ESG audits (baseline 9%) (p.146), linked to the Supplier Code of Conduct and Human Rights Policy.

"At present, in 2025 progress is in line with planning, although further work is required in audit stages and in the involvement of suppliers" (p.146).

Consumer/end-user policies

Reference: page 150.

"The Group has established specific policies to manage impacts on end-consumers and guarantee transparency, safety, and the protection of fundamental rights." The Ethics Code and Policy on Security Measures for the Protection of Personal Data are the main instruments, aligned with UN Guiding Principles, ILO Declaration and OECD Guidelines (p.150).

Engagement with consumers and end-users

Reference: page 150.

"The Group has not yet adopted a structured consumer/end-user engagement process, but as part of future initiatives, it plans to increase the occasions and opportunities for consumer/end-user engagement," through corporate communication channels and Group initiatives (p.150).

Remediation channels for consumers/end-users

Reference: page 150.

Elica has "a dedicated reporting channel in accordance with the provisions of the current legislation on whistleblowing (Legislative Decree No. 24/2023)" (p.150). B2B customers can also contact the Sales Department directly; end-users have "a freephone number ... provided ... indicated in the documentation accompanying the product," with reports tracked by ticket (p.150).

Actions on consumer/end-user impacts

Reference: page 151.

"The Group has not yet formalised an action plan to address impacts, manage material risks, and pursue material opportunities regarding consumers and end-users," attributed to an "ongoing development phase." In the meantime, Elica states it is "committed to guaranteeing high quality and safety standards for all its products, and the protection of all data entrusted to it" (p.151).

Consumer/end-user targets

Reference: page 151.

"Elica has not yet set specific, measurable targets as per the Minimum Disclosure Requirements introduced by the CSRD in relation to the material aspects identified in the Double Materiality Assessment." The Group states it "is working to structure, consolidate and develop its sustainability pathway, with the aim of defining monitorable targets in the near future" (p.151).

Business conduct policies

Reference: pages 154-155.

Core policies: the Ethics Code (behavioural guidelines for employees and collaborators); the Group Anti-corruption Policy, "updated in early 2025," aimed at "rais[ing] employee awareness, ensur[ing] transparency in supplier and partner relationships, and promot[ing] fair payment practices"; and the Group Whistleblowing Policy (p.154).

Reports received through the external whistleblowing portal "are processed rigorously by means of structured management involving designated internal functions to ensure that they are investigated independently and effectively," with protection against retaliation under Legislative Decree No. 24/2023 (p.155).

Supplier relationship management

Reference: pages 156-157.

"The Group has not adopted an official policy on late payments. However, Elica adopts well-established operating practices to ensure accurate compliance with payment terms," using the M-F06-SAF form to record agreed terms, with payments processed biweekly through the ERP system (p.156).

Supplier approval follows a structured process: self-assessment questionnaires ("Early Approval"), an ESG Survey used by the Quality and Sustainability Manager to set a risk index, and on-site audits; "suppliers who do not meet the minimum requirements are not permitted to conduct business with Elica" (p.157). "Elica has not identified vulnerable suppliers, as attested in internal audit reports that include specific checks on social and environmental risks" (p.156).

Anti-corruption

Reference: pages 157-159.

The Group Anti-Corruption Policy, drafted by Legal & Corporate Affairs and approved by the CEO, sits alongside the 231 Organisational Model covering Elica S.p.A., EMC FIME S.r.l. and Air Force S.p.A. (p.158). Named at-risk activity categories include relations with public administration, gifts/hospitality, facilitating payments, political/union relations, contract awards, M&A, recruitment and accounting records (p.158).

Training: "100% of risk functions [received] training" in 2025 (versus none recorded in 2024) (p.159), including a mandatory February 2025 session on the 231 Model, whistleblowing and anti-corruption delivered at Elica's headquarters.

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed via MDR-T-style effectiveness tracking rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS; this report is prepared under the 2023 ESRS.

Elica discloses no stated, quantified business-conduct target. Consistent with MDR-T's other limb, effectiveness is tracked in the absence of one: the Group reports that 100% of risk functions received anti-corruption training in 2025 (up from a 2024 baseline not separately stated) (p.159), that training completion "are constantly monitored, and the results are reported to the Supervisory Board to assess their effectiveness and level of compliance" (p.155), and that the Internal Audit & Risk Compliance function conducts operational, financial and compliance audits across Group scopes, escalating potential irregularities to legal counsel (p.158).

Elica also states: "Elica continues to monitor the effectiveness of these procedures, making regular updates and revisions to continuously improve their transparency and efficiency" (p.155, whistleblowing-channel effectiveness).

Confirmed incidents

Reference: page 160.

"In terms of processes and Group companies subjected to corruption risk assessment, companies that have adopted the 231 Model and/or conducted audits - even if only qualitative - on the subject are considered assessed ... No incidents were detected, nor were any fines received during 2025" (p.160).

Payment practices

Reference: page 160.

"The Group does not have a formal policy on late payments, but has established clear and well-defined procedures for managing transactions with suppliers," differentiating large enterprises (turnover >€500,000) from small enterprises, with payment terms agreed and recorded in the management system (p.160).

2025 performance: approximately 49% of payments (by value) to large-enterprise suppliers, and 48% to small-enterprise suppliers, met the standard contractual/legal payment terms (p.160). "No judicial proceedings are currently pending due to late payments for the reporting year 2025" (p.160). The analysis covered Elica S.p.A., EMC, AirForce, Elica Group Polska, Elicamex, Elica France and Elica GmbH (p.160).