Elkem ASA

The role of the administrative, management and supervisory bodies

Reference: page 79.

Environmental, social and governance (ESG) considerations "are embedded in Elkem's overarching business strategy and are collectively overseen by the board of directors." ESG-related risks and opportunities are regularly on the board's meeting agenda, and "several board members have industry experience, and are familiar with relevant sustainability challenges."

Each year the board conducts a strategic process that includes "a comprehensive evaluation of the group's ESG strategy," with detailed ESG performance updates presented at board meetings. The audit committee prepares the board for oversight of sustainability and non-financial reporting: reviewing internal controls, monitoring sustainability-related risk management, and tracking performance in external sustainability ratings. The board also performs an annual self-assessment of its performance, competence and effectiveness, including alignment with regulatory requirements.

Management oversight: the CEO holds overall operational responsibility for ESG and sustainability under board oversight. Day-to-day management is led by the CFO, who chairs the ESG steering committee, a management body drawn from corporate leadership with specific ESG responsibilities that meets quarterly to review progress and propose actions. The ESG office coordinates ESG efforts across the organisation, reporting to the steering committee.

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

Reference: pages 79-80.

The board "approves the group's business strategy and corporate governance policy, establishing the framework for strategic direction and oversight." Within this framework the ESG steering committee "meets quarterly to review progress, discuss key issues, and propose actions aligned with the strategy," and "monitors the development of key performance indicators (KPIs) and recommends strategic adjustments to the board when necessary."

Implementation of the ESG strategy sits with Elkem's business units and divisions. The steering committee includes senior management and "invites subject-matter experts to contribute to discussions and decisions on critical ESG topics." The ESG office, reporting to the steering committee, "works closely with business units and divisions to advise on sustainability issues, set targets, and drive continuous improvement," under the Elkem Business System (EBS) principle that "what gets measured gets managed."

Group management is separately assessed on ESG-related target achievement as part of incentive remuneration (see GOV-3).

Integration of sustainability-related performance in incentive schemes

Reference: page 80.

The CEO and group management receive performance-based compensation linked to predefined metrics aligned with their areas of responsibility. Short-term incentives (STI) "are capped at 100 per cent of the CEO's base salary and 50 per cent for other members of corporate management."

"Group management is assessed on progress and achievement of ESG-related targets, including the transition plan approved by the board. This progress is validated through performance on selected ESG ratings" (Carbon Disclosure Project scoring, S&P Corporate Sustainability Assessment, and EcoVadis). "ESG-related target achievement accounts for 1.5 per cent of the variable bonus for group management."

For 2025, corporate management's bonus structure "aligns with the CEO's metrics, including compliance and sustainability," with additional criteria on completion of compliance training to strengthen compliance culture and reduce the risk of substantiated misconduct cases.

Statement on due diligence

Reference: pages 83-84.

Elkem's due diligence process "is aligned with the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights," following the OECD Due Diligence Guidance for Responsible Business Conduct. It "aims to address and prevent adverse impacts related to labour rights, human rights, environmental issues, bribery, corruption, and corporate governance."

Due diligence is carried out for all new business ventures (mergers, acquisitions, joint ventures) and is "particularly emphasised when engaging with business partners, including suppliers, agents, customers, and resellers," following OECD-recommended steps. The same principles are integrated into Elkem's own operations and projects, including "comprehensive assessments of environmental and social impacts across all projects and operations."

Elkem states it has conducted "a group-wide double materiality assessment, a human rights risk assessment with an accompanying action plan, and a biodiversity risk assessment," with work ongoing to develop a biodiversity action plan. A six-step ESG due diligence cycle is illustrated (page 84): embed policies, identify and assess adverse impacts, cease/prevent/mitigate, provide or cooperate in remediation, track implementation, and communicate how impacts are addressed.

Risk management and internal controls over sustainability reporting

Reference: pages 84-85.

Management conducts an "annual enterprise risk evaluation comprising the Elkem group," based on interviews with divisions and corporate staff functions, assessing estimated financial impact, likelihood and mitigation activities. Risks are grouped into five categories -- strategic, financial, raw material, production and process, and market and product -- with ESG and climate-related risks integrated across these categories. Elkem follows "IFRS S2 (previously... TCFD)) and CSRD recommendations for climate risk reporting," reviewed and updated annually; biodiversity risks are assessed at regular intervals and monitored continuously at mining sites.

The audit committee ensures effective procedures and internal controls for sustainability and non-financial reporting, and the board conducts annual assessments of its own performance and competence.

Internal control over sustainability topics "is embedded in line management." The corporate internal control function supports management and the internal control and internal audit committee on the design of internal controls, "described and deployed through group governing documents," with its instructions formalised in Appendix K of the Governance policy. The ESG steering committee is described as "a key component in Elkem's internal control on sustainability related topics as the committee will address deviance from targets and policies," with its mandate formalised in Appendix J of the Governance policy.

Strategy, business model and value chain

Reference: pages 85, 87-90.

Elkem's strategy "is founded on dual-play growth and green leadership," targeting five per cent annual growth, a 25 per cent reduction in scope 1 and 2 CO2 emissions by 2030, a 15 per cent EBITDA margin annually, and net zero emissions by 2050, across its three divisions: Silicones, Silicon Products and Carbon Solutions.

Strategic review: "In January 2025, Elkem announced a strategic review of the Silicones division. At 13 February 2026, Elkem announced an agreement to sell the majority of its Silicones division to Bluestar," approved by the extraordinary general meeting on 9 March 2026 and expected to close by May 2026. "A potential full review of Elkem's material assessment, climate strategy, and transition plan is contingent upon completion of the transaction."

Value chain (pages 87-89): raw material sourcing (quartz, coal, wood), production (silicon, silicones, carbon solutions), specialisation for renewable energy, electronics, automotive and construction, and an integrated value chain from extraction to finished goods. Key positive impacts include production in renewable-energy-rich regions and products that enable the green transition; key negative impacts include emissions from reductant use, transportation, and hazardous operations. End markets span automotive, construction, electronics, health care, aluminium, ferroalloys and solar/wind turbines.

Interests and views of stakeholders

Reference: pages 86, 153.

"Engaging with stakeholders is essential for Elkem to understand expectations, identify key issues, and assess potential impacts." Through regular dialogue Elkem addresses social, health, safety, environmental and economic concerns, "ensuring that stakeholder perspectives inform action plans and are integrated into sustainability reporting."

Key stakeholders span employee unions, works councils, local communities, NGOs, suppliers, business partners, customers, industry associations, sustainability experts, authorities, banks and investors. Engagement occurs "at both corporate and business levels through local meetings, bilateral discussions, multi-stakeholder forums, and participation in industry associations," and "all business areas maintain structured forums for dialogue between management and employee representatives." Insights from these interactions "play a critical role in shaping Elkem's double materiality analysis and guiding the group's overall strategy."

Specific mechanisms include biannual meetings with Sámi reindeer districts near mining operations, ongoing dialogue with policymakers through Norsk Industri and Eurometaux, and participation in Prosess21 workshops. In 2025 Elkem received two cases through its grievance mechanism, both related to suppliers dissatisfied with commercial conditions; "all cases were investigated, and no further action was deemed necessary."​

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

Reference: pages 91-93 (double materiality assessment); per-topic detail throughout E1-G1.

Elkem's double materiality assessment (DMA) evaluates both impact materiality (effects on environment and society) and financial materiality (sustainability factors affecting the business). The 2025 process began with an inside-out impact assessment, paired with an outside-in financial assessment; "given the complexity of measuring sustainability-related risks, this year's efforts focused primarily on impact materiality," with stakeholder input obtained via a light update of the former materiality approach used as a proxy for external stakeholder views.

"The results, aggregated by ESRS topic, indicate that all main topics, apart from consumers and end-users (S4), are material to Elkem. As Elkem only sells business-to-business, it has little direct impact on consumers." Environmental risks and impacts in E1, E2 and E3 are described as "especially important," given significant emissions, energy and water use. Own workforce (S1), particularly HSE, ranks lower on financial materiality but "is still a key topic for Elkem," reflecting a pattern the company notes across several topics where outside-in financial impact is limited but risk and importance remain high.

The material IROs by topic are set out in the dedicated chapters (ESRS E1-E5, S1-S3, G1), which also describe how the IROs shape Elkem's actions, investments and business-model integration.

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

Reference: pages 91-92.

"All assessed impacts and risks have been aligned with the relevant topical ESRS standards." Elkem assessed whether topics carry an actual or potential impact, the affected stakeholder, time horizon, irremediability, scale, scope and likelihood, producing an impact score; "a similar approach" was applied to positive impacts. For opportunities, Elkem mapped the topic, source of opportunity, time horizon, financial impact and likelihood. The value chain was assessed "where required, or we have deemed it prudent."

The process is illustrated as a double materiality matrix plotting impact materiality (inside-out) against financial materiality (outside-in), placing pollution and climate change highest on both axes, and consumers and end-users lowest.

The topical chapters (E1-E5, S1-S3, G1) each repeat topic-specific IRO-1/SBM-3 sub-sections describing the assessed impacts, risks and opportunities in more detail, including per-topic impact tables classifying each row as actual/potential, material, financially material, positive/negative, an impact score, time frame, and location in own operations (OO) or value chain (VC).

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

Reference: pages 93-94; full content index at pages 163-166 ("ESRS Index of material disclosures").

Elkem's sustainability statement covers ESRS 2, E1 (Climate change, pp.103-113), E2 (Pollution, pp.114-117), E3 (Water and marine resources, pp.118-121), E4 (Biodiversity and ecosystems, pp.122-126), E5 (Resource use and circular economy, pp.128-132), S1 (Own workforce, pp.135-145), S2 (Workers in the value chain, pp.146-151), S3 (Affected communities, pp.152-163) and G1 (Business conduct, pp.159-163).

Topic assessed and found not material: "ESRS S4 is omitted and assessed as not material to Elkem. Elkem sells its goods to other companies who in turn produce consumer goods. Thus, we have deemed our direct impact on consumers and end-users as non-existent, and our possibility to affect our indirect impact as very limited. This means that the associated risks and opportunities are also limited."

Elkem states: "All policies, actions, metrics and targets relevant to the different topics are described in the different sections covering ESRS 2 (policies): E1, E2, E3, E4, E5, S1, S2, S3, and G1" (MDR-P, MDR-A, MDR-M, MDR-T, page 93). A detailed DR-by-DR content index with page references appears at pages 163-166.

Transition plan for climate change mitigation

Reference: page 108; roadmap graphic and pillars pp.107-109.

Elkem's climate roadmap "is aligned with the Paris Climate Agreement goal of limiting global warming to well below 2°C." The group targets a 25 per cent reduction in scope 1 and 2 emissions by 2030 compared to 2022 (approximately 840,000 tonnes CO2e), a 32 per cent reduction in the carbon intensity of main products over the same period, and net zero by 2050. Key decarbonisation levers: transitioning to biomass in smelting, reducing supply-chain emissions, increasing renewable energy use in China, and deploying carbon capture and storage (CCS).

"From 2022 to 2025, scope 1 emissions were reduced by 19 per cent (460,000 tonnes CO2e), while scope 2 emissions increased by 11 per cent (110,000 tonnes CO2e) due to higher production, and outsourcing of steam production, at our Xinghuo plant." The roadmap's three pillars are reducing fossil CO2 emissions, supplying materials for the green transition, and enabling circular economies.

The carbon-intensity target covers scope 1, 2 and upstream scope 3 for two product categories (silicones/siloxane and tapped silicon/ferrosilicon), representing 93 per cent of 2022 operating income; product group carbon footprint (PGCF) was 9 kg CO2e/kg product in 2025. "Elkem was planning to launch an absolute scope 3 target in 2025, but this has been postponed due to the strategic review" of the Silicones division. No significant CapEx/OpEx has been separately allocated to the plan beyond the actions and spending described under E1-3.

Identification of climate-related risks and scenario analysis

Back-filled from the ESRS 2 SBM-3/IRO-1 climate sub-sections in the E1 chapter (pages 106-107), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Physical climate risks "have been systematically assessed since Elkem's first TCFD report in 2021, with regular updates informed by research and tools such as the World Bank Group's Climate Change Knowledge Portal." As TCFD has been disbanded, Elkem "now looks to CSRD and IFRS S2 to guide climate risk related disclosure."

Elkem maps physical climate risk under both a low-emission and a high-emission scenario, scoring country/site combinations (Norway, Canada, Netherlands, USA, China, Brazil, France, Iceland) as low, low-medium, medium or medium-high risk, excluding sea-level rise, storm surge and river flood metrics, which are assessed on a location-specific basis. "Long-term planning incorporates hypothetical scenarios, including 2°C and 4°C global warming pathways. Elkem is looking to further develop the scenario analysis using ArcGIS."

The annual 2025 review "revealed no changes in temperature and precipitation patterns, or in the frequency and severity of extreme weather events that warrants investments or changes to site infrastructure." Water access is flagged as a specific physical risk in France and Brazil, with water-stressed sites identified using the WRI Aqueduct tool (see E3).

Resilience in relation to climate change

Back-filled from the E1 chapter's physical-risk review and the E1-9 financial-effects statement (pages 107, 113), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Elkem's annual physical climate risk review "revealed no changes in temperature and precipitation patterns, or in the frequency and severity of extreme weather events that warrants investments or changes to site infrastructure" (page 107). Consistent with this, under E1-9: "None of Elkem's assets are currently considered exposed to material physical climate risks, and no site improvements or operational changes have been required to address such risks."

Water access is identified as the main site-level physical vulnerability: in France, "prolonged dry periods have prompted government directives allowing restrictions on industrial water withdrawal, though Elkem's site has not yet been affected," and in Brazil "drought-related water scarcity remains a concern," with the company "actively assessing measures to ensure operational resilience" (page 107).

The transition plan's decarbonisation levers and adaptation actions (preventive maintenance, flood prevention at the Danish-equivalent water-stressed sites, dual sourcing) are described under E1-1/E1-3. The report does not describe a separate ESRS-defined resilience analysis distinct from this physical-risk review.

Policies related to climate change mitigation and adaptation

Reference: page 81 (governing documents); cross-referenced at page 109.

"Elkem's policies address climate mitigation through GHG emissions reduction, adaptation to climate impacts, and promoting energy efficiency and renewable energy. The group's emissions reduction policy emphasises replacing fossil-based reduction materials with biocarbon. Additionally, policies support circular economy, aligning with EU critical raw material priorities for products like silicon."

Climate-related commitments sit within the group's Global governing documents described under ESRS 2 (page 81 onward): the Governance policy and Code of conduct set overarching principles, and Elkem states it does not have a single dedicated climate policy separate from these governing documents and its Health, Safety and Environment (HSE) principles, which include "Elkem's 'zero-harm philosophy'" and goals "aligned with the Paris Climate Agreement to achieve net zero emissions by 2050."

"Our climate transition plan includes an evaluation of the most efficient decarbonization levers to reduce GHG emissions, priorities, timelines and targets" (cross-referenced from E1-1, page 109).

Actions and resources in relation to climate policies

Reference: pages 109-110.

Elkem is "actively implementing initiatives to improve energy efficiency and reduce its environmental footprint," including replacing outdated electrical motors with high-efficiency, variable-frequency-drive models, and transitioning the Xinghuo site from coal boilers to cogeneration.

Elkem Sicalo®: a carbon-looping project aiming for a CO2-free silicon production process by 2050, run with SINTEF and supported by the Research Council of Norway and the EU. "In 2025, Elkem invested NOK 14.7 million in Sicalo and received NOK 15.4 million in government grants," alongside NOK 15.2 million total spend on other GHG-reduction research.

Mo i Rana CCS study: in Q2 2025, Elkem completed a FEL2 concept study with Ferroglobe on energy recovery and carbon capture, targeting 412 kilotonnes of CO2 captured per annum; "the project is technically feasible, though the economic feasibility is dependent on frame conditions, which today are not in place."

Biocarbon transition: targeting a 50 per cent biocarbon share in smelting by 2031, including new sawmill-residue sourcing in Canada, certified under FSC/SFI/SVLK/PEFC; "operating expenses related to the transition from fossil to biocarbon reductants have amounted to NOK 3,275 million over the past four years." The biogenic share of emissions was 21 per cent in 2025. A separate NOK 33 million Innovation Norway grant funds a circular-economy pilot at the Fiskaa site (cement alternative from by-products, repurposed solar-panel silicon, slag-to-construction-material recycling).

Targets for climate change mitigation and adaptation

Reference: page 110.

"Elkem's climate targets address both absolute greenhouse gas emissions and the carbon intensity of its main products. By 2030, the group aims to reduce scope 1 and 2 emissions by 25 per cent compared to 2022 levels and achieve a 32 per cent reduction in the carbon intensity of its core product portfolio." An absolute scope 3 target planned for 2025 "has been postponed due to the strategic review" of the Silicones division.

Methodology (pages 108-109, tagged in the report as part of the target-setting narrative): targets are defined "using methodologies aligned with the GHG Protocol Corporate Accounting and Reporting Standard and the GHG Protocol Scope 2 Guidance," covering scope 1 and 2 with product-level carbon-intensity metrics reflecting material scope 3 emissions; scope 2 is calculated location-based. Key assumptions include "stable organisational and operational boundaries, the use of recognised emission factors, and recalculations only in the event of material structural or methodological changes."

Scientific basis: Elkem states its targets "are designed to be consistent with climate science and the objectives of the Paris Climate Agreement, aiming to limit global temperature increase to well below 2°C," reflecting "de-carbonisation pathways that are consistent with science-based transition trajectories for energy-intensive industries." The report does not describe third-party (e.g. SBTi) validation of these targets.

Energy consumption and mix

Reference: pages 110-111.

"Elkem's total energy consumption in 2025 amounted to 7,121 GWh, with the majority sourced from regions where renewable power is abundant. All smelting facilities, except one in China, operate on renewable electricity (Norway, Iceland, Canada, and Paraguay)."

2025 energy mix (scope 2 market-based): total fossil energy consumption 2,281 GWh (32% of total, unchanged from 2024); nuclear-sourced 104 GWh (1%); total renewable energy consumption 4,736 GWh (67%); share of renewable electricity in total electricity consumption 82%. Energy intensity based on net revenue was 0.00023 MWh/NOK (2024: 0.00022).

Energy recovery: "In 2025, Elkem recovered 928 GWh of energy from its facilities, up from 738 GWh in 2024," a 26 per cent year-on-year increase, generated via district heating, process steam and electricity from waste heat since the 1970s. The Mo i Rana FEL2 study (see E1-3) would add further recovery and carbon capture capacity.

Fuel-level detail (2025, GWh): crude oil/petroleum 84; natural gas 415; purchased fossil electricity/heat/steam/cooling 4,780; other fossil sources 886; purchased renewable electricity/heat/steam/cooling 955; self-generated non-fuel renewable ~0.

Gross scopes 1, 2, and 3 and total GHG emissions

Reference: pages 111-112.

"Scope 1 emissions, primarily from smelting operations, accounted for approximately 90 per cent of Elkem's direct emissions in 2025." Scope 2 uses location-specific emission factors (notably for China); scope 3 has been reported since 2021 across purchased goods and services, transportation, and end-of-life treatment.

Gross emissions (million tonnes CO2e), 2025 vs 2022 base year:

• Scope 1: 1.96 (2024: 2.03; 2023: 2.21; 2022 base: 2.42) — down 19%, "driven by the decommissioning of the Xinghuo coal fired boilers in 2023 and reduced activity at some smelters"
• Scope 2 location-based: 1.05 (2022: 0.94) — up 11%, "driven by the start of the Xinghuo external cogen plant"
• Scope 2 market-based: 3.19 (2022: 2.64) — up 21%
• Scope 3: 8.93 (2022: 7.38) — up 21%; scope 3 biogenic CO2 uptake/removals of 0.47 Mt disclosed for the first time in 2025
• Total (location-based): 11.94 Mt (2022: 10.74, +11%); Total (market-based): 14.55 Mt (2022: 12.44, +13%)

Product Group Carbon Footprint: 9.0 kg CO2e/kg product (2022 base: 6.9). GHG intensity per net revenue (market-based): 0.00047 tCO2e/NOK (2022: 0.00027). Biogenic CO2 share of total scope 1 emissions was 21 per cent in 2025 (2022 base: 20%).

GHG removals and carbon credits

Reference: page 113.

"While Elkem's core strategy focuses on reducing emissions at source, the group also assesses opportunities related to carbon credits and greenhouse gas (GHG) removal projects. Current initiatives include advancing research on carbon capture and storage (CCS), and carbon capture and utilisation (CCU), for smelting operations and scaling up the use of sustainable biocarbon."

"All carbon credits adhere to recognised third-party verification standards to ensure credibility and transparency."

The report does not disclose a quantified volume of GHG removals or carbon credits used or planned for 2025; the disclosure is limited to the qualitative statement of approach above, cross-referenced to the CCS/CCU research described under E1-1 and E1-3 (the Mo i Rana FEL2 study and the Sicalo® carbon-looping project).

Internal carbon pricing

Reference: page 113.

"Elkem applies an internal carbon price to incorporate the true cost of emissions into decision-making. This mechanism is aligned with prevailing market prices, ensuring that our internal pricing reflects current market conditions and the real alternative cost of reducing carbon emissions."

"By using the market price, we leverage the collective insight of market participants rather than relying on the perspective of a single analyst, thereby ensuring a robust and credible approach to carbon valuation."

The report does not disclose the specific price applied (e.g. NOK or EUR per tonne CO2e), its scope of application across the group, or which decision types it is used in beyond this general statement of methodology.

Financial effects of climate-related risks and opportunities

Reference: page 113; transitional risk and opportunity tables pp.104-106.

"Climate-related risks, such as changes in energy policy, may affect Elkem's long-term financial position. At the same time, the growing demand for green materials creates significant opportunities for revenue growth." Elkem "expects cost savings through enhanced energy efficiency and increased reliance on renewable energy, while anticipating higher revenues from low-carbon products, including materials for electric vehicles and eco-designed silicones. Quantitative assessments of these financial impacts are ongoing."

"None of Elkem's assets are currently considered exposed to material physical climate risks, and no site improvements or operational changes have been required to address such risks."

Six named transition risks are assessed (regulatory ETS/CBAM exposure, EU taxonomy/product-substitution risk, rising cost of low-emission raw materials, power-price inflation from electrification, political/CO2-compensation-scheme uncertainty, and rising compliance cost from new regulation), each rated by probability, potential financial impact and time horizon, with named mitigations (increasing biocarbon share, CCS/CCU R&D, supplier relationships, industry-association advocacy). Four transition opportunities are assessed (EV/power-electronics materials, circular economy/recycling, renewable-power/electrification demand, and CCS siting in Norwegian industrial clusters), each also rated by probability and potential financial impact.

Policies related to pollution

Reference: page 81 (governing documents); cross-referenced page 115.

"The HSE principles in Elkem highlight our pollution strategy: 'Focus on hazard identification, risk analysis, action implementation through understanding and removing causes.'"

Pollution-related commitments sit within Elkem's group governing documents described under ESRS 2 (page 81), principally the Elkem HSE policy, which "outlines the group's commitment to maintaining a safe and healthy working environment while minimising environmental impact," including "specific commitments to sustainable practices, such as waste reduction, circular economy principles, and supply chain management," and the Code of conduct for business partners, which requires partners to "minimise environmental impact."

No pollution-specific standalone policy document beyond these governing documents is described.

Actions and resources related to pollution

Reference: page 115.

"Local air emissions are systematically monitored to ensure compliance with public permits. At applicable sites, 17 parameters related to air emissions are reported quarterly to the corporate HSE function." Site HSE managers collect and submit the data, reviewed by the corporate HSE team and escalated to the vice president HSE for oversight, "ensuring transparency and adherence to regulatory requirements."

Elkem maintains "strict compliance with chemical product regulations globally, covering registrations, authorisations, safety data sheets (SDS), and labelling," prepared under the UN Globally Harmonised System (GHS). "With a portfolio of more than 4,000 products, regulatory and product compliance is a core priority."

For substances of very high concern (SVHC), "the group continuously monitors its product portfolio... Management plans are regularly reviewed to define risks and mitigation measures for each identified SVHC. Actions include substitution where feasible, phasing out substances posing unacceptable risks, or limiting exposure when substitution is not possible" (see E2-5).

Targets related to pollution

Reference: page 116.

Previous voluntary pollution targets (baseline year 2015) and 2025 progress:

• Dust: "Reduce dust by 30 per cent by 2025 from baseline year 2015 (1,970 metric tonnes). In 2025, Elkem's dust emissions is reduced by 55.4 per cent, and new targets will be considered after strategic review is concluded."
• SO2: "Reduce SO2 emissions by 3,000 tonnes from baseline year 2015 (7,392 metric tonnes). By 2025 we have reduced SO2 emissions by 21.2 per cent. The development is closely linked to the introduction of biocarbon reductants."
• NOX: "Elkem has reduced its NOX emissions by 22.1 per cent since the baseline year of 2015 (7,049 tonnes). New targets will be considered after strategic review is concluded."
• Water discharge: "Elkem has a target of full discharge permit compliance, meaning no significant spills to water."

"Elkem will develop new targets related to pollution in 2026." No SVHC-specific quantified target is stated beyond the qualitative substitution/phase-out approach described under E2-2/E2-5.

Pollution of air, water and soil

Reference: pages 114-117 (IRO table and metrics).

Emissions "originate primarily from the raw materials used and are subject to strict permitting and continuous monitoring. Pollutants such as heavy metals and polycyclic aromatic hydrocarbons (PAHs) are regulated under international and local frameworks." "Previous variations in emissions are primarily tied to production volume changes inherent to the process, influenced by raw material quality, process control, and investments in filtration or scrubber systems, all regulated by public permits. All production sites with emissions to air/water are ISO 14001 certified and subject to regularly third-party audits and control."

2025 pollutant metrics (tonnes unless noted), vs. 2024/2023:

• Dust to air: 878.0 (2024: 789.0; 2023: 1,012.0)
• SO2 to air: 5,822.0 (2024: 6,440.0; 2023: 6,700.0)
• NOX to air: 5,490.0 (2024: 5,460.0; 2023: 5,830.0)
• COD to water: 248.0 (2024: 238.0; 2023: 237.0)
• PAH to air: 960.0 kg (2024: 686.2 kg); PAH to water: 15.6 kg (2024: 35.5 kg)
• Nickel to water: 90.0 kg (2024: 43.3 kg); Copper to air: 162.0 kg; Copper to water: 207.3 kg (2024: 126.4 kg)
• Chrome to water: 156.4 kg (2024: 110.2 kg); Arsenic to air: 92.0 kg (2024: 65.2 kg); Arsenic to water: 15.7 kg (2024: 7.1 kg)

Ten distinct pollution impacts are identified in the E2 IRO table (mining tailings, hazardous-substance water pollution from carbon products, silicone-production effluent, SO2/NOX/dust emissions, acid rain, silicosis-type disease risk, mine-related air pollution affecting soil/biodiversity, PAH exposure downstream, and D4/D5/D6 soil and water contamination), all classified as material negative impacts.

Substances of concern and substances of very high concern

Reference: pages 116-117.

"A vital part of the European REACH regulation... is the identification and authorisation of substances of very high concern (SVHC). The European Chemicals Agency ECHA regularly updates its SVHC candidate list for authorisation."

Elkem has three main product areas where SVHC occur:

• Silicones: "D4, D5, and D6 are key intermediates (building blocks) in the production of silicones-based polymers," with "some other essential SVHC substances... used under strict conditions in a limited number of products."
• Silicon products and ferroalloys: made from natural raw materials (quartz, carbon, iron oxide) "which often contain trace amounts of heavy metals. Cadmium and lead are listed as SVHC, but their concentrations in Elkem's products are far below the generic threshold limit value of 0.1 per cent weight per weight and do not trigger regulatory action." The exception is Søderberg electrode paste (Carbon Solutions), exempted as an intermediate; "Elkem Carbon is successfully developing alternative products with new and safe binders."
• Carbon products: "High-temperature coal tar pitch (CAS no. 65996-93-2) is used as an intermediate in the production of Søderberg electrode paste. The pitch is transformed into coke in the following process." Elkem separately reports it "has successfully developed and tested a coal tar pitch-free solution called ELSEP® G electrode paste" (E5-2), since CTPht "is categorised as a substance of very high concern (SVHC) due to its carcinogenic and mutagenic properties."

Under E2-2, Elkem states: "No SVHCs listed on REACH Annex XIV are intentionally added to Elkem's silicon or ferroalloy products." Cyclic siloxanes (D4, D5, D6) are separately flagged as an E2/E4 biodiversity concern (accumulation in nature) and controlled via "spill prevention, process optimisation, R&D collaboration, and major investments in China to replace cyclic materials" (E3-4).

Policies related to water and marine resources

Reference: page 81 (governing documents); cross-referenced page 119.

"Elkem is committed to responsible consumption of water and marine resources. Water and marine resources-related policies focus on driving Elkem's overall consumption down, providing facilities that adhere to the UNICEF WASH principle and continuously making sure that no deviations occur in any of Elkem's sites globally. Furthermore, policies outline water maintenance and effective waste-water discharge to ensure that Elkem is always compliant with applicable effluent and discharge regulations wherever it operates."

"Elkem has outlined our commitments for sustainable water stewardship in our HSE and Elkem corporate policies," referring to the governing documents described under ESRS 2 (page 81). No standalone water policy document is described beyond the HSE policy and corporate policies.

Actions and resources related to water and marine resources

Reference: pages 119-120.

Elkem "monitors water withdrawal, consumption, and discharge to ensure responsible management and compliance with regulatory requirements." Most production units sit in water-abundant regions; a few sites in north-east China, South Africa and India are in water-stressed areas, where Elkem "applies water-saving measures, conducts systematic risk assessments, and limits withdrawals to minimise impact, and has reduced water consumption by 74 per cent over the last five years."

"All Elkem sites provide free potable water and sanitary facilities for employees and contractors, with showers and changing rooms available where required," adhering to the UNICEF WASH principle. Key enablers listed: substitution of raw materials, good housekeeping practices, new process/production technology, an advanced environmental-monitoring control programme, wastewater treatment/recycling/reuse, and transparency through CDP Water, where Elkem obtained an A score for 2025.

Targets related to water and marine resources

Reference: page 120.

Elkem follows SDG 6 (Clean water and sanitation) and SDG 12 (Sustainable consumption and production). Key targets:

• "Reduce water used per unit of produced silicones by 12 per cent by 2031 from baseline year 2020. Production of silicones accounts for 71 per cent of Elkem's total water consumption."
• "Reduce water consumption in areas at material water risk by 20 per cent from 2020 to 2031" (an internal Elkem KPI), targeting withdrawals at Roussillon, Saint-Fons and Xinghuo per tonne of silox produced.
• Full functioning WASH services at all facilities, and compliance with discharge-permit thresholds at all sites; "any non-compliance with these targets is treated as an HSE deviation, reported, and corrected in accordance with Elkem's internal procedures."

"In 2024, an increase in production capacity at site Xinghuo, without a corresponding increase in water withdrawals, shows Elkem's commitment to increasing water efficiency... The effect of this is evident in 2025."​

Water consumption

Reference: pages 120-121.

"Elkem's primary water consumption is linked to silicone production, representing 71 per cent of total withdrawals." Freshwater intensity for silicone production "decreased by 22 per cent in 2025 to 67.8 m3 per ton silox compared to the 2020 base year value of 87.3 m3 per ton silox, mainly driven by improved water efficiency in Xinghuo" -- described in the metrics table as a 74 per cent reduction against base year for the areas-at-water-risk target. Elkem "achieved a CDP Water Security score of A in 2025, maintaining the score from 2024."

Withdrawal (2025 vs 2024/2023), Megalitres: freshwater surface/rain/wetlands/rivers/lakes 43,859 (2024: 46,358; 2023: 39,385); groundwater (renewable) 2,948 (2024: 3,059); third-party sources 25,941 (2024: 28,064; 2023: 38,931).

Water withdrawals and discharges "are monitored and reported quarterly to corporate, using in-line meters or capacity-based calculations." Determination methods combine direct measurement (primary method, "accounts for the majority of reported data"), sampling with extrapolation, and best-estimate calculations. Critical discharges tracked: COD (reported under E2), silicone cyclics D4/D5/D6 (controlled via spill prevention and China process investment), and PAHs from coal-tar pitch (controlled via process control, water treatment and R&D on alternative binders). Water-stressed sites per the WRI Aqueduct tool: Carbon Ningxia, Ferroveld, Tianjin, Foundry Ningxia, Nagpur, Chakan, York, Santa-Perpetua and Shanghai.

Transition plan on biodiversity and ecosystems in strategy and business model

Reference: page 125.

"Industrial processes inherently affect biodiversity through emissions to air, water, and soil. Elkem complies with all applicable regulations and continuously implements measures to mitigate and reduce these impacts." Most production facilities sit near rivers, coastal regions or urban areas, "making stringent environmental safeguards essential," and Elkem "acknowledges the potential risk of incidents, such as fires or chemical spills," addressed through "strict pollution control and emergency response protocols."

"Elkem's approach is grounded in the mitigation hierarchy, prioritising avoidance and reduction of impacts, followed by restoration where feasible." While the business model is described as "generally resilient to biodiversity and ecosystem changes, given its limited dependence on vulnerable natural resources," Elkem states it "recognises its responsibility to minimise negative impacts and enhance positive contributions."

Elkem is "committed to achieving zero net loss of biodiversity in new projects, including mining operations," aligned with the EU Biodiversity Strategy for 2030 and Goal A of the Kunming-Montreal Global Biodiversity Framework (see E4-4). At present Elkem "does not engage in biodiversity offsets but focuses on preventive and restorative measures to minimise impacts."​

Policies related to biodiversity and ecosystems

Reference: page 81 (governing documents); cross-referenced page 125.

"Elkem has an HSE and sustainability policy covering biodiversity and ecosystem. For sourcing of biocarbon, a separate policy document is available," referring to the Corporate standard for sourcing of biocarbon, described under ESRS 2 governing documents as mandating "the use of legally established and sustainably managed wood sources," acceptable working conditions, zero tolerance for corruption, cooperation with NGOs and local authorities, regular audits, and adherence to international standards for traceability.

No further biodiversity-specific policy beyond the HSE/sustainability policy and the biocarbon sourcing standard is described.

Actions and resources related to biodiversity and ecosystems

Reference: page 125.

Three action areas are described: Mapping and risk assessment -- ArcGIS combined with IBAT data to map potential impacts from existing and future mining operations, with real-time updates on proximity to protected areas and key biodiversity areas (KBAs) and active dialogue with local stakeholders. Water efficiency improvements -- advanced water-handling systems at the Xinghuo plant in China to "reduce freshwater dependency and improve overall water efficiency, thereby mitigating physical climate risks and biodiversity impacts associated with water scarcity." Emission reduction and spill prevention -- aligned with the ESRS E2 chapter, "deploying advanced emission control technologies to reduce SO2, NOX, and dust emissions, implementing rigorous chemical safety protocols, and maintaining emergency preparedness plans," supported by continuous monitoring and maintenance.

Site-specific example: Elkem's agreement with reindeer grazing district 7 (Rákkonjárga) in Tana, Norway, "facilitates mining expansion while safeguarding biodiversity in one of the world's largest quartzite deposits" (page 124).

Targets related to biodiversity and ecosystems

Reference: page 126.

"Elkem is committed to achieving zero net loss of biodiversity in new projects, including mining operations. This ambition aligns with the EU Biodiversity Strategy for 2030, which focuses on preventing and restoring biodiversity loss, and with Goal A of the Kunming-Montreal Global Biodiversity Framework (GBF), aimed at halting biodiversity decline globally."

Strategic review and target setting: "Elkem is currently conducting a strategic review of its Silicones division... As part of this process, we have postponed setting additional biodiversity-related targets to ensure alignment with long-term business objectives and global frameworks. Once the review is complete, Elkem will update its biodiversity strategy and define clear, measurable targets that reflect both operational realities and stakeholder expectations."

The mitigation hierarchy (avoidance, minimisation, restoration/rehabilitation) is described as the foundation of the strategy pending those more specific targets, and Elkem states it "does not engage in biodiversity offsets but focuses on preventive and restorative measures."​

Impact metrics related to biodiversity and ecosystems

Reference: page 123 (proximity table); page 122 (site classification).

Elkem discloses the number of assets by proximity to protected areas (PA) and key biodiversity areas (KBA):

"If several protected areas (PA) or Key Biodiversity Areas (KBA) are present within a proximity category around a given asset or operation, they are counted as one. If a given PA or KBA are within proximity categories for several assets or operations, it is counted in for each of these assets or operations."

"While some sites are located near key biodiversity areas, none are within protected zones" is stated at a narrative level (page 122), while the table above records 3 assets inside a protected area and 0 inside a KBA; the two statements describe different metrics (protected areas vs. key biodiversity areas). Data are drawn from the Integrated Biodiversity Risk Assessment Tool (IBAT), expanded in 2023 to 5 km/15 km/50 km proximity bands.

Policies related to resource use and circular economy

Reference: page 81 (governing documents); cross-referenced page 128.

"Please refer to the section on governing documents under ESRS 2 for more details on our policies related to resource use and circular economy." Circularity is described as "one of Elkem's three core pillars in the green transition," implemented "through the Elkem Business System (EBS)," applying "a zero-waste philosophy that prioritises efficient resource use, minimisation of waste generation, and the reuse, recycling, or sale of residual materials."

The Governance policy and HSE policy (described under ESRS 2, page 81 onward) are the governing documents underpinning this approach; no standalone circular-economy policy document is described beyond these and the group's biocarbon sourcing standard (see E4-2).

Actions and resources related to resource use and circular economy

Reference: pages 129-131.

"All Elkem units are required to maintain an updated HSE management system that includes documented processes, risk assessments, applicable regulatory requirements, and controls demonstrating compliance," covering waste-related risks at site level.

Biocarbon: integrated into silicon and ferrosilicon production "to reduce reliance on fossil reductants," reducing SO2 emissions and, where certified, introducing circularity.

Packaging: big bags now contain "at least 30 per cent recycled polypropylene (rPP), cutting the carbon footprint by around 15 per cent annually," developed with Accon including a closed-loop recycling system; the DISH programme promotes pallet reuse and repair, repurposing "about 6,000 pallets annually" at Elkem Nagpur.

Product innovation: Sircle™ (launched 2025) is Elkem Silicones' trademark for circular silicone solutions, starting with in-house industrial waste. SILCOLEASE™ RE, a fully recycled solvent-free release-liner technology, achieves "a carbon footprint of just 1.1 kg CO2e per kg." BRIQSIL™ reuses fine materials from quartz/coal processing as a ferrosilicon substitute. Elkem Microsilica®, a by-product of silicon smelting, is used globally in concrete and construction. In August 2025 Elkem received a NOK 32.8 million Innovation Norway grant to develop green products from slag and silicon-material recycling; a coal-tar-pitch-free electrode paste (ELSEP® G) has been developed and tested (see E2-5).

Targets related to resource use and circular economy

Reference: page 131.

"By 2031, the group aims to achieve a 50 per cent biocarbon share at its smelters, ensuring that 100 per cent of the biocarbon used annually is sourced from verified, deforestation-free suppliers." For waste management, Elkem "targets a year-on-year reduction of 10 per cent in hazardous waste sent to landfill and waste to disposal, alongside a 10 per cent annual increase in waste recycled."

2025 progress: "Elkem achieved a 57 per cent reduction in hazardous waste to landfill compared to the previous year. The group increased the amount of waste recycled by 18 per cent, and while we saw a marginal decrease in hazardous waste recycled, 27 per cent of non-hazardous waste was recycled." Total waste generated in 2025 decreased overall. Certified biocarbon has been 100 per cent deforestation-free-sourced since 2022; in 2025, "94 per cent of the biocarbon was under certification schemes (FSC/PEFC/SFI/SVLK), while the remaining six per cent were followed up with regular audits including traceability checks."

"Reducing the carbon footprint per product remains a key objective... Specific product-level targets are under development."​

Resource inflows

Reference: page 132.

"Biocarbon as a reductant is a key tool for Elkem to reduce scope 1 emissions. By sourcing deforestation and conversion free biomass and using this as a reductant we reduce the need for fossil-based carbon reductants and reduce our emissions."

"In 2024, the biogene share of scope 1 emissions slipped to 19 per cent, from 20 per cent in 2023, due to shifts in production" (the E1-6 table separately shows the biogenic share recovering to 21 per cent in 2025). Certified, deforestation-free biocarbon sourcing has reached 100 per cent since 2022 (see E5-3).

The report does not disclose a total weight or breakdown of all material inflows (e.g. total quartz, coal, biocarbon and recycled-content tonnages) beyond this biocarbon/reductant framing; the disclosure is limited to the biogenic-reductant share metric above.

Resource outflows

Reference: pages 131-132.

"Elkem has a product line of about 4,000 products, and no metric currently exists for the number of products designed according to circular principles. However, most of our products are results of our three main product divisions, which implement circular principles. The results will be reflected in our product carbon footprint over time."

By-product and recycling volumes reported in the resource-use table (page 132) for 2025 vs. 2024: recycled waste 41,215 tonnes (2024: 34,788); by-products excl. Elkem Microsilica® sold to customers 105,888 tonnes (2024: 90,171); Elkem Microsilica® sold to customers 111,393 tonnes (2024: 111,689); total recycled waste incl. by-products and Microsilica® 258,497 tonnes (2024: 236,648), an increase of 9 per cent year on year.

Waste

Reference: pages 132-133 (resource-use and circular-economy metrics table).

Total waste generated: 343,724 tonnes in 2025 (2024: 348,243; 2023: 353,992; 2022: 462,745) -- a 1 per cent year-on-year decrease. "Changes in waste tonnages are linked principally to changes in business activity."

Non-recycled waste: 85,228 tonnes (2024: 111,595) -- down 24 per cent. Non-hazardous waste to landfill: 28,325 tonnes (2024: 53,407) -- down 47 per cent. Hazardous waste to landfill: 1,116 tonnes (2024: 2,617; 2023: 7,781) -- down 57 per cent. Non-hazardous waste to incineration: 2,025 tonnes (2024: 3,173) -- down 36 per cent. Hazardous waste to incineration: 53,761 tonnes (2024: 52,397) -- up 3 per cent.

Recycled waste: 41,215 tonnes (2024: 34,788) -- up 18 per cent, comprising non-hazardous waste recycled of 30,393 tonnes (2024: 23,860, up 27%) and hazardous waste recycled of 10,823 tonnes (2024: 10,928, down 1%). Including by-products and Elkem Microsilica® sold to customers, total recycled waste reached 258,497 tonnes (2024: 236,648), up 9 per cent.

Hazard classification is described per process line in the E5 IRO-1 narrative (page 128): carbon production waste is "largely reprocessed into new batches" with remainder sent to certified hazardous-waste treatment; silicon smelting waste streams are "mostly non-hazardous," with hazardous post-smelting material sent to certified disposal providers; silicone formulation generates "a substantial portion" of hazardous waste (acid water, solvents, hydrolysis by-products, sludge), treated on-site or via certified providers.

Policies related to own workforce

Reference: page 81 (governing documents); cross-referenced page 137.

"Topics related to our workforce are covered in our People policy, our HSE policy, our Code of conduct, and related procedures." The People policy "outlines the principles, objectives, and commitments related to the people processes within Elkem," aiming "to ensure standardised HR procedures across all business units," covering recruitment, competency development, employment terms, diversity, work-life balance, exits and data privacy, reviewed annually with amendments approved by the CEO.

The HSE policy "outlines the group's commitment to maintaining a safe and healthy working environment," including the "zero-harm philosophy" and the FORUS HSE system, and the Speak up policy sets out reporting channels for suspected Code of conduct violations, including anonymous options and protection against retaliation.

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

Reference: page 139.

Elkem "applies a range of tools designed to mitigate risks and negative impacts while capitalising on opportunities for improvement," emphasising "active employee involvement in health and safety management." This runs through tailored site HSE organisations, comprehensive training via the FORUS HSE management system (basic and role-specific), regular audits, internal self-assessments and continuous improvement initiatives.

On the organisational side, engagement runs through "employee representation on the Board of Directors, open dialogue and negotiations with unions, and internal communication channels such as intranet and town hall meetings." Development discussions between leaders and employees "provide a framework for feedback, goal setting, and identifying growth needs." A global Speak up channel allows anonymous reporting of suspected Code of conduct violations "without fear of retaliation, ensuring privacy for all parties."

"All data reported is extracted from different HR systems, and complied and quality assured by the HR department and SVP for HR."​

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

Reference: page 139; incident data page 144-145.

Remediation and concern-raising for own workforce runs through the same Speak up channel described for engagement (S1-2): a global, third-party-hosted, anonymous-capable channel covering "suspected violations of the group's Code of conduct," available in multiple languages, "ensuring reports are handled confidentially and professionally."

Incident-level data confirms the channel is used and tracked: in 2025, "45 complaints" were filed through channels for own workers to raise concerns (2024: 26), described as "total number of cases registered in Speak Up case management system from 1 January 2025 to 31 December 2025. Includes both unsubstantiated and fully or partially substantiated cases." Zero substantiated incidents of discrimination and zero severe human rights issues connected to own workforce were recorded in both 2025 and 2024, and "no mention of 'Elkem' in the OECD Database of Specific Instances."​

Taking action on material impacts on own workforce

Reference: pages 140-141.

Elkem is "committed to a zero-harm philosophy, aiming to reduce frequency rates by 10 per cent from the 2022 baseline and ensuring that all site personnel meet the required training hours for their job level." Actions target 100 per cent completion of annual development discussions, and specific diversity/equity/inclusion measures: balanced gender/age/nationality distribution in the workforce, diverse and unbiased recruitment, systematic development of female leaders and critical-position planning, mandatory training completion, Human and Organisational Performance (HOP)/safety-leadership training, and full rollout of FORUS HSE introduction training.

Effectiveness is tracked: turnover analyses by gender, years of service and age; regular pay-equity audits and external benchmarks; engagement-score tracking with targets to reduce short- and long-term sick leave. Following the December 2025 Saint Fons Sud explosion (S1-14), findings on pedestrian-vehicle segregation "have been shared across all sites to prevent recurrence," and automated pedestrian safety systems "have been mandated and installed on the forklifts in the organisation" following a separate fatal forklift incident.

Targets related to own workforce

Reference: pages 140-141.

Targets span health and safety (10 per cent frequency-rate reduction from the 2022 baseline; required training-hour completion by job level; 100 per cent mandatory-training completion; full FORUS Introduction rollout), organisational development (100 per cent completion of annual development discussions), and diversity, equity and inclusion (balanced gender, age and nationality distribution across the workforce and leadership; diverse and unbiased recruitment; systematic development of female leaders and critical-position planning).

Additional target areas: turnover reduction through proactive retention measures informed by turnover analysis; pay equity, addressed through "regular pay equity audits and external benchmarks"; and health and well-being, targeting "high engagement scores" and "reducing both short-term and long-term sick leave." No single-figure numeric target is stated for diversity representation beyond the qualitative "balanced" ambitions described.

Characteristics of the undertaking's employees

Reference: page 142.

Workforce by region (2025): APAC 3,082; EMEA 3,039; AMER 879; total 7,000 employees.

By contract type: permanent employees 6,580 (APAC 3,071; EMEA 2,706; AMER 803); temporary employees 188 (APAC 11; EMEA 105; AMER 72); non-guaranteed-hours employees 232 (APAC 0; EMEA 228; AMER 4).

By working time: full-time employees 6,443; part-time employees 136.

Definitions are provided for each category (page 142): permanent employees have an ongoing contract typically without a predetermined end date and full benefits; temporary employees are hired for a specific period or project; non-guaranteed-hours employees have no fixed contracted hours; full-time employees work the group's defined full-time hours (typically 35-40 hours/week) with full benefits; part-time employees work fewer hours, often under 35/week, with partial benefits depending on policy.

Characteristics of non-employee workers

Reference: page 142 (contractor headcount table).

Contractors by region, 2025 vs. prior years (number): Europe (EMEA) 137 (2024: 149; 2023: 96; 2022: 125); Asia (APAC) 135 (2024: 167; 2023: 160; 2022: 171); Americas (AMER) 23 (2024: 26; 2023: 27; 2022: 35); Africa (EMEA) 0 in all years; total 295 contractors in 2025 (2024: 342; 2023: 283; 2022: 331).

Non-employee workers are also referenced in the S1 impact table as a group exposed to hazardous-substance and injury/fatality risks alongside employees (page 136); separate work-related-injury metrics are disclosed for the contractor population under S1-14, distinct from the employee figures.

Collective bargaining coverage and social dialogue

Reference: page 139.

"All employees are free to join unions, and 39 per cent of the global workforce is covered by collective bargaining agreements that define salary and working conditions."

Coverage rate by region, 2025 (unchanged from 2024): Employees EEA 71 per cent; Employees non-EEA 12 per cent; Total 39 per cent.

Diversity metrics

Reference: page 142.

Female share, 2025 vs. 2024/2023/2022:

• In the group: 25% (2024: 25.4%; 2023: 25.1%; 2022: 25%)
• In management (corporate/divisional/plant management): 21% (2024: 27%; 2023: 24%; 2022: 30%)
• Among all leaders with personnel responsibility: 27% (2024: 27%; 2023: 25%; 2022: 22%)
• In the Elkem leadership programmes: 22% (2024: 38%; 2023: 32%; 2022: 36%)
• In the global technical trainee programmes: 33% (2024: 41%; 2023: 31%; 2022: 38%)
• Among blue collar: 16% (2024: 17%; 2023: 14%; 2022: 17%)
• Among white collar: 36% (2024: 36%; 2023: 32%; 2022: 35%)
• Among part-time workers: 64% (2024: 44%; 2023: 42%; 2022: 31%)
• Among temporary workers: 28% (2024: 31%; 2023: 27%; 2022: 25%)
• Among new hires: 26% (2024: 33%; 2023: 30%; 2022: 26%)
• Among leavers: 28% (2024: 31%; 2023: 29%; 2022: 27%)

Age distribution, employees (2025): under 30: 15%; 30-50: 57%; over 50: 28%. Age distribution, managers (2025): under 30: 2%; 30-50: 60%; over 50: 38%.

Adequate wages

Reference: pages 144-145.

"Elkem strives to offer competitive salaries aligned with local market standards, without positioning itself as a leading pay provider. To ensure fairness, annual reviews of base salaries are conducted, supported by surveys that verify equal pay for equal responsibilities."

"Full-time employees must receive wages and benefits sufficient to cover basic needs such as food, clothing, and housing." All employees, including part-time and temporary staff, "receive written documentation detailing their compensation, benefits, and working hours," complying with the more protective of national legislation, industry standards or internal agreements. Employees are guaranteed at least one day off in every seven-day period. "Details of our pay gap analysis for Norway can be found in the ARP report" (referenced but not reproduced in the sustainability statement).

Social protection

Reference: page 145.

"Pension and insurance coverage are provided in accordance with local legal requirements." This sits within the combined S1-10/S1-11/S1-16/S1-17 section on "Adequate wages, social protection, remuneration metrics, and incidents and complaints" (pages 144-145), alongside the wage and benefits commitments described under S1-10.

No further detail is given on social-protection coverage for specific risk categories (e.g. sickness, unemployment, employment injury, parental leave, retirement) beyond the general statement that pension and insurance provision follows local legal requirements in each jurisdiction where Elkem operates.

Persons with disabilities

Reference: page 143.

"Elkem employs persons with disabilities (S1-12), but we do not collect this kind of data nor report on the number of individuals with disabilities. Our office spaces are adapted to be used by persons with disabilities, and in Norway we follow the requirements in the Norwegian Equality and Anti-Discrimination Act and other relevant requirements. The same applies for other countries where Elkem operates, i.e. we always comply with local rules and regulations. Some of the operations at our production sites are exempt from the requirements due to the nature of the operations and are thus not suitable for persons with disabilities."​

Training and skills development metrics

Reference: pages 139-140.

Average training hours per employee, 2025 (Female/Male/Total split shown for select years): Total 12.1 hours in 2025 (2024: 23.5; 2023: 7.4); by gender in 2025, female 10.7 hours (2024: 18.3; 2023: 9.8), male 11 hours (2024: 19.3; 2023: 9). "This indicator measures the average time invested in training and development activities. An increase in training hours signals Elkem's focus on continuous learning and skill enhancement."

Participation in regular performance and career development reviews: 94% in 2025 (2024: 96%; 2023: 78%). By gender, female 78% and male 100% in the years shown. Participation in internal leadership development programmes: 22% in 2025 (2024: 37.5%; 2023: 25%).

Elkem's leadership programmes "aim to strengthen diversity by ensuring broad geographical representation and age distribution, and by increasing the share of female participants," reflecting a belief that "diverse leadership teams contribute to better decision-making, higher engagement, and improved well-being."​

Health and safety metrics

Reference: pages 137-138.

"Despite Elkem's strong emphasis on safety, three fatalities and one life-changing injury occurred in two separate incidents in China and France" during 2025 (page 135). The two named incidents below account for the three fatalities; the report does not itself state which of the two sits in China.

Employee work-related injuries, 2025 vs. 2024/2023/2022/2021: Fatalities 3 (2024: 0; 2023: 0; 2022: 0; 2021: 0), rate 0.22; high-consequence injuries 0 in all years shown; lost workday injuries 26 (2024: 20; 2023: 11; 2022: 13; 2021: 21), rate 1.9; other recordable injuries 22 (2024: 32), rate 1.6; total recordable injuries (TRIR) 48 (2024: 52; 2023: 42; 2022: 44; 2021: 51), rate 3.6 (2024: 3.5); hours worked 13,355,694.

Contractor injuries, 2025: fatalities 0 (2023: 4; 2022: 2); lost workday injuries 2 (2024: 12; 2023: 24); other recordable injuries 11 (2024: 13); total recordable injuries 13 (2024: 25), rate 3.7 (2024: 5.4); hours worked 3,505,501.

Named incidents: a fatal forklift accident, where "the incident was thoroughly investigated... findings reinforced the critical importance of pedestrian segregation from vehicles... as mandated by Life Saving Rule No. 9," leading to mandated automated pedestrian-safety systems on forklifts. A fatal explosion at the Saint Fons Sud site (France) on 22 December, in the pilot workshop (APIL), "resulted in the loss of two colleagues. Two additional colleagues were seriously injured, with one sustaining life-changing injuries," under internal and external investigation "when Elkem's annual report 2025 was finalised in February 2026."​

Compensation metrics (pay gap and total compensation)

Reference: page 143.

"Salary: CEO to median employee in Norway" ratio: 11:1 in 2025 (2024: 11:1; 2023: 11:1; 2022: 10:1). "Details of our pay gap analysis for Norway can be found in the ARP report" (external document, not reproduced in the sustainability statement).

Appendix 3 datapoints on other SFDR/Benchmark-Regulation compensation metrics (e.g. gender pay gap, excessive CEO pay ratio) are not reproduced in the extracted text of this chapter beyond the CEO-to-median-employee ratio above; the report does not disclose a group-wide (non-Norway) gender pay gap percentage in the sustainability-statement text.

Incidents, complaints and severe human rights impacts

Reference: page 145.

Incidents and complaints, 2025 vs. 2024:

• Substantiated incidents of discrimination: 0 (2024: 0)
• Complaints filed through channels for own workers to raise concerns: 45 (2024: 26) -- "total number of cases registered in Speak Up case management system from 1 January 2025 to 31 December 2025. Includes both unsubstantiated and fully or partially substantiated cases."
• Severe human rights issues and incidents connected to own workforce: 0 (2024: 0)
• Severe human rights issues/incidents that are violations of UN Global Compact Principles and OECD Guidelines for Multinational Enterprises: 0 (2024: 0) -- "No mention of 'Elkem' in the OECD Database of Specific Instances."

"Elkem maintains strict reporting and investigation procedures for all incidents, ensuring transparency, accountability, and continuous improvement," and confirms the December 2025 Saint Fons Sud accident (see S1-14) "was still under internal and external investigation when Elkem's annual report 2025 was finalised in February 2026."​

Policies related to value chain workers

Reference: page 81 (governing documents); cross-referenced page 147.

"Elkem's policies and statements regarding value chain workers are supported by multiple governing documents including the Code of conduct, HSE policy, Third-party risk management procedure, and Human rights programme." The Code of conduct and Code of conduct for business partners "are aligned with the UN Guiding Principles on Business and Human Rights and are based upon internationally recognised standards, including the ILO Declaration on Fundamental Principles and Rights at Work," communicating expectations for suppliers and contractors on transparent contracts, minimum living wage, maximum working hours, minimum age standards, and rights to organise and bargain collectively where legally permitted.

Processes for engaging with value chain workers about impacts

Reference: page 147.

Elkem's approach "is guided by the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises." Mitigation measures include "integrity due diligence for raw material suppliers (intermediaries and producers), pre-qualification audits, and on-site visits for critical raw material suppliers," aiming "to audit its most critical raw material suppliers prior to purchasing."

"Elkem maintains regular engagement with suppliers to reinforce its expectations and commitment to ethical practices throughout the value chain," with high-risk suppliers subject to an annual audit plan; non-compliance triggers warnings and corrective-action requirements, escalating through "improvement plans, financial penalties, or contract termination" for persistent violations. The head of the compliance function owns the Human rights programme, and the procurement council shapes global procurement strategy and policy, working with the corporate compliance team to integrate human-rights due diligence into supplier management.

Processes to remediate negative impacts and channels for value chain workers to raise concerns

Reference: page 148.

Elkem's grievance mechanism "is designed for individuals and communities affected by our plants, projects, or other business activities worldwide," managed by the ESG team, which coordinates resolution across the organisation and monitors follow-up.

The Speak up channel is "a secure reporting platform for external and internal parties to report potential noncompliance with Elkem's Code of conduct," hosted by an independent external supplier for whistleblower anonymity, available in multiple languages. Investigations are led by Elkem's Head of Investigations under strict confidentiality protocols. "Any incidents or investigations revealing practices that could lead to human rights violations trigger corrective actions, including updates to governing documents, introduction of new internal controls, enhanced training, and adjustments to roles and responsibilities," with prompt remedial action and, where necessary, compensation for affected individuals.

Taking action on material impacts on value chain workers

Reference: pages 148-149.

A prior third-party human-rights risk assessment "confirmed that Elkem faces a high inherent risk of adversely affecting human rights due to the nature of its operations, geographic footprint, and the size and complexity of its supply chain," finding strong own-operations systems but "the absence of a global supplier management system" as the main gap.

In response, Elkem introduced a global Supplier Relationship Management (SRM) system in 2024, enabling "systematic, risk-based supplier qualification and follow-up," standardised vetting and lifecycle compliance monitoring; "throughout 2025, the implementation of the SRM system has progressed further." "In 2025, the corporate compliance department conducted 83 IDDs (integrity due diligence) on raw material suppliers. 35 findings were related to Workers in the value chain (ESRS S2)", such as labour-standards compliance concerns. On-site audits cover critical raw-material suppliers; of roughly 200 raw-material suppliers in the highest-risk mining/processing/forestry sectors, "72 per cent hold ISO certification... up from 25 per cent of suppliers in 2024."

Effectiveness metrics (2025 vs. 2024/2023/2022): share of new suppliers assessed/pre-qualified 100% (2024: 100%; 2023: 80%; 2022: 100%); share of new raw-material suppliers audited 50% (2024: "no audits due to Covid-19"; 2023: 60%; 2022: 100%); adverse human-rights concerns reported in supply chain 1 (all prior years: 0); confirmed cases of child or forced labour 0 (all years); cases reported through grievance mechanisms 2 (2024: 5; 2023: 1; 2022: 6).

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

Reference: page 150.

"Elkem aims to assess and screen all suppliers, and all raw material suppliers are subject to audits," to reduce the risk of breaches of the Code of conduct for business partners. In 2025, "60 per cent of all new raw material suppliers were audited."

Code of conduct signing campaign: of Elkem's 8,300 high-risk suppliers (those in countries on the UN's Trade Sanctions Risk List, and providers of raw materials, logistics, financial services and marketing), "41 per cent (3,500)... have signed our Code of conduct," including 100 per cent of the 600 suppliers to the India plant and 80 per cent of high-risk Chinese suppliers ("the goal is 100 per cent"). Overall, "approximately 6,000 suppliers (36 per cent of all suppliers) have signed the Code of conduct for business partners." Suppliers who refuse to sign "are 'deactivated'... therefore, no longer able to do business with Elkem." "Our efforts to ensure supplier compliance will continue in 2026 and beyond."​

Policies related to affected communities

Reference: page 81 (governing documents); cross-referenced page 155.

"Relevant policies for affected communities are Elkem's HSE policy, our Speak up policy, the Communications and public affairs policy, and the Procedure for sponsoring and donations procedure," all described under the ESRS 2 governing-documents section. The Sponsoring and donations procedure "ensures that all sponsorships, charitable donations, and community support activities align with the group's values and compliance policies," with approval processes for contributions over EUR 5,000 and guidelines on restricted organisations and conflicts of interest.

Processes for engaging with affected communities about impacts

Reference: pages 155-156.

Elkem "maintains open channels for external stakeholders to communicate with both local sites and corporate offices," tailoring "stakeholder dialogue and community engagement" to each site's local context. For significant operational changes, Elkem "undertakes thorough stakeholder consultations to identify potential impacts and agree on appropriate mitigation measures" -- for example, working "closely with local reindeer herding interests" on the Tana, Norway quartzite mine expansion.

The same SRM-based supplier engagement/signing campaign described under S2-5 applies here: "almost 4,000 (44 per cent) of Elkem's high-risk suppliers have now signed our Code of conduct or demonstrated equivalent internal standards," rising to 100 per cent of the 600 Nagpur, India suppliers and 33 per cent of high-risk Chinese suppliers; overall "approximately 6,000 suppliers (34 per cent of all suppliers globally)." "In 2025, our compliance department registered four IDD-related findings related to 'affected communities'," including supplier engagement on medical access for employees, prayer facilities, and consultative meetings on a mine expansion.

Processes to remediate negative impacts and channels for affected communities to raise concerns

Reference: page 156.

Only designated spokespersons (CEO, CFO, VP corporate communications & public affairs, and relevant managers) "may speak on behalf of the group, ensuring consistent and aligned external messaging"; plant managers may speak for their local plants "in alignment with the global communications strategy." External stakeholders "can confidentially raise concerns through a public grievance mechanism available on Elkem's website," while both internal and external parties can use the secure Speak up channel. "All reports received through these mechanisms are managed by Elkem's ESG office and compliance department, which oversee the resolution process in collaboration with relevant teams," ensuring "privacy and protection for stakeholders at risk." For detailed grievance and misconduct figures, the report cross-refers to the Business conduct (G1) chapter.

Taking action on material impacts on affected communities

Reference: pages 156-157.

Named community actions in 2025: consultations with local reindeer herders on the Tana, Norway quartzite mine expansion "ensuring sustainable coexistence and respect for traditional livelihoods"; at Elkem Nagpur, India, equipment provided to restore roads after severe monsoon damage, enabling forest rangers "to resume patrols and safeguard tiger populations," followed by a seven-year reforestation project planting "more than 2,000 trees"; the Wings Fly High digital-education project delivering mobile computer classrooms to under-resourced schools near Nagpur, which "has provided thousands of sessions, improved exam results, and helped hundreds of children return to school"; the Ferroveld learnerships (South Africa) and Colorir project (Brazil) for education and skill-building; and Elkem Thamshavn, named "Apprenticeship Company of the Year 2025" at the Thams Conference, which donated a NOK 25,000 prize to Skattkammeret supporting children and youth in the Orkland region.

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

Reference: page 157.

"Elkem has no explicit targets related to engagement with affected communities, but has set targets to minimise negative impacts (see chapters on climate change, pollution, and water). Elkem manages its material impact by voluntary initiatives and maintaining strict compliance with environmental permits and regulations." Deviations from pollution controls "are addressed through established HSE processes."

"As a cornerstone employer in several locations, Elkem plays a vital role in local economies, providing jobs, tax revenue, and community support through programmes such as sponsorships for schools and sports teams. The group continuously works to strengthen dialogue and trust with communities and is exploring the establishment of outcome-oriented, time-bound targets to further enhance its commitment. Elkem's aim is to avoid conflicts with local communities, minimise negative impact, and promote strong communities."​

Business conduct policies and corporate culture

Reference: pages 160-161.

"Elkem's governing documents establish clear principles for responsible business conduct across all entities. The Code of conduct and Governance policy are anchored at the highest level and approved by the board of directors." Operational compliance is overseen by the corporate compliance team, which "provides employees and management with tools and guidance to ensure actions align with Elkem's standards."

2025 training completion rates (target group / rate): Introduction to Elkem's Code of conduct 8,166 / 95.06%; Compliance awareness training to newcomers 112 / 85.71%; Code of conduct refresher (twice yearly) 2,856 / 99.72%; Anti-corruption academy 2025 (risk-based target group) 1,123 / 99.02%; Elkem sanctions school (one-off risk-based campaigns) 891 / 94.95%; Introduction to human rights (risk-based target group) 482 / 96.06%; Anti-trust (risk-based target group) 1,051 / 96.19%.

"Elkem's commitment is reinforced by dawn raid guidelines implemented across major sites," with targeted eLearning and bespoke training for high-risk jurisdictions and employee groups to mitigate anti-competitive-behaviour, human-rights and trade-sanction risks.

Prevention and detection of corruption and bribery

Reference: page 161.

"Elkem enforces a strict anti-bribery and corruption policy, particularly in jurisdictions with elevated risk. A risk-based approach underpins continuous improvement of anti-bribery measures, including regular risk assessments that guide both existing operations and new business ventures," reinforcing "Elkem's zero-tolerance policy."

Business partners -- agents, consultants, suppliers, joint ventures -- must comply with the Code of conduct for business partners. In 2025 Elkem "focused on exploiting the opportunities provided by the SRM platform for improved supplier risk management" and "advanced our efforts to mitigate the compliance risks associated with our distributors," developing "a more rigorous onboarding and approval process" and enhanced intermediary compliance monitoring; from 2026, "selected intermediaries will be enrolled in our training program" covering sanctions and anti-corruption.

The Speak up channel, hosted by a third party, enables confidential/anonymous reporting in multiple languages for internal and external parties, with matters escalated to senior management or the audit committee as needed. Investigations follow "a structured, fact-based methodology," conducted by dedicated investigators independent of operational leadership. "After five years of dedicated effort... Elkem's compliance programme has reached a significant milestone, now recognised by Deloitte as one of the best among international peers," having advanced "from an informal maturity level to 'operationally effective' status" since the 2020 initial audit. "In 2025, Elkem reported no significant legal or regulatory violations resulting in material penalties."​

Targets related to business conduct

Back-filled from the G1-MDR-T-tagged "Incidents of corruption or bribery" section (page 162), which serves the effectiveness-tracking limb of MDR-T under the 2023 ESRS, where G1-3 targets fell under MDR-T rather than a standalone disclosure requirement.

Elkem does not state a numeric target for corruption/bribery incidents. Instead, effectiveness of its anti-corruption and Speak-up framework is tracked through reported case trends and awareness measures: "In 2025, significant efforts were made to increase awareness and usage of the Speak up channel. A new requirement for local management to report locally registered cases to corporate compliance was introduced to ensure group-wide learning and process improvements. Units are now also obligated to display the Speak up poster in common areas, and awareness campaigns have been directed towards all employees. The efforts have had the desired effect, with reported cases increasing from 2024 to 2025."

Reported misconduct cases rose from 15 in 2024 to 26 in 2025 (see G1-4), which the report frames as the intended, positive effect of increased awareness and reporting channels, rather than a deterioration in conduct. No separate quantified target (e.g. a percentage reduction in confirmed corruption cases) is stated.

Incidents of corruption or bribery

Reference: page 162.

Incidents of misconduct, 2025 vs. 2024/2023/2022:

• Total number and nature of misconduct reports: 26 (2024: 15; 2023: 14). 2025 breakdown: company/professional code violation 11; inappropriate workplace behaviour and harassment 10; HR case 7; corruption and fraud 6; conflict of interest 5; competition law 2; cyber security & data protection 1; HSE violation 1; human rights violation 1; sanction violation 1.
• Confirmed cases of corruption and fraud: 0 (2024: 1; 2023: 1; 2022: 6)
• Confirmed incidents where employees were dismissed or disciplined for corruption: 0 (2024: 1; 2023: 0; 2022: 2)
• Public legal cases regarding corruption brought against the organisation or its employees: 0 (2024: 1; 2023: 0; 2022: 0)
• Confirmed incidents where contracts with business partners were terminated or not renewed due to corruption violations: 0 (2024: 0; 2023: 0; 2022: 5)

"In 2025, significant efforts were made to increase awareness and usage of the Speak up channel," including a new requirement for local management to report locally registered cases to corporate compliance and mandatory display of Speak up posters; "the efforts have had the desired effect, with reported cases increasing from 2024 to 2025."​

Political influence and lobbying activities

Reference: page 162.

"Elkem maintains active dialogue with government policymakers, media, civil society, non-governmental organisations, research institutions and international institutions to communicate its position on key industry issues. The group does not support political or religious organisations, nor individuals or groups outside recognised charities, and strictly prohibits contributions to discriminatory, harmful, or unlawful activities." Exceptions are limited to "small symbolic gestures related to employees' religious holidays," governed by the gifts and hospitality procedure.

"Elkem primarily represents its interests through industry organisations, and any engagement with external lobbyists is conducted transparently, in accordance with legal requirements, and with prior approval from the vice president of corporate communications & public affairs," following the third-party risk management procedure. "Every sponsorship and social contribution is subject to rigorous due diligence and must uphold Elkem's ethical standards and compliance commitments."

2025 membership fees disclosed: Norsk Industri NOK 1,066,623; SICOS (French chemicals/biotech syndicate) EUR 25,473; Norsk Bergindustri NOK 168,465 (page 163; Eurometaux fee also listed but its figure is cut off in the extracted text).

Payment practices

Reference: page 162.

"Elkem strives to pay all invoices within reasonable time. The key guideline is to pay the invoice within 45 days of it being issued. This is regardless of whether it is a large corporate supplier or an SME."

The report does not disclose further payment-practice datapoints (e.g. average actual payment time achieved, percentage of invoices paid within standard terms, or a description of standard contractual payment terms by supplier category) beyond this 45-day policy statement.