Ellos Group

Governance structure

Reference: pages 13-14.

Named responsibilities (p.13): Board of Directors – "responsible for sustainability reporting. Has the overall responsibility for the Group's sustainability work... Approves Ellos Group's Code of Conduct." Group Management – implements the Code of Conduct, approves sustainability strategies/ESG targets, reviews material IROs before the Board. Sustainability Steering Group – monitors legal developments and reviews the DMA before Group Management. Audit Committee – oversees financial/non-financial reporting, audits and risk management; reports to the Board. Global Sourcing, Operations, People & Culture, Finance & Legal, IT/PMO each hold topic-specific responsibility.

Composition (p.13-14): Board – five members (two employee representatives) plus the CEO, 33% women (25% prior year). Audit Committee – two independent non-executive members, 0% women. Group Management – eight individuals, 38% women. Sustainability Steering Group – 50% women.

"The Board conducts an annual evaluation of its own competence... An adequate level of competence is assessed to be present within the Board regarding environmental and social matters, responsible business conduct and the assessment of the Group's impacts, risks and opportunities."

Information flow to governance bodies

Reference: page 15.

"The Board, the Audit Committee and Group Management receive updates from the Sustainability Director and the Sustainability Manager three times a year regarding business and operational sustainability risks, including changes in material impacts, risks and opportunities, the outcomes of due diligence processes as well as the status of actions taken, metrics and targets."

Updates to business ethics policies go to the Board for approval. "The Board and Group Management consider sustainability impacts, risks and opportunities as part of their oversight of the Group's strategy," including trade-offs between short-term operational needs and long-term sustainability targets. "All material impacts and the risks and opportunities identified in the double materiality assessment have been addressed by Group Management and the Board during the reporting period," cross-referencing SBM-3.

Sustainability in incentive schemes

Reference: page 15.

"The members of Group Management who participate in the Group's incentive programme have targets linked to sustainability. The targets are individually designed," covering examples such as building reporting-capable systems, improving supplier GHG data quality, or adjusting product mix/pricing to cut emissions per unit sold. "The Group has a climate target to reduce its total greenhouse gas emissions by 50 per cent from the 2020 base year to 2030," with annual interim targets built into the incentive programme.

"Incentive programmes are approved by the Board. The year 2024 was the first year with sustainability-related targets included in the incentive programmes." As reported, the share of variable remuneration linked to sustainability targets was 7.5% in both the 2025 and 2024 reporting periods.

Due diligence core elements mapping

Reference: pages 15-16.

Ellos Group maps the UNGP/OECD due diligence core elements to disclosures across the statement:

• (a) Embedding due diligence in governance, strategy and business model: GOV-2, GOV-3, SBM-3.
• (b) Engaging with affected stakeholders in all key steps of the due diligence: SBM-2, IRO-1, S1-2, S2-2, S4-2.
• (c) Identifying and assessing adverse impacts: IRO-1.
• (d) Taking actions to address those adverse impacts: E1-1, E1-3, E2-2, E3-2, E5-2, S1-4, S2-4, S4-4.
• (e) Tracking the effectiveness of these efforts and communicating: E1-4, E2-3, E3-3, E5-3, S1-5, S2-5, S4-5.

This mapping table appears directly under GOV-4 in the statement (p.16), pointing the reader to where each due diligence element is disclosed in detail elsewhere in the report.

Risk management and internal controls

Reference: page 17.

"The identification and management of risks related to environmental and social sustainability and corporate governance are part of Ellos Group's internal control framework. The Group applies the COSO framework... It consists of five components: control environment, risk assessment, control activities, information and communication as well as monitoring."

"The risk assessment related to inaccuracies in the sustainability statement follows the same structure as the risk assessment for the financial report and is conducted at least once per year," using a risk matrix (high/medium/low). The CFO coordinates the risk assessment and reports results to the Board.

"The risk of significant errors occurring in the sustainability statement is primarily considered to be related to human error or incomplete data." Mitigations: accounting principles based on ESRS; the Sustainability Manager monitoring KPIs; complex calculations (Scope 1, 2, 3) "always verified by at least two individuals"; clear governance; and collection of sustainability data through "dedicated software systems for sustainability reporting."

Strategy, business model and value chain

Reference: pages 17-19.

Ellos Group's "vision is to be the leading shopping destination in the Nordic region for the woman in mid-life." Sales run through three e-commerce platforms – Ellos, Jotex, Homeroom – plus the payment brand Elpy. Operations are based in Borås, Sweden. Net sales for 2025 were SEK 3,463.7 million. The Group employed 612 people (615 in 2024), all in Sweden.

The Group owns no manufacturing facilities; it works through 479 product suppliers (606 in 2024) across 86 countries (91). Purchased goods by geography (2025 / 2024): China 52%/55%, India 14%/13%, Europe 11%/13%, Bangladesh 11%/8%, Other Asia 11%/10%. "The Group does not operate in the sectors of fossil fuels, chemical production, controversial weapons or in the sector of tobacco cultivation and production."

Value chain (p.18): upstream – Tier 1 direct suppliers and agents to Tier 2-4 factories (sewing/assembly, fabric mills, yarn manufacturing, agriculture/forestry, primarily Asia); own operations – the Borås head office/warehouse; downstream – customer use/washing/repairs, return handling and end-of-life. Transport is mainly sea freight from Asia and truck within Europe.

Stakeholder engagement

Reference: pages 20-21.

"The Group's key stakeholders are customers, employees, suppliers, communities and owners/investors." Per the stakeholder table (p.20):

• Customers: purpose is understanding needs/sustainability expectations; method is customer surveys, customer service dialogue, website/social media; result is a focus on safe, more sustainable, responsibly produced products.
• Employees: purpose is a safe, meaningful workplace; method is employee surveys, internal meetings on culture, whistleblowing; result is a focus on health & safety, diversity and positive culture.
• Suppliers: purpose is alignment on ethics, human rights, environment; method is supplier assessments, audits, collaboration programmes, whistleblowing; result is a more sustainable supply chain.
• Communities: purpose is positive local impact "always from a non-political and non-religious standpoint"; method is dialogue and partnerships with local organisations.
• Owners/Investors: purpose is transparency on strategy and sustainability commitments; method is investor meetings, interim and annual reports.

Additional context: employee surveys inform S1; the own-workforce-who-are-not-employees group's interests "are not, at present, taken into account" (p.21). Results are discussed in the Sustainability Steering Group and reported to Group Management and the Board.

Material impacts, risks and opportunities

Reference: pages 22-30.

The DMA produced material impacts and risks across climate, pollution, water, biodiversity, resource use, own workforce, value chain workers, consumers, and business conduct. "Ellos Group is not reporting on ESRS E4 Biodiversity and ecosystems in the environmental information section of this year's sustainability statement" even though biodiversity impacts were identified as material (p.22).

Named material items (pp.22-26) include: GHG emissions/energy in the value chain; air/soil/water pollution, chemicals, microplastics; water consumption/scarcity upstream; biodiversity impacts via cotton/wood sourcing; waste, virgin material use, recyclability, raw-material-cost risk; health/safety and discrimination risk for employees; working conditions/rights for value chain workers; personal data, product safety, marketing and portrayal of women for consumers; and culture, whistleblower protection, animal welfare, payment terms and corruption/bribery.

Changes versus the prior DMA (p.27): "Energy – no longer financially material... Resource outflows related to products and services – no longer financially material... Workers in the value chain – working conditions – no longer financially material," e.g. extended producer responsibility costs "have been incorporated into the budget."

"The Group's own facilities in Viared in Borås are assessed not to have a negative impact on biodiversity and ecosystems" (p.28).

DMA process

Reference: pages 31-34.

"During 2025, Ellos Group carried out a review of the double materiality assessment, which was first conducted in 2023," with EFRAG guidance, in five steps: (1) mapping operations/value chain/stakeholders; (2) stakeholder dialogue; (3) impact gross list; (4) quantitative assessment; (5) qualitative assessment and Board/Group Management approval.

Scoring: negative impacts rated on severity (scale + scope + irremediable character) and likelihood, 1-5 scale each. "The threshold for materiality was set as a slanting line... Severity was prioritised over likelihood, and any impact with a severity greater than four was considered material, regardless of likelihood... The threshold for materiality regarding negative impacts related to human rights was set lower." Financial materiality used a size (SEK M) × likelihood matrix on the same logic.

Sub-topics excluded as irrelevant (p.32-33): pollution of living organisms/food resources; marine resources ("not dependent on other marine resources than water"); impacts on the state of species ("no financial risk... as the Group's direct dependence on species concerns domesticated animals"); ESRS S3 as an entire topic ("a small customer to the suppliers... limited ability to influence"); and G1 lobbying ("does not consider this to be political engagement").

Climate scenario analysis (p.33-34): conducted in 2024 using NGFS guidance, three scenarios – Net Zero Emissions 2050, Current Policies, Delayed Transition (full detail under E1-2-ScenarioAnalysis).

ESRS content index

Reference: pages 12, 34-37.

"The following tables list all ESRS disclosure requirements in ESRS 2 and the nine topical standards that are material for Ellos Group and that have formed the basis for preparing the sustainability statement... In cases where the phase-in option is applied, no reference is provided (-)."

This is Ellos Group's first sustainability statement prepared under ESRS (p.12): "This is the first year the Group has prepared a sustainability statement in accordance with ESRS." Under "Phased-in disclosure requirements" (p.12): "In accordance with ESRS 1 'Appendix C List of phased-in disclosure requirements', certain information is omitted during this first year." The statement names biodiversity specifically: "Biodiversity and ecosystems has been identified as a material topic for Ellos Group. The Group is not reporting on biodiversity and ecosystems in this year's environmental information section."

The index (pp.34-37) lists page references for every material DR in ESRS 2, E1, E2, E3, E5, S1, S2, S4 and G1, with a dash where the phase-in option was used (E1-9, E2-5, E3-5, E5-6, S1-7, S1-12, and all of E4). "The Group has not used incorporation by reference for any disclosure requirements or data points" (BP-1, p.12).

Transition plan for climate change mitigation

Reference: pages 41-45.

"Ellos Group has established a transition plan based on the Green House Gas (GHG) accounting for the 2020 base year, aiming to gradually reduce the Group's total GHG emissions by 50 per cent in absolute terms by 2030," aligned with the EU climate targets and the Paris Agreement 1.5°C objective. "The target concerns a near-term reduction; no climate-neutrality target has yet been set."

The plan allocates the 50% reduction across six strategic areas (p.42): Suppliers 67% (renewable energy/efficiency at suppliers), Product mix 13%, Materials 8% (higher recycled-material share), Transport 7% (biofuel sea freight, fossil-free last mile), Packaging 4%, and Scope 1&2 1% (renewable electricity/district heating).

Locked-in emissions (p.44): "operations generate locked-in greenhouse gas (GHG) emissions primarily in the upstream value chain... The majority of these emissions are indirect (Scope 3)... A large share of the climate impact of garments is already locked in at the time of purchase."

Approval and resourcing: the plan "has been approved by Group Management and the Board" and is linked to management incentives (GOV-3). "There are currently no planned major financial investments (CapEx) resulting from the risks identified in the materiality assessment" (p.27), though a 1 FTE was added in 2025 to collect supplier energy data (E1-3).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 (pages 33-34) and E1-4 (page 46), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"A climate-related scenario analysis was conducted in 2024 using the guidelines from the Network of Central Banks and Supervisors for Greening the Financial System (NGFS) to examine how Ellos Group's assets and business activities may be exposed to physical risks or transition risks" (p.33).

Scenarios used: (1) Net Zero Emissions 2050 – "50 percent chance of limiting global warming to below 1.5°C"; (2) Current Policies – "global warming of approximately 3°C"; (3) Delayed Transition – "global warming of approximately 2°C." Transition risk was assessed mainly against Net Zero 2050, physical risk against Current Policies, and both against Delayed Transition (p.34).

Scope: covered "own operations and value chain" (p.34), considering developments in society, technology, market and policy (p.46). No global-average-temperature-projection methodology beyond the scenario descriptions is given, and no update date beyond "conducted in 2024" is stated.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 (pages 27-28), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"The Group continuously performs resilience analyses of its strategy and business model and assess its ability to manage material climate-related impacts and risks across its entire operations and value chain" (p.27), though a formal, ESRS-defined resilience analysis has not been performed.

"The Group is actively working to secure resilience in its strategy and business model in relation to climate change and, in connection with the climate scenario analysis, has evaluated its resilience against the identified risks in the analysed scenarios. No assets are assessed to be exposed to risk; however, risks related to the Group's product portfolio have been identified." The Group states it "has good ability to adapt its strategy and business model over the medium and long term," citing: not concentrating purchasing with a single supplier; collecting supplier-location data relevant to water, precipitation, heat and cyclone risk; following up on suppliers' own climate resilience; reducing dependence on natural materials; increasing recycled-fibre share; and maintaining a higher buffer stock of Never-Out-of-Stock products (p.27).

Policies related to climate change mitigation and adaptation

Reference: page 43.

Three policies govern climate-related work, all Group Management/Board approved:

• Environmental Policy (Board-approved, part of the Code of Conduct): "aims to reduce Ellos Group's environmental impact by mitigating climate change, protecting natural resources and preserving biodiversity," covering sustainable materials/production, energy efficiency, responsible transport, waste management and sustainable packaging.
• Design Policy (Group Management-approved): sets targets for products designed with sustainability as a baseline across the full life cycle; "material choices must be prioritised based on low CO2e impact and recyclability."
• Purchasing Policy (Group Management-approved): governs supplier relationships through written agreements and environmental/CSR follow-up, prioritising long-term collaboration.

"Group Management holds the overall responsibility for policy compliance... The operational responsibility for implementation and compliance lies with Ellos Group's Sustainability Director."

Actions and resources in relation to climate change policies

Reference: pages 43-45.

Actions map to the six transition-plan levers:

• Suppliers: systematic sustainability data collection via the Worldfavor platform (energy, water, emissions, chemicals, waste), Tier 1 in 2025 with Tier 2 planned for 2026; a 1 FTE resource was added in 2025.
• Materials: shifting to recycled/certified materials with lower GHG footprints (detailed under E5).
• Packaging: e-commerce bags are 80% post-consumer and 20% post-industrial recycled plastic; cartons predominantly recycled paper; 4.1 million parcels delivered in 2025.
• Transport: predominantly sea freight; "a general ban on air freight for product deliveries" introduced in 2025 (Purchasing Director approval needed for exceptions); goal of fossil-free customer deliveries by 2030.
• Scope 1 and 2: company cars phased to electric; Borås electricity fully renewable; district heating became fully renewable (Bra Miljöval-certified) from April 2025, at an OpEx increase of SEK 0.1 million.

Progress: "From the transition plan's base year up to the end of 2025, Ellos Group has achieved a reduction of 32,107 tCO2e equivalent to 24 per cent." Expected 2030 reductions per lever (of each lever's own baseline): Suppliers 55%, Transport 58%, Materials 34%, Packaging 32%, Scope 1&2 91%.

Targets related to climate change mitigation and adaptation

Reference: pages 46-47.

"Ellos Group aims to reduce total market-based greenhouse gas emissions by 50 per cent in absolute terms by 2030 compared with the 2020 base year," covering Scope 1, 2 and 3 (GHG Protocol), across the full value chain. Categories 11 and 12 have not yet been inventoried for materiality (assessment planned 2026). "The Group has not yet set a long-term climate target, but the ambition is to develop one in the near future."

For Scope 1 and 2, the target was GHG neutrality by 2025; actual 2025 emissions were 207.9 tCO2e, so "the target has not been achieved when calculated as a gross target," attributed to not replacing conventional refrigerants and non-certified district heating in Jan-Mar 2025 (before the April 2025 switch to certified heating).

"The Group's target is aligned with the 1.5°C scenario, as the target is a 50% reduction in emissions, but it has not yet been externally reviewed or validated in accordance with established frameworks. The targets are therefore not currently classified as science-based." Achieving the Scope 3 target is described as "highly dependent on supplier engagement and on the pace of energy transition in their respective countries." Intensity metric CO2e/kg of resource inflows fell from 7.5 (2024) to 7.0 (2025).

Energy consumption and mix

Reference: page 47.

Ellos Group operates in NACE sector G – Wholesale and retail trade, a high climate impact sector, so 100% of net revenue (SEK 3,463.7 M) is used for energy-intensity purposes.

2025 vs 2024 figures: total fossil energy consumption 9.6 MWh (145.3 MWh in 2024), 0.10% of total (1.40% in 2024); fuel from renewable sources 9,975.5 MWh (10,214.9 MWh); total renewable consumption 9,975.5 MWh, 99.9% of the mix (98.6% in 2024); total energy consumption 9,985.1 MWh (10,360.2 MWh). Energy intensity was 0.0000029 MWh per SEK of net revenue.

Consumption "consists mainly of electricity and district heating used in its own operations in Borås, as well as a smaller share of fuels for the Group's vehicles." "As part of the Group's target for net-zero emissions in Scope 1 and 2, all electricity purchases and most district heating for 2025 have been made with guarantees of origin," calculated from supplier data.

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 47-49.

2025 vs 2024 (base year 2020 in brackets), tCO2e: Gross Scope 1: 73.7 (138.4; base 2.3), -47% YoY. Scope 2 location-based: 182.6 (358.1; base 331.2). Scope 2 market-based: 134.2 (300.4; base 240.0). Total Scope 3: 102,111.8 (103,840.8; base 134,185.0), -2%, of which Purchased goods and services 95,852.9 (97,458.3), Upstream transport & distribution 5,188.6 (5,182.2), Fuel/energy-related activities 5.3% covered by primary data, Waste generated in operations 43.3 (74.8), Business travel 160.3 (296.3), Employee commuting 771.3 (726.0). Total GHG emissions (market-based): 102,319.7 tCO2e (104,279.7; base 134,427.3), -2% YoY. Location-based total: 102,368.1 tCO2e. GHG intensity: 0.0000295 tCO2e market-based per SEK net revenue.

"Purchased products account for 99.8 per cent of the Group's total emissions." Primary data covers only Upstream transportation and distribution, Waste generated in operations and Business travel, "which together account for 5.3 per cent of Scope 3 emissions... The greenhouse gas emission data has not been validated by an external body."

Omitted Scope 3 categories: Use of sold products and End-of-life treatment (no reliable industry-average wash/lifespan data); Capital Goods (too small to be material this year); Upstream leased assets, Downstream transportation and distribution, Downstream leased assets, Franchises and Investments (not relevant to the business).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 49.

"During 2025, Ellos Group did not engage in any greenhouse gas removal activities or the purchase of carbon credits." No further detail is given, consistent with the 50% absolute-reduction target being a gross target with no stated reliance on removals or credits.

Internal carbon pricing

Reference: page 49.

"Ellos Group does not currently apply internal carbon pricing." No further detail on plans to introduce a carbon price, or on how climate-related decisions are otherwise weighed financially, is given elsewhere in the statement.

Policies related to pollution

Reference: page 50.

"The main impact from pollution arises in the Group's upstream value chain through production, during transportation both upstream and downstream in the value chain, as well as during the use and washing of products sold by the Group in the downstream value chain."

The Environmental Policy and Product Policy "serve as guidelines to minimise the negative impact of pollution, both within the company's operations and across the entire value chain," covering chemical usage, waste reduction and transport-emission limits, plus a push toward organically grown materials "to reducing soil pollution." These are complemented by the Supplier Code of Conduct and Supplier Manual, which require suppliers to comply with environmental laws, hold environmental permits, and manage air/water emissions and hazardous waste correctly.

"The policies currently do not include the limitation of negative impacts relating to microplastics or how to avoid incidents and emergencies connected to pollution or substances of concern." The Board approves the Environmental and Product Policies; the Sustainability Director holds operational responsibility.

Actions and resources related to pollution

Reference: pages 50-51.

For own-brand products, Ellos Group bans substances of concern and substances of very high concern via a Restricted Substances List (RSL) and Manufacturing Restricted Substances List (MRSL), communicated through the Supplier Manual. In 2025 the Group began mapping which own-brand suppliers hold an external chemical inventory system, which will feed an upcoming supplier evaluation score.

"The Group does not sell products containing hazardous chemicals according to the RoHS Directive or the REACH Regulation." Own-brand bans cover PVC (except electrical cables), PFAS, antibacterial additives, flame retardants in textiles/leather/footwear, and DMFu moisture absorbers; work is underway to extend this to external brands. Compliance is checked via chemical testing before production start, with particular focus on baby clothing and food-contact materials; substances of very high concern are proactively monitored to allow phase-out ahead of formal restriction.

On microplastics: "The Group is aware of the environmental and health risks posed by microplastics, especially within the textile industry," and is "actively working to reduce the amount of microplastics by exploring more sustainable material alternatives." "Currently, the Group is unable to measure the effectiveness of policies and actions related to pollution impacts," though it aims to develop this capability.

Targets related to pollution

Reference: page 51.

"The Group does not have detailed knowledge of these emissions and has therefore not yet set specific targets for pollution." Air-pollution reduction is instead pursued indirectly through the Climate Action Plan's fossil-fuel targets (E1-4); soil-pollution reduction is addressed under resource use and circular economy targets (E5-3). "The Group has currently not set any specific targets related to water pollution or microplastics." Expected results are described qualitatively: fewer hazardous chemicals in products via supplier monitoring, substance bans and chemical testing, "an ongoing process aimed at continuous improvement and therefore have no specific end date."

Pollution of air, water and soil

Reference: page 51.

"Ellos Group's significant environmental impacts related to pollution originate primarily in the value chain rather than in the Group's own operations. Against this background, the Group does not specifically report on pollutant emissions or on the occurrence and use of microplastics arising from its own operations." The Group's own operations (Borås offices and warehouse) "do not cause emissions to soil, air or water"; chemical use in the value chain "primarily occurs within the Tier 2-4 supplier tiers" (p.50).

Policies related to water and marine resources

Reference: page 52.

"Water has been identified as a negative impact and risk in the upstream value chain, primarily in connection with cotton cultivation and with dyeing, washing and finishing processes in textile production... Ellos Group's policies related to water are therefore focused on the upstream value chain." Customer-phase water use (washing) and the Group's own Borås operations are not covered by a specific policy because "customers are mainly located in the Nordic countries and Northern Europe, areas with low water scarcity," and Borås "is not located in a high water-stress area." "Sustainable oceans and seas are not included in the Group's policies."

Through the Purchasing Policy and Design Policy, purchasing is directed toward certified, less water-intensive materials/processes, and the Supplier Manual's chemical requirements (E2) reduce water pollution. The Supplier Code of Conduct establishes suppliers' responsibility "to provide unrestricted access to clean water for their workers." Group Management approves the Design and Purchasing Policies; the Sustainability Director holds operational responsibility.

Actions and resources related to water and marine resources

Reference: pages 52-53.

"Ellos Group currently has no actions that are directly targeted at water use within the supply chain." Reduction is pursued indirectly through certified materials: GOTS (strict water/wastewater standards), the Better Cotton Initiative, and LENZING™ ECOVERO™ viscose (produced from certified wood with "significantly lower water consumption"). Jeanologia laser/ozone finishing technology can cut denim wash-water use "by up to 95 per cent compared with traditional methods"; 68% of the Group's own-brand denim production is Jeanologia-certified.

Supplier water data is collected via the Worldfavor platform, currently covering Tier 1 suppliers (generally low water use, sewing/assembly) with Tier 2 (more water-intensive wet processes) planned next. "This work is an ongoing process without a specific end date."

Targets related to water and marine resources

Reference: page 52.

"Ellos Group's material impact and risk related to water are primarily found in the production stage for the Group's own products. Data collection from Tier 1 suppliers has been initiated, but these data need to be verified and analysed before Ellos Group can establish measurable and time-bound targets related to water resources." No quantified water target is therefore yet in place.

Water consumption

Reference: page 52.

"The Group's own operations are located in an area without water risk and receive water supply and wastewater management from Borås Energi och Miljö. All water is treated and returned for reuse. In 2025, the total water consumption amounted to 7,469 m³. The data is validated by Borås Energi och Miljö, ensuring accuracy and transparency." No value-chain water-consumption figure is given, consistent with the statement that upstream Tier 1-4 supplier water data collection is still in progress (E3-2).

Policies related to resource use and circular economy

Reference: pages 52-53.

Three policies apply: the Design Policy requires all own-brand products "to be designed with sustainability as a starting point and in preparation for forthcoming legislation on sustainable products and the circular economy (Ecodesign for Sustainable Products Regulation, ESPR)," covering the full life cycle – material selection, production, use, repair, recycling, reuse – with emphasis on recycled-material share, waste reduction, lifetime extension, mono-material design and energy efficiency. The Purchasing Policy directs sourcing toward organic cotton, recycled polyester and FSC-certified wood and bans air transport (tightly regulated exceptions only, from 2025). The Environmental Policy covers energy efficiency, renewable-energy transition, Scope 3 emission reduction, sustainable transport/packaging, and recycling/waste management, with a packaging ambition of "100 per cent recycled material in packaging by 2030."

The Board approves the Environmental Policy; Group Management approves the Design and Purchasing Policies; the Sustainability Director holds operational responsibility.

Actions and resources related to resource use and circular economy

Reference: pages 53-54.

Materials: cotton is 30% of own-brand textile content; the Group targets 100% "more sustainable cotton" (organic, recycled, or BCI-certified). 52% of own-brand textile products are mono-material, easing recycling. In 2025, 79% of own-brand viscose was Lenzing EcoVero (certified wood source, up to 50% lower emissions/water impact than conventional viscose); 68% of own-brand FSC-certified wood furniture.

Packaging and waste: e-commerce bags are 80% post-consumer / 20% post-industrial recycled plastic, cutting CO2e per bag by 58% versus virgin plastic; cartons are predominantly recycled paper. Damaged-packaging products are repacked and resold; otherwise sold through the Outlet store.

Materials – wood: "all wood and paper products comply with the EU Timber Regulation No. 995/2010."

The implementation of planned measures "does not require any significant operating expenditure (OpEx) or capital expenditure (CapEx)." Long-term goal: 100% of own-brand textile materials certified or recycled by 2030.

Targets related to resource use and circular economy

Reference: pages 54-55.

Five measurable, time-bound targets, all for 2030 (interim 2025 targets in brackets), with 2025 actual / 2024 actual:

• More sustainable cotton: target 100% by 2030 (interim 50% by 2025) – actual 96% (2025) / 95% (2024); baseline 81% (2018).
• Recycled polyester/polyamide: target 100% by 2030 (interim 50% by 2025) – actual 64% / 57%; baseline 1% (2019).
• EcoVero viscose: target 100% by 2030 (interim 50% by 2025) – actual 79% / 67%; baseline 37% (2023).
• FSC-certified solid-wood furniture: target 100% by 2030 (interim 50% by 2025) – actual 69% / 52%; baseline 0% (2019).
• Sales of more sustainable textile products: target 100% by 2030 (interim 50% by 2025) – actual 65% / 57%; baseline 19% (2019).

"An interim target of 50 per cent was set for 2025, which has been exceeded by a wide margin" for each of these. Data is sourced from the Group's BI system; "no changes have been made to data sources or processes during the defined measurement period." Targets "go beyond legislative requirements."

Resource inflows

Reference: page 55-56.

"In 2025, the Group's products contained more than 170 different materials." Total weight of purchased goods rose 6% year on year. Top materials by weight (tonnes): Polyester 2,371; Cotton 1,723; MDF 1,498; Steel 653; Iron 619; Polypropylene 477; Chipboard 410; Glass 408; Plywood 391; Pine 364.

Totals (2025 / 2024, tonnes): Total weight of products and materials 14,705.7 / 13,818.3; technical materials 8,896.9 / 8,307.5; biological materials 5,808.7 / 5,510.9, of which 39.9% / 38.7% sustainably sourced (certified GOTS, OCS, BCI, FSC, EcoVero); secondary (reused/recycled) materials 1,786.7 / 1,029.2 tonnes, or 12.2% / 7.4% of total inflows.

"Material data is available for 95 per cent of the total weight, while the remaining share is estimated through an extrapolation... The reported data on resource inflows has not been validated by an external body." A new product data system in 2026 is expected to improve data quality.

Resource outflows

Reference: page 56.

Design for durability and recyclability: "each product category includes classic and timeless designs to further extend product lifespan," mono-materials are prioritised for recyclability, and some furniture segments offer replaceable covers to extend product life.

Recyclable content (2025): textile products – 2,685,028 kg recyclable of 4,319,875 kg total (62.2%), counting only textile clothing/home textiles (38% of outflows by weight) and defining "recyclable" as ≥95% single-fibre content. Packaging – 2,236,386 kg recyclable of 2,236,386 kg total (100%), "as no material mixtures are used."

"In 2025, 729 kg of products were sent for destruction due to mould and pest infestation" (400 apparel units, 31 home textile units, 814 decoration units; causes: moisture damage and pest infestation). Repairability: "Most textile products in the range can be repaired if the damage occurs in a seam"; some products include a spare button; furniture and more complex products currently have no offered repair service or spare parts.

Waste

Data drawn from the E5-5 Resource outflows section (pages 56-57), covering the "Waste" content that the 2025/2026 ESRS separates into its own disclosure requirement; this split did not exist under the 2023 ESRS the report was prepared against.

"The Group's waste primarily consists of packaging from logistics operations, with corrugated cardboard accounting for the largest share. Plastic and untreated wood also contribute significant portions of total waste." "In 2025, 87 per cent of the generated waste was sorted into separate fractions and recycled, while 13 per cent was used for energy recovery. Only a negligible share was sent to landfill" (versus 23.4% non-recycled in 2024).

Total waste diverted from disposal: 628.4 tonnes (589.7 in 2024), of which recycling 627.5 (584.1). Total hazardous waste: 0.1 tonnes in 2025 versus a restated 8.1 tonnes in 2024 – "the lower quantity of hazardous waste reported for 2025 is due to improved categorisation. The 2024 figures reflect an overestimation of hazardous waste."

"Through the Group's waste management service provider, detailed and reliable tracking of all waste from its own operations is obtained, based on direct measurements."

Policies related to own workforce

Reference: pages 57-58.

"The Group has policies in place to manage all identified material impacts related to its own workforce... developed in accordance with applicable legislation and with the interests of employees in mind. The policies are easily accessible on the intranet. No significant updates to the policies were made during the reporting period."

Human rights: the Group "respects human rights, including labour rights, civil and political rights and economic, social and cultural rights" per the Human Rights Policy (OECD Guidelines-based).

Health and safety: governed by the Occupational Health and Safety Policy, covering "the entire workforce and all individuals present at Ellos Group's workplaces." The CEO holds ultimate responsibility; the Safety Committee (with elected Handels/Unionen safety representatives) applies and develops the policy, participates in planning of premises/equipment/processes, and helps develop prevention action plans.

Diversity and inclusion: the Equality and Diversity Policy applies to all employees with "zero-tolerance... towards all forms of offensive treatment, harassment, sexual harassment or discrimination." "There are no specific commitments in the Equality and Diversity Policy related to the inclusion or positive action of individuals... who may be at particular risk of vulnerability." The CEO has overall responsibility; the People & Culture Director coordinates implementation.

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

Reference: pages 58-59.

Dialogue channels include workers' representatives, safety representatives, goal/competence-development reviews, and "a direct link to, the whistleblowing service," all accessible via the intranet. "Four employee surveys are conducted annually," measuring employee perceptions including the Employee Net Promoter Score (eNPS) – percentage of promoters minus detractors. "In 2025, the average eNPS score was 33 (19). The Group's ambition is to maintain an eNPS above 25." The People & Culture Director has overall responsibility for monitoring engagement and following up on survey-based actions.

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

Reference: pages 59-60.

Employees experiencing bullying, discrimination or harassment can contact a manager, a health and safety representative, People & Culture, or report anonymously via the whistleblowing service. "People & Culture[,] who analyse what has occurred in light of the relevant legislation, speak with the parties involved, verify the facts and identify actions to remedy negative impacts." "Should penalties be imposed by, for example, the Equality Ombudsman or the Labour Court, the Group complies with those decisions."

Grievance-channel information is mandatory in new-employee onboarding and reinforced through awareness campaigns. Effectiveness is monitored via an employee-survey question on whether staff "know how to act and whom to turn to." "The Group does not currently track employees' confidence in the channels but intends to explore the possibility of introducing this next year."

Taking action on material impacts on own workforce

Reference: pages 60-61.

Material impacts are health and safety for employees and discrimination against employees. Incidents are documented in reports signed by the reporter, a safety representative and the immediate manager, escalated to the Security Manager, who decides whether reporting to the Swedish Work Environment Authority is required, and reviewed by the Safety Committee.

Health and safety: regular workplace inspections with safety representatives (at least annually); collaboration with an external occupational-healthcare partner; 2025 lectures on stress/exhaustion prevention, relaxation techniques and menopause/midlife women's health; the "Movement" wellness programme (padel, golf, trail running), free gym access and wellness allowances.

Equality and diversity: planned 2026 manager training on inclusive leadership and unconscious bias; an annual pay audit "to counteract unjustified pay differences based on gender." "The actions do not entail significant operating expenditure (OpEx) or require capital expenditure (CapEx)." All 2025 incident cases "resulted in employment-law measures, information initiatives and training measures to prevent future incidents" (cross-referenced to S1-17).

Targets related to own workforce

Reference: page 61.

Gender-balance targets, linked to UN SDG 5: 60/40% (women/men) among all employees, given the Group operates in a female-dominated industry, and 50/50% among managers at all levels and within Group Management. 2025 actuals: overall distribution 62/38% (61/39% in 2024); managers excluding Group Management 55/45% (53/47%); Group Management 38/62% (33/67%).

"The targets are recurring and apply to each full reporting period... no milestones or interim targets have been set, nor is there a base year or baseline value." For health and safety, "there are currently no established measurable, outcome-oriented or time-bound targets... The Group assesses that measuring and analysing outcomes is sufficient to monitor the effectiveness of the actions undertaken," reviewed annually for whether a target should be set.

Characteristics of the undertaking's employees

Reference: page 61.

Average number of employees (FTE), 2025 / 2024: women 314 / 305; men 195 / 197; total 509 / 502, all in Sweden (Borås). By employment type, 2025 total: permanent 481, temporary 23, non-guaranteed hours 5. "Temporary employment mainly consists of parental leave cover. The majority of on-demand employees are school students who assist in logistics operations during peak periods." On-demand hours are standardised at 160 hours/month.

Turnover: 59 employees left in 2025 (40 in 2024); turnover rate 11.6% (8.0%). Note: the 2024 sustainability statement covers 2024-01-01 to 2024-12-31 while the 2024 financial statements cover only 2024-10-15 to 2024-12-31, so the two 2024 figures do not align.

Collective bargaining coverage and social dialogue

Reference: page 62.

"All individuals who were employed within Ellos Group, permanent, temporary and on-demand employees, were, without exception, covered by collective agreements and represented by workers' representatives during the reporting period." Coverage rate: 100%, all employees within the EEA (Sweden). "The Group does not have an agreement with its workers on representation in a European Works Council or a council in a European Company (SE) or a European Cooperative Society (SCE)."

Diversity metrics

Reference: page 62.

Top management (Group Management) gender split: 2025 – 3 women (37.5%), 5 men (62.5%); 2024 – 3 women (33.3%), 6 men (66.7%).

Age distribution as at 2025-12-31 (2024-12-31): under 30 – 118 (117); 30-50 – 277 (269); over 50 – 213 (229); total headcount 608 (615) – this headcount figure differs from the S1-6 average-FTE figure because it is measured at the balance sheet date.

Adequate wages

Reference: page 62.

"Each year, Ellos Group carries out a salary review in accordance with collective agreements, in which minimum wages are clearly stipulated," negotiated between employers and trade unions "in line with the EU Directive on adequate minimum wages (2022/2041)." Share of employees not receiving an adequate wage: 0% in both 2025 and 2024.

Social protection

Reference: page 62.

"All employees are covered by social protection in the event of income loss due to major life events such as illness, unemployment, occupational injury, parental leave and retirement, in accordance with Swedish legislation." No further breakdown by category or country is given, consistent with the entire workforce being based in Sweden.

Training and skills development metrics

Reference: pages 62-63.

"All employees within Ellos Group have an individual performance and development plan," set annually with the manager and reviewed twice a year. 89% of employees had a performance and development review with their manager in 2025 (women 90.8%, men 86.7%); the remainder mainly due to parental or other leave.

"In 2025, a total of 4,267 training hours were successfully completed... an average of 8 hours of training per employee." (2024 comparatives for average training hours are not disclosed – shown as "-".) Data is drawn from the Group's HR system and verified by People & Culture staff.

Health and safety metrics

Reference: pages 63-64.

"100 per cent of the Group's employees are covered by Ellos Group's occupational health and safety system." 2025 vs 2024: work-related fatalities 0 in both years (figures cover employees and non-employees in the own workforce); work-related accidents 22 (30); lost days due to work-related injuries 227 (3); frequency of accidents 25 (35) per stated basis.

"Work-related accidents have decreased during the year, but one of the reported incidents resulted in long-term sick leave. This is the reason why the number of lost days is much higher for 2025." "Reporting of cases related to work-related ill-health is not carried out due to legal restrictions on the collection of such information."

Work-life balance metrics

Reference: page 63.

Right to family-related leave: 100% for both women and men in 2025 and 2024, under the Swedish Act on the Right to Leave for Urgent Family Reasons and the Parental Leave Act. Use of family-related leave, 2025 (2024): women 61.1% (36.7%); men 36.4% (22.8%); total 51.7% (31.3%).

Remuneration metrics (pay gap and total remuneration)

Reference: page 63.

Gender pay gap: 4.4% in 2025, down from 10.5% in 2024, calculated on gross hourly pay (monthly salary converted to hourly). "In 2025, the gender pay gap decreased. This is primarily attributed to the Group's targeted efforts over recent years to address the gap." On-demand employees are excluded from the calculation.

CEO-to-employee pay ratio: 11.8 in 2025, down from 15.5 in 2024, calculated as CEO total remuneration (fixed, variable, taxable benefits, pensions excluded) divided by the median remuneration of all other employees. The decrease "is due to the variable components of the CEO's compensation." No adjustment is made for purchasing-power differences since all employees are paid in SEK.

Incidents, complaints and severe human rights impacts

Reference: page 64.

2025 (2024): incidents of discrimination, including harassment – 4 (0); complaints via grievance mechanisms – 8 (0); complaints via OECD National Contact Points – 0 (0); fines/sanctions/compensation – SEK 0.2 M (0); cases of severe human rights impacts – 0 (0).

"In 2025, eight complaints were reported through the grievance mechanisms, of which four cases concerned work-related incidents resulting from discrimination or harassment within the own workforce. All cases resulted in measures being taken, including information and training initiatives to prevent recurrence." The SEK 0.2 M in fines/penalties related to employment-law disputes, "none of these fines or penalties concerned discrimination, harassment or cases of severe human rights impacts." "The documentation procedure was introduced in 2025, and it is possible that additional cases might have been identified had the Group initiated the compilation process earlier in the year."

Policies related to value chain workers

Reference: pages 64-65.

Human Rights Policy (UNGP-based): "requires the Group to prevent its operations from causing harm to people and their rights," covering working environment, living wages, working hours, freedom of association, collective bargaining, forced labour and child labour. "Human trafficking is not currently covered in the policy, but the intention is to integrate this in the next revision."

Supplier Code of Conduct: requires own-brand suppliers to follow international conventions on worker safety/conditions; "explicitly prohibits forced labour, child labour and human trafficking"; aligned with the ILO Declaration. External-brand suppliers must have an equivalent code; non-compliant suppliers must submit a corrective action plan within six months or lose the business.

"During 2025, Ellos Group identified several deviations from the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work and the OECD Guidelines for Multinational Enterprises... during audits. They primarily related to working environment and safety conditions and insufficient conditions for fair wages." The Board holds ultimate responsibility; the Purchasing Director and Sustainability Director hold operational responsibility respectively.

Processes for engaging with value chain workers about impacts

Reference: page 66.

"Factory audits are conducted regularly by a nominated third party in accordance with the Amfori BSCI and Sedex SMETA standards... An inspection is generally carried out every 12-24 months." Ellos Group is a member of Amfori, which "through its global network works to promote more sustainable trade." Site visits by Ellos Group employees to supplier factories, "primarily in China, India and Bangladesh," support open dialogue on working conditions, climate action and quality.

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

Reference: pages 66-67.

Breaches of the Supplier Code of Conduct or failed audits trigger root-cause analysis and a corrective process. Channels for workers: an anonymous whistleblowing service on the Group's website, and access to International Accord's grievance mechanism in Bangladesh. "Amfori BSCI audits include specific assessments of workers' awareness of and trust in grievance mechanisms." Suppliers must inform employees of the whistleblowing service (a Supplier Code of Conduct requirement) and establish their own secure, confidential workplace-level grievance channels, monitored via audits and worker interviews.

Taking action on material impacts on value chain workers

Reference: pages 67-68.

New own-brand suppliers (61% of sales value) undergo pre-onboarding assessment with Amfori BSCI/Sedex SMETA certificates and must sign the Supplier Code of Conduct. Existing suppliers face regular third-party inspections (200+ control points: documents, worker/management interviews, facility inspection). Results feed a proprietary social sustainability grading system built with Bureau Veritas on the Amfori BSCI base, adding women's-rights/safety questions and a severity breakdown; suppliers are graded A-Green, B-Blue, C-Orange, D-Red. Deviations trigger a Corrective Action Plan (CAP) with follow-up verification; repeated or serious violations can lead to termination, "always taking into account the potential negative impact such a termination could have on workers."

Fire, electrical and building safety are addressed through the International Accord in Bangladesh and Pakistan, where the due diligence process identified a higher health-and-safety risk. "No severe human rights issues or incidents related to workers in the value chain were reported in 2025." Actions are integrated into regular operations with no specific OpEx/CapEx allocated.

Targets related to value chain workers

Reference: page 69.

Target 1: 100% of own-brand Tier 1 suppliers to have an approved audit report from the past 24 months – achieved at 100% in both 2025 (233 active suppliers, 125 protocols reviewed) and 2024 (238 suppliers, 160 protocols reviewed).

Target 2: 90% of active own-brand Tier 1 suppliers to reach the two highest grading levels (Blue/Green) by end of 2030 – 87% at end of 2025, against an established 2024 baseline of 81%. 2025 grading distribution: A-Green 9.9% (23 suppliers), B-Blue 77.3% (180), C-Orange 7.3% (17), D-Red 5.6% (13); total 233 suppliers.

Targets "were established by an experienced internal team consisting of specialists within CSR and Sourcing. External stakeholders have not been involved in setting or evaluating the targets," and "have not changed in 2025."

Policies related to consumers and end-users

Reference: pages 69-70.

Policies cover the identified material impacts – personal data/credit information and product safety. "A policy for responsible marketing has been developed but has not yet been formally approved by Group Management."

Human rights: the Human Rights Policy covers "the right to personal safety"; an annual systematic review of material human rights risks to consumers is conducted. "No cases of non-compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work or the OECD Guidelines for Multinational Enterprises in the downstream value chain were reported during the reporting period."

Data protection: governed by the Data Protection Policy (applies to all employees and the Board), specified further in the Privacy Policy and Cookie Policy, GDPR-aligned, informing customers of their right to complain to IMY (Sweden's supervisory authority).

Product safety: governed by the Product Policy, aligned with the General Product Safety Regulation (GPSR), covering risk assessment, testing, quality control and manufacturing-transparency guidance for consumers.

Processes for engaging with consumers and end-users about impacts

Reference: page 71.

Ellos Group engages via "customer service channels, the website and social media," including in connection with complaints about faulty products or suspected product-related injury, and via a dedicated email address for the Data Protection Officer. "The Customer Service Manager has the operational responsibility for ensuring active engagement with consumers and for ensuring that their feedback is considered in the Group's decision making and improvement processes." The Data Protection Officer oversees GDPR compliance of the engagement process.

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

Reference: pages 71-72.

2025 channels: email, telephone, chatbot and an AI-driven FAQ. Remedies "may be provided in different ways depending on the nature of the case," including repair, replacement, price reduction, cancellation or reimbursement. Customers can exercise GDPR rights (erasure, subject access, objection) by email or phone. Effectiveness is measured through the Customer Satisfaction Index (NKI), Trustpilot and Net Promoter Score (NPS). Whistleblowing protections against retaliation extend to this channel (cross-referenced to G1-1).

Taking action on material impacts on consumers and end-users

Reference: pages 72-73.

Personal data: a Data Protection Officer is appointed (not legally mandatory but chosen "to ensure effective management of GDPR related risks"), supported by a GDPR Council (Group Management, Legal, customer-facing functions); annual reporting to the Council and CEO.

Product safety: RSL/MRSL substance bans; mandatory testing via external labs in China, Bangladesh and India and the Group's own Borås facility; children's clothing tested to EN 14682; "Ellos Group does not permit animal testing." External-brand products get risk-based spot checks.

Responsible marketing: a diverse range of models, "restrictive in its use of retouching," no alteration of body shape, stretchmarks or wrinkles; the 2025 "Full of life" campaign for women in midlife across Sweden, Norway, Denmark and Finland; digital-accessibility work under the Swedish Act (2023:254) across shopping, checkout, Elpy and returns.

Measures "do not require significant operating expenditure (OpEx) or capital expenditure (CapEx) beyond the ordinary budget" and are monitored via NKI, Trustpilot and NPS.

Targets related to consumers and end-users

Reference: page 73.

"There are currently no established measurable, outcome oriented or timebound targets related to personal data and credit information, product safety or responsible marketing." The Group instead relies on "the existing follow-up of customer service cases, cases involving the Data Protection Officer or the legal counsel, and the number of product recalls" to monitor effectiveness. "The Sustainability Manager, together with the responsible director within Group Management, conducts recurring evaluations of the need to establish targets."

Business conduct policies and corporate culture

Reference: pages 73-75.

Business conduct guidelines cover "bribery and corruption, competition, trade sanctions, sponsorships and donations, diversity and integrity"; all employees, managers and Board members must follow them. The Board holds ultimate oversight; the CEO is responsible for compliance; Group Management for fostering the culture. "The Group currently does not have a policy for training on business ethics but intends to review the need to introduce one."

Corporate culture: based on the core values "Entrepreneurship, Humble Winners and Joy," with principles including open communication, respect, encouraging initiative, and preventing conflicts of interest.

Whistleblower protection: the whistleblowing service, run by "an external impartial service provider," is open to employees and external parties including suppliers' workers; "all whistleblowers are protected under the Swedish Whistleblower Act." The whistleblowing team comprises the Sustainability Manager, People & Culture Director, Security Manager and General Counsel.

Animal welfare: Ellos Group is a Fur Free Retailer programme member and its Product Policy bans real fur, mulesing, angora wool, animal testing and products from endangered species, and restricts down/feathers to meat-production by-products with no live plucking; leather is accepted only from animals bred for meat production.

Management of relationships with suppliers

Reference: pages 75-76.

Ellos Group "prioritises long term supplier relationships... As a result of this, the Group increased the average order value with its suppliers by 14 per cent during 2025 compared with the previous year." The Purchasing Policy governs material/supplier selection, payment terms and delivery times; standard payment terms are "normally 30-60 days net."

Supplier selection: environmental and social factors are assessed; own-brand suppliers must pass an evaluation and sign the Supplier Code of Conduct (see S2-1). External-brand suppliers must have an internationally aligned Code of Conduct, a risk-identification process for their own value chain, a restricted-substances list matching Ellos Group's, and chemical-monitoring procedures.

Late payment: "The Group does not have a policy to prevent late payments, particularly to small and medium sized enterprises, but the Group has internal processes to ensure that late payments are made as infrequently as possible," via an automated invoice-management and order-matching workflow with reminders and monitoring of unapproved overdue invoices.

Prevention and detection of corruption and bribery

Reference: page 77.

Managed through the Anti-Bribery and Anti-Corruption Policy and Sponsorship Policy; suppliers commit via the Supplier Code of Conduct, and, "due to the complexity of the upstream value chain," must also monitor their own sub-suppliers – "the Group does not accept unauthorised sub suppliers." Concerns can be reported via the whistleblowing service, handled confidentially by a dedicated function, with incidents reported to Group Management and the Board.

"Training on corruption and bribery has been provided to all employees in the Group during the year." Annual confirmation of having read and understood the policy: 100% of Group Management and the Board; 65.8% of all employees in 2025 (no 2024 comparative given). High-risk functions identified: purchasing, sales and marketing, finance, legal, and leadership positions; 67% of employees in those high-risk functions completed the annual confirmation. "Group Management and the Board do not receive recurring training on corruption and bribery but are assessed to have sufficient competence in the area." No significant OpEx/CapEx is attributed to this work.

Targets related to business conduct

This disclosure requirement is standalone only from the 2025/2026 ESRS; under the 2023 ESRS the report is prepared against, business conduct targets fell under MDR-T. No stated numeric target for corruption prevention, whistleblower protection or the other G1 topics is given anywhere in the statement.

Ellos Group instead tracks effectiveness in the absence of a formal target, satisfying MDR-T's other limb: the annual confirmation completion rate of the Anti-Bribery and Anti-Corruption Policy is measured and reported (100% of Group Management/Board, 65.8% of all employees, 67% of high-risk-function employees in 2025, G1-3, p.77); incidents of corruption or bribery are tracked through the WhistleB whistleblowing service and other grievance channels, with the Group reporting "not become aware of any breaches... during the year" and "no convictions or fines" (G1-4, p.77); and payment-practices compliance is monitored, with 91% of product-supplier invoices and 90% of cost-supplier invoices paid on time in 2025 (G1-6, p.77). Beyond training completion and incident monitoring, no dedicated measurable, outcome-oriented target for business conduct is disclosed.

Incidents of corruption or bribery

Reference: page 77.

"The Group has not become aware of any breaches of the Anti-Bribery and Anti-Corruption Policy during the year. The Group has also not had any convictions or fines for violations of anti-corruption or anti-bribery laws during the reporting period." Data is collected through the WhistleB whistleblowing service and other grievance channels. "The information relating to corruption and bribery has not been validated by any external party other than the assurance provider."

Payment practices

Reference: page 77.

"During the year, Ellos Group has paid its supplier invoices on average 37 days (35) after the invoice date." Standard contractual terms are 30 or 60 days for product suppliers and 30 days for cost suppliers. On-time payment rate: 91% (86%) of product-supplier invoices and 90% (84%) of cost-supplier invoices; product invoices made up 93% (92%) of all invoices paid.

"The Group's payments of supplier invoices during the year are not assessed to have resulted in significant negative consequences for small and medium-sized enterprises. Ellos Group has not been involved in any legal proceedings regarding late payments to suppliers during the year." Not externally validated beyond the assurance provider.