Elopak

The role of the administrative, management and supervisory bodies

Reference: pages 61-62 (listed in the ESRS content index at page 75). Composition datapoints under §21(c) are incorporated by reference to the Governance chapter, 'Board of directors', pages 47-48 (page 60).

"The Board is accountable for sustainability matters", with day-to-day management of the IROs, strategy, targets and reporting "handled by the line organization and embedded into regular business processes" (page 61).

Committee structure (page 61):

• The Board Audit and Sustainability Committee (BASC) is "mandated by the Board to oversee ESG governance, frameworks and reporting", including the attestation process, compliance, stakeholder expectations, CSRD reporting and the effectiveness of internal control and risk management. The BASC "is informed yearly about the DMA process and material topics".
• The Board Succession and Compensation Committee (BSCC) oversees management compensation and succession.

Management "is responsible for the execution of sustainability initiatives and approving sustainability-related targets", and has delegated regulatory and reporting tasks to an ESG council chaired by the EVP Product and Development, meeting quarterly, supported by subject-matter-expert networks (page 62).

Diversity (page 62): the Board has a gender diversity ratio of 75%, "consisting of three females (43%) and four males (57%)", five shareholder-elected directors and two employee representatives, all non-executive, of which 57% are independent. Management has a gender diversity ratio of 25%, "two females (20%) and eight males (80%)". Elopak states "No other forms of diversity have been measured".

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

Reference: pages 62-63 (ESRS content index, page 75).

"Elopak has integrated risk assessments, target setting and KPIs in the business planning process, thereby ensuring alignment between IROs, business plan and strategy" (page 62). The Board was informed "on a regular basis, both directly and through its committees"; Management "kept a range of sustainability matters on their monthly meeting agenda".

A quarter-by-quarter table of 2025 agenda items is given for each governing body (page 63):

Board - Q2 approval of the 2024 Annual Report including the CSRD-compliant Sustainability statement, approval of the Human and labor rights transparency statement, sustainability-roadmap update and a safety review; Q3 a "Deep dive on the sustainability roadmap"; Q4 an update on legal and compliance matters including risk assessment.

BASC - Q1 review of the 2024 Annual Report; Q2 review of the Human and labor rights transparency statement; Q3 "CSRD audit plan presented by the external auditor"; Q4 "Results of the DMA update and the next steps for CSRD reporting", the interim CSRD audit summary, and the annual legal and compliance review.

Management - monthly safety updates in every quarter, plus in Q4 "Results of the DMA update presented by the Sustainability controlling team", "Anchoring of CSRD targets", and a whistleblower-case status update.

Integration of sustainability-related performance in incentive schemes

Reference: page 63 (ESRS content index, page 75). The §29 datapoints are incorporated by reference to the Remuneration report 2025, section 'Long-term incentive program (LTIP)', page 14 (page 60).

"The Long term incentive program (LTIP) aims to ensure achievement of Elopak's long term strategic goals in a sustainable way. The LTIP applies to the Management and senior management and includes performance on GHG emission reduction targets as part of the incentive scheme" (page 63).

Elopak does not quantify the percentage of variable remuneration linked to sustainability or climate performance inside the Sustainability statement itself, pointing instead to the separate Remuneration report. Target-setting progress under E1-4 notes that "Additional details on the sustainability-related incentive schemes can be found under 'General information'" (page 81). The Board Succession and Compensation Committee is the body responsible for overseeing management compensation (page 61).

Statement on due diligence

Reference: pages 63-64 (ESRS content index, page 75). Also listed in the Appendix B datapoint table as ESRS 2 GOV-4 §30 at page 63 (page 133).

"The objective of sustainability due diligence is to identify, prevent, mitigate, and take responsibility for managing actual and potential impacts on the environment and people. We are committed to conducting due diligence in line with the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Responsible Business Conduct, and the Norwegian Transparency Act" (page 63). Elopak "annually publishes a statement of due diligence assessments in accordance with the Transparency Act on our website".

A mapping table sets out where each core element of due diligence is addressed (page 64):

• (a) Embedding in governance, strategy and business model - GOV-2, GOV-3, SBM-3
• (b) Engaging with affected stakeholders - GOV-2, SBM-2, IRO-1, S1-2, S2-2
• (c) Identifying and assessing adverse impacts - IRO-1, SBM-3
• (d) Taking actions - "MDR-A: E1-3, E4-3, E5-2, S1-4, S2-4, S4, G1-3"
• (e) Tracking effectiveness and communicating - "MDR-T: E1-4, E4-4, E5-3, S1-5, S2-5, S4, G1" and "MDR-M: E1-5, E1-6, E1-7, E5-4, E5-5, S1-6, S1-7, S1-8, S1-9, S1-14, S1-16, S2-5, S4, G1-4"

Risk management and internal controls over sustainability reporting

Reference: page 64 (ESRS content index, page 75).

"In 2025, we established new governance documents to improve our sustainability reporting and reinforce internal controls for CSRD reporting and carbon accounting. The CSRD Reporting procedure identifies risks, outlines internal control strategies and assigns responsibilities to ensure the accuracy of our disclosures. The introduction of the Climate impact standard and the Carbon accounting procedure further strengthens our oversight and transparency in climate-related reporting and governance" (page 64). New digital tools for disclosure management and carbon accounting were implemented, providing "improved compliance controls in the reporting processes".

"The CSRD project management team monitored and assessed risks in reporting material topics, providing monthly updates to the appropriate management bodies. Risk prioritization follows the approach outlined in the CSRD Reporting procedure, as no separate methodology has been established" (page 64).

Main risks identified: "data complexity, insufficient compliance controls, involvement of multiple internal stakeholders and potential delays", which "could result in inaccuracies within the sustainability reporting". Mitigations are "strengthening internal compliance controls and ensuring clear and structured project management". After publication the CSRD project management team runs a post-mortem whose "evaluation results form the basis for recommendations related to compliance controls, efficiency improvements and possible adjustments to internal functions or processes" (page 64).

Strategy, business model and value chain

Reference: pages 65-66 (ESRS content index, page 75). §40(a) and §40(g) are incorporated by reference to 'How we create value' (page 7), 'Global presence' (page 8), 'Market drivers' (page 11) and 'Our strategy' (pages 13, 19), per page 60. Elopak applies the phase-in for "SBM-1 40b, c (significant ESRS sectors)" (page 59).

"Elopak provides end-to-end packaging solutions, delivering fiber-based packaging, filling machines and technical and after market services. Elopak has sales to over 70 markets, in Europe and North America as well as emerging markets in MENA and India", supplying dairy, juice, plant based and home and personal care segments (page 65).

"Sustainability is embedded in our strategy, ambitions and targets, and one of the main pillars in our strategy is to 'Leverage the plastic replacement shift'... As part of this priority, Elopak is aiming to accelerate the shift from plastic to carton packaging, beginning with scaling our D-PAK™ fiber-based solutions in the home and personal care market" (page 65). Mid-term People and Planet targets "correspond directly to those set for the material topics S1 Own workforce (health and safety), E1 Climate change, and E5 Resource use and circular economy".

A two-column value chain map for cartons and filling machines sets out upstream, own operations and downstream stages (page 66): wood "mainly sourced from Sweden, Finland and the US", petrochemicals into polymers, bauxite into aluminium; iron ore from "Australia, Brazil, China and India" for filling machines; aseptic filling machines produced at the German plant with machines also bought from Shikoku; downstream, cartons are filled by customers and "After use, cartons are handled by local waste managers for recycling and remade into new products".

The joint ventures in Mexico and the Dominican Republic "are not consolidated and therefore included as part of Elopak's value chain" (page 59).

Interests and views of stakeholders

Reference: pages 68-69 (ESRS content index, page 75).

"Stakeholder engagement is a central part of the DMA, with Elopak focusing on qualitative interviews and regular contact with key stakeholders" (page 68). Elopak engages "our workforce, suppliers, customers, investors, banks, unions, NGOs and authorities". In Europe it engages unions "through the European Works Council (EWC), holding regular meetings"; outside Europe there are "follow-up and separate dialogues with unions at each site".

Elopak names its own gap: it "will continue with stakeholder dialogue and work with improvements in areas that need to be further assessed like communication with affected communities and workers in the value chain, as this is not directly covered in our current stakeholder dialogue" (page 68).

A table covers eight stakeholder groups with interaction mode, topics raised and outcome (pages 68-69): customers/retailers (raw material sourcing, circularity, climate, product development); suppliers (climate and decarbonization, forestry and biodiversity, circularity, workers in the value chain); shareholders/investors and financial institutions (systematic ESG approach, ambitious targets); employees (health and safety, well-being, diversity and inclusion, code of conduct); government/regulators; NGOs and associations (transparency, nature, human and labor rights, responsible sourcing); local communities (safety, good place to work, work life balance); and the EWC unions, with "Meetings once a year", frequent dialogue and "Bi-monthly updates with management".

"The outcomes of the DMA were presented to relevant management bodies for review and anchoring" (page 68).

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

Reference: page 67, with the full IRO overview at pages 71-72 (ESRS content index, page 75). Elopak applies the phase-in for "SBM-3 48e (anticipated financial effects)" (page 59).

"None of the material risks or opportunities identified in the DMA were assessed to have a financial effect on financial position, financial performance and cash flows in the current financial year. See more information in Note 30 Financial climate impact" (page 67).

Elopak states plainly that it has no ESRS-compliant resilience analysis: "Elopak has not conducted a resilience analysis that is ESRS compliant, as this will be addressed in 2026 following the completion of the climate risk analysis and biodiversity strategy" (page 67).

Topic-by-topic interaction with strategy and business model (page 67) covers climate change ("We aim to leverage the plastic replacement shift"), biodiversity ("None of the sites in Elopak's own operations were found to be material due to negative or positive impact on biodiversity sensitive areas"), own workforce ("The production of carton and filling machines at our plants pose a risk of injuries for our employees"), and workers in the value chain, where negative impacts "are especially associated with workers in processing activities of certain raw materials and transportation".

The 'Overview of material IROs' table (pages 71-72) lists 24 individually described IROs across E1 (5), E4 (1), E5 (7), S1 (4), S2 (3), S4 Food safety, entity-specific (1) and G1 (3), each tagged to value chain position (upstream / own operations / downstream) and time horizon (short / medium / long).

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

Reference: page 70, with topic-specific process descriptions at pages 73-74 (ESRS content index, page 75). The E1 datapoints §20(b)(ii) and (c)(ii) are incorporated by reference to 'Note 30 Financial climate impact', page 192 (page 60).

"The DMA methodology considers a sustainability topic as material if it significantly impacts people or the environment (impact materiality) or if it presents risks and opportunities that could materially affect our future financial performance or position (financial materiality)" (page 70). Both dimensions "were scored on a 1-5 scale, resulting in a prioritized list of IROs", with negative human rights impacts prioritising "severity over likelihood".

The four-phase process is Understand, Identify, Evaluate, Decide (page 70). In 2025 Elopak "reviewed the long list of potential material matters, integrated new inputs, and updated scoring using a new tool", and "The DMA results were validated by the ESG Council... and presented to the BASC". Elopak notes a limitation: "Desktop research was conducted instead of interviews with external stakeholders" and "Going forward, we will explore ways to improve the collection of input from external stakeholders, including external experts" (page 70).

Climate (page 73): an updated assessment of climate-related hazards for own sites used "IPCC SSP1-2.6 (Below 2°C) as a low-emission scenario, and SSP3-7.0 (2.7°C to 3.0°C) as a high-emission scenario", with geospatial coordinates per site and five risk levels.

Biodiversity (page 74): guided by "the first two steps of the Taskforce on Nature-related Financial Disclosures' (TNFD) LEAP approach", mapping sites against biodiversity-sensitive areas and IBAT STARt/STARr layers. "Elopak has identified one site near a protected area, but no site activities are identified to negatively affect this protected area."

Pollution (page 73): "Following the DMA update, pollution is no longer regarded as a material topic." Water (page 73): "No material IROs related to water and marine resources were identified... Elopak does not use water for production processes in own operations."

Across every topical screening the report repeats that "Consultations with affected communities were not conducted" (pages 73-74).

Climate-specific risk identification and scenario analysis is also presented under E1-2 (2025 ESRS numbering).

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

Reference: pages 75-76, with the Appendix B datapoint table at pages 133-135.

Elopak prints a full ESRS content index headed "Disclosure requirements in ESRS covered by the Sustainability statement" (pages 75-76): "Elopak applied impact and financial materiality thresholds as defined in the DMA process, mapping material topics at sub- and sub-sub levels in line with ESRS 1 AR 16. The ESRS 1 Appendix E flowchart was used to determine material disclosure requirements and data points."

The index lists, with page references: ESRS 2 BP-1, BP-2, GOV-1 to GOV-5, SBM-1, SBM-2, SBM-3, IRO-1, IRO-2; E1 E1-1 to E1-7; E4 E4-1 to E4-5; E5 E5-1 to E5-5; the EU Taxonomy Article 8 disclosures; S1 S1-1 to S1-9, S1-14 and S1-16; S2 S2-1 to S2-5; "ESRS S4 Food safety - MDR - Minimum disclosure requirements - 121"; and G1 G1-1, G1-3 and G1-4.

No E2 or E3 disclosure requirement appears, consistent with the 2025 DMA update, and no S3 disclosure requirement appears. S1-10 to S1-13, S1-15, S1-17, G1-2, G1-5 and G1-6 are likewise absent.

A separate appendix, "Summary of ESRS datapoints that derive from other EU legislation and their materiality" (pages 133-135), lists each Appendix B datapoint against SFDR, Pillar 3, Benchmark Regulation and EU Climate Law columns, marking entries "NR" (not relevant), "NM" (not material) or "Phase-in" where applicable - for example E2-4 §28, the E3 datapoints, S1-17 §103(a) and §104(a), the S3 and S4 datapoints and G1-1 §10(b)/(d) are all marked NM, while the E1-9 datapoints are marked Phase-in.

Transition plan for climate change mitigation

Reference: page 79 (ESRS content index, page 75; Appendix B lists ESRS E1-1 §14 'Transition plan to reach climate neutrality by 2050' at page 79 and §16(g) 'Undertakings excluded from Paris-aligned Benchmarks' at page 79 - see page 133).

Elopak discloses a Decarbonization roadmap and states its shortfall against the standard in its own words: "Our decarbonization roadmap outlines the key actions that support our Science Based Targets initiative (SBTi) commitments. While it provides a structured approach to reducing emissions across our value chain, it does not yet meet all ESRS E1 requirements for a transition plan, as our Scope 3 target is currently validated under the SBTi Well below 2 °C pathway rather than the 1.5 °C pathway required by ESRS" (page 79).

Levers by scope (page 79):

• Scope 1 and 2 - "Our SBTi target for combined Scope 1 and 2 emissions is a 42% reduction by 2030, and we have achieved 39% reduction in 2025 compared to our baseline 2020. Reductions in our Scope 1 and 2 emissions are expected to contribute approximately 1% of our total targeted GHG reductions by 2030." Scope 1 work focuses on "replacing fossil fuels in operations and enhancing energy efficiency"; Scope 2 on continuing to "source 100% renewable electricity across all operations".
• Scope 3 - levers "have been identified and integrated into our operational planning. While these actions are defined, we have not yet quantified the emission reductions achieved in 2025."

Locked-in emissions (page 79): "We have performed a qualitative assessment of our key assets, which did not identify any potential locked-in GHG emissions... We will continue evaluating potential locked-in GHG emissions related to our value chain in 2026."

Investment: no climate CapEx or OpEx figure is given. "Pending a review of our SBTi targets, we will assess the possibilities of a ESRS compliant transition plan. As part of this, we will also assess potential significant CapEx and OpEx related to the action plans" (page 79). "Elopak is not excluded from EU Paris-aligned benchmarks" (page 79).

Governance: "The decarbonization roadmap has been reviewed by the relevant members of Management, and progress will be monitored and reported through the ESG council and the Environment network" (page 79).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1, where this content is disclosed in the FY2025 report (page 73, with the risk table at page 71 and the financial-statement link at page 192). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risk classification (page 71). Elopak's material E1 IROs separate the two risk types explicitly: "E1.1 Elopak faces physical climate-related risks across its operations and value chain" and "E1.2 Elopak faces transitional climate-related risks across its operations and value chain", both tagged upstream, own operations and downstream across short, medium and long horizons.

Methodology (page 73). "In 2025, Elopak conducted an updated assessment of climate-related hazards for own sites. This assessment applied the IPCC SSP1-2.6 (Below 2°C) as a low-emission scenario, and SSP3-7.0 (2.7°C to 3.0°C) as a high-emission scenario. The assessment utilized geospatial coordinates for each site to evaluate climate-related hazards under both scenarios. Each climate variable was classified into one of five risk levels, based on how frequently its projected future mean annual value exceeds the current median value."

The earlier scenario analysis (page 73). The transition-risk work still rests on a 2022 TCFD assessment: scenarios were "based on the IPCC's Sixth Assessment Report (2021) and Summary for Policymakers (2018)" and "reflected the best available information at the time of the 2022 TCFD assessment". Two scenarios were evaluated: a "Low emission scenario (2˚C pathway)" requiring "a 50% reduction in GHG emissions from 1990 levels by 2030", and a "High emission scenario (no climate policies 4˚C)". "Long-term horizons were set to 2100 for physical risks."

Gaps Elopak states itself. The 2025 hazard assessment covers own sites only; "In 2026, we plan to continue our work on climate risk by updating and completing the scenario analysis to encompass both physical and transition risks in our own operations and value chain" (page 73). No global average temperature projection is attached to the 2025 SSP pair beyond the ranges given. "The climate scenarios applied are consistent with the key climate-related assumptions used in the financial statements, see Note 30" (pages 73, 192).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3, where this content is disclosed in the FY2025 report (page 67, with supporting text at pages 73 and 87). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Elopak states that it has not performed a resilience analysis as defined under the ESRS. "Elopak has not conducted a resilience analysis that is ESRS compliant, as this will be addressed in 2026 following the completion of the climate risk analysis and biodiversity strategy" (page 67).

The company sets out what the future analysis will cover: "The work on conducting a resilience analysis will be addressed following the completion of the climate risk analysis in 2026, and therefore was not finalized in 2025. The scope of the resilience analysis will be to assess how the identified climate-related risks interact with Elopak's strategy and business model" (page 67).

What is disclosed in place of a resilience analysis:

• Financial resilience - "None of the material risks or opportunities identified in the DMA were assessed to have a financial effect on financial position, financial performance and cash flows in the current financial year" (page 67). Note 30 adds that "The climate risk financial impact assessment concludes that the potential of revenues is by far higher than the risk of costs and that the revenues is likely to occur earlier than the costs", that increased climate-related cost "will over time be passed on to the customers", and that "we consider the risk of impairment related to climate risk to be low" (page 192).
• Capacity to adapt - Note 30 records that emission-reduction targets "are mainly met by replacing old production line components with new, more energy-effective components. Most of the replaced parts are already fully depreciated", and that lease contracts for separable cap lines were reassessed ahead of the tethering requirement (page 192).
• A parallel gap is disclosed for biodiversity: "In 2026, we will focus on establishing the transition plan and assessing the resilience" (page 87).

Policies related to climate change mitigation and adaptation

Reference: page 78 (ESRS content index, page 75).

"Climate change is covered in our Sustainability policy and Environmental policy. The Sustainability policy covers the governance structure, main principles and all material topics. The Environmental policy is based on Elopak's vision, mission and Code of conduct and is part of our sustainability governance" (page 78).

"The Environmental policy outlines the approach for identifying and managing IROs related to climate change mitigation and adaptation. Elopak's commitment to the UN Paris Agreement (COP21) is anchored through the Environmental policy. It describes Elopak's efforts to mitigate climate change through our approved Science-based targets" (page 78).

"The Environmental policy also includes Elopak's target of purchasing 100% renewable electricity for all sites where we have operational control. All operations are committed to initiate and report on projects related to GHG reductions and energy saving and efficiency" (page 78).

Two boundaries are stated. On energy production: "As Elopak does not currently have any renewable energy production at our sites, and the topic is not covered in our Environmental policy." On adaptation: "Climate change adaptation is also addressed in the Environmental policy through the work on climate risk analysis based on the TCFD framework" (page 78).

Both policies are held internally in the Elopak Management System (EMS), are owned by the Senior Director Sustainability, and are mapped to all five E1 IROs (E1.1 to E1.5) in the policy table (page 78).

Actions and resources in relation to climate change policies

Reference: page 80 (ESRS content index, page 75).

"Our Sustainability roadmap continues to guide Elopak's internal efforts to mitigate climate change by reducing GHG emissions. In 2025, our focus has been on professionalizing our sustainability work and embedding it more deeply across the company", including closer work with "Procurement, Product & Development, and Finance" and more use of the ESG Council and Environment network (page 80).

Scope 1 project examples (page 80):

• "Replacing fossil-fired processes with electric alternatives"
• "Transferring energy used for production equipment and processes from gas to electricity"
• "Reducing waste through operational excellence"
• "Changing petroleum powered forklifts to electric"

Scope 2 - "we continue to source 100% renewable electricity across all operations, a long-standing commitment that remains a cornerstone of our decarbonization efforts" (page 80).

Scope 3 levers and actions (table, page 80):

• Category 1, Purchased goods and services - reduce aluminium ("increasing the share of aluminium-free packaging solutions"); reduce polymers ("assessing options to reduce plastic content, transition to fiber-based closures, or eliminate closures altogether where feasible"); switching board types and polymer feedstock ("The development of Natural White Board with Stora Enso supports this ambition. Our offering of recycled and renewable polymers aligns with PPWR requirements - five years ahead of regulation"); supplier engagement.
• Categories 4 and 9, transportation - alternative fuels (biofuels or electric transport, "while monitoring long-term potential for hydrogen solutions") and change transport mode ("modal shifts such as increased rail or sea freight").
• Category 11, use of sold products (filling machines) - marked "To be assessed".

Elopak qualifies the table itself: "the actions are still being finalized, and their implementation may depend on the availability and allocation of resources" (page 80). No monetary resources are attached to the actions.

Targets related to climate change mitigation and adaptation

Reference: page 81 (ESRS content index, page 75; Appendix B lists ESRS E1-4 §34 'GHG emission reduction targets' at page 81 - page 133).

"Elopak has set targets for each emission scope, in line with the Corporate Net-Zero Standard from SBTi. These targets are compatible with the Paris Agreement and validated by SBTi" (page 81).

The targets (page 81):

• Scope 1 and 2 - "reduce Scope 1 and Scope 2 emissions by 42% by 2030 from a 2020 base year", using a market-based approach for Scope 2. "Elopak's Scope 1 and 2 targets are in line with the 1.5°C pathway as defined by SBTi."
• Scope 3 - "cut the absolute emissions in selected Scope 3 categories by 25% by 2030 from a 2020 base year. The Scope 3 target is in line with the Well below 2°C pathway as defined by SBTi."
• Long term - "reduce absolute Scope 1, 2, and 3 GHG emissions 90% by 2050 from a 2020 base year."
• "Our SBTi targets are gross targets meaning that no carbon credits or avoided emissions are used as means to achieve the targets."

Method and review: targets "were set using the SBTi Corporate Net-Zero Standard (Version 1.0, October 2021) and follow a cross-sector emission pathway compatible with limiting global warming to 1.5°C. Internal stakeholders were involved in the target-setting process." They "will be reviewed at least every five years", including "an assessment of potential changes to critical assumptions regarding future developments of business activities" (page 81).

Adaptation gap, stated by the company: "We currently do not have a specific target related to climate change adaptation. In 2026, we will continue our work on climate risk, covering both transitional and physical risks, and use this to assess how we can best track the effectiveness of relevant policies and actions" (page 81).

Energy consumption and mix

Reference: page 82 (ESRS content index, page 75; Appendix B lists E1-5 §37, §38 and §40-43 at page 82 - page 133). 2024 comparatives were restated - see 'Changes in presentation of E1 metrics', page 136.

Energy consumption, MWh (page 82), 2024 restated then 2025:

• Fuel from petroleum products 1,921 → 1,904
• Fuel from natural gas 13,378 → 14,156
• Fuel from other fossil sources (propane) 6,163 → 5,095
• Total fossil energy consumption 21,462 → 21,154; share of fossil sources 18% → 17%
• Nuclear: nil in both years
• Purchased renewable electricity 94,412 → 97,638
• District heating 4,484 → 3,827
• Total renewable energy consumption 98,896 → 101,465; share of renewable sources 82% → 83%
• Total energy consumption 120,358 → 122,619 MWh
• Energy intensity 0.104 → 0.102 MWh per EUR 1,000

Elopak reports no self-generated non-fuel renewable energy and no fuel consumption from renewable sources including biomass, both nil.

Renewable electricity contractual instruments (page 82), 2025 shares of 97,638 MWh: EECS GO 66,640 MWh (68%), REC 19,005 MWh (19%), I-REC 11,982 MWh (12%), REGO 5 MWh, POL GO 7 MWh. "To document the purchase of renewable electricity, we receive cancellation statements from the official certificate registries, including the Nordic Energy Certificate System (NECS), I-REC, REC, and the REGO Standard registers. The renewable electricity metrics are considered to be validated through the cancellation statements. The other energy-related metrics are not validated by an external body other than the assurance provider" (page 82).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 83-85 (ESRS content index, page 75; Appendix B lists E1-6 §44 at page 83 and §53-55 GHG intensity at page 84 - page 133). 2020 and 2024 figures were restated - see page 136.

Emissions, tCO2e (pages 83-84), 2024 restated then 2025:

• Gross Scope 1: 4,627 → 4,572 (-1%); 0% from regulated emission trading schemes
• Scope 2 location-based: 20,484 → 22,658 (+11%); Scope 2 market-based: 186 → 153 (-18%)
• Scope 1+2 market-based: 4,813 → 4,725 (-2%); 2030 milestone shown as 4,476
• Scope 3 total: 671,228 → 718,552 (+7%), of which Cat.1 purchased goods and services 488,069 (+6%), Cat.2 capital goods 16,835 (+45%), Cat.4 upstream transport 33,777 (+6%), Cat.9 downstream transport 26,371 (+6%), Cat.11 use of sold products 44,332 (+31%), Cat.12 end-of-life 64,200 (+7%), Cat.15 investments 33,551 (-5%)
• Total GHG (location-based) 696,339 → 745,782 (+7%); total (market-based) 676,041 → 723,277 (+7%)
• GHG intensity per net revenue: location-based 0.602 → 0.619; market-based 0.585 → 0.600

SBTi-boundary emissions (page 84): Scope 1+2 market-based fell from a 2020 base of 7,717 to 4,725; the SBTi Scope 3 subset rose from a 2020 base of 465,840 to 473,686 (2024) and 512,171 (2025), +8% year on year, against a 2030 milestone of 349,380.

Method (pages 83-85): GHG Protocol, operational control consolidation. Emission factor sources "include DEFRA, IEA, AIB, EXIOBASE, NTM and supplier-specific factors". "Primary activity data has been used in all Scope 3 categories, except Cat. 7 Employee commuting, Cat. 12 End-of-life treatment of sold products and Cat. 15 Scope 3 emissions from JVs. The percentage of primary activity data used is 87%" (page 84). Categories 8, 10, 13 and 14 are marked not relevant, with leased filling machines now folded into Cat. 11 (page 85).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 86 (ESRS content index, page 75; Appendix B lists E1-7 §56 at page 86 - page 133).

"Elopak currently only holds the CarbonNeutral® Packaging certification in accordance with the 2025 version of the CarbonNeutral® Protocol... In 2025, Elopak offered CarbonNeutral® Packaging certification to customers by offsetting specified product emissions through carbon credits from outside our value chain. However, we do not use carbon credits in our carbon accounting or to reduce the reported Scope 1, 2 or 3 emissions" (page 86).

Metrics (page 86): total volume of credits purchased and cancelled was 88,856 tCO2e in 2024 and nil in 2025, because "In 2024, Elopak pre-purchased and retired carbon credits for the reporting years 2024 and 2025. Therefore, no additional carbon credits have been purchased or retired in 2025." Total volume planned to be cancelled in future: "No unretired carbon credits held in account." The 2024 split was 94% avoidance/reduction and 6% removal, by standard 94% Gold Standard-VER and 6% VCS, with 0% issued from EU projects and 0% qualifying as a corresponding adjustment under Article 6 of the Paris Agreement.

The 2024 removal credits came from "a project called Degraded Grasslands Afforestation, Uruguay. As an afforestation project, the removals come from biogenic sinks"; avoidance projects were "Bondhu Chula Stoves, Bangladesh", "Lingasugur Wind Power, India" and "Circle Gas Smart Meters, Kenya" (page 86).

Two forward statements: "we will phase out the CarbonNeutral® logo from our products starting in 2026, ensuring alignment with the Empowering Consumers for the Green Transition (ECGT) directive by September 2026"; and "Our SBTi targets include both a net-zero target and gross emission reduction targets, and there is a need to further assess how residual emissions are intended to be neutralized" (page 86).

Transition plan on biodiversity and ecosystems

Reference: page 87 (the ESRS content index lists "E4-1 Transition plan and consideration of biodiversity and ecosystems in strategy and business model" at page 87 - page 75).

"Elopak's business relies heavily on nature and its resources, particularly forest-based raw materials. Our DMA identified that upstream sourcing of raw materials can negatively impact biodiversity. Activities such as wood procurement may reduce local biodiversity and ecosystem services, while bauxite extraction can occur in ecologically sensitive areas, contributing to habitat loss. To mitigate these impacts, Elopak prioritizes sourcing certified materials. Certifications such as FSC, ISCC+, and ASI support the protection of biodiversity and ecosystems" (page 87).

Elopak states that it does not yet have a biodiversity transition plan. "In 2025, Elopak conducted an assessment of its impact on biodiversity and ecosystems in own operations. The assessment was guided by the first two steps of the TNFD LEAP approach... In 2026, we will focus on establishing the transition plan and assessing the resilience" (page 87). The planned-actions table repeats this: "Develop holistic biodiversity strategy and transition plan - Biodiversity transition plan including resilience analysis - Own operations and upstream value chain - Started - 2026" (page 89).

Appendix B records the linked ESRS 2 SBM-3 (E4) datapoints at page 67: §16(a)(i) activities negatively affecting biodiversity-sensitive areas, §16(b) land degradation, desertification or soil sealing, and §16(c) threatened species (page 134). The corresponding SBM-3 text reads: "None of the sites in Elopak's own operations were found to be material due to negative or positive impact on biodiversity sensitive areas... Elopak has not identified any direct impact on threatened species in own operations" (page 67).

Policies related to biodiversity and ecosystems

Reference: page 87 (ESRS content index, page 75; Appendix B lists E4-2 §24(b) sustainable land/agriculture practices and §24(d) policies to address deforestation at page 87, and marks §24(c) sustainable oceans/seas practices "NM" - page 134).

"Elopak's Environmental policy and procurement procedures/standards set strict requirements for sourcing wood and bauxite, emphasizing independent certifications such as FSC and ASI to ensure traceability and compliance" (page 87).

"In addition, the Environmental policy includes other environmental impact drivers such as climate change related to wildfire, land use change related to forest management and forest restoration. Also, sourcing of bauxite can potentially take place in biologically sensitive areas, which could lead to pollution in these areas. Furthermore the policy states that Elopak supports initiatives to protect forests and biodiversity and combat illegal logging and deforestation. Elopak must comply with the EU Deforestation Regulation (EUDR), and we will implement changes to relevant policies, if needed" (page 87).

Two gaps are stated by the company itself:

• "The Environmental policy does not currently address the social consequences of biodiversity and ecosystems-related impacts. This will be assessed in 2026 as part of the extended LEAP assessment" (page 87).
• "The biodiversity-related risk assessment concluded that none of Elopak's operations sites are situated in or near a biodiversity sensitive area. It has therefore not been considered necessary to develop a biodiversity and ecosystem protection policy" (page 87).

The policy table names two instruments mapped to IRO E4.1: the Environmental policy (Senior Director Sustainability) and the Responsible sourcing of paperboard standard (Chief Procurement Officer), which "ensures that all paperboard used by Elopak is responsibly and legally sourced" (page 87).

Actions and resources related to biodiversity and ecosystems

Reference: pages 88-89 (ESRS content index, page 75).

Certification is the principal action. "Elopak has been certified by the Forest Stewardship Council (FSC) since 2010... All of Elopak's plants are FSC-certified (FSC-C081801, FSC-C180237 and FSC-C193727)" (page 88). "In 2025, we sold 52% FSC-labeled cartons worldwide, while 84% of the sales volume in Europe was labeled with the FSC logo." "As of 2015, 100% of Elopak's purchased raw board has come from certified or controlled wood sources."

"100% of the circular and bio-circular polymers Elopak purchases are certified according to International Sustainability and Carbon Certification (ISCC)+", verified "using a mass balance approach". "In 2025, the Aluminium Stewardship Initiative (ASI) Performance Standard certification was renewed... all aluminium sourced in 2025 came from ASI certified suppliers" (page 88).

Actions taken in 2025 (table, page 89): FSC certification of all plants; ISCC+ certification of Elopak b.v. (Netherlands), Elopak Denmark A/S, Elopak Canada Inc. and sales units such as Elopak GmbH; ASI Performance Standard certification of Elopak b.v., Elopak A/S, PrJSC Elopak-Fastiv (Ukraine) and Elopak ASA. All marked "Completed for 2025 / Ongoing action".

Actions planned to 2026 (page 89): assessment of biodiversity projects with suppliers; extend the LEAP assessment to "A holistic biodiversity strategy"; raw board supplier collaborations; and develop a holistic biodiversity strategy and transition plan including resilience analysis - all marked "Started".

Boundaries stated: "Elopak does not plan to use biodiversity offsets in our action plans", and incorporation of "local and indigenous knowledge and nature-based solutions... is currently only covered through the FSC certification" (page 88). On EUDR: "End of 2025, it was announced that the application date has been moved to end of 2026" (page 88).

Resources: the Green Bond Investor Report 2024 box records that "In 2024, Elopak issued three green bonds totaling EUR 232 million. Out of this, EUR 169 million was allocated to the purchase of FSC-certified paperboard, which accounted for 58% of the total sourced paperboard in 2024. EUR 27 million of the bond was allocated to new production lines certified in accordance with the standards of the FSC™" (page 89).

Targets related to biodiversity and ecosystems

Reference: page 90 (ESRS content index, page 75).

"Elopak's biodiversity target aims to ensure a sustainable supply chain for raw board, circular and bio-circular polymers and aluminium through product certifications according to the most stringent and credible standards" (page 90). The target, mapped to IRO E4.1, has three limbs:

• "Raw board: 100% FSC, SFI or PEFC certified or controlled wood"
• "Circular and bio-circular polymers: 100% ISCC+ certified"
• "Aluminium: 100% ASI certified"

each qualified as "or similar strict certification".

Scope and method: "The target is related to the material negative impact of raw materials in our upstream value chain. The target applies to all own operations and do not consider any biodiversity offsets. The target is primarily related to the avoidance layers of the mitigation hierarchy" (page 90).

Gap stated by the company: "Elopak will explore both how future targets can apply ecological thresholds, and be informed by or aligned with national policies and legislation, such as the Kunming-Montreal Global Biodiversity Framework, the EU Biodiversity Strategy for 2030, as this is currently not included in our assessment" (page 90).

Impact metrics related to biodiversity and ecosystems change

Reference: page 90 (ESRS content index, page 75).

Elopak reports the certified-material metrics that underpin the E4 target, "Purchased certified raw materials covered in target" (page 90), 2024 then 2025:

• Raw board - percentage FSC, SFI or PEFC certified or controlled wood: 100% → 100%
• Bio-circular and circular polymers - percentage ISCC+ certified: 100% → 100%
• Aluminium - percentage ASI certified: 52% → 100%

Reporting principles (page 90): "Data collection is based on contractual agreements with suppliers, volume reports from suppliers as well as data from mass balance documentations." Each metric "Applies to all volumes"; for polymers, "Fossil-based polymers are not included". "The metrics have not been validated by an external body other than the assurance provider."

No land-use, ecosystem-extent or species-population metric is reported. The supporting basis is the site-level screening described under IRO-1: relevant sites were "mapped towards biodiversity sensitive areas, distinguishing between 'in' and 'near'", and towards "IBAT's STARt, STARr and Rarity-Weighted Richness layers as proxies to IUCN Red List of Threatened Species". "Elopak has identified one site near a protected area, but no site activities are identified to negatively affect this protected area" (page 74). "The assessment did not cover our value chain" (page 74).

Policies related to resource use and circular economy

Reference: page 91 (ESRS content index, page 75).

"Resource use and circular economy are addressed in our Environmental policy, which sets out how we identify and manage IROs related to these topics across the value chain. For resource inflows, the policy guides material choices toward circular and responsibly sourced inputs. It also covers resource outflows from our own operations and downstream activities, including recycling, packaging alternatives, investments in technological developments and waste management throughout the value chain" (page 91).

"The policy also addresses the commitment to minimizing waste and ensuring recycling of waste from all production sites. Elopak particularly aims to keep hazardous waste at a minimum and to ensure this is disposed of according to best practice and local regulation" (page 91).

A single policy instrument is tabled - the Environmental policy, owned by the Senior Director Sustainability, held internally in the EMS, and mapped to all seven E5 IROs (E5.1 to E5.7) (page 91).

The regulatory framing is set out alongside: "Elopak's commitment to enhance recyclability and reduce the carbon footprint of our cartons aligns with the Packaging and Packaging Waste Regulation (PPWR) set to take effect in 2030, as well as the Single-Use Plastics (SUP) directive, all while ensuring compliance with food safety legislation" (page 91). "Our commitment to sourcing responsible raw materials through our certifications is also reflected in our Environmental policy" (page 91).

Actions and resources related to resource use and circular economy

Reference: pages 92-93 (ESRS content index, page 75).

"Elopak's approach to recyclability and recycling starts with product development... In line with these [Design for Recycling] guidelines, Elopak is optimizing its packaging designs for improved recyclability, ensuring easy reprocessing of different components" (page 92).

Named product actions (page 92): "alternative barriers in our cartons, such as fiber-based or polymer-based options, to replace traditional aluminium foil"; "new product development to replace plastic closures, including the future launch of fiber-based caps"; expanding "our original Pure-Pak® Easy-Opening system"; value engineering to reduce "the amount of board and polymer coatings"; offering "renewable sourced polyethylene (PE), as opposed to fossil-based"; and "by collaborating with our polymer suppliers in 2025 we launched the first cartons that incorporate post-consumer recycled (PCR) advanced recycled PE (arPE) content".

Actions table (page 93), each with outcome, scope, status and completion:

• Renewable PE from biomass waste - completed for 2025, ongoing (E5.2)
• Alternatives to aluminium foil - "First generation eSense launched. The range of applications will broaden by 2030" (E5.1, E5.3, E5.4, E5.5, E5.6)
• Incorporated recycled content - "First launch in 2025" (E5.1, E5.2, E5.3, E5.4, E5.5)
• Internal waste reduction efforts - the Operational Excellence (OpX) program using Total Productive Maintenance (E5.7)
• Innovative opening devices - fiber-based opening devices, started, due 2030 (E5.1, E5.3-E5.6)
• Material reduction and value engineering - started, due 2030 (E5.1, E5.3)

On PPWR: "Elopak is currently preparing to meet the new requirements... Elopak holds the presidency of the global Food & Beverage Cartons Alliance (FBCA) while also having key roles in other industry alliances such as 4evergreen" (page 92). No monetary resource figure is attached to the E5 actions.

Targets related to resource use and circular economy

Reference: page 96 (ESRS content index, page 75).

One target is set: "100% of cartons designed for recycling by 2030", mapped to IROs E5.3, E5.4, E5.5 and E5.6 (page 96).

"Elopak's target is for our entire portfolio to be technically compatible with the recycling processes in the markets where we operate and to comply with applicable standards and legal requirements. As recycling is still a developing industry, the standards for recyclability are also evolving. In Europe, to harmonize the evaluation of packaging recyclability across Europe, the PPWR will introduce common standards defining when packaging is considered 'Designed for Recycling'... The target is not mandated by external regulation" (page 96).

Elopak states which IROs carry no target: "We currently do not have CSRD-related targets for IROs E5.1, E5.2 and E5.7, as these topics are managed through internal KPIs and other management processes. The effectiveness of related policies and actions is monitored through internal processes using selected metrics, reflecting our ambition to manage these impacts and risks" (page 96). That is, sourcing impacts, access to renewable and recycled materials, and own-operations waste have no disclosed target - the MDR-T effectiveness-tracking limb is used instead.

The E4 certification target (100% FSC/SFI/PEFC raw board, 100% ISCC+ polymers, 100% ASI aluminium) is cross-referenced as the resource-inflow-related target: "See 'E4 Biodiversity and ecosystems' for further information on our target to ensure a sustainable supply chain" (pages 90, 96).

Resource inflows

Reference: pages 94 and 97 (ESRS content index, page 75). Resource inflow was newly identified as material in the 2025 DMA update (page 59).

One metric is given (page 97): "For the production of our cartons, closures and filling machines, 78% of the total materials used consisted of sustainably sourced biological materials. Recycled components were introduced in 2025 and constituted less than one percent of total materials used to manufacture Elopak's products (including packaging)." Reporting principle: "Board and bio-circular polymers are considered sustainable sources biological material. No biological material is used in the production of filling machines" (page 97).

A quantitative datapoint is withheld under national law. "For E5 resource inflow, the metrics related to the total weights of materials have been omitted under § 2-4 (4) of the Norwegian Accounting Act due to commercial sensitivity" (page 59). So the absolute tonnage of materials used is not disclosed, only the percentage split.

Narrative inflow description (page 94): "Elopak's primary resource is paperboard, and we have long collaborated with our suppliers to ensure that 100% of our fiber originates from responsibly managed sources... Polymers are included in the carton structure to ensure liquid-tight functionality... For aseptic products, an ultra-thin aluminum layer is used to provide the barrier properties required to maintain food safety and shelf stability." Filling machines "are primarily constructed from stainless steel, selected plastics and a range of electronic and mechanical components". "Elopak has implemented robust supply chain controls and requires all suppliers to adhere to our Supplier Code of Conduct" (page 94).

Resource outflows

Reference: page 95, with the waste metrics at page 97 (ESRS content index, page 75; Appendix B lists ESRS E5-5 §37(d) non-recycled waste and §39 hazardous and radioactive waste at page 97 - page 134).

"Elopak provides packaging solutions, and our resource outflows primarily consist of fiber-based cartons and associated materials, as well as components from our filling machines and spare parts" (page 95).

Cartons. "After collection and sorting, liquid packaging cartons enter dedicated recycling streams, where fibers are separated from plastic and aluminium layers... The resulting paper fraction is used to manufacture new products such as cardboard and paper-based materials." On the non-fibre fraction: "PolyAl recycling refers to the process of recycling the non-fiber components of liquid packaging carton with an aluminium barrier. A growing number of recyclers and manufacturers are investing in technologies to reprocess this fraction into secondary raw materials for products such as automotive parts, pallets and furniture" (page 95).

Recyclability, third-party assessed: "Elopak has engaged with a European recycling certification body (HTP Cyclos) that has assessed our main product families as achieving 95% or higher recyclability at the EU level" (page 95). The corresponding metric: "100% of Elopak's sales contain no materials that are incompatible with recycling. The 2025 evaluation is based on industry Design for Recycling guidelines and internal expert assessment. Once the PPWR methodology is finalized by January 2028, it will become our metric and reference framework for the European market" (page 97).

Filling machines. "The estimated lifetime of these machines is approximately 20 years, supported by regular service and refurbishment"; Elopak "offers refurbished second-hand filling machines for extended lifetime", and at end of life "scrapping and recovery of valuable materials such as stainless steel becomes the final step" (page 95).

Transport packaging. "Due to food contact requirements, most of our transport packaging is made from virgin materials. However, Elopak proactively seeks opportunities to introduce recycled content wherever it is technically feasible and compliant with safety standards" (page 95).

No expected durability, reparability or recycled-content-in-products percentages are quantified beyond the design-for-recycling metric.

Waste

Reference: page 97, with the waste-management narrative at pages 95-96. The Appendix B datapoint table lists ESRS E5-5 §37(d) non-recycled waste and §39 hazardous and radioactive waste, both at page 97 (page 134). Waste is one of Elopak's material E5 sub-topics: "E5.7 The waste produced in own operations has a negative impact" (pages 71, 91).

Production waste, tonnes (page 97), 2024 then 2025:

• Diverted from disposal, recycling - hazardous 56 → 39; non-hazardous 33,017 → 33,515; total 33,073 → 33,554
• Preparation for reuse and other recovery operations: nil in both years
• Directed to disposal - incineration 526 → 631 (hazardous 122 → 145; non-hazardous 404 → 486); landfill 1 → 0; other disposal operations 63 → 0; total 590 → 631
• Total waste generated 33,663 → 34,185 t (hazardous 242 → 184; non-hazardous 33,421 → 34,001)
• Total non-recycled waste 590 → 631 t, being 79% of hazardous waste, 1% of non-hazardous waste and 2% of total waste in 2025 (2024: 77% / 1% / 2%)

Reporting principle: "Waste: reported by category and treatment type in internal reporting tool. Hazardous waste: inks, solvents and other hazardous waste. Non-hazardous waste: board, paper, polyethylene and industrial waste. The metrics have not been validated by an external body other than the assurance provider" (page 97).

Management: "Elopak's internal waste reduction efforts are managed through its Operational Excellence (OpX) program... rooted in the industry-recognized Total Productive Maintenance (TPM) methodology. The core objective is to achieve zero losses by empowering all employees to become Equipment Owners" (page 95). The programme "started at the Terneuzen Converting site and subsequently extended to the Aarhus site" and covers autonomous maintenance, focused improvement, planned maintenance and quality maintenance (page 96). No waste target is set: E5.7 is one of the three IROs Elopak states it manages through internal KPIs rather than a CSRD target (page 96).

No radioactive waste is reported.

Policies related to own workforce

Reference: pages 105, 109 and 112 (the ESRS content index lists all three pages for S1-1 - page 76; Appendix B lists S1-1 §20 human rights policy commitments, §21 ILO due diligence and §22 trafficking at page 104, and §23 workplace accident prevention policy at page 109 - page 134).

Elopak restructured its S1 chapter this year and splits its workforce policies across three sub-sections.

Working conditions (page 105): the Code of conduct, owned by the Board of Directors, "Describes Elopak's social responsibility; human and labor rights, the right to collective bargaining for all employees, the elimination of forced or compulsory labor, diversity and equal opportunities, health and safety, speaking up and reporting unethical behavior" (IROs S1.1, S1.3). Alongside it sit the Reporting concerns and internal investigation procedure (S1.1, S1.3), the revised Employee performance management procedure and the updated Onboarding procedure (both S1.3).

Health and safety (page 109): the Safety policy "Outlines our commitment to ensure a safe work environment for all employees, contractors and authorized visitors"; the Health, safety and working environment procedure; the updated Employees' safety on business travels procedure; and the Safety reporting procedure - all mapped to IRO S1.2.

Diversity and inclusion (page 112): the Diversity, equity and inclusion policy, which "also reflects any disciplinary action of intimidation, bullying, victimization, abuse or harassment"; the Recruitment procedure; the Total compensation standard; and the revised Senior employee retention standard - all mapped to IRO S1.4.

Underlying commitment: "Elopak strives to respect all applicable laws, rules, regulations, and industry standards concerning working hours, minimum wages, and rules related to the working environment in line with human rights as defined by the United Nations. We respect the freedom of employee association and the right to collective bargaining agreements stated in our Code of Conduct" (page 104). All policies are held internally in the EMS.

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

Reference: page 104 (ESRS content index, page 76). GOV-4 maps this DR to due diligence element (b), engaging with affected stakeholders (page 64).

"In Elopak, we engage with our employees through several methods and phases in the employee's life cycle. The engagement is done through our annual performance and development process, one-to-one meetings, leadership calls, various surveys and in our whistleblower channel... The Chief Human Resources Officer (CHRO) has the operational responsibility for engagement with our own workforce" (page 104).

Effectiveness is tracked by survey: "The People survey allows us to track the effectiveness of our engagement with our own workforce. The survey carried out by the end of 2025 reached a 72% response rate, engagement level of 77% and shows progress in most areas when compared with the People survey from 2023. However, we observe from the survey that further actions are needed to strengthen collaboration and communication. All managers are expected to discuss the survey results within their teams and define actions to improve ways of working" (page 104). Onboarding surveys are run "after one and six months of employment".

Workers' representatives (page 104): "We work closely with both local works councils and unions, alternative forums (India and Saudi Arabia) as well as with our European Works Council (EWC). Members of Management have regular meetings with EWC." Elopak discloses two locations without formal unions: in India "No formal union is registered, but several committees are in place (e.g. Safety, reward and recognition) replacing a formal union"; in Saudi Arabia "Associations and collective bargaining agreements are not custom practice... P&O and local management hold quarterly forums on safety, well-being and wages, replacing a formal union."

It also discloses a vulnerable group: "In Saudi Arabia, we have foreign guest workers, which is customary practice. These workers have employment contracts with a staffing agency and Elopak is continuously monitoring their rights and conditions. This reduces the risk of breaches of decent working conditions, including any unjustified wage deductions" (page 104).

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

Reference: page 105 (ESRS content index, page 76; Appendix B lists S1-3 §32(c) grievance/complaints handling mechanisms at page 105 - page 135).

"In Elopak we are committed to providing effective remediation when negative impacts on people are identified, whether caused by our own operations or through our supply chains. This is outlined in our reporting concerns and internal investigation procedure. Concerns about misconduct or human-rights related grievances can be raised through internal reporting channels or via our external whistleblower helpline, which is accessible to all stakeholders" (page 105).

Effectiveness assessment: "We assess the effectiveness of these channels through regular communication with employees and external stakeholders, monitoring key metrics related to reports of misconduct, and public disclosure of aggregated case data. These measures help ensure that our channels remain accessible, trusted and capable of identifying potential adverse impacts" (page 105).

Remedy: "Remediation is provided where we identify that our operations, supply chains, or business relationships have caused or contributed to negative human rights impacts", including "Stopping activities that are causing or contributing to adverse impacts" and "Developing and implementing plans to seek to prevent or mitigate actual or potential adverse impacts" (page 105).

"The effectiveness of remediation is assessed by Elopak's Whistleblower secretariat, led by the Chief Legal and Compliance Officer. The Secretariat is responsible for assessing and managing concerns reported through the whistleblower helpline, ensuring that each case is handled appropriately" (page 105). Further mechanics are given under G1: the helpline "is available in eight languages and accessible to external stakeholders, including workers in our value chain. It offers anonymous reporting and is managed by an independent service provider", and "Elopak strictly prohibits any form of retaliation against individuals who raise concerns in good faith" (page 127).

Taking action on material impacts on own workforce

Reference: pages 106, 110 and 113 (the ESRS content index lists all three pages - page 76). GOV-4 maps S1-4 to due diligence element (d), MDR-A (page 64).

Working conditions (page 106). Two actions are tabled: the updated Onboarding procedure - "New activities in 2025 included tours to our manufacturing plants and test center, virtual networking sessions with guest speakers, and informal meetings with Executive Management members on site" (completed 2025, S1.3) - and the Performance and development plan, with "Completion rate 96%" (ongoing, S1.3). "In 2025 we concluded our graduate program with all graduates in permanent roles after two years of training."

Health and safety (page 110). Actions focus on three areas: "Machine safety: Developing safety levels to allow focus on core tasks"; "Safety culture: Building through the 'Safe by Choice' program, based on a safety perception survey"; and "Special safety topics: Addressed at the Group level using safety KPIs". Completed in 2025: a safety week themed "Take action"; mapping of "All machines and machine lines in production environments"; and "Run the second safety perception survey across Elopak supporting 'Safe by Choice'". Planned to 2026: strengthen safety culture, develop machine safety levels, and analyse safety data. Business-travel risk is managed "within our established Duty of Care concept".

Diversity and inclusion (page 113). 2025 focus was "leadership capability, inclusive culture, and talent pipeline diversity". Completed actions: structured DEI discussions with line managers in all business areas; revision of the Total compensation standard "in order to prepare for the EU Equal Pay Directive"; "Mandatory DEI e-learning for all global managers" with "284 managers completed DEI training courses"; and advancing gender equity in critical specialist and leadership roles through structured succession planning. Planned to 2026-2027: "ensuring representation of both females and males in final recruitment rounds" and a Culture shaping program. "We are dependent on skilled and motivated employees to deliver on our growth strategy, and we risk loss of critical knowledge due to an aging workforce" (page 113).

Targets related to own workforce

Reference: pages 106, 111 and 114 (the ESRS content index lists all three pages - page 76). GOV-4 maps S1-5 to due diligence element (e), MDR-T (page 64).

Two targets are set.

Health and safety (page 111): "3.2 TRI frequency rate per 1 million hours worked by 2030" (IRO S1.2). "The top-level target to describe the safety level in Elopak is the same as for many other companies and industries, namely the total number of recordable injuries (TRI), and TRI frequency rate (TRI FR)." "The 2030 target for TRI FR is broken down into annual sub-targets, which are agreed on with the respective business units, areas, and sites... The starting point is suggested by Corporate Safety, and the Safety officers and their managers can come with input before final targets are agreed." Elopak adds a candid line: "our current performance proves that parts of our organization still have a potential for developing its safety culture." Performance is monitored through KPIs, internal audits and ISO 45001 audits.

Diversity (page 114): "40% females in senior management positions within 2030" (IRO S1.4). "To achieve 40% females in senior management by 2030, we will implement targeted recruitment, mentorship programs, succession management, retention strategies, and foster an inclusive culture while tracking progress." "The target has been approved by Management as a group target, and progress is measured through selected ESG KPIs on a yearly basis." Progress statement: "In 2025, we made progress in increasing female representation at key stages of our talent pipeline, however, we still have a way to go with reaching our target."

Targets Elopak states it does not set (page 106): "We currently do not set CSRD-specific targets for IROs S1.1 and S1.3, as these areas are managed through internal KPIs and management processes. The effectiveness of policies and actions is monitored internally using selected metrics." That is, the contracted-worker reputational risk and the workforce-engagement impact are tracked under the MDR-T effectiveness limb rather than by target.

Characteristics of the undertaking's employees

Reference: page 107 (ESRS content index, page 76).

Headcount by gender (page 107), 2024 then 2025: female 460 → 478; male 1,774 → 1,891; other 0 → 2; not disclosed 0 → 4; total employees 2,234 → 2,375.

By employment type (page 107), 2025: permanent 2,343 (469 female, 1,868 male, 2 other, 4 not disclosed); temporary 32 (9 female, 23 male); non-guaranteed hours employees nil. In 2024 the split was 2,193 permanent and 41 temporary.

By country (page 107), 2025 with share of total: Netherlands 525 (22.1%), Denmark 300 (12.6%), Canada 289 (12.2%), Germany 249 (10.5%), Norway 194 (8.2%), India 170 (7.2%), Ukraine 152 (6.4%), USA 105 (4.4%), Morocco 98 (4.1%).

Turnover (page 108): "Employees who have left Elopak" 153 → 201; "Rate of employee turnover" 7.1% → 8.9%.

Method: "Employees: Measured as the headcount of all employees (permanent and temporary) at year-end, excluding externals... Data for employees in India is not available in centralized systems, and the data is therefore based on manual reporting" (page 108). Turnover excludes temporary employees. "Due to seasonal variations in our production facilities, temporary workers are hired in our plants in Canada, the Netherlands, Denmark and Morocco" (page 107). "The metrics have not been validated by an external body other than the assurance provider."

No breakdown by region for employees leaving is given, and gender categories "other" and "not disclosed" appear for the first time in 2025.

Characteristics of non-employee workers

Reference: page 108 (the ESRS content index lists "S1-7 Characteristics of non-employees in the undertaking's own workforce" at page 108 - page 76).

Metric (page 108): "Non-employees in the own workforce" 219 in 2024 → 126 in 2025.

Method, disclosed with its limitation: "Non-employees are only registered in centralized HR system based on need for internal system access. In some business units full time equivalents (FTEs) are reported. The non-employee number reported is a combination of the above, reported at year-end" (page 108). No split between self-employed people and workers provided by undertakings primarily engaged in employment activities is given, and the mixed headcount/FTE basis is acknowledged rather than resolved.

Context is given for the two locations where non-employee arrangements matter most (page 107):

• Morocco - "an integration plan for employing temporary workers from the staffing agency has been in force since 2019 and 45 employees were permanently employed by Elopak in 2025. The integration plan is completed and there are no more temporary workers engaged in the entity. In case the production will need temporary workers in the future, they will be engaged up until six months, in line with Moroccan labor law."
• Saudi Arabia - "the number of local nationals and guest workers are registered by the authorities in governing portals reflecting the adequate balance of guest workers and local nationals. Elopak complies with this and will continue to follow up on. By the end of 2025, there were six contractors in the legal entity."

Elopak's material IRO S1.1 is framed around this group: "Elopak may face reputational risk in regions with higher rates of contracted workers due to unfavorable working conditions and employment terms" (pages 72, 104). Health and safety reporting "includes workers in our joint ventures, and follows the approach applied to our own workforce" (page 67).

Collective bargaining coverage and social dialogue

Reference: page 108 (ESRS content index, page 76).

Coverage (page 108): "Percentage of employees covered by collective bargaining agreements" 60.7% in 2024 → 58.3% in 2025.

By country, percentage of employees covered (page 108), 2024 then 2025: Germany 98.4% → 98.4%; Denmark 100.0% → 100.0%; Netherlands 100.0% → 100.0%; Norway 100.0% → 100.0%.

By coverage band (page 108), for 2025: the 0-19% band contains Germany among EEA employees and MENA and India among non-EEA employees; the 60-79% band contains Denmark; the 80-100% band contains the Netherlands and Norway. Workplace representation (EEA only) is recorded for Germany, Denmark, the Netherlands and Norway, and the Americas appear in the 20-39% band.

Method: "Collective bargaining and social dialogue: Percentages calculated based on numbers reported by local P&O from all units. Local P&O maintains oversight of national agreements. The metrics have not been validated by an external body other than the assurance provider" (page 108).

The material IRO behind this disclosure is S1.3: "The lack of processes to engage with own workforce and to drive collective bargaining, social dialogue, and freedom of association may negatively impact employee participation" (pages 72, 104). Elopak discloses the two exceptions directly: in India "Workers... have the fundamental right to form a union, and the employer neither restricts nor supports workers in this. No formal union is registered, but several committees are in place", and in Saudi Arabia "Associations and collective bargaining agreements are not custom practice... and no formal unions are in place" (page 104).

Diversity metrics

Reference: page 115 (ESRS content index, page 76).

Gender distribution at senior management level (page 115), 2024 then 2025: female 32 (23%) → 35 (25%); male 107 (77%) → 104 (75%); other and not disclosed nil; total 139 in both years.

Distribution of employees by age group (page 115), 2025: below 30 - 295 (61 female, 232 male, 2 not disclosed); 30-50 - 1,228 (272 female, 952 male, 2 other, 2 not disclosed); over 50 - 852 (145 female, 707 male). 2024 comparatives: 268, 1,151 and 815.

Definition, disclosed: "Senior management: Elopak is using the Mercer global position classification system, and senior management have been defined as employees in positions with grade 6 (Senior) Manager or (Senior) Specialist or higher. Positions in jointly owned entities are not classified and not included in reporting" (page 115).

"Data has been reported manually by local P&O, as the data is not yet available in a centralized systems. A new People management system will be implemented in 2026 for consistent reporting and internal control mechanisms. The metrics have not been validated by an external body other than the assurance provider" (page 115).

Context: "we have a diverse workforce consisting of over 50 different nationalities", and "The packaging industry has traditionally been dominated by men. However, we aim for a balanced gender distribution across all hierarchical levels" (page 112). The 25% female share of senior management in 2025 sits against the S1-5 target of 40% by 2030 (page 114).

Health and safety metrics

Reference: page 111 (ESRS content index, page 76; Appendix B lists S1-14 §88(b) and (c) number of fatalities and number and rate of work-related accidents, and §88(e) days lost, both at page 111 - page 135).

Safety metrics (page 111), 2024 then 2025:

• Workforce covered by health and safety management system: 100% → 100%
• Number of recordable work-related accidents for own workforce: 18 → 18
• Rate of recordable work-related accidents (TRI FR): 4.3 → 4.0
• Number of cases of recordable work-related ill health: 10 → 5
• Number of fatalities as result of work-related injuries and work-related ill health: nil → nil
• Number of days lost to work-related injuries and work-related ill health: 145 → 125

Against the 2030 target of 3.2 TRI FR per million hours worked (page 111), the 2025 rate of 4.0 leaves the gap open.

"All employees and contractors in Elopak are covered by our safety management system. In this system, reporting, management, and defined countermeasures per incident, are mandatory activities. Arms, hands, and fingers are injured most frequently, most often by getting squeezed or cut. Data from leading and lagging indicators are much used as base for mitigating activities. Standardizing on tools, methods and personal protective equipment are proved effective" (page 111).

Reporting principles (page 111): "Workforce covered: All employees in own workforce covered"; the accident rate is "Accidents per million hours worked (total recordable injuries / total hours worked * 1 000 000)"; the fatality count covers "an employee in own workforce or other workers working on undertaking's sites". "The metrics have not been validated by an external body other than the assurance provider." Health and safety reporting "includes workers in our joint ventures, and follows the approach applied to our own workforce" (page 67).

Compensation metrics (pay gap and total compensation)

Reference: page 115 (the ESRS content index lists "S1-16 Remuneration metrics (pay gap and remuneration)" at page 115 - page 76; Appendix B lists §97(a) unadjusted gender pay gap and §97(b) annual remuneration ratio at page 115 - page 135).

Metrics (page 115):

• Gender pay gap, total (incl. variable pay): 14.9% in 2025. No 2024 comparative is given.
• Annual remuneration ratio, total (incl. variable pay): 16.7 in 2025. No 2024 comparative.
• Annual remuneration ratio, base salary: 9.0 in 2024 → 9.4 in 2025.

The missing comparatives are explained. "For S1 Own workforce, the methodology used to calculate gender pay gap total (incl. variable pay) and annual remuneration ratio total (incl. variable pay) has been updated. As a result, comparative figures for 2024 have not been included" (page 59).

Method, disclosed with its estimate flagged: the gender pay gap is "the difference in total pay between males and females, where total pay is defined as the average annual cash payment before taxes (i.e. base salary, bonus, overtime pay, shift- and other allowances). This difference is divided by the average total pay for males and expressed as a percentage." For the remuneration ratio, "the highest paid individual's total remuneration in 2025 as a ratio to the median. The median was not obtained directly but has been estimated at 5% below the average, based on consultations with Mercer" (page 115).

"Employees at all job levels have been included in these metrics. Data has been reported manually by local P&O, as the data is not yet available in a centralized systems. A new People management system will be implemented in 2026 for consistent reporting and internal control mechanisms. The metrics have not been validated by an external body other than the assurance provider" (page 115).

Related action: Elopak "Revised the Total compensation standard in order to prepare for the EU Equal Pay Directive", with the outcome "Equal compensation across genders for the same level/position" (page 113).

Policies related to value chain workers

Reference: page 117 (ESRS content index, page 76; Appendix B lists S2-1 §17 human rights policy commitments, §18 policies related to value chain workers and §19 ILO due diligence at page 117, and marks §19 non-respect of UNGPs "NM" - page 135).

Four instruments are tabled (page 117):

• Human rights policy (Chief Legal and Compliance Officer, external) - "Explains Elopak's commitment to respecting human rights, outlined in our CoC, and our approach to managing human rights risks arising from Elopak's activities and business relationships."
• Supplier Code of Conduct (SCoC) (Chief Procurement Officer, external) - covering "business ethics and legal compliance, food safety compliance, human and labor rights, and environment and climate. It is based on international recognized standards including the International Bill of Human Rights, UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises and the ILO declarations on Fundamental Principles and Rights at Work."
• Responsible Supply Chain Standard (Director Procurement Process Excellence, internal) - covering "risk assessments, integrity due diligence for new and existing suppliers, and actions to address non-compliance through corrective and mitigating measures."
• Procurement policy (Chief Procurement Officer, internal).

All four are mapped to IROs S2.1, S2.2 and S2.3.

"Elopak's approach to supporting human rights in our supply chains follows a risk-based approach. It is based on the UN Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance for Responsible Business Conduct" (page 117). The SCoC "addresses key human rights risks such as forced and child labor (including trafficking), freedom of association and collective bargaining, non-discrimination and equal opportunities, working hours, wages and benefits, regular employment, marginalized populations as well as health, safety and well-being", and suppliers are expected to ensure "equivalent standards are applied to their own suppliers" (page 118). Elopak cross-refers to its "Human and Labor Rights Transparency statement" under the Norwegian Transparency Act (page 117).

Processes for engaging with value chain workers about impacts

Reference: page 118 (ESRS content index, page 76). GOV-4 maps S2-2 to due diligence element (b), engaging with affected stakeholders (page 64).

Elopak states plainly that engagement is indirect. "Elopak seeks to understand and address actual and potential impact on workers in the value chain through a risk-based, mainly indirect engagement approach embedded in our supplier engagement and due diligence processes. Elopak does not engage directly with workers in the value chain or their representatives. Insight into working conditions and potential impact is mainly obtained indirectly through suppliers and third party assessment mechanisms" (page 118).

The mechanisms disclosed (page 118):

• The SCoC "is mandatory for supplier qualification and is expected to be cascaded throughout suppliers' own value chain".
• Risks are identified through "inherent risk assessment of the supply chain and targeted supplier assessment conducted as part for the supplier qualification and Integrity Due Diligence (IDD) process, taking into account factors such as product/service category, country of operation, commercial exposure and any know red-flags".
• "Medium and high-risk suppliers are assessed via third-party ESG rating platforms (EcoVadis), supplier self-assessment questionnaires, with additional desktop background screenings... and in some cases via in-depth IDDs carried out by third party. Where relevant and high risk, on-site audits and follow up may be conducted including labor and human rights criteria."
• "A Supplier human rights capacity building questionnaire is used for selected key and high-risk suppliers, supporting engagement and pre-audit mapping of human rights risks. Selected quality related on-site audits include checklist for human and labor rights to assess working condition and raise awareness on-site. These, amongst others, include questions related to availability and effectiveness of reporting mechanisms related to raising concerns."
• "Where gaps are identified, Elopak engaged with suppliers on corrective actions. Repeated non-compliances may result in termination of the contract."

The same gap is acknowledged at group level under SBM-2: communication with "workers in the value chain... is not directly covered in our current stakeholder dialogue" (page 68).

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

Reference: page 118 (ESRS content index, page 76).

"Elopak encourages suppliers, business partners, and their employees to raise concerns related to human rights, labor rights or other principles set out in the SCoC. Suppliers are expected to maintain effective grievance mechanisms that allow workers and affected communities to raise concerns safely and without retaliation. Concerns can also be reported through Elopak's reporting channel and whistleblowing helpline, which are accessible to external stakeholders" (page 118).

On remedy: "Where Elopak has caused or contributive to a material negative impact on workers in the value chain, or where such impacts are identified through due diligence, audits or grievance mechanisms, Elopak seeks to contribute to remedy through engagement with the relevant suppliers, including corrective action plans and suitable follow-up measures. To promote transparency and effectiveness, we provide clear guidance on these mechanisms and publicly report metrics on concerns and cases reported and addressed" (page 118).

The helpline mechanics are given under G1: it "is available in eight languages and accessible to external stakeholders, including workers in our value chain. It offers anonymous reporting and is managed by an independent service provider", with reports assessed by the Whistleblower Secretariat comprising Legal and Compliance and HR representatives, and "all concerns are investigated promptly, fairly, confidentially, and objectively" in line with the EU Whistleblower Directive (page 127).

Outcome for 2025: the IDDs run for critical and high-risk suppliers "identified no instances of forced labour, child labour, or major human rights violations. No related concerns were reported through grievance or whistleblowing channels" (page 119). Elopak does not disclose how many value chain workers are aware of or trust the channels.

Taking action on material impacts on value chain workers

Reference: page 119 (ESRS content index, page 76; Appendix B lists S2-4 §36 "Human rights issues and incidents connected to its upstream and downstream value chain" at page 119 - page 135). GOV-4 maps S2-4 to due diligence element (d), MDR-A (page 64).

"To identify, prevent, and mitigate potential negative human rights impacts, Elopak applies a risk-based supplier due diligence approach, including supplier assessments and Integrity Due Diligence (IDD), with particular focus on high-risk suppliers, categories, and geographies" (page 119).

2025 priority actions (page 119): "conducting IDDs for critical and high-risk suppliers providing goods and services to Elopak sites in India, Canada, the United States, Morocco, and Saudi Arabia, as well as suppliers of filling machines and related equipment originating from high-risk countries. These assessments identified no instances of forced labour, child labour, or major human rights violations. No related concerns were reported through grievance or whistleblowing channels."

"To further strengthen supply chain risk management, EcoVadis IQ+ was introduced in 2025 to assess inherent risks across the entire supply chain. Selected suppliers were subject to additional assessments using EcoVadis Vitals, EcoVadis Ratings, or Elopak's Supplier Assessment Questionnaire." "During 2025, Elopak also revised and strengthened its SCoC, with enhanced requirements on suppliers to conduct human rights due diligence... Contractual clauses were updated accordingly" (page 119).

Actions table (page 119) - taken in 2025: "By 2025 97% of key suppliers (by spend) signed/accepted Elopak SCoC"; "By 2025 94% of key suppliers (by spend) were screened"; procurement-team training "completed for local teams in USA, Germany, Canada, Saudi Arabia, Morocco and India". Planned to 2026: further SCoC engagement; screening all key suppliers; further training; "Human rights assessment and capacity building meetings with selected suppliers"; and "Integrating clause on responsible business conduct... in key supplier contracts", marked "Not started".

Risk context (page 116): raw materials for cartons represent "approximately 50% of Elopak total external purchasing spend", and forced and child labour risks are "associated with sourcing from certain high-risk geographies, including China and India".

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

Reference: page 120 (ESRS content index, page 76). GOV-4 maps S2-5 to due diligence element (e), under both MDR-T and MDR-M (page 64).

Two targets, both due 2026 (page 120):

• "Ensure that 100% of key suppliers sign, accept or demonstrate conformance to our global SCoC by 2026, including requirements to ensure and uphold workers' rights in the value chain" (S2.1, S2.2, S2.3)
• "Ensure that 100% of key suppliers are screened on social and environmental criteria by 2026" (S2.1, S2.2, S2.3)

"Targets are identified and proposed by the Procurement excellence function in alignment with relevant internal stakeholders including the Procurement leadership team and finally approved by the EVP Packaging and Procurement as part of the yearly business planning process" (page 120).

Progress (page 120): "By 2025 approximately 97% of our key suppliers, 100% of our raw material suppliers as well as 88% of all suppliers (by spend) have signed, accepted or demonstrated conformance to our SCoC. In 2024, the corresponding figures were 95%, 100% and 84%." On screening: "By 2025 94% key suppliers (by spend) have been assessed and screened either via EcoVadis, via our internal Supplier Integrity due diligence process... or via in-depth Integrity due diligence assessment conducted with support from external partners. This is an increase from 84% in 2024."

Scope and its limits are disclosed: "Key suppliers are defined based on their business criticality and spend levels as well as their sustainability risk levels", covering direct raw material suppliers and indirect suppliers "mainly related to logistics and transport, plant investments and maintenance, as well as services associated with higher human rights risk such as facility services". Crucially, "Key suppliers exclude equipment suppliers (including spare parts and components). Suppliers related to this business area and categories are treated with similar processes but are not included in targets for key suppliers" (page 120). Data comes from the "global Supplier spend cube covering the majority of Elopak supplier spend", with some local sites retrieved manually.

Business conduct policies and corporate culture

Reference: page 125, with the policy table at page 127 and training metrics at page 131 (ESRS content index, page 76). The Appendix B table marks G1-1 §10(b) UN Convention against Corruption and §10(d) protection of whistle-blowers as "NM" (page 135).

"Elopak's culture of integrity is anchored in clear commitments from the Board and Management. These commitments are embedded through our global compliance program, which is designed to prevent, detect, and respond to breaches of laws, regulations, and internal policies. The program is managed by the Group Legal and Compliance function, led by the Chief Legal and Compliance Officer, who maintains an independent reporting line to the BASC" (page 125).

"Our governing documents define Elopak's commitments and requirements for responsible business conduct. These documents form the Elopak Management System (EMS), launched in 2024 to standardize and document all global processes" (page 125).

Code of Conduct (page 125): it "covers key areas such as anti-corruption and bribery, business partner integrity, human rights, conflicts of interest, gifts and hospitality, anti-money laundering, fair competition, insider trading, and sanctions and trade compliance. All new employees complete CoC e-learning during onboarding, and all employees undergo annual mandatory training, confirming they have read and understood the CoC."

Policy table (page 127): Code of conduct (Board of Directors, external, G1.1); Anti-corruption policy (Chief Legal and Compliance Officer, G1.2); New country entry and business partner integrity procedure (G1.2); and Reporting concerns and internal investigation procedure (G1.1, G1.3).

Corporate culture metrics (page 131): Code of conduct training completion 2024 → 2025 - employees 99% → 100%; Management 100% → 100%; Board 100% → 100%. Also "In 2025, 73% of Elopak's processes were documented and made available in EMS, up from 32% in 2024."

Context: "Elopak operates 12 manufacturing plants and supply 70 markets worldwide through market units and partners in over 40 countries. Hence, we are exposed to heightened governance risks... Several of our markets rank high on global indices for corruption, political, and civil risk" (page 125).

Prevention and detection of corruption and bribery

Reference: page 128, with the anti-corruption policy description at page 126 and reporting channels at page 127 (the ESRS content index lists "G1-3 Procedures to address corruption and bribery" at page 128 - page 76).

"Elopak's Anti-corruption policy outlines our zero-tolerance to bribery and corruption. It identifies main risk areas and describes considerations used to assess circumstances of bribery and corruption, covering areas such as facilitation payments, public officials, gifts and hospitality, and conflicts of interest" (page 126). The report reproduces "the countries in which Elopak operates and their respective scores from Transparency International's Corruption Perception Index 2025".

Risk assessment (page 128): "In 2025, Elopak improved the legal and compliance risk data collection and assessment process... Legal, Compliance and Procurement developed tailored risk questionnaires covering our value chain elements and distributed these to our risk owners, representing global procurement, manufacturing plants/business areas, and market units. Elopak's joint ventures were included in the scope. Among various compliance topics, the questionnaires covered corruption risks, such as bribery, facilitation payments, sponsorships and donations, gifts and hospitality, and conflicts of interest. ... The annual legal and compliance risk assessment was approved by the Management and Board at the end of 2025." Elopak also "conducted visits to our entities in Morocco and Canada to review key compliance areas, including corruption and bribery risks".

Integrity due diligence (page 126): country risk assessments "covering sanctions, regulatory, geopolitical, and reputational factors", supported by "Elopak's Country watch list", plus "audits or reviews of high-risk partners, including joint ventures".

Separation of investigation from management (page 127): the Chief Legal and Compliance Officer has an independent reporting line to the BASC and "meets the BASC regularly, to report on whistleblower cases, including cases of corruption and bribery, if any. In addition, certain concerns are... notified immediately to the CEO and the Board."

Training reach (page 131): among employees in risk-exposed positions - inside information 100% (classroom), conflicts of interest 91%, gifts 94%, sanctions and trade compliance 77%, integrity due diligence 65%, and speaking up and reporting concerns 56%.

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T disclosures rather than as a numbered disclosure requirement. G1-3 Targets became a standalone DR only in the 2025/2026 ESRS, and Elopak's statement was prepared under the 2023 ESRS.

Elopak sets two explicit business conduct targets (page 130):

• "Drive commitment to responsible business conduct by ensuring all Elopak employees complete our Code of conduct training in 2026" (IROs G1.1, G1.3)
• "Facilitate one way of working by developing a complete EMS process landscape by end of 2026" (IROs G1.1, G1.2, G1.3)

Governance of the targets is disclosed: "Targets are proposed by internal key stakeholders responsible for the implementation of the respective IROs, meaning the Chief Legal and Compliance Officer, and approved by the Chief Financial Officer. All targets were approved by the Management as part of Elopak's annual business planning process" (page 130).

Progress against both (page 131): Code of conduct training completion rose from 99% to 100% of employees in 2025, with Management and the Board at 100%; and "In 2025, 73% of Elopak's processes were documented and made available in EMS, up from 32% in 2024. In 2026, we aim to complete the entire EMS process landscape."

Effectiveness is also tracked outside the targets, the MDR-T alternative limb: "Through the regular Employee survey, we obtain key insights into how employees perceive our integrity culture and the effectiveness of our speak-up practices" (page 128), and "The 2025 Employee survey shows improved employee confidence in Elopak's ethical business conduct and an improvement where employees feel that they can report unethical behavior without fear of retaliation" (page 129).

Incidents of corruption or bribery

Reference: page 131 (ESRS content index, page 76; Appendix B lists G1-4 §24(a) "Fines for violation of anti-corruption and anti-bribery laws" and §24(b) "Standards of anti-corruption and anti-bribery" at page 131 - page 135). GOV-4 maps G1-4 to MDR-M (page 64).

Nil return, stated: "In 2025, there were zero convictions related to the violation of anti-corruption and anti-bribery laws, and hence no such fines. The same applied in 2024" (page 131).

Anti-corruption and bribery training coverage (page 131), "Employees in risk exposed positions for corruption who have completed a specific course on anti-corruption and bribery":

• Inside information - classroom - 100%
• Conflicts of interest - computer-based - 91%
• Gifts - computer-based - 94%
• Sanctions and trade compliance - computer-based - 77%
• Integrity due diligence - classroom - 65%
• Speaking up and reporting concerns - classroom - 56%

Reporting principles (page 131): the anti-corruption training is "Training for functions most exposed to risk of corruption and bribery, encompassing sales, service, procurement, finance, HR, including Legal and Compliance", and "Within each category, the denominator of the calculation represents the total number of relevant employees per course". Elopak notes that "Comparative figures are not available at the same level of granularity". "The metrics have not been validated by an external body other than the assurance provider."

No number of confirmed incidents, dismissals or contract terminations related to corruption is separately reported, and no breakdown of the nature of incidents is given. Whistleblower cases are reported to the BASC and, where relevant, immediately to the CEO and the Board (page 127), and Q4 2025 Management agenda items included a "status on whistleblower cases" update (page 63).