Eltel Ab

The role of the administrative, management and supervisory bodies

Reference: pages 28-29.

Board of Directors: six members elected by the AGM, all non-executive, plus two employee representatives. Two of the six elected members are women (33%). 100% of elected board members are independent of the company (p.29).

The Board and its committees, including the Audit Committee, are responsible for approving sustainability policies and commitments, approving the business plan (including sustainability-related objectives, strategies and risks), approving sustainability targets, overseeing material sustainability matters through regular review, reviewing annual sustainability reporting, and overseeing internal/external audit processes.

Group Management Team (GMT): nine members, four women. The President and CEO holds the highest senior-management position responsible for overseeing sustainability impacts, risks and opportunities, chairs the GMT, and reports directly to the Board. Country-level management teams handle sustainability matters locally (HR, HSSEQ, finance, legal, procurement, customer relations), reporting to country CEOs with functional links to Group functions.

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

Reference: page 29.

Sustainability agenda items were discussed during Board of Directors (BoD) and Audit Committee (AC) meetings in 2025, with briefings from the Group Management Team and heads of relevant functions (Sustainability, Internal Audit). Topics discussed in 2025 included:

• Materiality assessment and sustainability impacts, risks and opportunities
• Progress toward climate targets and application of the new science-based Scope 3 target
• Health and safety performance
• Incidents and the whistleblowing system
• Employee engagement survey results
• Sustainability-linked financing

Integration of sustainability-related performance in incentive schemes

Reference: pages 29-30.

Sustainability performance is incorporated into the short-term incentive scheme for the CEO and the Group Management Team, aligned to two priorities:

• Health and safety - 5% of short-term incentives, measured by the Lost Time Injury Frequency Rate (LTIFR).
• Climate change mitigation - 5% of short-term incentives, measured by three KPIs derived from Eltel's SBTi targets: decreasing direct emissions, increasing the share of renewable electricity, and increasing the share of supply chain emissions covered by suppliers with SBTi targets.

Guidelines are approved and updated at the Annual General Meeting.

Statement on due diligence

Reference: page 60 (Annexes to the Sustainability Statement).

Eltel maps the five core elements of due diligence to where they are addressed in the sustainability statement:

Risk management and internal controls over sustainability reporting

Reference: page 28.

Eltel's risk management and internal control system for sustainability reporting follows the Group's common risk-management framework, based on the ISO 31000 standard. The Group Sustainability Team prepares and consolidates the ESRS report; ESRS reporting uses Eltel's internal reporting processes overseen by Group Finance, with Group Shared Services performing routine data validation; EU Taxonomy reporting is managed by Group Finance.

"Key risks associated with sustainability reporting relate to the accuracy and completeness of reported information." Controls include internal audits, routine data validation, process monitoring and third-party consultant/auditor review. Findings are communicated to the Group Management Team and Audit Committee.

Strategy, business model and value chain

Reference: page 31.

Eltel is "a service provider for critical communication and power infrastructure," delivering maintenance, upgrade and turnkey project services (design, planning, building, installing, securing network operation) in Finland, Sweden, Norway and Denmark, with a presence in Germany and Lithuania and Group support functions in Poland.

Value chain: main inputs are around 4,000 employees and subcontractors across 135 facilities and a leased fleet of around 3,000 vehicles. Upstream: network materials/components sourced mainly from European tier-1 suppliers, subcontractors, wholesalers and manufacturers. Downstream: telecom and power network owners/operators, utility companies, industrial customers and the public sector.

Strategy integrates sustainability through (1) reducing value-chain emissions and promoting responsible practices, and (2) capturing energy-transition opportunities in solar, e-mobility, battery storage and smart grids.

Interests and views of stakeholders

Reference: page 32.

Key stakeholders identified: own workforce (employees), workers in the value chain, affected communities, suppliers/subcontractors, customers, and investors/analysts. Engagement runs through the double materiality assessment (DMA) and ongoing operational interactions.

Selected mechanisms: employees - annual group-wide engagement survey (85% response rate in 2025), employee representatives including two on the Board; value chain workers - supplier surveys, site-level dialogue and safety walks; communities - whistleblowing channel and customer-service contact points.

DMA outcomes and stakeholder input feed into strategy and the annual materiality review.

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

Reference: pages 34-35.

Eltel's 2025 double materiality assessment identified material impacts, risks and opportunities across E1 (Climate change), E4 (Biodiversity), E5 (Resource use and circular economy), S1 (Own workforce), S2 (Workers in the value chain), S3 (Affected communities) and G1 (Business conduct).

The most material sub-topics, from both an impact and financial perspective, are climate change mitigation and health and safety (for own employees and subcontractors). A table (pages 34-35) sets out each topic, type (negative/positive impact, risk or opportunity), description, value-chain location and time horizon; e.g. GHG emissions is a negative impact spanning "Upstream, Own operations," while climate adaptation-driven power-network upgrades are a downstream opportunity.

ESRS E2 (Pollution) was reassessed as not material for 2025 (see IRO-1); E3 (Water) and S4 (Consumers and end-users) were not identified as material.

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

Reference: page 33.

Eltel's double materiality assessment (DMA) was first conducted in 2024 and is reviewed and updated annually; the 2025 assessment applied the established methodology. IROs are assessed across own operations and the upstream/downstream value chain, and across short-, medium- and long-term horizons.

Thresholds: impacts scoring an average of 3 or higher across applicable criteria, and risks/opportunities scoring 10 or more (magnitude x likelihood), are considered material. Inputs include internal stakeholders, external experts, enterprise risk management (ERM)/HSEQ processes, and frameworks including SASB, TCFD and the WWF Water Risk Filter.

Key 2025 change: "In the previous reporting period, ESRS E2 was assessed as material due to non-CO2 air pollutant emissions from the vehicle fleet. Following a refined materiality assessment supported by external environmental expertise, it was concluded that Eltel does not operate site locations where pollution of air, water or soil results in significant environmental or human health impacts... Consequently, ESRS E2 is assessed as not material for the current reporting period 2025."

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

Reference: pages 61-65 (Appendix: IRO-2 ESRS disclosure requirements covered / IRO-2 Disclosures from other EU legislation).

Eltel's ESRS content index lists page references for BP-1, BP-2, ESRS 2 GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2, and the topical standards E1, E4, E5, S1, S2, S3 and G1. E2, E3 and S4 do not appear in the index (assessed not material). Several rows carry a "Phased-in" flag with no page (E4-1; S1-13) under the ESRS 1 Appendix C transitional reliefs, and others show "-" with a short explanatory note where no Group-level target has yet been set (E4-4, S3-5, and the business-conduct/anti-corruption targets underlying G1-3-Targets).

A second table, "IRO-2 Disclosures from other EU legislation" (pages 64-65), cross-references SFDR, Pillar 3 and Benchmark Regulation datapoints, marking most as "Not material" for Eltel (e.g. E1-7, E2-4, E3-1, E3-4, S4-1) and a small set of banking-related E1-9 sub-datapoints as "Phased-in."

Transition plan for climate change mitigation

Reference: page 36.

"A formal transition plan as defined in the ESRS E1-1 standard has not yet been prepared and approved." Eltel's approach is instead guided by science-based targets, first verified by SBTi in 2022: an absolute Scope 1 reduction target, a renewable-electricity Scope 2 target, and (in 2025) a shift from an engagement-based Scope 3 target to an absolute 25% reduction by 2030. A comprehensive transition plan incorporating the new Scope 3 target "is under development and expected to be completed in 2026."

Decarbonization levers: Scope 1 fleet electrification/fuel switching; Scope 2 transition to 100% renewable electricity by 2030 via Guarantees of Origin; Scope 3 supplier engagement on science-based targets.

Locked-in emissions: "Eltel has no significant locked-in greenhouse gas emissions from key assets or products." Not excluded from the EU Paris-Aligned Benchmarks. OpEx for decarbonization is mainly renewable-energy premiums; CapEx is moderate, mainly fleet renewal via long-term leases.

Identification of climate-related risks and scenario analysis

Back-filled from the E1 transition-risk assessment (IRO-1-E1), disclosed in the FY2025 report on page 36. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Eltel conducted a transition risk assessment in 2025, applying the TCFD framework and ESRS principles, using two IEA-based climate scenarios: Stated Policies (STEPS) and Net Zero Emissions (NZE), the latter aligned with limiting warming to 1.5C. Risks were assessed across short- (2025-2026), medium- (2026-2031) and long-term (2031-2050) horizons, covering carbon pricing, regulatory developments, market shifts and stakeholder expectations, for own operations with consideration of upstream/downstream implications.

"All material climate-related risks identified are transition risks. Climate-related physical risks identified in Eltel's DMA do not exceed the materiality threshold." The report notes "a more granular evaluation of physical risks and comprehensive resilience testing... remains to be completed."

Resilience in relation to climate change

Back-filled from E1-1, disclosed in the FY2025 report on page 36. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"Eltel has not assessed the resilience of its strategy and business model in line with the ESRS by preparing a resilience analysis. Eltel plans to prepare the analysis during 2026."

In the interim, the transition-risk assessment (see E1-2-ScenarioAnalysis, page 36) informs how climate-related transition events could affect assets and business activities, but the company states this "remains to be completed to fully assess strategic resilience," and physical-risk evaluation has not been carried out to a comparable depth.

Policies related to climate change mitigation and adaptation

Reference: page 37.

Climate-related impacts, risks and opportunities are managed through the Sustainability Policy and Environmental Policy. The Sustainability Policy commits Eltel to reducing climate impacts in line with its science-based targets and to cooperating with clients/value-chain partners; it also recognizes opportunities from providing "infrastructure solutions that support the transition to a robust, resilient and carbon-neutral society." Eltel participates in SBTi, CDP and EcoVadis.

The Environmental Policy sets standards for climate mitigation, resource use, biodiversity and chemicals management, committing to regulatory compliance and the precautionary principle. Material transition risks (increased costs, implementation challenges, supply-chain disruption) are managed through risk-management and procurement processes rather than climate policy. Policies commit to full transition to renewable electricity by 2030.

Actions and resources in relation to climate change policies

Reference: page 38.

2025 mitigation actions: fleet electrification - EV share rose from 14% to 18%, reducing Scope 1 emissions; fuel switching - over 1.2 million litres of renewable HVO purchased (860,000 litres more than 2024); renewable electricity sourcing - expanded Guarantees of Origin, with some country units reaching 100% coverage, cutting market-based Scope 2 emissions; supply-chain engagement - the share of Scope 3 emissions from suppliers with approved/committed SBTi targets increased and 2025 engagement targets were met, with focus shifting toward measurable emission reductions.

Operating expenditure is mainly renewable-energy premiums and vehicle leasing; capital expenditure relates primarily to fleet renewal. Implementation is embedded in ordinary business planning.

Targets related to climate change mitigation and adaptation

Reference: page 39.

SBTi-validated targets (SBTi Criteria v5.0, 2021 base year, aligned with 1.5C):

• Scope 1: reduce GHG by 42% by 2030 (base 14,908 tCO2e); 9,109 tCO2e actual in 2025, a 41% cut from base year (2025 target was 12,076 tCO2e).
• Scope 2: 100% renewable electricity by 2030; 93% actual in 2025, up from 34% at base year (2025 target 62%).
• Scope 3: over 67.4% of suppliers (by emissions, categories 1,2,4,5,6) with own science-based targets by 2026; 40% actual in 2025, up from 28% in 2024 (2025 target 35%).

The 2021 baseline "has been adjusted to account for change in organization structure in 2024." Progress is reviewed annually by the GMT and BoD; a CDP Climate Change score of B was received in 2025.

Energy consumption and mix

Reference: page 40.

Total energy consumption 2025: 59,657 MWh (down from 73,994 MWh in 2024). Fossil sources: 35,764 MWh (60% of total, down from 80% in 2024), mainly crude oil/petroleum products (33,805 MWh) plus fossil-sourced purchased electricity/heat (1,881 MWh). Nuclear sources: 471 MWh (1%). Renewable sources: 23,425 MWh (39% of total, up from 18%), comprising 10,263 MWh purchased renewable electricity/heat/cooling and 13,162 MWh fuel consumption from renewable sources.

Approximately 83% of electricity consumption is measured or invoiced; the remaining 17% (facilities without a controlled electricity contract) is estimated using cost- or area-based proxies. Eltel operates in a high climate-impact sector under EU Regulation 2022/1288.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 41-42.

2025 (tCO2e): Scope 1: 9,109 (2024: 14,163). Scope 2 location-based: 562; market-based: 579 (2024: 732/2,463). Scope 3 total: 110,434 (2024: 107,390), of which Purchased goods and services 97,269; Capital goods 45; Fuel/energy-related activities 3,214; Upstream transport/distribution 7,363; Waste generated in operations 65; Business travel 2,471; Employee commuting 8. Total GHG emissions, market-based: 120,123 tCO2e (2024: 124,016).

Biogenic CO2 emissions from biofuel combustion: 4,115 tCO2e (reported separately). 0% of Scope 1 emissions are covered by regulated emission trading schemes. Scope 3 is estimated primarily using the spend-based method, except categories 5, 6 and 7; 5% of Scope 3 emissions use primary data. Main emission-factor sources: BEIS and Exiobase.

Policies related to biodiversity and ecosystems

Reference: page 43.

New network infrastructure construction within or near legally protected areas typically requires an environmental impact assessment (EIA) and risk assessment, or similar environmental surveys, with mitigation of biodiversity/ecosystem impacts incorporated from the planning phase. When performing activities that may significantly affect legally protected biodiversity areas, site-specific instructions are followed to minimize environmental impacts. Power and telecommunication infrastructure may traverse or sit near biodiversity-sensitive areas; Eltel "strives to avoid harmful impacts on nature and adhere to all applicable regulations."

Actions and resources related to biodiversity and ecosystems

Reference: page 43.

"Eltel has not yet established a formal biodiversity action plan as specified under ESRS E4-3. However, in 2025, we undertook a comprehensive biodiversity materiality assessment to identify and understand nature-related impacts, risks, and opportunities across its operations and value chain."

The assessment "helped identify key areas of relevance across Eltel's operations and value chain, and supported internal engagement to build awareness and define ambition levels." Although a formal roadmap remains in development, Eltel has outlined initial steps: integrating biodiversity into procurement and project processes, collecting data on material volumes and origins, and engaging employees, suppliers and subcontractors.

Targets related to biodiversity and ecosystems

Reference: page 61 (ESRS content index).

No page-cited target content appears in the E4 chapter; the ESRS content index instead states directly: "Eltel has not set Group-level targets on biodiversity. The development of such targets will be evaluated as part of the 2026 sustainability framework review." This mirrors the pattern used elsewhere in the report (E5-3, S3-5, G1 business-conduct/anti-corruption targets) where a Group target has not yet been formalized.

Policies related to resource use and circular economy

Reference: page 44.

Managed through the Responsible Procurement Policy, Environmental Policy, HSSEQ Policy and Supplier Code of Conduct. Eltel "does not currently have a specific policy targeting the reduction of virgin material use," because network infrastructure components are "typically made from technically specified materials designed for long operational lifetimes, making substitution with recycled inputs currently limited." Instead, the approach focuses on extending asset life and high recycling rates at end of life, under the ISO 14001-certified environmental management system, with equivalent standards required of suppliers via the Supplier Code of Conduct.

Actions and resources related to resource use and circular economy

Reference: page 44.

Eltel requests Environmental Product Declarations (EPD) and Product Environmental Profiles (PEP) from manufacturers of key network materials, supporting decision-making and the Green Choice offering. Waste management prioritizes sorting, recycling and minimizing waste sent for disposal under the ISO 14001-certified system, via partnerships with circularity, recycling and waste-management companies. The majority of waste originates from decommissioned network infrastructure Eltel does not own but upgrades/dismantles for customers; responsibility for waste management "may vary by customer, contract, or project."

Targets related to resource use and circular economy

Reference: page 44.

"Eltel has not yet established a target for resource inflow. We will review this in 2026." On waste, the company states: "We are working to develop a Group-level waste-management target to be adopted in 2026. In the meantime, several of our subsidiaries have established country-level targets focused on efficient waste sorting."

Resource inflows

Reference: page 44.

"Data on the total weight of products and materials used across Eltel's operations are not currently available at Group level. Work is ongoing to enhance data collection and reporting on material inflows." This development is explicitly linked to improving Scope 3 emissions calculations, establishing a Scope 3 reduction target, and the biodiversity impact assessment, "which are expected to improve the availability of data on material volumes and composition for future reporting periods."

Resource outflows

Reference: page 44.

Common waste fractions include telecommunication and power cables, construction waste and electronics; common materials present in Eltel's waste streams include metals, plastics, wood, concrete, asphalt and soil. The total amount of non-recycled waste in 2025 was 2,290 tonnes (36%). The total amount of radioactive waste, as defined under Directive 2011/70/Euratom, is 0 tonnes. Electronic waste is categorized as hazardous waste in Sweden but generally non-hazardous in Eltel's other operating countries.

Waste

Reference: page 44.

2025 waste data (tonnes): Total waste generated 6,293 (non-hazardous 5,208; hazardous 1,085). Waste diverted from disposal: 5,791 total (preparation for reuse 4; recycling 4,003; other recovery operations 1,784). Waste directed to disposal: 502 total (incineration 458; landfilling 25; other disposal 19).

Waste data covers material managed through Eltel's direct contracts with circularity, recycling and waste-management partners; waste handled under customers' or subcontractors' own arrangements is excluded.

Policies related to own workforce

Reference: pages 49-50.

Addressed through the Code of Conduct, People Policy and People Instruction, Whistleblowing Policy, and HSSEQ Policy, aligned with the UN Guiding Principles on Business and Human Rights, the ILO Declaration, the International Bill of Human Rights, and the OECD Guidelines. Eltel is a signatory to the UN Global Compact.

The People Policy sets "zero tolerance for child labor, forced or compulsory labor, human trafficking, and any form of servitude, abuse, or exploitation," upholds freedom of association and collective bargaining, and commits to fair treatment regardless of nationality, gender, sexual orientation or other protected attributes. Occupational health and safety is managed under an ISO 45001-certified system across all operating countries.

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

Reference: page 50.

Eltel conducts an annual group-wide employee engagement survey; 85% of permanent employees responded in 2025. Results are anonymized but aggregated at the appropriate organizational level to inform management decisions; the most senior roles responsible are HR directors/managers in each country.

Collective agreements are in place in Finland, Sweden, Norway and Denmark. Eltel cooperates with employee representatives at Group level, including two employee representatives on the Board of Directors, and local cooperation covers occupational health and safety and collective bargaining in the Nordic countries and Lithuania.

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

Reference: page 50.

Health and safety incidents follow a structured process (root cause analysis, investigation, corrective actions) overseen by HSE management; other matters are handled by line management or HR, with effectiveness monitored through internal follow-up. Employees can raise concerns via direct reporting to managers/HR or Eltel's whistleblowing system, which ensures confidentiality, impartial review and protection against retaliation. Channel availability is communicated at orientation and reinforced through mandatory annual Code of Conduct training.

Taking action on material impacts on own workforce

Reference: pages 50-51.

Health and safety actions run through a group-wide HSE organization, with country HSE managers under the Group HSE Director, preparing annual HSE action plans; group-wide initiatives include Eltel's Life-Saving Rules and the annual Safety Week. Incident monitoring uses a group-wide near-miss/observation reporting tool. Worksite inspections and management safety walks are documented in Eltel's HSE system with country-level annual targets.

Training and development runs through the mandatory Performance and Development Dialogue (PDD, at least twice yearly). In August 2025 a data-protection incident at a third-party Swedish provider exposed employee/consultant personal data; Eltel followed its incident/crisis-management procedures and informed affected individuals, with investigations ongoing at reporting date.

Targets related to own workforce

Reference: page 51.

Health and safety targets 2025: LTIF target 4.0 (actual 3.0, 2024: 3.8); TRIF target 12 (actual 13.4, 2024: 13.2); short-term sick leave target 2% (actual 6.5%, 2024: 5.9%); fatalities target 0 (actual 0). LTIFR "decreased from 3.8 in 2024 to 3.0," close to its historic low.

Engagement target: Employee Engagement score target 3.75 (actual 3.9, unchanged from 2024). The employee Net Promoter Score improved from -5 to +3; survey participation rose from 83% to 85%.

Characteristics of the undertaking's employees

Reference: page 52.

Headcount by gender and country (2025): Total 3,942 (Men 3,372; Women 570), split Finland 1,325, Sweden 1,041, Norway 549, Denmark 442, Others (Germany/Poland/Lithuania) 585. Average headcount for the year: 4,121.

By contract type: Permanent 3,765 (Men 3,230/Women 535); Temporary 147 (Men 115/Women 32); Non-guaranteed hours 30 (Men 27/Women 3). Employee counts are disclosed at country level for Finland, Sweden, Norway and Denmark (each above 10% of total workforce); "Others" covers Germany, Poland and Lithuania.

Collective bargaining coverage and social dialogue

Reference: page 53.

Employees covered by collective bargaining agreements (2025): Finland 100%, Sweden 100%, Norway 98%, Denmark 65%, Others 0%, Group total 81%. Eltel has no employees outside the EEA.

Diversity metrics

Reference: page 53.

Top management gender distribution (Group Management Team): 4 women / 5 men, a 45% / 55% split. Age distribution of employees: under 30 - 18%; 30-50 - 52%; over 50 - 30%.

Adequate wages

Reference: page 53.

"All employees are paid adequate wages in accordance with the applicable benchmarks." In Finland, Sweden, Norway and Denmark, minimum wages are set by collective bargaining agreements; in Germany, Lithuania and Poland, statutory minimum wages apply.

Social protection

Reference: page 53.

"All Eltel employees are covered by social protection through public programs, collective agreements or insurance." Coverage includes loss of income due to sickness, unemployment, employment injury or acquired disability, parental leave, and retirement.

Health and safety metrics

Reference: page 53.

2025 vs 2024: employees covered by ISO 45001-certified management system, 100% (both years). Work-related fatalities: 0 (0). Work-related accidents: 77 (91). Accident frequency (per million hours): 11.7 (12.0). Occupational illness: 11 (9). Days lost to work-related accidents: 319 (880). "Data on fatalities resulting from occupational illness is not available." "Information about non-employees is not included in the reported health and safety metrics."

Work-life balance metrics

Reference: page 53.

Parental leave (2025): 100% of employees entitled; 6% took parental leave, comprising 210 men and 31 women.

Work-life balance is identified in the 2025 materiality assessment as a positive-impact sub-topic under S1: "Support for employees' work-life balance," affecting own operations across short-, medium- and long-term horizons (pages 34-35).

Compensation metrics (pay gap and total compensation)

Reference: page 54.

Gender pay gap 2025: 5%, calculated as (average gross hourly pay of male employees - average gross hourly pay of female employees) / average gross hourly pay of male employees, with no adjustment for role or seniority.

CEO pay ratio: the highest-paid individual's annual remuneration is 22 times the median annual remuneration of all employees (excluding the highest-paid individual).

Incidents, complaints and severe human rights impacts

Reference: page 54.

"In the reporting period, the Whistleblowing system did not yield any cases that were assessed as actual or potential negative human rights impacts affecting employees. No severe human rights incidents were identified, and no related sanctions, penalties or compensation were issued during the reporting period." Whistleblowing reports alleging discrimination or harassment are disclosed under G1-1.

Policies related to value chain workers

Reference: page 55.

Addressed through the Code of Conduct, Supplier Code of Conduct, Responsible Procurement Policy and HSSEQ Policy, aligned with the UN Guiding Principles, the ILO Declaration, the International Bill of Human Rights and the OECD Guidelines. The Supplier Code of Conduct sets minimum expectations for all suppliers, subcontractors and business partners: prohibiting child, forced or compulsory labor, human trafficking and discrimination/harassment/abuse, and requiring fair wages, lawful working hours and freedom of association. For work under Eltel's direct supervision, the ISO 45001-certified HSSEQ system applies systematic risk assessment and competence requirements.

Processes for engaging with value chain workers about impacts

Reference: page 55.

Country HSE teams, procurement and project management hold operational responsibility for subcontractor engagement, under the Group HSE Director. Mechanisms include site-level daily interactions, safety walks targeting subcontractors, online onboarding/safety-induction training, and - for certain subcontractors - direct access to Eltel's incident/observation reporting systems. Subcontractors may be required to submit a safe job analysis or risk assessment before starting work. Effectiveness is assessed indirectly through safety-performance trends rather than direct consultation with vulnerable workers.

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

Reference: page 56.

Where Eltel has caused or contributed to a material negative impact on value chain workers, remediation follows established HSE processes (incident reporting, root cause analysis, corrective actions), with performance-review follow-up. Subcontractor workers can raise concerns directly with site/project/HSE management or through Eltel's whistleblowing system, which is accessible to external stakeholders. "While formal trust assessments are not yet in place, Eltel is committed to ensuring that all workers can raise concerns without fear of retaliation."

Taking action on material impacts on value chain workers

Reference: page 56.

Subcontractor health and safety actions are embedded in annual, country-specific HSE action plans overseen by the Group HSE Director, and in procurement contract terms requiring compliance with legal/site safety standards, occupational healthcare, accident insurance, PPE and permits. Value chain LTIFR was 2.8 in 2025, down from 4.1 in 2024 - a broader safety indicator covering employees, non-employee temporary staff and subcontractor workers, with subcontractor hours estimated from invoicing.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities (S2)

Reference: page 56.

Fatal accidents target: 0 for 2025 (2025 actual: 0; 2024 actual: 0), tracked alongside the value chain LTIFR (2.8 in 2025, see S2-4).

Policies related to affected communities

Reference: page 57.

Managed through the Sustainability Policy (objective to support "robust and resilient societies") and the HSSEQ Policy (health, safety and quality requirements for reliable network service delivery). Eltel states it plays "a crucial role in restoring operations during and after storms, floods, or crises," and that maintenance/upgrades to power networks "enhance energy security."

Processes for engaging with affected communities about impacts

Reference: page 57.

Communities are engaged through the whistleblowing system (accessible to external stakeholders for community-impact concerns), defined incident-communication protocols during crises (informing customers, authorities or directly affected individuals), and direct contact via Eltel's general customer-service channels or through customers when work is carried out near private homes or occupied buildings.

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

Reference: page 57.

Eltel states it "maintains a strong commitment to its stakeholders, establishing effective communication channels and addressing adverse impacts arising from its activities," cross-referring to the S3-2 engagement channels. Health and safety toward surrounding communities is managed through structured hazard identification, safe work planning and control measures under the integrated ISO 14001, 45001 and 9001-certified HSEQ management system.

Taking action on material impacts on affected communities

Reference: page 57.

Eltel maintains continuity management and emergency preparedness for critical national infrastructure, working with authorities and customers on rapid response readiness. In 2025, Eltel contributed to restoring and repairing critical infrastructure both in its home markets and abroad, including assisting with extensive storm-related power network repairs in Ireland.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities (S3)

Reference: page 61 (ESRS content index).

No page-cited target content appears in the S3 chapter; the ESRS content index instead states directly: "Eltel has not set Group-level targets on affected communities. The development of such targets will be evaluated as part of the 2026 sustainability framework review."

Business conduct policies and corporate culture

Reference: page 58.

Governed by the Code of Conduct plus the Supplier Code of Conduct, Whistleblowing Policy, Responsible Procurement Policy, Anti-Bribery and Anti-Corruption Policy, Finance Policy, Risk Management Policy and Competition Instruction.

Whistleblowing system (per the EU Whistleblowing Directive): communicated via mandatory annual Fair Play training and the intranet; available in local languages except Lithuania and Germany; managed by local Legal Managers with a third-party provider for confidentiality. 2025: 37 reports, 22 individual cases; 24 reports closed; 13 reports (3 cases) remained under investigation at year-end; none resulted in criminal proceedings. Report categories: business ethics incidents 3 (2024: 6), discrimination/harassment 3 (2024: 9), other HR matters 30 (2024: 10), environmental non-compliance 1 (2024: 0). Fair Play training completion: 89% (2024: 87%).

Management of relationships with suppliers

Reference: pages 58-59.

Suppliers must uphold legal compliance, environmental responsibility, fair competition, labor/human rights and anti-corruption standards under the Supplier Code of Conduct. Supplier Surveys were sent to 174 key suppliers in 2025, selected by their Scope 3 emissions impact and procurement spend share, gathering ESG management information. Climate criteria increasingly guide supplier selection, prioritizing those with science-based targets; a new e-learning for procurement staff on managing value-chain climate impacts was introduced in 2025.

Prevention and detection of corruption and bribery

Reference: page 59.

Zero-tolerance approach under the Anti-Bribery and Anti-Corruption (ABAC) Policy, applying to employees, directors, managers, subcontractors and partners, prohibiting facilitation payments and improper influence. Risk-based due diligence covers country, transaction, business-opportunity and partnership risk, with contractual anti-corruption obligations placed on third parties. Reports of suspected bribery/corruption are reviewed by the local Head of Legal, then the General Counsel and Audit Committee. Anti-bribery/anti-corruption topics are covered in the mandatory annual Fair Play training.

Targets related to business conduct

Addressed via the G1 chapter's business-conduct and anti-corruption MDR-T statements, disclosed in the FY2025 report on page 61 (ESRS content index).

No formal Group-level targets are set. The index states directly under G1-1: "Eltel has not set Group-level targets on business conduct policies. The development of such targets will be evaluated as part of the 2026 sustainability framework review." A parallel statement appears under G1-3: "Eltel has not set Group-level targets on anti-corruption. The development of such targets will be evaluated as part of the 2026 sustainability framework review."

Confirmed incidents of corruption or bribery

Reference: page 59.

"In 2025, no significant fines, sanctions or incidents were recorded relating to any non-compliance with Eltel's Code of Conduct or any laws and regulations. No fines or convictions related to anti-corruption or anti-bribery laws occurred in 2025."