Enersense International Oyj

The role of the administrative, management and supervisory bodies

Reference: pages 35-36.

At the end of 2025, Enersense's Board of Directors consisted of five members and the Group Leadership Team of six members. There are no employees or employee representatives on the Board. During 2025, 40% of Board members were women and 60% men; at year-end, 0% of the Group Leadership Team were women and 100% were men (0:6).

Two Board committees operated in 2025: the Audit Committee and the Remuneration Committee. The Audit Committee "has a special task to assist the Board of Directors in sustainability reporting and monitoring the implementation of its assurance, to monitor and assess the company's reporting system and procedures in sustainability reporting" (p.35) and is responsible for monitoring Enersense's impacts, risks and opportunities; the Board approves the results of the double materiality assessment.

For business conduct specifically (G1-GOV-1, p.36), the Board approves the Code of Conduct and "is responsible for matters related to it, including defining principles related to corporate culture, corruption and bribery." The Board sets the sustainability target level; the Group Leadership Team sets the targets and reports achievement annually to the Board.

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

Reference: pages 37-38.

The Board of Directors is briefed at least once a year on the progress of sustainability activities and key risks, approves the double materiality assessment results and the Sustainability Report, and reviews the assurance plan. The Audit Committee reviews sustainability reporting systems and the assurance plan annually and "addresses sustainability issues as necessary."

Matters addressed by the Board in 2025 included: the double materiality assessment, human rights due diligence, strategic targets for occupational safety and climate emissions, setting an SBTi-aligned emissions target and transition plan, the Sustainability Plan, supplier-relations risk management, and EU Taxonomy. The Group Leadership Team discussed the same items plus HSEQ reviews and personnel-survey results, and "discussed occupational safety matters at every meeting" during 2025.

Integration of sustainability-related performance in incentive schemes

Reference: page 38.

Sustainability-related impacts are built into Enersense's short- and long-term incentive plans:

Climate metrics feature across cycles: 2023-2025 ties to a reduction in emissions from company cars in Finland (a quarter of the 15% weighting); 2024-2026 ties to the share of business related to renewable energy (a third of the 20% weighting); 2025-2027 carries two climate metrics - carbon handprint and total emissions reduction (Scopes 1-3) - together two thirds of the 20% weighting. The Board decides CEO and Group Leadership Team remuneration.

Statement on due diligence

Reference: pages 38-39 (due diligence core-element mapping table).

Enersense maps the core elements of due diligence to sections of the Sustainability Report:

"Enersense has integrated human rights and environmental due diligence into its governance and operations," with the key elements described across these report sections (p.38).

Risk management and internal controls over sustainability reporting

Reference: page 39.

Sustainability reporting is implemented centrally at Group level, with roles split so that "the persons responsible for content production and data collection for the report are not the same as the persons responsible for checking the content." The Board is responsible for internal auditing; the Audit Committee monitors "the effectiveness, adequacy and appropriateness of internal control."

The Sustainability Report has been assured (limited assurance) by an independent third party, KPMG Oy Ab. Sustainability reporting risks were assessed in 2024 as part of an internal audit, and in 2025 the reporting process was reviewed in a feedback discussion involving all parties in the reporting process. Identified risks include "ensuring data accuracy, the precision of estimation results in emissions calculations, and data availability," mitigated through defined reporting responsibilities, a reporting system, and separate content producers and reviewers for every section. The Audit Committee discusses reporting progress and risk findings at least once a year.

Strategy, business model and value chain

Reference: pages 40-41.

Enersense is "a lifecycle partner to customers in energy transmission and generation, the industrial energy transition, telecommunications and data centres," organised in three Business Units: Power, Connectivity and Energy Transition. In 2025 it sold its wind and solar power project development business to Fortum (26 February), decided to ramp down its zero-emission transport solutions business (28 February), and sold its Marine and Offshore Unit to Davie (11 July).

Two strategic sustainability targets are set by the Board: Safety (towards zero accidents, continuously decreasing lost-time incident frequency) and Climate (SBTi-aligned reduction targets for 2023-2035: -63% Scopes 1-2, -38% Scope 3).

Key production inputs are steel, electrical and telecommunications equipment, and subcontracting services. The value chain runs from Tier 3/Tier 2 raw-material and steel/concrete suppliers, through direct suppliers and Enersense's own design/construction/O&M operations, to direct customers (electricity network companies, energy producers, industrial and telecom customers, data centres) and, further downstream, consumers and dismantling services. "Enersense's customers are not direct consumer customers, nor do consumers directly use its products or services."

Interests and views of stakeholders

Reference: pages 42-43.

Key stakeholders and engagement channels (p.42): customers (regular meetings, surveys, service management); employees (information sessions, job-satisfaction and other surveys, performance appraisals); shareholders (Annual General Meeting, regular communication); suppliers (emails, calls, meetings, audits, contracts); trade unions (regular meetings, communication in change projects); analysts, funding providers and Nasdaq Helsinki (disclosure-obligation communication, webcasts, Capital Markets Day); media (interviews, media events, releases); authorities (regulatory reporting and cooperation); and associations (industry cooperation, dialogue with NGOs).

Views of customers, shareholders and personnel "have an impact on the development of Enersense's operations, products and services," and stakeholder views on sustainability impacts are discussed by the Board and management in decision-making. The company's own workforce is consulted through the methods described in section S1-2 (p.43).

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

Reference: pages 44-46.

The double materiality assessment identified material impacts, risks and opportunities across E1, E3, E5, S1 and G1: climate change mitigation (GHG emissions upstream, own operations and downstream - all actual negative impacts) and climate change adaptation (an opportunity from green-energy demand growth); energy (energy intensity of steel production and of Enersense's own fuel use); water withdrawal and water use in upstream raw-material production; resource use and the circular economy (steel-intensive infrastructure projects); employment security (a positive impact of long-term contracts); health and safety (a potential negative impact and a related cost risk); training, development and diversity (a risk of failing to attract/retain talent); corporate culture (a positive impact); supplier relationships (a risk of failures in monitoring sustainability requirements); and corruption and bribery (a risk concentrated in the Baltic countries).

In addition, "material sustainability topics to which the transitional provision has been applied" were identified for biodiversity (E4) and value chain workers (S2) - see BP-2. "Enersense has yet to implement a resilience analysis for its strategy and business model" (p.45).

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

Reference: pages 47-50.

The double materiality assessment "covered all sub-topics and sub-sub-topics of sustainability matters listed in ESRS 1 General Disclosures AR 16" and built on the initial 2023-2024 assessment. Environmental impacts are also identified regularly through the ISO 14001 certification process; in spring 2025 Enersense refined its assessment of nature-related impacts using a Biodiversity Consultancy/SBTN-based tool.

Topic-specific findings (pp.48-50): for climate (E1), Enersense "has yet to systematically identify physical risks," has identified transition risks (regulation, carbon tariffs) and one green-energy opportunity, and "no scenario analysis has yet been conducted." For pollution (E2), air-pollution impact from the (now-sold) Marine and Offshore Unit's VOC emissions was reassessed as not material, remaining below E-PRTR thresholds. For water (E3) and resource use (E5), impacts concentrate in upstream steel and concrete production. For biodiversity (E4), dependencies were identified on raw materials and renewable energy; sites are not near biodiversity-sensitive areas. For business conduct (G1), Baltic operations carry elevated corruption/bribery exposure; "Enersense has not consulted affected communities as part of the impact assessments."

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

Reference: page 51 (content index, pp.34-51); Appendix on EU-legislation datapoints, pp.52-56.

Enersense's printed content index lists, with page references: ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2); E1 (E1-1 to E1-6, E1-8); E3 (E3-1 to E3-3); E5 (E5-1 to E5-4); S1 (S1-1 to S1-6, S1-9, S1-13, S1-14, S1-17); and G1 (G1-1, G1-2). E1-7, E1-9, and every E2, E4, S2, S3 and S4 disclosure requirement, and G1-3 through G1-6, do not appear in this index.

BP-2 (p.34) states directly: "Standard E2 Pollution has been assessed as not material, and the newly reported standards are E3 Water and Marine Resources and E5 Resource Use and Circular Economy," and that Enersense "has decided to apply the transitional provisions and omit the disclosures required under standards E4 and S2" despite identifying material topics there. A separate Appendix (pp.52-56) cross-references specific datapoints to SFDR, Pillar 3, Benchmark Regulation and EU Climate Law references, marking many as "Non-material."

Transition plan for climate change mitigation

Reference: page 69.

In 2025 Enersense set science-based GHG reduction targets and submitted them to the Science Based Targets initiative (SBTi), which approved them in February 2026. The targets are "based on absolute emission reduction targets, requiring a reduction of at least 63% in its own direct emissions (Scope 1 and Scope 2) and a 38% reduction in indirect emissions in the value chain (Scope 3) between 2023 and 2035," in line with the Paris Agreement's 1.5°C goal.

Key decarbonisation measures: transition to electric vehicles and machinery, renewable/biofuels instead of fossil fuels, and procurement of recycled and emission-free steel and concrete; service providers are encouraged to set SBTi or similar targets. Cited uncertainties include "the limited availability of low- and zero-emission steel," variation in supplier emission intensity, and "the difficulty of committing service providers to ambitious emission reduction targets." Enersense states the plan "does not require significant operating or capital expenditure" and it is "not currently planning to seek green financing." The transition plan has been approved by Enersense's Group Leadership Team and Board of Directors. Enersense is not excluded from the EU's Paris-aligned benchmarks.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 (p.48) and the E1-SBM-3 sub-section (p.70), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Enersense states plainly: "Enersense has yet to systematically identify physical risks related to the climate. Furthermore, Enersense has yet to assess how its assets and business operations may be exposed to, and how sensitive they are to risks related to the climate" (p.48). Transition events have been identified through risk management processes and the double materiality assessment over the short and medium term: "stricter regulation, carbon tariffs and emissions reduction targets" as potential transition risks, and "the green energy transition" as a potential opportunity through increased sales.

"No scenario analysis has yet been conducted, and if conducted, it is expected to provide more specific results in terms of both physical and transition risks" (p.48). The E1-SBM-3 sub-section repeats: "no climate scenario analysis has yet been conducted. The resilience analysis and climate scenario analysis are planned to be conducted in the coming years" (p.70).

Resilience in relation to climate change

Back-filled from the E1-SBM-3 sub-section under ESRS 2 SBM-3 (p.70), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Enersense states: "The climate resilience of the strategy and business model has yet to be assessed through a resilience analysis. Furthermore, no climate scenario analysis has yet been conducted. The resilience analysis and climate scenario analysis are planned to be conducted in the coming years" (p.70; the same statement, in near-identical wording, also appears under SBM-3 at p.45).

No capacity-to-adapt or uncertainty analysis is presented, consistent with no resilience analysis having been carried out. The double materiality assessment did identify one climate-related opportunity (green-energy demand growth) and no material climate-related risks (SBM-3, p.44-45), but this falls short of the formal resilience analysis the disclosure requirement describes.

Policies related to climate change mitigation and adaptation

Reference: page 70.

Enersense's climate policies apply "to all Enersense employees, subsidiaries and businesses throughout the value chain": the Code of Conduct (Board-approved; covers GHG reduction across the value chain, environmental efficiency, biodiversity, circular economy); the Environmental Policy (Group Leadership Team-owned; ISO 14001:2015-aligned; commits to reducing GHG emissions, procuring renewable energy, increasing low-carbon material use, and is the basis for the SBTi commitment); the Vehicle Policy (Group Leadership Team-owned; prefers hybrid/electric vehicles, renewable fuels, and energy-efficiency measures for the production fleet); and the Supplier Code of Conduct (Group Leadership Team-owned; requires suppliers to reduce environmental impact and set science-based, time-bound emission targets).

Implementation is monitored through management reviews, carbon footprint calculations and ISO 14001 audits, plus supplier inspections for the Supplier Code (detailed under G1-2). All climate policies are available to employees on the intranet and, for the Code of Conduct and Supplier Code of Conduct, to external stakeholders.

Actions and resources in relation to climate change policies

Reference: pages 71-72.

2025 actions and 2026 plans, organised by lever: reducing value-chain GHG emissions - pilot substation and power-line projects using recycled/low-emission steel structures, galvanised coatings and concrete elements, achieving "product-specific emission reductions of around 15-40%... for steel and concrete, depending on the material"; increasing renewable energy - 71% (2024: 92%) of purchased electricity and 60% (2024: 86%) of heating were renewable or emission-free in 2025; 120 new electric production vehicles purchased in Finland (about 30% of Finland's vehicle fleet), replacing diesel cars; biofuels reached 9% of total fuel consumption; accelerating supply-chain decarbonisation - continued collaboration with WWF Finland to increase demand for low-emission steel, and development of supply-chain emissions-data collection; climate adaptation - three further pilot projects with a customer using recycled steel and concrete in substation/power-line structures.

Enersense states the measures "do not require significant operating or capital expenditure" and implementation "is not dependent on the availability or allocation of resources."

Targets related to climate change mitigation and adaptation

Reference: page 73.

Three SBTi-validated targets from a 2023 baseline, all to 2035:

"Result: Emissions from own operations declined by 17% and from the value chain by 25% from 2023." Key levers and their share of the 2035 reduction target: market changes/sector decarbonisation (-15%), fleet electrification (-12%), bio/renewable fuels (-5%), supplier SBTi commitments (-10%), recycled steel (-14%), low-emission steel (-2%), recycled/low-emission concrete (-0.5%), renewable/biofuels in maintenance (-1%), and further measures/innovation (-40%).

A fourth, non-science-based carbon handprint target was also set: more than 50% of customer offers to include low-emission materials or solutions by 2028 (monitoring begins 2026). "Climate scenarios have not been considered, as scenario analysis has not yet been carried out" (p.73).

Energy consumption and mix

Reference: page 74.

2025 Group energy consumption fell to 36,072 MWh (2024: 57,503 MWh, -37%). Of this, total fossil energy consumption was 22,726 MWh (2024: 31,428 MWh, -28%), representing 63% of total consumption (2024: 55%); renewable sources (including biomass) reached 9,505 MWh (2024: 15,029 MWh), or 26% of total consumption, unchanged year on year; nuclear-sourced energy fell to 3,841 MWh (2024: 12,732 MWh, -70%), or 11% of the total.

Energy intensity for activities in high climate-impact sectors was 118 MWh per MEUR of revenue in 2025 (2024: 135, -13%), on revenue from those sectors of EUR 307 million (2024: EUR 425 million, -28%).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: page 75.

Total GHG emissions (market-based) fell from a 96,255 tCO2e 2023 baseline to 73,196 tCO2e in 2025, an 18% decline versus the 2024 comparable figure (89,307 tCO2e); location-based totals moved from 96,323 tCO2e (2023) to 73,670 tCO2e (2025, -17% vs. 2024 comparable). Gross Scope 3 emissions were 66,769 tCO2e in 2025 (2023 baseline: 88,590 tCO2e; -19% vs. the 2024 comparable figure of 82,065 tCO2e), of which purchased goods and services was by far the largest category at 57,055 tCO2e, consistent with the SBM-3 finding that "a large part of the value chain's GHG emissions are generated in Enersense's customer projects and in the manufacture of the steel and concrete used in the company's production activities."

Emissions are calculated under the GHG Protocol Corporate Standard and the Corporate Value Chain (Scope 3) Standard, using operational control as the consolidation method and the Carbon+Alt+Delete tool; "the metrics have not been validated by an external party" beyond the limited-assurance engagement covering the statement as a whole. The 2023 base year and 2024 figures were restated to cover only core operations, following the divestment of the wind/solar project-development business and the Marine and Offshore Unit, and the wind-down of the zero-emission transport business.

Internal carbon pricing

Reference: page 77.

"Enersense does not apply internal carbon pricing mechanisms." No further detail is provided; this is a complete, nil disclosure rather than an omission.

Policies related to water and marine resources

Reference: page 77.

Enersense manages water impacts through the Supplier Code of Conduct, applied to the raw-material manufacturing chain (notably steel): suppliers "must comply with applicable environmental legislation, permits and Enersense's guidelines," and "resource efficiency is required in terms of limited resources such as water." The Code explicitly "does not address water resource management, water procurement or the use of marine resources" as a dedicated topic, and there is no direct reference to water treatment or pollution prevention - water efficiency is addressed indirectly, through the general requirement to use limited resources efficiently and through encouraging suppliers to offer recycled-content products (recycled steel and concrete "consumes less water"). The Code of Conduct is described further under E1-2.

Actions and resources related to water and marine resources

Reference: page 78.

In 2025 Enersense "implemented measures to manage and mitigate the water-related impacts of its supply chain," aimed at the targets in E3-3: reducing water consumption and increasing recycled-material use. Costs were roughly estimated as part of the climate transition plan; implementation "does not require significant operating or capital expenditure," is "not dependent on the availability or allocation of resources," and Enersense has "no plans to seek green financing." "Enersense has not carried out targeted measures related to water risk areas."

Targets related to water and marine resources

Reference: page 78.

Under the 2025-2028 Sustainability Plan: Target 1 - commitment to the Supplier Code of Conduct across 100% of procurement costs (monitoring begins 2026); 2025 action: the Code was updated to add a water resource-efficiency requirement, and pilot substation/power-line projects used recycled steel and low-carbon concrete, whose "production processes... consume less water than the manufacture of virgin materials." Target 2 - more than 50% of customer offers to include a low-emission materials/solutions proposal by 2028 (shared with E1-4/E5-3; monitoring begins 2026).

"The targets are set by Enersense, and in target setting, stakeholders were consulted through ongoing stakeholder cooperation. The targets are not science-based or materially related to water risk areas."

Policies related to resource use and circular economy

Reference: page 79.

The Supplier Code of Conduct governs the impact of building materials such as steel: suppliers "are required to use limited resources, such as energy, water and raw materials, efficiently and to enhance recycling and reuse." Enersense "values suppliers who offer innovative solutions that reduce the carbon footprint in the supply chain," with particular emphasis on low-emission steel and concrete options containing recycled materials. The policy is described further under E1-2.

Actions and resources related to resource use and circular economy

Reference: page 79.

In 2025 the Supplier Code of Conduct was updated to add "a requirement to take resource efficiency and the circular economy into account, including the preference for recycled materials," and requests for quotation now ask for innovative, low-carbon steel and concrete options. Pilot projects for substations and power lines used "low-emission steel structures, galvanised coatings, masts and concrete elements," aimed at reducing virgin raw-material use. For 2026, Enersense "intends to continue offering its customers more responsible materials," though "the impact of future actions has not yet been assessed." As with E1-3/E3-2, costs "do not require significant operating or capital expenditure" and are "not dependent on the availability or allocation of resources."

Targets related to resource use and circular economy

Reference: page 79.

Two 2025-2028 Sustainability Plan targets, shared with E1-4 and E3-3: Target 1 - Supplier Code of Conduct commitment across 100% of procurement costs by 2028 (monitoring from 2026), covering resource-efficiency and circular-economy requirements. Target 2 - more than 50% of customer offers to include a low-emission materials/solutions proposal by 2028.

"The use of recycled materials in construction projects promotes resource efficiency and the circular economy as their production processes consume less virgin raw materials and water." Progress will be tracked via sales systems and project-specific material choices from 2026. "The targets are not science-based."

Resource inflows

Reference: page 80.

2025 steel and concrete inflows (first year measured):

"Steel and concrete were identified as material topics in the double materiality assessment." Roughly half the steel weight comes directly from invoice data, with the remainder estimated via technical dimensions or euro-per-tonne coefficients; concrete weights are calculated from supplier dimensions and typical density. "Steel and concrete were identified as material flows of significance in the 2025 double materiality assessment only," so no comparable 2024 figure exists and 2025 is the first baseline year.

Policies related to own workforce

Reference: pages 81-82.

Key policies: Personnel Policy (Group EVP HR-owned; covers safe working environment, leadership, occupational safety and wellbeing, employee development, diversity); Code of Conduct (complements the Personnel Policy on human/labour rights, equal opportunities, non-discrimination); Occupational Health and Safety Policy (Board/CEO-approved, ISO 45001-aligned; certified and audited annually); and Human Rights Policy, prepared in 2025 and approved by the Board, covering "the key human rights impacts, and Enersense's approach to mitigating human rights risks in its own operations and across the supply chain."

Policies align with the UN Guiding Principles on Business and Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work, and apply zero tolerance for harassment and discrimination across an explicit list of grounds. "Enersense has no specific policy commitments regarding the inclusion of or positive action in favour of persons belonging to particularly vulnerable groups." All policies are on the intranet, with mandatory training via the WeLearn platform.

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

Reference: page 83.

Engagement runs through occupational health and safety cooperation, Group/Business Unit-level dialogue, and the WeSense employee survey (at least annually). Employee representatives take part in occupational safety risk assessments and workplace surveys, and dialogue with legal representatives occurs "at least four times a year" in Finland; Baltic countries hold occupational health and safety and environmental dialogue plus personnel surveys.

In Finland, Enersense applies collective agreements from the technology, energy, and electricity/ICT sectors, all providing for cooperation dialogue on occupational health and safety. Specific risk groups identified - minors, pregnant women, employees past retirement age, and employees with disabilities - have their views addressed in work planning and risk assessments. 2025 outcomes from this engagement included continued development of the HSEQ information system, improved safety reporting transparency, and enhancements to sickness-absence management.

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

Reference: page 84.

Remediation runs through HSEQ risk-assessment guidelines, the WeCare incident reporting/handling system, the HSEQ Network, and workplace assessments; after remedies, a residual-risk assessment checks whether they were sufficient. Own-workforce personnel are covered by occupational-accident insurance and paid at least the national minimum incapacity compensation.

Concern-raising channels: the whistleblowing channel, an ethics email, an HR email for harassment/personnel matters, and WeCare for HSEQ matters; all are available in every operating country and accept anonymous notifications. Reporters are protected against retaliation under Directive (EU) 2019/1937 as implemented nationally, per the Code of Conduct. "Enersense aims to ensure that people in its own workforce are aware of the above processes and perceive them as reliable ways to raise concerns," reinforced through mandatory training, newsletters and safety briefings.

Taking action on material impacts on own workforce

Reference: pages 85-86.

Measures addressing occupational health and safety and talent retention (2025-2028 unless noted): a safety-culture development programme (benchmarking against companies with strong safety practices); data-driven safety and work-ability management (real-time HSEQ dashboards); ongoing HSE risk assessments; HSEQ system development (new tools deployed autumn 2024, extended in 2025); continuous workplace surveys in Finland with occupational healthcare; replacement-work models (2024-2025, reducing sick leave); and workwear renewal (2025-2026).

Workforce-development measures: full use of the WeLearn learning platform; ongoing leadership training; and a Finland-wide working community development plan. None of these measures "require significant operating or capital expenditure."

Targets related to own workforce

Reference: page 87.

Occupational health and safety, 2025 results against target:

"Enersense achieved its defined key occupational safety targets and made significant improvements compared with both 2024 and previous years." 2026 targets: LTIF < 5.5, TRIF < 8, serious accidents 0. The Board approved 2025 targets in spring 2025; stakeholders were not consulted in setting or monitoring them.

Skilled and diverse workforce target: by 2028, women to reach at least 28% of white-collar and 5% of blue-collar employees; 2025 result: 24% (white-collar), 2% (blue-collar). No target has been set for long-term employment relationships, though tenure/turnover is monitored (S1-6). Mandatory-training completion is also monitored, but "the topic became material only in the reporting year, and the setting of a target will be considered at a later stage."

Characteristics of the undertaking's employees

Reference: pages 88-89.

By gender (2025): 1,341 men, 191 women, 2 other/undisclosed - total 1,534 (2024: 1,883). Average FTEs for the year: 1,709. By country (2025): Finland 956, Estonia 294, Latvia 226, plus Lithuania (under 10% of total, not broken out) (2024: Finland 1,251, Estonia 315, Latvia 254). By region: Finland 956, Baltics 578 (2024: 1,251 / 632).

Contract type (2025, headcount): 1,296 permanent employees; 60 fixed-term; 29 with non-guaranteed hours. Employee turnover 2025: 15.5% (270 leavers against an average headcount of 1,743.9), versus 13.3% in 2024; 97 Finland-based employees transferred out via a business transfer on 12 July 2025 and are excluded from leaver counts. Age distribution (2025): under 30 = 206 (13.4%), 30-50 = 810 (52.8%), over 50 = 518 (33.8%), total 1,534. Data are sourced from the Oracle Fusion HCM system; "the metrics have not been validated by an external party."

Diversity metrics

Reference: page 90.

Age distribution of employees (2025): under 30 = 206 (13.4%); 30-50 = 810 (52.8%); over 50 = 518 (33.8%); total 1,534 (see country breakdown under S1-6). Gender distribution of the Group Leadership Team (senior management, 2025): 7 members, 100% men, 0% women. Both datasets are sourced from the Fusion People HR system and cover the entire Group in Finland and the Baltic countries; "the metrics have not been separately validated by an external body."

Training and skills development metrics

Reference: page 90.

Average training hours per employee in 2025: 8.5 hours overall (men: 7 hours; women: 19 hours), drawn from Enersense's WeLearn learning-platform reporting tool and covering all employees at 31 December 2025 in Finland and the Baltic countries; external training not logged in the system is excluded. "Development discussions are conducted with all employees at Enersense. However, related data are not currently collected systematically." The metrics have not been externally validated.

Health and safety metrics

Reference: page 91.

The incident rate is calculated as 1,000,000 x incidents / working hours (TRIF); the 2024 figure was later revised from 15 following a more accurate working-hours calculation. Coverage is certified under ISO 45001 (per S1-1). "The metrics have not been validated by an external body."

Incidents, complaints and severe human rights impacts

Reference: page 92.

"There have been no cases of discrimination, harassment, or serious human rights violations in Enersense's activities. There have also been no fines, penalties or damages paid in this context." There were no reports of discrimination or harassment in 2025 (2024: three reports). Data are drawn from the whistleblowing channel and HR contact people in Finland and the Baltic countries; "the metrics have not been separately validated by an external body."

Business conduct policies and corporate culture

Reference: pages 93-94.

Corporate-culture policies: the Code of Conduct (Board-approved; covers ethical business practices, fair competition, anti-bribery and corruption, conflicts of interest, human rights and the environment; commits to the UN Guiding Principles); the Procurement Policy (VP Procurement-owned; sets supplier-approval and audit criteria); the Supplier Code of Conduct (Group Leadership Team-owned; environmental/social requirements for suppliers, detailed under G1-2); and the Anti-Bribery and Anti-Corruption Policy, aligned with the UN Convention against Corruption (legal department-owned; personnel-facing).

Culture rests on three values: "Be brave, Grow responsibly and Together." Code of Conduct training is mandatory at induction; by end-2025, 76% of employees had completed it. Concerns can be raised confidentially to a manager, through the public whistleblowing channel, or to the Ethics Committee (EVP Legal, EVP HR, CFO), which investigates without delay, protects whistleblowers against retaliation under Directive (EU) 2019/1937, and informs reporters of serious-misconduct outcomes within three months.

Management of relationships with suppliers

Reference: pages 95-96.

Supplier relationships are managed through joint meetings, selection processes and audits, targeted especially at "high-risk areas... identified in relation to subcontracting chains and non-EU suppliers." The Supplier Code of Conduct sets environmental criteria (compliance with environmental law/permits, encouragement of SBTi-or-equivalent targets, preference for lower-emission steel and concrete) and social criteria (occupational health and safety, human/labour rights, non-discrimination, harassment-free working conditions).

Compliance is monitored via Business Unit-led audits, risk-based by supplier classification: strategic suppliers are audited once every three years, covering Supplier Code compliance and HSEQ; other suppliers face statutory checks and audits "if required." New suppliers undergo a background check before onboarding. Target: commitment to the Supplier Code of Conduct across 100% of supplier spend, first monitored from 2026.

Targets related to business conduct

Back-filled from the G1 business conduct chapter (G1-3, pp.95-96), which sits under the 2023-ESRS MDR-T minimum disclosure requirement for targets rather than as a standalone DR. Data key G1-3-Targets did not exist as its own requirement under the 2023 ESRS.

No numeric target is stated for bribery and corruption; instead, Enersense discloses the other MDR-T limb - effectiveness tracked in the absence of a formal target. The Code of Conduct states a zero-tolerance policy, with an explicit stated objective: "In line with the zero-tolerance approach, Enersense's ongoing objective is that its operations are not associated with any cases of bribery or corruption" (p.96). Effectiveness is tracked through: mandatory Code of Conduct training completion (76% of employees by end-2025); training coverage of "100% of risk functions" (mandatory for all employees and new hires); Ethics Committee investigation and Board/Audit Committee reporting of any cases; and a dedicated anti-bribery/anti-corruption training programme prepared in 2025 for 2026 rollout.