Europris ASA

Reference: page 35.

The board "consists of seven non-executive, all independent members, with a gender ratio of 4:3 (female to male)"; the management group has "two senior executives and thirteen non-executive members" (5 women, 10 men). "Europris ASA has no direct employees and therefore no requirement to appoint employee representatives to the board", though "three employees are represented on the board of the Europris AS subsidiary and as observers to the board of Europris ASA" (page 35). The audit committee "has an overarching responsibility to oversee the sustainability reporting" and reports recommendations to the board, which "retains responsibility for deciding on and implementing" them. Day-to-day management of material IROs sits with the sustainability and finance departments under a steering group listing seven named roles (page 35-36).

Reference: page 35.

"Sustainability as a standalone topic is reviewed by the board at least once a year, with specific themes addressed more frequently if needed. In June 2025, the board reviewed the status of the first-year sustainability reporting" and received "an update on the group strategic project addressing sustainable products and related communication" (page 36). "Sustainability-related risks and opportunities are reported to and approved by the board annually as part of the risk management process", and "for 2025, high risks identified through the double materiality analysis (DMA) were included in the overall risk management process" (page 36).

Reference: page 36.

"For all employees that have bonus agreements, at least 20 per cent of the bonus shall be connected to ESG-related issues and all members of the management group have ESG targets linked to climate mitigation aligned with the approved science-based targets. For the C-Suite level, the total bonus linked to climate mitigation varies between ten and twenty per cent" (page 36). Incentive schemes are "reviewed and updated once a year by the management group, approved by the CEO and overseen by the board", which "holds exclusive responsibility for setting and overseeing the CEO's incentive plan."

Reference: page 36.

The statement sets out a table mapping the core elements of due diligence to where they are covered: embedding due diligence in governance ("ESRS 2 GOV-2 (p.35), G1 (p.127), S2 SBM-3 (p.110 and S2 Actions (p.103)"), engaging with affected stakeholders ("ESRS 2 SBM-2, S2 (p.113)"), identifying and assessing adverse impacts ("ESRS 2 IRO-1 and SBM-3 (p.110)"), and taking action / tracking effectiveness ("S2 Actions (p.103)" for both). "All suppliers are required to sign the group's Code of Conduct... prior to entering into an agreement" and the group "conducts annual due diligence assessments and employee training as well as supplier dialogue, audits and meetings" (page 36).

Reference: page 37.

"One of the biggest risks is ensuring that correct data is received on time." To manage this, "the four-eyes principle is applied to the report", a "sustainability reporting system" was implemented in 2024 to strengthen internal controls, and a steering group for ESG reporting drives readiness and compliance. "The audit committee is responsible for overseeing the quality of the sustainability statement in the annual report" and, with the internal steering group and the external auditor, "evaluates the process related to the reporting of sustainability data"; this "was done as part of the interim audit process in October 2025, and finalised in March 2026" (page 37).

Reference: page 37.

"The group's value chain extends from raw material extraction to end-of-life waste management" across nine steps (raw material production, transport, material processing, production, head office, storage, retail, customer, waste management), simplified in a value-chain diagram (page 38-39). "The group's climate ambitions are aligned with the objectives of the Paris Agreement, including a long-term ambition to achieve net-zero emissions by 2050." Key strategic challenges named: progressing the climate action plan, enhancing product circularity, strengthening ESG data quality, and "further embedding a coordinated group-wide approach to social compliance in the value chain" (page 38-39), alongside a table of sustainability-linked strategic targets across climate, circularity, workforce and workers in the value chain (pages 39-41).

Reference: page 41.

Nine stakeholder groups are described with their interests and engagement channels: banks and funding, customers, investors and analysts, suppliers, employees, NGOs, local communities, and government and regulators (pages 41-42). "Below are the top three topics concluded from stakeholder interviews: Product lifecycle and environmental impact... Supply chain transparency and labour conditions..." (page 42). "The management group is informed about the views and interests of affected stakeholders through processes such as the review and revision of the double materiality analysis", supplemented by the annual customer and employee surveys (page 42).

Reference: page 43.

The double materiality assessment (DMA), conducted in 2024 and updated in 2025, followed four phases (understand, identify, assess, determine), covering "all group operations and subsidiaries" and the full value chain. Materiality of impacts was scored on "scale, scope and irremediable character, multiplied by likelihood"; risks/opportunities on "nature of the effect... magnitude and... likelihood." The result: "the group has fifteen material sub-topics across seven sustainability topics" (page 44). A separate TCFD-aligned climate risk analysis, conducted in 2024, evaluated physical and transition risks in a low-emission (RCP 2.6/SSP1-2.6, IPCC) and high-emission (RCP 8.5/SSP5-8.5, IPCC) scenario, and transition scenarios APS and BAU (IEA) (pages 44-45).

Reference: page 119.

"ESRS Index can be found on page 119" (page 44). Appendix A lists, by ESRS and DR code, every disclosure requirement the statement covers with its page reference, from BP-1/BP-2 and GOV-1 through GOV-5, SBM-1 through SBM-3 and IRO-1/IRO-2, through E1-1 to E1-8, the E4 phase-in summary, E5-1 to E5-5, S1, S2 and S4 disclosure requirements, and G1-1, G1-3 and G1-4 (pages 119-122). "Incorporation by reference: ESRS index: All disclosure requirements reported on according to the ESRS is listed in appendix A" (page 35). This index is the authority used throughout this entry to determine reported status.

Reference: page 47.

"The double materiality assessment has concluded that seven out of ten sustainability topics are material to the group": E1 Climate change, E4 Biodiversity and ecosystems, E5 Resource use and circular economy, S1 Own workforce, S2 Workers in the value chain, S4 Consumers and end-users, and G1 Business conduct (page 47), with fifteen material sub-topics detailed in the table of material sustainability topics (page 48). "No risks or opportunities have been assessed to have a significant effect on the group's current financial position within the reporting year. Such financial effects are therefore not described further" (page 47). "The updated assessment did not result in changes in material topics" versus 2024, though S1 materiality was reassessed at sub-sub-topic level (page 47).

Reference: page 55.

"A complete transition plan in line with the requirements of the ESRS has not yet been finalised. The work is ongoing, and this process is expected to continue in the coming years." In 2025 the group "developed a group-wide framework to further structure its work on mitigating actions, resulting in a climate action plan", with key levers identified in "purchased goods, transport and electricity consumption", evaluated on emission-reduction potential, cost and feasibility. "A steering group with representatives from the management group and C-suite level" oversees implementation, meeting bi-annually, with the board "informed on progress on an annual basis" (page 55-56).

Reference: page 56.

"A climate policy was developed in 2025" outlining "the group's ambitions and commitments to reduce greenhouse gas emissions in accordance with science-based targets." It covers scope 1, 2 and 3 emissions, is "communicated to relevant roles through email and meetings", and is "available internally" and published at the investor relations sustainability page. "The most senior role accountable for the implementation of the policy is the VP Strategy and Sustainability", with department heads responsible for operationalisation. The policy sets overarching targets (net-zero by 2050, short-term by 2030), a review cycle of "every three years, or if significant changes in legislation, strategy or climate targets occur" (page 56).

Reference: page 56.

Actions are organised by responsible VP (Commercial for product, Supply Chain/Distribution for transport, Store Operations for energy) and focus on "the energy use in own operations and the two scope 3 categories in the value chain with the greatest emissions, category 1 and category 4" (pages 56-58). Named, partly-quantified levers include LED-lighting (77 of 92 stores converted; "about 35 per cent" reduction in store MWh), solar panels, certificates of origin in Sweden, deep-sea bio-fuel (7,576 tCO2e saved in 2025), bio-gas lorries (four in operation, eight more due H1 2026), a 30% recycled-content target for polyester/plastic by 2030, and work towards deforestation-free sourcing (pages 58-60).

Reference: page 61.

SBTi-approved targets: net-zero by 2050, scope 1+2 GHG down 42% by 2030 (2021 base), scope 3 GHG down 25% by 2030, scope 3 FLAG emissions down in line with a zero-deforestation commitment for primary deforestation-linked commodities by end-2025, plus a store energy-efficiency target of 80 kWh/m2 by 2030 (page 61-63). "Scope 1 and 2 are compatible with limiting global warming to 1.5°C, while scope 3 targets fulfil the well-below 2°C minimum requirement" (page 61). Against the 2021 baseline, scope 1+2 emissions are up 48.4% (target -42%), explained by "a 52.1 per cent increase in the market-based emission factor"; scope 3 is down 18.3% and FLAG down 29.4%, both ahead of pace (page 63).

Reference: page 63.

Total energy consumption was 82,761 MWh in 2025 (73,161 in 2024), of which purchased electricity and district heating made up 98.3%. The renewable share of total energy consumption rose to 23.1% from 18.8% in 2024 as the residual Nordic grid mix began reporting nuclear and renewable shares separately. Energy intensity fell 1.9% to 5.26 MWh per million NOK of net revenue from activities in high climate impact sectors (page 64-65). "For stores where some or all data on actual energy use is lacking... total energy use is estimated based on the stores' floor area and average energy consumption per square metre for comparable group stores" (page 63).

Reference: page 65.

2025 GHG inventory (Group and franchises, financial-reporting-period basis): gross Scope 1 212 tCO2e, gross market-based Scope 2 20,664 tCO2e, total gross Scope 3 578,935 tCO2e (of which purchased goods and services 514,573 tCO2e is the largest category), for total market-based emissions of 599,812 tCO2e, up 10.4% year on year. FLAG emissions were 170,205 tCO2e. Calculated per the GHG Protocol using CEMAsys, with emission factors from "DEFRA 2025, Ecoinvent 3.11 & 3.12, Agribalyse 3.1, Agri-footprint 6.3" (page 67). Franchises are consolidated under operational control: "100 per cent of the franchises' GHG and FLAG emissions are included in the respective inventories" (page 67).

Reference: page 69.

"The group is not involved in any projects to remove GHG from the atmosphere or to mitigate emissions through the purchase of carbon credits outside the group's value chain. Actions to neutralise any residual emissions in 2050 to reach the science-based net-zero target, will be developed over the coming years. Buying carbon removal credits is the most probable alternative" (page 69).

Reference: page 69.

"The group does not apply any internal carbon pricing schemes" (page 69).

Back-filled from ESRS 2 IRO-1, where this content is disclosed in the FY2025 report (pages 44-46). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Both physical and transition risks were classified and evaluated. Physical risks used a low-emission (RCP 2.6/SSP1-2.6, IPCC, warming limited to 2°C) and a high-emission (RCP 8.5/SSP5-8.5, IPCC, warming exceeds 4°C) scenario. Transition risks used Announced Pledges (APS, IEA, 2°C) and Business-as-usual (BAU, IEA, exceeds 4°C). No 1.5°C-aligned, no/limited-overshoot scenario was used: "the low-emission scenario is not aligned with the 1.5 degree target, but in the upper range of the Paris Agreement's goal to keep global temperatures well below 2°C" (page 45) - a gap the report does not otherwise flag. Scope covered Scandinavian own-operations assets and upstream ports/transport routes from Asia and Europe, though "not conducted at a specific geolocation level" (page 46). Key assumptions on regulation costs, supplier behaviour and customer expectations are set out on pages 45-46. The TCFD-aligned analysis was "conducted in 2024" (page 44); nothing in the FY2025 statement says it was refreshed in 2025, only that the DMA overall was updated.

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

Back-filled from ESRS 2 SBM-3, where this content is disclosed in the FY2025 report (pages 54-55). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"Following the climate risk analysis and the double materiality assessment... the group evaluated the resilience of its strategy and business model to identified risks, as well as its capacity to capitalise on opportunities" (page 55). Results: in a high-emission scenario physical risk predominates and resilience "relates to the flexibility in a broad product range and a large number of suppliers located in different geographic regions"; in a low-emission scenario, resilience rests on the traceability and product-data projects under E5 and the group's positioning on affordable, sustainable products (page 55). "Rough estimates of the anticipated financial effects... were considered in the resilience assessment, as exact current and anticipated financial effects have not yet been calculated." Uncertainty: "assumptions regarding transition risks and opportunities are more uncertain" than physical risks and are reviewed yearly; "no material risks or opportunities have been excluded from the resilience analysis" (page 55).

Climate-specific resilience is also presented under E1-3 (2025 ESRS numbering).

Reference: page 76.

The group has "adopted a commodity policy and guidelines for sustainable sourcing" and, since plastics are "one of the group's most material raw-material categories", a dedicated plastic policy setting "clear ambitions to minimise plastic consumption, increase the share of recycled content and ensure improved recyclability" (page 76). Guidelines for circular product sourcing cover third-party certification, recycled/recyclable packaging, reduced packaging volume, and increased recycled/renewable material share, applying "when the main material is plastic or a commodity potentially involved in deforestation" (page 76-77). "The most senior role accountable for the implementation of the policy is the VP Strategy and Sustainability" (page 76).

Reference: page 77.

Actions include a dedicated regulatory team tracking circularity rules with a new quality-assurance role recruited in 2025 (starting Q1 2026); circular sourcing guideline harmonisation across Europris and ÖoB; two internal 2025 targets to raise recycled polyester/plastic content to 30% by 2030 and explore recycled aluminium; the Green Dot plastic pledge (since 2020); and waste actions that reduced residual waste to 17.6% of the 11,207 tonnes generated (page 77-79). "Product data is currently not sufficient to track progress accurately, and therefore detailed progress cannot be disclosed" on packaging switches (page 78).

Reference: page 79.

Targets: maintain a durable-goods complaint rate below 0.34% (actual 2025: 0.24%); provide spare parts for relevant durable goods (target not yet defined; actual 11.3%, up from 9.2% in 2024); and "reach an overall sorting rate of 90 percent by 2030" (actual 2025: 85.8%, on a rising trend from 85.2% in 2024) (page 79-80). "The two targets related to establishing a representative sample of products with ESG data have been removed. Measurable metrics will be disclosed once adequate data is available" (page 79).

Reference: page 80.

Total material inflows were 296,414 tonnes in 2025 (235,116 in 2024), of which biological materials were 58.0% (up from 56.8%) and technical materials 42.0%. Sustainably sourced biological material rose to 14.1% from 12.0%, "primarily caused by an increase in Nordic Swan labelled kitchen rolls", measured against a group list of "18 sustainability-related certification schemes, such as FSC and the Nordic Swan ecolabel" (page 80-81). "The share of secondary materials... is unknown due to limitations in product data quality" (page 81). Estimates for ÖoB are based on purchase cost by product category relative to Europris; segment Norway and franchises use actual product weight data (page 80).

Reference: page 81.

Resource outflows cover durability, repairability and recyclable content of products sold. Durability is proxied by complaint rate on durable goods (0.24% in 2025, down from 0.26%), since "industry-average durability data is not available." Repairability, measured as the share of durable goods with at least one spare part available, rose to 11.3% from 9.2% (page 81-82). "The share of recyclable materials in products is unknown due to limitations in product data quality" (page 81). Waste from own operations, the other resource outflow, totalled 11,207 tonnes in 2025 (page 82).

Reference: page 82.

Total waste was 11,207 tonnes in 2025 (9,772 in 2024), dominated by cardboard and paper (7,580 tonnes) and residual waste (1,590 tonnes, 17.6% of the non-recyclable total); hazardous waste fell to 11.9 tonnes from 40.8. "Over 82 per cent is recycled and less than 18 per cent is incinerated, while only a small fraction goes to landfill", and "as the amount of waste prepared for reuse is unknown, all waste diverted from disposal is reported as recycled" (page 82). The group targets "an overall sorting rate of 90 per cent by 2030" (actual 2025: 85.8%) (page 79).

Reference: page 87.

Policies cover "secure employment, health and safety, as well as topics on diversity and gender equality, and training and skill development", with the CFO responsible for implementation (page 87). The ethics policy addresses workplace conduct, data protection, whistleblowing, and "child labour, forced labour and human trafficking", aligned with the UN Guiding Principles, the ILO Declaration and the OECD Guidelines (page 87-88). HSE policies cover accident prevention, sick-leave, "inclusion of people with disabilities" and working-environment improvement (page 88). The diversity and equality policy meets Norway's Equality and Anti-Discrimination Act and Sweden's Discrimination Act, supported by an EDI resource group established in 2025 (page 88).

Reference: page 88.

Engagement runs through direct channels (performance reviews, departmental meetings, quarterly town halls, bi-weekly newsletters) and through workers' representatives (quarterly formal committees; union negotiation on HSE changes in segment Sweden; weekly management-union meetings at the Europris logistics centre; the 2025 EDI resource group) (page 88-89). The annual employee survey measures perceived involvement in decisions: stores scored 6.3/7 in 2025 (unchanged), while headquarters/logistics scored 5.2, up 0.2 points (page 89). Responsibility sits with the CFO via the HR departments, supported by local managers and HSE/HR professionals (page 88).

Reference: page 89.

Employees can report through their manager, safety representative, Working Environment Committee, HR, or an independent third-party whistleblowing channel ("ÖoB introduced the channel internally in 2025 and will make it externally available early 2026") (page 89). Effectiveness is checked via the employee survey, which asks about confidence in raising concerns and awareness of whistleblowing processes (page 89). "An explicit ban on retaliation towards whistleblowers is integrated into internal guidelines and is part of digital training programmes" (page 89).

Reference: page 89.

Secure employment: temporary workers fell to 523 (from 528) while non-guaranteed-hours workers rose to 1,214 (from 1,186); actions include transparent staffing practices and a completed "optimal staffing project" (page 89-90). Health and safety: sickness absence fell to 6.8% (from 7.5%), though recorded work-related accidents rose to 96 (from 68) and lost days to 463 (from 311), "reflect[ing] the inclusion of Lekekassen"; responses include risk assessments, task rotation, a "goods-to-person" logistics system, and a new HSE role from 2026 (page 90). Training and skill development, EDI actions (an EDI resource group formed in 2025) and NAV collaboration (370 participants in 2025) are also described (page 90-92).

Reference: page 92.

Targets: a gender-balanced split in leadership positions of at least 40% each way (actual 2025: 54% women/46% men, against 51/49 in 2024); an employee-survey attractiveness score of at least 6 (actual: 6.3, met each year since 2022); a NAV workforce-inclusion metric with no defined target (370 participants in 2025, up from 356); and sickness absence below 7.5% for 2025 and 6.8% for 2026 (actual 2025: 6.8%) (page 92-93). "During 2025, the IROs were linked to sub-sub topics, resulting in removal of disclosure requirements S1-8, S1-15 and S1-16" (page 92).

Reference: page 93.

"In 2025, the number of employees in the group was 5,443", reported as headcount averaged daily across the reporting period, broken down by country and gender; full-time-equivalent figures are cross-referenced to "the consolidated financial statement note 6 on page 150" (page 93). A formula error in the 2024 turnover calculation under this section was identified and corrected (page 35).

Reference: page 94.

Non-employee workers in the group's own workforce are disclosed, distinct from the value-chain workers covered under S2; the sourcing office in China, described elsewhere as consisting of "35 employees", is one example of personnel "not defined as employees" but engaged in group operations (page 102, 127). The description-of-workers table (page 86) identifies "hired personnel through third party" as a non-employee category exposed to the same material IROs (temporary/non-guaranteed hours, physically demanding tasks, potential discrimination) as employees in stores and logistics.

Reference: page 95.

Diversity metrics include the gender split in leadership positions - 54% women / 46% men in 2025, up from 51/49 in 2024, against a minimum-40%-each target - covering "top management and store managers" following a 2025 methodology revision that narrowed the leading-positions definition and restated 2023-2024 figures accordingly (page 92, 95). The board itself has a 4:3 female-to-male ratio (page 35).

Reference: page 96.

Social protection is reported through the group's collaboration with the Norwegian Labour and Welfare Administration (NAV): "in 2025, 370 individuals participated in the programme, compared to 356 in 2024 and 256 in 2023", supporting "individuals outside the labour market to gain work experience and re-enter the job force", with a particular focus on young people and migrants, plus internship programmes at ÖoB (minimum two per store location) and Europris headquarters (page 91-92, 96).

Reference: page 96.

"The number of recorded work-related accidents in 2025 was 96, compared with 68 in 2024. The rate of recorded work-related accidents in 2025 was 18.2, compared with 14.2 in 2024. Lost days due to work-related injuries and ill health totalled 463 in 2025, compared with 311 in 2024" (page 90). "The rise reflects the inclusion of Lekekassen in the data and a general increase across the group" (page 90). Sickness absence was 6.8% in 2025, down from 7.5% in 2024 (page 90, 93).

Reference: page 94.

"During the reporting year, the group has not identified any breaches of non-respect of the UN Convention on the Rights of the Child, ILO Conventions Nos. 138, 182 and 79, and ILO Recommendation No. 146" in relation to own workforce (page 89). Incidents and complaints are handled through the internal reporting channels and the third-party whistleblowing channel described under S1-3, with case-by-case severity-based follow-up and anti-retaliation protection (page 89).

Reference: page 100.

"An ethical trade policy" (overarching, for all employees) and "a supplier Code of Conduct" (for suppliers/business partners) are aligned with the UN Guiding Principles, the ILO Declaration and the OECD Guidelines, with "zero tolerance for human rights violations" (page 100). "Europris has reported according to the Norwegian Transparency act since 2022." The ethical trade policy is implemented by the CFO; the supplier Code of Conduct by VP Commercial, operationalised by the Quality Manager, and signature is "a mandatory requirement when entering into an agreement" (page 100-101).

Reference: page 102.

"The group does not engage with workers in the value chain directly, as it can be challenging due to geographic disparities, language barriers and cultural barriers", so engagement runs through suppliers via due diligence, audits, mail and face-to-face meetings, with the Category Director as overall owner and the China sourcing office (35 employees) as the key point of contact for Asian suppliers (page 102). Worker-level engagement relies on credible proxies, "mainly through Amfori", whose BSCI audits (score C or better) monitor supplier compliance (page 102). "The group has no global framework agreements with Global Union Federations or other similar organisations" (page 102).

Reference: page 102.

"In the event of a breach, the group and the supplier will jointly prepare a plan for remedying the breach", with contract termination only "if the supplier remains unwilling to remedy the breach following repeated enquiries." "No remediation were offered in 2025, as there were no instances determined to be relevant to this matter" (page 102). A third-party whistleblower channel is available, though "the channel may not be easily accessible as the value chain worker may not be aware of their employer's connection to the group", and "it has not yet been determined when the group will assess ways" to raise that awareness (page 102-103).

Reference: page 102.

Actions in 2025 include an updated two-tier risk matrix with mandatory due diligence for all medium-risk countries (removing supplier self-assessment); on-premise training for exposed procurement/logistics roles in Norway, Sweden and Asia; an in-depth logistics-sector risk workshop with suppliers; on-site supplier visits from the China sourcing office for quality and social-compliance checks; and extending the group's risk-mitigation system to segment Sweden, bringing ÖoB into common targets and reporting (page 103). "Around one third of ÖoB's purchases from high risk countries are sourced outside the Chinese sourcing office", work the group intends to bring into scope going forward (page 103).

Reference: page 104.

Target: all products sourced from high-risk areas come from socially audited suppliers. "In 2025, the group achieved social compliance audit coverage for 95.9 per cent of purchase costs originating from high-risk countries", an improvement on 2024 and above target, with ÖoB-volume through the China sourcing office (about 70% of ÖoB's high-risk purchase cost) included for the first time in 2025 (page 104). "Value chain workers have not been directly involved in the process" of setting the target (page 104).

Reference: page 107.

"The Marketing Act alongside the Empowering Consumers for the Green Transition Directive, provides the overarching regulatory framework for advertising and communications... For this reason, a separate policy is not established related to information-related impact of uninformed sustainable choices." A dedicated quality-assurance policy is "scheduled for completion in 2026" to cover product safety (page 107). "During the reporting year, the group has not identified any breaches of non-respect to the UN Convention on the Rights of the Child" in connection with consumers (page 107).

Reference: page 108.

Engagement runs through the customer service centre (complaints, response-time-bound), a website feedback function and post-purchase rating emails for loyalty-programme members, in-store meetings, market surveys (monthly to annual), media monitoring, and an annual brand tracker (introduced 2024) that monitors consumer perceptions of Europris's sustainability positioning (page 108-109). VP Commercial holds operational responsibility for consumer-related engagement in Europris; equivalent roles cover ÖoB and the pure-play companies (page 109).

Reference: page 108.

Marketing-related complaints are handled by the marketing department (with legal counsel where needed) and resolved directly with the customer; quality complaints go to a claims manager who assesses whether the issue is isolated or systemic, escalating larger cases with legal input. "During the reporting year, a total of 26 cases were reported and resolved in Europris, compared with 31 cases in the previous year, that resulted in compensation payments to customers. In ÖoB, 38 cases were reported and resolved" (page 109). A third-party whistleblower channel is also available to consumers (page 109).

Reference: page 110.

Actions cover packaging waste (Green Dot Norway membership, recycling pictograms, allergen/religious labelling), informed sustainable choices (the "greenwashing poster" commitment; third-party-certified chain sales up to 14.0% from 11.5%), plastic-bag reduction (down 16.6% in 2025, a pilot reusable transport box that won "1st place in the packaging world star 2025"), and product safety (one recall in 2025, a new QA role from Q2 2026, red/yellow/green product risk categorisation, and pre-shipment inspections run through the China sourcing office) (page 110-113).

Reference: page 112.

Targets: maintain a durable-goods complaint rate below 0.34% (actual 2025: 0.24%); reach 90% overall sorting rate by 2030 (actual: 85.8%); increase third-party-certified chain sales annually (actual 2025: 14.0%, from 11.5% in 2024); and zero recalls on own-sourced products (actual 2025: one recall, versus zero in 2024) (page 112-113). "Consumers and end-users have not directly been involved in setting the targets" (page 113).

Reference: page 116.

Governance policies comprise the supplier Code of Conduct (detailed under S2), an anti-corruption policy, and a whistleblowing policy, "revised annually and approved by the board" with the CFO accountable for implementation (page 116-117). The anti-corruption policy forbids offering or accepting "money or other benefits" for improper influence and requires "adequate procedures for risk analysis of third parties" (page 116). The whistleblower policy sets out reportable misconduct, reporting routes and case-handling "in line with the transposing Directive (EU) 2019/1937", with anonymous reporting supported (page 117).

Reference: page 117.

"Zero tolerance policy towards corruption and bribery applies to everyone in the group", extending to business partners "when they represent the group or act on its behalf." Prevention measures: the Code of Conduct, mandatory supplier sign-off, employee training, and a whistleblower channel (page 117). "During the reporting year, the group has not been subject to any convictions for violations of anti-corruption or anti-bribery laws, nor has it received any fines" (page 118). Detection relies on functions-at-risk training - "of the 64 employees defined as functions at risk in 2025, 89.1 per cent received training during 2025" (page 118).

Back-filled from the business conduct chapter, where this content is disclosed in the FY2025 report (pages 116-118). This disclosure requirement did not exist as a standalone DR under the 2023 ESRS the report was prepared against; under that standard, business conduct targets fell to MDR-T. No numeric corruption-prevention target is stated. Effectiveness is instead tracked: training coverage of at-risk functions is measured year over year ("89.1 per cent received training during 2025", up from a comparable 2024 baseline, page 118), supported by a formal incident process (division manager to director to CEO to the board) and an audit-committee review of the reporting process finalised in March 2026 (page 37, 118). "During the reporting year, the group has not been subject to any convictions for violations of anti-corruption or anti-bribery laws, nor has it received any fines" (page 118), and "the group does not have any existing investigating committee separate from the chain of management" (page 118).

Reference: page 117.

"During the reporting year, the group has not been subject to any convictions for violations of anti-corruption or anti-bribery laws, nor has it received any fines." Suspected cases follow an escalation path from division manager to designated director to CEO, with the CEO ensuring matters reach the board "at scheduled intervals" (page 117-118). Training in 2025 covered head office roles in Norway and Sweden and the China sourcing office, targeting "individuals in roles identified as being at high risk" such as category managers, sourcing directors and logistics leads; "supervisory bodies were not included in the training sessions during this period" (page 118).