Exel Composites Plc
Material Topics
Sustainability statement, in full
The complete text of Exel Composites Plc’s FY2025 sustainability statement is held here – 88 pages, captured from the published report. Every disclosure below also links to its own passage.
ESRS 2 – General Disclosures
GOV-1The role of the administrative, management and supervisory bodiesReported
The role of the administrative, management and supervisory bodies
Reference: pages 24-25.
The Board of Directors is "the highest governance body in relation to sustainability matters" and oversees "the company's approach to sustainable and responsible economic growth and transitioning to low-carbon and circular economy" (p.24). The Board confirms the corporate strategy including strategic sustainability targets and the sustainability function's budget, and does the company-related risk assessment, including sustainability-related risks, quarterly. The Board approved the strategic sustainability targets — Zero harm, Scope 1 & 2 GHG emission reduction, Zero waste to landfill, and improving employee engagement — and has approved the Code of Conduct, Human Rights Policy, Whistleblowing guidance and DEI policy, among others (p.24).
In 2025, the Board had 5 non-executive members, three female (60%) and two male (40%), a gender diversity ratio of 1.5, all independent of the company and its major shareholders (p.25). The Exel Leadership Team (ELT) had six members, one female (17%). The Board's Audit and Risk Committee and People and Remuneration Committee support governance of business conduct and People matters respectively (p.24).
GOV-2Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodiesReported
Information provided to and sustainability matters addressed by the administrative, management and supervisory bodies
Reference: pages 26-27.
The Board, meeting at least seven times a year, "discusses reviews related to different areas of sustainability, presented by Exel Leadership Team and specialists," covering material impacts, risks, opportunities and progress against targets; audit results are also reported to the Board (p.26). In 2025, Board and committee reviews "covered all of Exel's material topics: climate change mitigation, resource use and circular economy, own workforce, and business conduct," including CSRD requirements, occupational safety status, the employee engagement survey results, and a whistleblowing notification (p.26).
The ELT monitors the same targets "but in a more detailed level," with monthly business unit reviews of non-financial figures, and its 2025 reviews covered the same four material topics (p.27).
GOV-2(was GOV-3)Integration of sustainability-related performance in incentive schemesReported
Integration of sustainability-related performance in incentive schemes
Reference: page 27.
Exel's short-term incentive program covers all employees, and ELT remuneration "is tied to Group's financial performance and achievement of strategic targets, including sustainability-related targets" (p.27). In 2025, sustainability-related KPIs were included in the performance development review "for some Group employees, mainly in the finance team, research and production": environmental KPIs to support GHG reduction targets, scrap-reduction KPIs in production, and a target that 100% of research focus on sustainable composite solutions. "The KPIs varied from person to person, and proportion of variable remuneration was 5-30%, depending on the person" (p.27).
GOV-3(was GOV-4)Statement on due diligenceReported
Statement on due diligence
Reference: page 28.
The statement provides a table mapping the core elements of due diligence to where they are addressed in the sustainability statement: embedding due diligence in governance/strategy (ESRS 2 information provided to the Board, incentive schemes, SBM-3); engaging with affected stakeholders (ESRS 2 stakeholder interests, IRO-1, and topical policies under E1, E5, S1, G1); identifying and assessing adverse impacts (IRO-1, SBM-3 and topical IRO tables); taking action (topical Actions sections under E1, E5, S1, G1); and tracking effectiveness (topical Metrics and Targets sections under the same four standards) (p.28).
GOV-4(was GOV-5)Risk management and internal controls over sustainability reportingReported
Risk management and internal controls over sustainability reporting
Reference: pages 28-29.
"The main responsibility for the internal control and risk management relating to the financial and sustainability reporting process lies with the Board," whose Audit and Risk Committee supervises compliance, under an Internal Control Policy approved by the Board (p.28). Sustainability reporting is centrally handled by Group finance, with QEHS teams providing local data reviewed by Group QEHS and Group accounting.
Identified risks include "the accuracy of information due to the currently manual data collection, timing of the availability of the information, the limited availability of value chain data especially in emission and electricity calculations and therefore the need to use of industry averages" (p.29). Mitigations include assigned data owners, a 4-eyes principle, third-party support on emission calculations, and a more automated data-collection platform being introduced (p.29).
SBM-1Strategy, business model and value chainReported
Strategy, business model and value chain
Reference: pages 29-32.
Exel "develops, designs and manufactures high quality composite solutions" (glass and carbon fiber reinforcements with resins) sold into buildings and infrastructure (20.7% of 2025 revenue), Energy (22.4%), Transportation (19.0%), Industrial (13.5%) and Other (24.5%) (p.29-30). The company is headquartered in Mäntyharju, Finland, with 667 employees at year-end 2025 and production in Austria, China, Finland, USA and India; the Belgium factory closed in Q1 2025 (p.30). Exel states it "is not active in the fossil fuel sector, chemical production, controversial weapons or the cultivation and production of tobacco" (p.30).
Upstream, Exel buys reinforcements, resins and additives sourced from petrochemicals and minerals, mainly from Europe, China, India and the USA (p.30-31). Downstream, its OEM, integrator and distributor customers operate in over 50 countries (p.31). The business model and 2024-2028 transformative strategy are described as "closely linked with climate change mitigation and resource use and circular economy" (p.29, 32).
SBM-2Interests and views of stakeholdersReported
Interests and views of stakeholders
Reference: pages 33-35.
A table sets out engagement channels, purpose and how outcomes were used in operations for six stakeholder groups: customers, employees, suppliers and business partners, investors/shareholders/analysts, industrial associations, and the general community (p.33-35). Examples: over 50 employees' views were considered in the Group strategy work, resulting in Zero harm and employee engagement Group targets; supplier engagement on responsible and sustainable business conduct fed a target to "include more bio-based and recycled raw materials in the offering"; and participation in the KiMuRa project and the European Circular Composites Alliance (ECCA) supports the zero-landfill target and a move toward a more circular business model (p.34-35).
SBM-3Material impacts, risks and opportunities and their interaction with strategy and business modelReported
Material impacts, risks and opportunities and their interaction with strategy and business model
Reference: pages 38-42.
Exel's 2025 DMA finds four material themes: E1 Climate change (climate change mitigation); E5 Resource use and circular economy (resource inflows, resource outflows, waste); S1 Own workforce (health and safety); and G1 Business conduct (corporate culture, protection of whistleblowers, corruption and bribery, management of supplier relationships including payment practices) (p.39). Per-topic tables set out each impact/risk/opportunity, its type, location and time horizon, and management response (p.39-40), and an overview graphic maps them together (p.41).
On financial effects: "the material risks and opportunities identified in the DMA do not involve factors that would require... adjustments to Exel Composites' assets and liabilities on the balance sheet... within the next annual reporting period" (p.42), and "the quantitative disclosure of anticipated financial effects... will be omitted in accordance with 'Quick Fix' Delegated Regulation" (p.42).
IRO-1Description of the processes to identify and assess material impacts, risks and opportunitiesReported
Description of the processes to identify and assess material impacts, risks and opportunities
Reference: pages 35-38.
Exel's first Double Materiality Assessment (DMA) ran November 2023-February 2024, updated in January 2025, in four phases: preparation and scoping; mapping IROs (long-list workshops across QEHS, R&D, sourcing, strategy, People & Culture and IR, plus stakeholder interviews); assessing materiality (led by external experts against severity/scale/scope/irremediability for impacts and size/likelihood of financial effect for risks and opportunities, informed by OECD Guidelines, UNGPs and EFRAG's DMA guidelines); and validation, approved by the Board (p.35-36).
For climate, a site-level physical risk assessment used "a high emissions scenario (SSP3-7.0) and a Paris-aligned low emission scenario (SSP1-2.6)" from IPCC AR6, covering horizons to the 2030s and 2060s; "for transition risks and opportunities, the assessment process does not apply scenario analysis" (p.36-37). Pollution/water screening found no material sites; biodiversity was screened with the WWF Biodiversity Risk Filter, finding no material IROs as "none of the factories locate in or in vicinity of nature reserves" (p.37-38).
IRO-2Disclosure requirements in ESRS covered by the undertaking's sustainability statementReported
Disclosure requirements in ESRS covered by the undertaking's sustainability statement
Reference: pages 43-45.
Exel's ESRS content index lists, under ESRS 2: BP-1, BP-2, GOV-1/2 (combined row), GOV-3, GOV-4, GOV-5, SBM-1, SBM-2, SBM-3, IRO-1, IRO-2, and the cross-cutting MDR-P/MDR-A/MDR-M/MDR-T rows (each naming Policies/Actions/Metrics/Targets "under E1: Climate change mitigation, E5: Resource use & circular economy, S1: Own workforce, G1: Business Conduct"). Under the topical standards it lists all nine E1 DRs (E1-1 to E1-9), all six E5 DRs (E5-1 to E5-6), four S1 DRs (S1-1, S1-6, S1-14, S1-17), and five G1 DRs (G1-1, G1-2, G1-3, G1-4, G1-6) (pp.43-45). No E2, E3, E4, S2, S3 or S4 disclosure requirement appears in the index.
E1 – Climate Change
E1-1Transition plan for climate change mitigationReported
Transition plan for climate change mitigation
Reference: pages 50-51.
"The company does not have a transition plan aligned with the goals of the Paris Agreement in place, but it plans to draft and adopt the plan by 2028. The targets are not externally assured. They are not yet based on conclusive scientific evidence" (p.50). Exel's Scope 1 & 2 reduction targets "were not set based on any climate scenarios, as the company had not yet conducted a scenario analysis when setting the targets in 2023" (p.50).
Decarbonisation actions described include renewable-energy heating, solar power investment, guarantee-of-origin electricity purchases, and Scope 3 measurement work begun in 2025, with a Scope 3 target planned for 2026-2027; "the implementation of the plan will be financed with income funding without external funding" (p.51).
E1-2(was covered under ESRS 2 IRO-1)Identification of climate-related risks and scenario analysisReported
Identification of climate-related risks and scenario analysis
Back-filled from ESRS 2 IRO-1, where this content is disclosed in the FY2025 report (pages 36-37). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.
Exel's site-level physical climate risk assessment used "a high emissions scenario (SSP3-7.0) and a Paris-aligned low emission scenario (SSP1-2.6)" from IPCC AR6, covering time horizons to the 2030s (2025-2044) and 2060s (2055-2074), and assessed "exposure to relevant chronic and acute temperature, wind, water and solid mass related climate hazards as defined in (EU) 2021/2139" using site geospatial coordinates (p.36-37). "For transition risks and opportunities, the assessment process does not apply scenario analysis or different time horizons"; transition risks were assessed "on a general level" only, without identifying assets or activities incompatible with a climate-neutral transition (p.37).
E1-4(was E1-2)Policies related to climate change mitigation and adaptationReported
Policies related to climate change mitigation and adaptation
Reference: pages 47-48.
Exel manages environmental issues through its Sustainability Policy, Code of Conduct, Supplier Code of Conduct, and QEHS policy, plus ISO 9001/14001/45001/26000 certification. "Exel does not have a specific policy on climate change risks and adaptation measures"; general risk management is covered by the Risk Management Policy, "which, however, does not specifically address climate change mitigation" (p.47).
The Code of Conduct states Exel "takes environmental aspects into account when making business decisions" and avoids materials/methods posing environmental risks where alternatives exist. The travel policy addresses business-travel emissions specifically. "Energy efficiency or renewable energy deployment is not explicitly addressed in any of the policies" (p.48).
E1-5(was E1-3)Actions and resources in relation to climate change policiesReported
Actions and resources in relation to climate change policies
Reference: pages 50-51.
2025 actions: continued use of renewable heating in Finland, solar power plants in Finland and Austria, a new Austria factory building with class A++ energy performance, and "securing the use of carbon-neutral electricity by purchasing guarantees of origin in Finland" — 53% of Group electricity was guarantee-of-origin in 2025 (29% in 2024) (p.51). The renewable energy share rose to 28% (24% in 2024). Planned 2025-2030 actions include "expanding the use of carbon-neutral electricity outside Finland," targeting roughly 90% of relevant Scope 2 emissions in the USA, China and India, plus a solar power plant in China "installed but not commissioned in 2025" (p.51). "Exel hasn't set any other detailed time horizons... or quantified the expected overall contribution of each decarbonization lever" (p.51).
E1-6(was E1-4)Targets related to climate change mitigation and adaptationReported
Targets related to climate change mitigation and adaptation
Reference: pages 48-49.
Long-term Group target: Scope 1 & 2 GHG emission reduction — "short term, by 2030: 50% reduction... long term, by 2050: Carbon neutrality," measured on a market-based basis, base year 2018 (2019 for the US operations) (p.48). 2025 progress: Scope 1 & 2 emissions were 2.7 thousand tonnes, down from 3.7 thousand tonnes in 2024 and 53% below the 2018 baseline of 5.8 thousand tonnes (p.48-49). "Exel expects to set targets for Scope 3 GHG emission reduction step-by-step during 2026-2027" (p.49). The targets are not externally assured and "are not yet based on conclusive scientific evidence" (p.50).
E1-7(was E1-5)Energy consumption and mixReported
Energy consumption and mix
Reference: pages 51-52.
Total energy consumption was 17,755 MWh in 2025 (18,997 MWh in 2024). Fossil energy consumption fell to 7,629 MWh (8,929 MWh in 2024, 43% of the total), of which 5,494 MWh was purchased fossil electricity/heat/steam/cooling. Renewable energy consumption rose to 4,967 MWh, 28% of the total (24% in 2024), including 1,531 MWh of renewable fuel and 3,127 MWh of purchased renewable electricity/heat/steam/cooling. There is no nuclear or coal consumption (p.52). Energy intensity was 17,755 MWh / EUR 103,194,158 net revenue — all Exel operations are counted as high climate impact sector activity (p.52).
E1-8(was E1-6)Gross Scopes 1, 2, 3 and Total GHG emissionsReported
Gross Scopes 1, 2, 3 and Total GHG emissions
Reference: pages 52-53.
Gross Scope 1 emissions were 469 tCO2eq in 2025 (553 in 2024, 904 in base year 2018). Gross location-based Scope 2 was 2,738 tCO2eq and gross market-based Scope 2 was 2,205 tCO2eq (p.52-53). "Exel does not yet report the Scope 3 emissions, and therefore cannot report the GHG emissions intensity, as this requires the calculation of total GHG emissions" — Scope 3 is one of the datapoints explicitly listed as omitted under the phase-in option for companies with under 750 employees (p.24, 53). Total biogenic emissions in 2025 were 664.9 tCO2 (546.3 Scope 1, 118.6 Scope 2) (p.53). The 2024 Scope 2 comparative was restated from 4,363 tCO2e after a new external emissions platform changed the emission-factor source (p.53).
E1-9(was E1-7)GHG removals and GHG mitigation projects financed through carbon creditsReported
GHG removals and GHG mitigation projects financed through carbon credits
Reference: page 53.
"No projects are financed through carbon credits" (p.53). The statement discloses no GHG removals or carbon-credit-financed mitigation projects for the reporting period.
E1-10(was E1-8)Internal carbon pricingReported
Internal carbon pricing
Reference: page 53.
"Exel does not apply internal carbon pricing schemes" (p.53). This nil return sits in the same paragraph as the statement that no projects are financed through carbon credits, immediately after the disclosure of Exel's Scope 1 and market-based Scope 2 GHG emissions and ahead of the note on the omission of anticipated financial effects (E1-9) under the phase-in option for companies with under 750 employees (p.53). No further detail on internal pricing tools, shadow prices, or a stated plan to introduce one is given elsewhere in the statement.
E5 – Resource Use and Circular Economy
E5-1Policies related to resource use and circular economyReported
Policies related to resource use and circular economy
Reference: page 55.
"In 2025, Exel adopted a Group Sustainability Policy that sets the principles for resource use and circular economy" applying to all employees and anyone representing Exel (p.55). It "commits Exel to using natural resources responsibly and improving resource-efficient supply chains, including increasing the use of waste- and residue-based raw materials and contributing to the circular economy," implemented through R&D, life cycle assessment and GHG calculation work, coordinated by the SVP, Technology and Sustainability, and reviewed annually (p.55).
E5-2Actions and resources related to resource use and circular economyReported
Actions and resources related to resource use and circular economy
Reference: pages 57-59.
Actions include continued research into bio-based resins and fibers (flax, jute, hemp), with "partial bio-based resins... commercially introduced in 2024, and further use increased during 2025" (p.57), and recycling of composite waste via the cement co-processing route — "now all composites profile waste at Exel's sites in Finland is utilized in co-processing in cement manufacturing," delivered through Kuusakoski Oy and Finnsementti Oy, achieving "more than 70%" glass-fiber recycling (p.58-59). A 2024 partnership with Fairmat recycles carbon-fiber scrap from two Finnish factories via pyrolysis, recovering "68% of the material (by weight)" (p.59). Exel is also researching fuller circular recycling, converting resins and fibers back into new raw materials, though "no timeline or targets are yet set" (p.59).
E5-3Targets related to resource use and circular economyReported
Targets related to resource use and circular economy
Reference: pages 55-56.
Long-term Group target: "Zero waste to landfill by 2028," base year 2018 (p.55-56). 2025 progress: "73% reduction from approximately 2,500 tonnes to landfill in 2018 to approximately 672 tons in 2025" (99% reduction to ~19 tons in 2024) (p.56). Exel "has also set a Group-level target according to which 100% of research will focus on sustainable composite solutions," with no specific target year; "all new research projects initiated in 2025 and six out of eight ongoing research projects were assessed to include sustainability topic" (p.57). "Exel hasn't set any numerical targets for using recycled or bio-based materials" (p.56).
E5-4Resource inflowsReported
Resource inflows
Reference: pages 56-59.
Total weight of materials used was 11,893.3 tonnes in 2025 (18,039.2 tonnes in 2024): 979.1 tonnes biological materials (bioresin 214.4t, wooden packaging 764.7t) and 10,914.2 tonnes technical materials (reinforcements 6,802.0t, resins 2,479.3t, other materials/packaging 1,633.0t) (p.59). Sustainably sourced biological materials and secondary reused/recycled materials were both 0% in 2025 and 2024 (p.59). "Exel Composites production of composites currently mainly relies on virgin materials... The rate of recyclable content in products and packaging is close to zero percent" (p.57).
E5-5Resource outflowsReported
Resource outflows
Reference: pages 57-59.
Exel's products have typical service lives of "20-25 years for wind turbines and even 30-50 years for window frames," and "Exel does not give a general lifetime guarantee in years" since customers quote lifespans differently (p.57-58). "Low weight of composites is beneficial... which reduces fuel costs and carbon dioxide emissions" over the product lifecycle, and components are "low maintenance compared to other materials such as steel" (p.58). Repairs, including "significant, large surface area repairs," are possible "although not always commercially feasible" (p.58). The company does not track recycling rates for packaging materials: "Exel does not have data on rate of recycling of packaging, as there is no sufficient information available from customers" (p.59).
E5-5(was E5-5-Waste)WasteReported
Waste
Reference: pages 58-60.
Total waste was 2,966 tonnes in 2025 (2,644 tonnes in 2024): 85 tonnes hazardous (17 incinerated, 67 other disposal) and 2,881 tonnes non-hazardous (834t recycled, 1,375t other recovery, 672t landfill) (p.60). In 2025, "46% (68%) of Exel's composite waste was utilized in energy re-use, 28% (28%) was recycled and 23% was sent to landfill, majority of which was produced by the manufacturing unit in the United States"; non-recycled waste rose to 26% of total waste from 3% in 2024 (p.58, 60). "Manufacturing units in Austria, China, India, Belgium and UK did not have any landfill waste in 2025" (p.58). The main recycling route for glass-fiber composite waste is co-processing in cement manufacturing (see E5-2).
S1 – Own Workforce
S1-1Policies related to own workforceReported
Policies related to own workforce
Reference: pages 69-70.
Exel's workforce policies are the Code of Conduct, Human Rights Policy, Diversity, Equity and Inclusion Policy, and Remuneration Policy (all Board-approved), plus the QEHS and Chemicals policies approved by the ELT (p.69). The Human Rights Policy commits to "safeguarding the rights to freedom of association, collective bargaining, safe working conditions, fair remuneration, and reasonable working hours," opposes child labor and forced labor, and applies globally "to all individuals associated with Exel, including employees, contractors, suppliers, and business partners" (p.70). All policies cover Exel's own employees group-wide, "with the exception of Exel's subsidiary in India (Kineco Exel Composites India, KECI)... not fully integrated into Exel Composites' system and policies" (p.69).
S1-3(was S1-4)Taking action on material impacts on own workforceReported
Taking action on material impacts on own workforce
Reference: pages 73-75.
2025 health-and-safety actions included review of accidents, near-misses and unsafe conditions with regular safety patrols and audits, and a "Group-level safety awareness campaign targeted to all employees" covering physical safety and mental well-being (p.75). A Group-wide SOP on personal protective equipment was developed, and "Exel developed and implemented a Sustainability Policy during 2025" (p.74-75). Effectiveness is monitored through root cause analysis shared globally after every accident, with "a one-page alert leaflet of the risk, root cause analysis and corrective actions" sent to all sites (p.74). The 2025 LTIR was 5.6 per million hours worked, down from 7.0 in 2024 (p.75).
S1-4(was S1-5)Targets related to own workforceReported
Targets related to own workforce
Reference: pages 72-73.
Long-term Group target: "Zero harm" — zero lost time injuries measured by LTIR, with no target year specified as "the target is reviewed annually" (p.72-73). LTIR was 5.6 per million hours worked in 2025, against 7.0 (2024), 6.0 (2023), 10.8 (2022) and 7.8 (2021), with annual sub-targets of 0 in 2025 and 2024 (p.73). Progress is monitored monthly by site and business unit heads and reported to the ELT; "no Group-level targets have been set" for near-miss or unsafe-condition reporting, which are tracked as company KPIs rather than ESRS-mandated metrics (p.73, 76).
S1-5(was S1-6)Characteristics of the undertaking's employeesReported
Characteristics of the undertaking's employees
Reference: pages 77-78.
Total employees: 667 at end-2025 (637 in 2024) — 498 male, 169 female, none recorded as other or not recorded (p.77). By country: Finland 284, China 167, Austria 80, USA 75, other countries 61 (p.77). Of the total, 534 were permanent and 130 fixed-term employees (3 non-guaranteed-hours); 645 full-time and 22 part-time (p.78). Employee turnover was 23% in 2025 (149 leavers) versus a restated 16% in 2024, under a revised methodology now including "all leavers, whatever the reason"; the increase is "explained by employee reductions resulting from the closure of the Belgian plant, as well as fixed-term contracts made to offset seasonal fluctuations" (p.77).
S1-13(was S1-14)Health and safety metricsReported
Health and safety metrics
Reference: pages 75-76.
2025 KPIs: LTIR 5.6 per million hours worked (7.0 in 2024); rate of recordable work-related accidents for own workforce 5.6 (7.0); 8 recordable accidents (10 in 2024); 84 days lost to work-related injuries for employees (120 in 2024) and 0 for non-employees; 0 fatalities in own workforce and 0 among other workers on Exel's sites, in both years; 82.3% of own workforce covered by a health and safety management system that is internally and/or externally audited or certified (84.9% in 2024) (p.75-76). "Exel will omit information about non-employees in accordance with 'Quick Fix' Delegated Regulation" (p.76).
S1-16(was S1-17)Incidents, complaints and severe human rights impactsReported
Incidents, complaints and severe human rights impacts
Reference: pages 71-72.
"In 2025, no human rights incidents were reported. During the reporting period, two whistleblowing notifications were received through the whistleblowing channel, both concerning internal practices and processes. Each notification was subject to a thorough investigation, which confirmed that corrective actions had already been implemented... No fines, penalties, or compensation were paid or requested in connection with these matters" (p.71-72).
G1 – Business Conduct
G1-1Business conduct policies and corporate cultureReported
Business conduct policies and corporate culture
Reference: pages 80-81.
The Board-approved Code of Conduct "covers the company's approach related to compliance with laws and regulations, business conduct and relations with business partners, commitment to anti-corruption and reporting breaches" and applies to all Group companies and employees (p.80). The CEO-approved Anti-Corruption Policy applies worldwide to Exel entities, employees, suppliers and contractors; the Board-approved Decision-making and signing policy sets monetary approval limits; and Board-approved Whistleblowing guidance complies with the EU Whistleblowers Directive (p.80-81). "Even though trainings did not take place yet in 2025, the Code of Conduct policy is available on the intranet and is part of onboarding for new hires" (p.81).
G1-2Management of relationships with suppliersReported
Management of relationships with suppliers
Reference: pages 81-83.
Supplier conduct is governed by the Supplier Code of Conduct, Anti-Corruption Policy and Decision-making and signing policy; "there is no specific policy that explicitly mentions preventing late payments and SME practices" (p.82). Supplier qualification includes commitment to the Supplier Code of Conduct and a background check; regular audits cover "Labor and Human Rights, Health and Safety, Environment, Ethics and compliance," with an annual target of 4-6 critical-supplier audits — 10 were conducted in Europe and North America in 2025 (p.82-83). "There were no serious violations identified, and no supplier relationships were ended based on audits" in 2025, though "some corrective actions" followed minor health-and-safety findings (p.83).
G1-2(was G1-3)Prevention and detection of corruption and briberyReported
Prevention and detection of corruption and bribery
Reference: pages 83-85.
"Exel Composites has a strict zero-tolerance policy against bribery and corruption in any form" under its Code of Conduct and Anti-Corruption Policy, with a two-step invoice approval process and Board/CEO approval required for donations (p.83-84). "Functions identified to be most at risk in respect of corruption and bribery are sales, purchases, and payment transactions"; anti-corruption training was made available to at-risk functions in 2025, though "quantitative training coverage... and completion data is available only from 2026 onwards" as reporting functionality went live at year-end (p.84). "There were no confirmed incidents of corruption and bribery or convictions or fines for violation of anti-corruption and anti-bribery laws in 2025... No severe human rights issues and incidents were reported either" (p.84-85).
G1-3(part of MDR-T/GDR-T disclosures)Targets related to business conductReported
Targets related to business conduct
Reference: page 84. The FY2025 statement is prepared under the 2023 ESRS, which had no standalone business-conduct targets DR; the ground is covered by MDR-T, referenced in Exel's ESRS content index as "Targets under... G1: Business Conduct" (p.44).
"There are currently no measurable time-bound targets set related to business conduct, including protection of whistleblowers, anti-corruption and bribery. The company will re-evaluate the need for setting targets in 2026, as the global human resource platform was fully launched in 2025 and there will be base values for KPIs available" (p.84). In the absence of a target, effectiveness is tracked: "Exel follows the number of reports received through the whistleblowing channel, but no targets are set for this. The company follows the development of its corporate culture as part of its employee engagement survey" (p.84).
G1-4Incidents of corruption or briberyReported
Incidents of corruption or bribery
Reference: pages 84-85.
"There were no confirmed incidents of corruption and bribery or convictions or fines for violation of anti-corruption and anti-bribery laws in 2025. There were no public legal cases regarding corruption or bribery brought against Exel and its own workers during the reporting period" (p.84-85).
G1-6Payment practicesReported
Payment practices
Reference: page 84.
"The payment period for invoices from direct and indirect suppliers ranges from 7 to 120 days. The average time the company takes to pay an invoice was 47 days in 2025 (2024: 59)" (p.84). Standard terms are "on average 60 days" for raw materials (90 days in China) and approximately 30 days for indirect sourcing such as services and insurance; the main raw-material supplier category (glass fiber, carbon fiber, resins, additives) represents "approximately 8% (2024: 19%) of annual invoices by number" (p.84). "There were no legal proceedings outstanding for late payments in 2025" (p.84).