Fine Foods & Pharmaceuticals N.T.M. S.p.A.

Governance roles

Reference: pages 48-52.

Governance follows the traditional model: Shareholders' Meeting, Board of Directors and Board of Statutory Auditors (page 48). The Board has 10 members, six men and four women, so 40% are from the least represented gender (Table 1, page 49). The text states six executive, four non-executive and four independent directors (page 49). At least one Board member has governance, compliance, sustainability, internal control and risk management expertise (page 49).

Committees (pages 49-52): the ESG Committee advises the Board on building sustainability into strategy, assesses sustainability reporting and reports to the Board at least every six months; the Remuneration and Nomination Committee; the Control, Risk and Related Parties Transactions Committee; and the Gender Equality Steering Committee, set up in 2025. "There are no employee representatives in the Group's management and control bodies" (page 52). The datapoint table marks the GOV-1 gender diversity and independent director datapoints "Material" (page 69).

Sustainability matters addressed by the Board

Reference: pages 50-53, 68.

ESG Committee members meet regularly with the people who run ESG work: the ESG specialist, the HR and Procurement Directors, the ESG Manager and outside consultants (pages 50, 52). After these sessions the Committee reviews results, proposes action plans, assesses new or updated policies, sets objectives and takes up issues raised by stakeholders, with a focus on impacts, risks and opportunities (page 52). Its outcomes go to the Board at least every six months (page 53). Each year the Board, supported by the ESG Committee, reviews the double materiality results to decide which topics to report (page 68). The Control, Risk and Related Parties Transactions Committee also examines periodic non-financial information for its bearing on internal control and risk management (page 51). The list of material IROs sits under SBM-3 (page 53).

Sustainability in incentive schemes

Reference: pages 53-54, 58.

The Remuneration and Nomination Committee authorized a short-term variable pay component for the Managing Director that depends on specific objectives, including sustainability ones. These "account for approximately 10% of the total short-term incentive" (page 53). In 2024 more executives and managers received annual ESG-linked MBO goals where relevant to their roles, mainly on ESG qualification of the supply chain, the Group's ESG assessment, coordinating work teams and technologies that cut resource consumption (page 53). The 2025 audit table records the ESG MBO system as maintained for all first-level and middle managers who affect ESG results (page 54). The 2026-2028 Plan sets a target to apply an ESG-based MBO system to all directors and managers who influence ESG outcomes (page 58).

Statement on due diligence

Reference: pages 53, 63.

The Group says it has not yet adopted a due diligence process that fully follows internationally recognized frameworks such as the UN Guiding Principles on Business and Human Rights or the OECD Guidelines for Multinational Enterprises (page 53). It identifies actual and potential negative impacts and acts to prevent or mitigate them, as set out in the topical chapters, and states that from 2026 it will "gradually implement due diligence" in the business areas affected (page 53). In its UN Global Compact reporting it has set a future target to establish a Business and Human Rights Action Plan (page 63). Current supply chain work runs through the supplier Code of Conduct and EcoVadis assessments (pages 121, 131).

Risk management and internal controls

Reference: pages 53, 67.

The Group is "gradually incorporating ESG principles and sustainability reporting standards" into its risk management and internal control system (page 53). It added steps to its Financial Closing procedure so the data behind reported figures is complete, accurate and available on time, issued guidelines for internal and external information requests, and ran consistency and plausibility checks on historical databases as part of GHG reporting (page 53). Gaps it names itself: no specific formalized procedure feeds internal control findings back into sustainability reporting, and formalizing internal monitoring and control of sustainability risks and opportunities is planned to start in 2026 (page 53). Risk assessment involves several Managers and Process Managers, the Managing Director takes part in prioritization, and the Internal Audit head prepares a risk control plan (page 67).

Strategy, business model and value chain

Reference: pages 40-47, 53-58.

Fine Foods is an Italian independent contract development and manufacturing organization (CDMO) serving nutraceutical, pharmaceutical and cosmetics customers. At 31 December 2025 the Group employed 839 people and had revenue of EUR 252.1 million (page 40). The Zingonia plant makes food supplements, the Brembate plant makes pharmaceuticals and the Fine Cosmetics plant at Trenzano makes cosmetics (pages 41-44, 125-126). Value chain stages are business development, research and development, scale-up and production, and quality assurance and control (page 47). Strategy sits in the 2022-2025 Sustainability Plan, with 2025 results audited on pages 53-56, and the 2026-2028 Plan, approved by the ESG Committee on 27 February 2026 (pages 56-58). The datapoint table marks involvement in fossil fuel, chemical production, controversial weapons and tobacco activities "Non material" (pages 69-70).

Interests and views of stakeholders

Reference: pages 58-60, 67-68, 119, 123.

The report tabulates stakeholder groups with engagement methods and expectations: employees, customers, shareholders and investors, suppliers, local communities, local and regulatory authorities, certification bodies, trade associations, and banks and insurers. Methods include satisfaction questionnaires, workshops, surveys, trade union discussions, business review meetings and the supplier qualification process (pages 58-60). An Engagement Policy approved by the Board on 30 March 2022 governs dialogue with investors (page 60). For the double materiality assessment, engagement was limited to internal stakeholders, including HSE, Procurement, HR and Energy managers; external stakeholders were mapped for future engagement (pages 60, 67-68). Value chain workers are not among its stakeholder categories (page 119), and there is no direct interaction with consumers or end users (page 123).

Material impacts, risks and opportunities

Reference: pages 63-67.

Three tables list what the Group treats as material. Impacts from own operations (Table 2, 12 rows) cover GHG emissions, air pollution, water consumption in water-stressed areas, soil pollution from process waste, occupational injuries, training gaps, lack of inclusion, work-life balance and wages, consumer health, whistleblower protection, supplier payment practices and corruption (pages 63-64). Value chain impacts (Table 3, 13 rows) add supplier emissions, water and soil contamination, substances of concern, microplastics, biodiversity loss from raw material processing, raw material depletion, and child labor, forced labor, harassment and safety risks for value chain workers (pages 64-65). Table 4 lists one opportunity (subsidized finance for renewable energy plants) and nine risks (pages 65-67). The Group says no opportunity carries a material risk of significant adjustment to assets and liabilities next year, and that no Group-specific disclosures arose (page 67).

Process to identify and assess IROs

Reference: pages 67-68, 83, 91.

Impact materiality: the Group mapped its operating context (activities, business relationships, regions), identified impacts through dialogue with internal stakeholders and a corporate-level review of a long list of impacts. Negative impacts were rated on likelihood and severity (scale, scope, irremediable nature); positive impacts on likelihood, scale and scope (pages 67-68). Financial materiality: risks and opportunities were derived from the material impacts, from dependencies and from actions under the 2022-2025 Plan, then ranked by likelihood and potential financial effect (page 68). The Board, supported by the ESG Committee, reviews the results every year (page 68). IROs were linked to risk areas in a risk management system "inspired by the COSO ERM Framework", which was not fully adopted (page 68). Climate physical risk used SSP5-8.5 and transition risk the IEA Net-zero Emissions scenario (page 83); water was screened with the WRI Aqueduct tool (page 91).

ESRS disclosure requirements covered

Reference: pages 68-76.

The statement prints a table of material topics and sub-topics with page references: E1 (energy and climate change), E2 (substances of concern, pollution of air, water and soil, microplastics), E3 (water and marine resources), E4 (biodiversity and ecosystems), E5 (resource inflows; waste and resource outflows related to products and services), S1 (working conditions; equal treatment and opportunities for all), S2 (equal treatment; working conditions; other work-related rights), S4 (personal safety of consumers and end-users) and G1 (corporate culture) (pages 68-69). The table is topic-level and lists no individual disclosure requirements. Its page numbers do not match this PDF: the contents page puts climate change at page 82, and the table cites page 87 (pages 35, 69). A second table lists datapoints from other EU legislation with "Material" or "Non material" flags and page references (pages 69-76). The report also says IROs were ranked low, medium or high (page 76).

Transition plan for climate change mitigation

Reference: pages 82-83.

The Group has no transition plan "that guarantees business strategy and model are compatible" with limiting warming to 1.5°C under the Paris Agreement. It intends "a preliminary analysis" of how to approach this in the 2026-2028 Strategic Plan (page 82). Because there is no plan, "no investments or financing were identified". No plan was approved by the governing and control bodies, and none is planned for next year (page 83). The report states the Group has no locked-in GHG emissions from its key assets and products (page 83), while 85.60% of 2025 energy use came from fossil sources, mostly natural gas (pages 85-86). The datapoint table marks the E1-1 datapoints "Non material" (page 70). GHG targets are given under the policies, actions and targets paragraphs (page 83).

Identification of climate-related risks and scenario analysis

Back-filled from the E1 impact, risk and opportunity management subsection (page 83), which restates ESRS 2 IRO-1 for climate. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Material climate impacts: direct and indirect GHG emissions, and indirect emissions from suppliers. One material physical risk: operational and financial risk from damage to Group assets in acute and chronic climate events. Transition risk: higher energy procurement costs as fossil fuels deplete and demand for guarantees of origin rises. Transition opportunity: subsidized finance for new renewable energy plants (page 83).

Risks were assessed over short, medium and long term, covering direct operations and the value chain. Physical risk used the high-emission scenario SSP5-8.5 (IPCC AR6); transition risk and opportunity referenced the IEA Net-zero Emissions by 2050 scenario (page 83). The report describes SSP5-8.5 as a path to a 4.4°C rise (page 83). No analysis was run on compatibility of corporate assets or activities with a climate-neutral economy under the Taxonomy framework (page 83), and for some Taxonomy DNSH criteria a climate risk and vulnerability assessment "was not carried out" (page 78).

Resilience in relation to climate change

Back-filled from the E1 strategy subsection (page 83), which restates ESRS 2 SBM-3 for climate. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The Group states it carried out no resilience analysis. It "did not conduct a resilience analysis" of its business model or strategies across any timeframe, and no climate scenarios or results are available for review (page 83).

What the report offers instead is the list of material climate IROs (a physical risk to assets from acute and chronic climate events and a transition risk of higher energy procurement costs, page 83), the climate actions it prioritizes (100% renewable electricity supply, photovoltaics, a cogenerator, efficiency projects, page 84), and a statement that the 2026-2028 climate targets were set without climate risk scenarios or scientific benchmarks (page 85). The biodiversity chapter gives the same position: no resilience assessment of strategy and business model (page 94).

Policies related to climate change mitigation and adaptation

Reference: page 84.

The ESG Committee approved a Climate and Environmental Protection Policy that carries forward the HSE Policy already set within the ISO 14001 and ISO 45001 management systems. It rests on three principles (numbered 7 to 9): environmental protection, climate protection, and sustainable resource use and eco-design. The Group ties it to UN SDGs 7, 12 and 13 and to its Global Compact commitments. Implementation measures are an organizational structure with people and resources, training on environmental procedures, awareness campaigns, projects to cut waste of resources and energy, and cooperation with public bodies, schools and companies on responsible consumption. The policy addresses mitigation and adaptation, with the stated aims of improving energy efficiency and raising the share of renewable energy (page 84).

Actions and resources in relation to climate change policies

Reference: pages 84-85.

Prioritized actions (page 84): monitoring energy use and systematically cutting waste; buying electricity from renewable sources, with 100% green supply across all three plants; self-generating electricity from photovoltaic panels and from a cogenerator; investing in energy efficiency of machinery, plant and processes; and encouraging suppliers to decarbonize their processes.

In 2025 the Group studied linking the Fine Cosmetics plant to a nearby solar installation, to be operational by 2026, and ran a Fine Cosmetics project to cut fuel use by improving energy use in industrial processes, notably compressor start-up with steam generators (pages 84-85).

Resources: there are "no significant cost items, either OPEX or CAPEX" in expenses incurred or planned for these measures, and the Group has made no specific CAPEX plan to match Delegated Regulation 2021/2178 (page 85).

Targets related to climate change mitigation and adaptation

Reference: pages 55-56, 85.

2022-2025 Plan: cut Scope 1 and 2 (location-based) GHG intensity per million euros of turnover against a 2022 baseline. The 2025 audit shows 37.30 against 39.30 in 2022, a 5.1% reduction (page 55).

2026-2028 Plan, approved on 27 February 2026 and set for the first time (page 85): cut energy intensity by 10% against a 2024 baseline of 1.369 MWh per ton of bulk (printed "1,369" on page 56), and cut market-based Scope 1 and 2 GHG intensity by 10% against a 2024 baseline of 2.43 tCO2e per ton of bulk (pages 56, 87, 89). Both are measured per ton of bulk produced (page 85).

The Group says it "didn't rely on specific climate risk scenarios or scientific benchmarks" and set the targets to fit organic growth and a three-year capacity expansion plan (page 85). No absolute or Scope 3 target is stated. Targets were agreed with area managers without involving supply chain workers (page 85).

Energy consumption and mix

Reference: pages 85-87.

Total energy consumption was 44,722.62 MWh in 2025, up from 40,497.05 MWh in 2024 (Table 8, page 86). Fossil sources supplied 38,280.59 MWh (85.60%, down from 90.07%): natural gas 37,376.33 MWh, plus petrol and diesel 904.26 MWh. Renewable sources supplied 6,442.02 MWh (14.40%): purchased renewable electricity 5,684.45 MWh and self-generated non-fuel renewable energy 757.58 MWh. Nuclear is 0% (pages 85-86). All purchased electricity comes from 100% green supply contracts backed by Guarantees of Origin (page 86). The Group classes itself as a high climate impact sector under NACE 10.8.6 and reports intensity of 177.40 MWh per million euros of net revenue (166.14 in 2024) and 1.365 MWh per ton of bulk production (1.369) (pages 86-87). It attributes the rise to another plant at Brembate, cogenerator maintenance and higher production (page 86).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 87-89.

2025 (2024), tCO2e: Scope 1 8,107.08 (8,103.83), none under emissions trading schemes. Scope 2 location-based 1,226.81 (774.13) and market-based 0 (0), because purchased electricity is covered by Guarantees of Origin. Scope 3 74,865.23 (64,017.13): purchased goods and services 52,615.35, capital goods 11,846.70, fuel- and energy-related activities 2,737.71, upstream transport 2,682.08, waste 168.87, upstream leased assets 0.11 and downstream transport 4,814.41 (page 87).

Total GHG emissions: 84,216.71 location-based and 82,989.91 market-based, about 15% above 2024 (pages 87, 89). Intensity: 329.19 tCO2e per million euros of net revenue market-based, and 2.53 per ton of bulk (pages 88-89).

Method: GHG Protocol, IPCC AR6 100-year GWPs, DEFRA, ISPRA, AIB and Ecoinvent 3.10 factors, and a spend-based method for cost data (page 88). The text says six of 15 Scope 3 categories were included and then lists seven (page 88).

Policies related to pollution

Reference: pages 89-90.

Pollution falls under the same Climate and Environmental Protection Policy approved by the ESG Committee. It aims to minimize negative environmental impacts, particularly air, water and soil pollution (page 90). Measures: protect the environment and people's health and prevent voluntary or accidental pollution by choosing the best available technologies; give stakeholders open access to environmental data; and run an ISO 14001 environmental management system with certification (page 90). The Group says it adopts best available practices to protect air, water and soil. The E2 chapter states that the one material pollution impact from its own operations is air pollution, from industrial processes (page 89).

Actions and resources related to pollution

Reference: page 90.

Actions aim at environmentally responsible management across the supply chain: assessing the environmental impact of value chain parties, engaging them in improvements and working with suppliers on more sustainable solutions. Where applicable and financially sustainable, purchasing criteria are to avoid substances classified as hazardous, to choose products from renewable raw materials with certified sustainable origin (for example FSC paper, organic farming), and to prefer products designed under "green chemistry" criteria. For hazardous substances the Group works within its scope for third parties and follows its customers' formulation choices, while checking that purchased materials meet REACH (EC 1907/2006) and CLP (EC 1272/2008). Safety data sheets are reviewed and suppliers contacted when action is needed. The stated goal is to keep operational staff's exposure to a minimum (page 90).

Targets related to pollution

Reference: pages 56, 90.

The pollution targets in the 2022-2025 Plan were achieved in financial years before the current reporting period (page 90). For 2026-2028 the Group has set qualitative goals only: a hazardous chemical monitoring system that meets applicable safety standards under its ISO 14001 system, covering substances of concern, pollution of air, water and soil, and microplastics, with 2026 actions of an internal data update and supplier activation (page 56). The report states no quantified pollution target and no baseline for the new goals (pages 56, 90).

Pollution of air, water and soil

Reference: pages 89-91.

Air emissions in tons, 2025 (2024), Table 14: nitrogen oxides as NO2 24.27 (22.18); VOC/TOC 13.63 (15.42); particulate matter 0.73 (1.92); ammonia 0.0001 (0.0001), from the Trenzano plant only; microplastics generated or used 0 (0) (pages 90-91). VOC/TOC and particulate matter come from all plants, nitrogen oxides from Zingonia and Brembate (pages 90-91). Data come from sampling in April 2025 (Zingonia, Brembate) and May 2025 (Trenzano), tested by accredited laboratories under ISO/IEC 17025 (page 91). Operating hours are an estimate: eight hours a day for 220 days, 1,760 hours a year (page 91). The Group says emissions to soil and water were minimal and gives no water or soil pollutant figures (page 89). The E-PRTR pollutant datapoint is marked "Material" (page 72).

Substances of concern and substances of very high concern

Reference: pages 64, 66, 89-91.

The report states that "During 2024-2025, the Group did not use any substances classified as" substances of concern or substances of very high concern, under a heading "Substances of concern and very high concern" (page 91). That nil return is the whole E2-5 disclosure. No amounts of substances generated, used, procured or leaving the facilities are given.

Context: substances of concern is a material sub-topic. The value chain impact is potential harm to people and the environment from active substances in pharmaceuticals, supplier raw material processes and disposal, and the risk is legal and reputational exposure from mismanagement (pages 64, 66, 89). The Group says it follows its customers' formulation choices and checks purchases against REACH and CLP (page 90).

Policies related to water and marine resources

Reference: page 92.

Water is covered by the same Climate and Environmental Protection Policy, which aims to safeguard the environment where the Group operates, including Trenzano, an area with high water stress (page 92). The Group builds environmental considerations into product design to cut non-renewable raw materials upstream, and assesses process designs with supply chain partners to reduce water use (page 92). It states that it "has not adopted, at present, policies addressing the sustainability of seas and oceans" and, in the targets paragraph, that as a precaution it considers it has no policy that fully meets the ESRS Standard (page 92). The datapoint table marks the E3-1 water policy datapoints "Material" (page 73).

Actions and resources related to water and marine resources

Reference: pages 55, 92.

As a precaution the Group considers it has not undertaken actions that meet ESRS requirements, because several actions in the 2022-2025 Plan lacked defined quantitative targets and timeframes (page 92). It lists steps taken to improve water use: a Group-wide water consumption monitoring network, which the 2025 audit shows operating at the Zingonia, Brembate and Trenzano plants (page 55), and production processes designed to minimize water use (page 92). The Group will consider defining or updating actions to meet the requirements (page 92).

Targets related to water and marine resources

Reference: pages 55, 57, 92-93.

Internal targets set in the 2022-2025 Plan are described as voluntary and not legally binding (page 92). The 2025 audit reports water intensity of 236.7 m3 per million euros of turnover against 352.6 in 2022, a 32.9% reduction (page 55). Against 2024, intensity rose 14% per revenue unit and 7% per ton of bulk (page 93). For 2026-2028 the Plan sets a quantitative target to cut water intensity by 20% from a 2024 baseline of 1.71 m3 per ton of bulk and a goal of at least one water efficiency project (page 57). The Group says it has not assessed IROs related to marine resources or set marine targets (page 92).

Water consumption

Reference: pages 92-93.

2025 (2024): total water consumption 59,678.92 m3 (50,499.00), of which 17,517 m3, about 29%, in areas at water risk including high water stress (13,102). Withdrawals 67,079.92 m3 (56,121); discharges 7,401 m3 (5,622). No water was recycled, reused or stored. All water comes from the public supply, and discharges leave through a sewer outlet at the Fine Cosmetics Trenzano plant (pages 92-93). Intensity: 236.73 m3 per million euros of net revenue (207.17) and 1.82 m3 per ton of bulk (1.71) (page 93). Consumption rose 18% (page 93). Only the area where Fine Cosmetics operates is classed as at risk; Zingonia and Brembate are low risk, using WRI Aqueduct 4.0 (page 93). The 2024 figure was revised after a new calculation method and the installation of meters at Fine Cosmetics (page 93).

Transition plan on biodiversity and ecosystems

Reference: page 94.

The Group states it has not conducted a resilience assessment of its strategy and business model for physical, transitional and systemic biodiversity risks, so "no transition plan on this subject was defined" for the reporting period (page 94). It says the material biodiversity impact sits with suppliers of raw and packaging materials, so the SBM-3 requirements do not apply to it (page 94). No Group site is near a sensitive biodiversity area, so no mitigation measures under the Birds or Habitats Directives and no Environmental Impact Assessment under Directive 2011/92/EU were needed (page 94).

Policies related to biodiversity and ecosystems

Reference: pages 94-95.

As a precaution the Group says it has no policy on biodiversity and ecosystems that fully meets the ESRS Standard (page 94). It points to the Climate and Environmental Protection Policy, approved by the ESG Committee and overseen by the Managing Director, which stresses sustainable resource use and eco-design as the way to address ecosystem damage (page 94). The policy steers the supply chain toward better management of human rights and environmental impact and, where feasible, favors products from renewable raw materials with certified sustainable origin (for example FSC paper, organic farming) and "green chemistry" designs (page 95). It names material sourcing as a potential driver of biodiversity loss and supports awareness through training and cooperation with public bodies and schools (page 95). The Group is a member of the Roundtable on Sustainable Palm Oil (page 95).

Actions and resources related to biodiversity and ecosystems

Reference: pages 55, 95-96.

The Group says it has not yet undertaken actions that fully meet the ESRS Standard (page 95). Actions described: in 2024-2025 an EU Deforestation Regulation due diligence process (supply chain mapping, identifying raw and packaging material suppliers, linking customs codes to sensitive materials, asking suppliers to certify no deforestation since 31 December 2020, and tracking systems with an external traceability platform). The Regulation's strategic raw materials used in production are cocoa, coffee, soya, palm oil and wood (page 95). The Group is an RSPO member for palm oil used in cosmetics and prefers FSC-certified paper for boxes (page 95). The Urban Planting project with the Municipality of Verdellino offsets reduced soil permeability on land bought in Zingonia by planting trees on three municipal plots, to be maintained in 2026 (page 95). An eight-hive apiary project (Apicoltura Urbana) on municipal land in Brembate, launched in 2024, is under review for the 2026-2028 Plan (pages 55, 96).

Policies related to resource use and circular economy

Reference: page 97.

As a precaution the Group says it has no policy on resource use and the circular economy that fully meets the ESRS Standard (page 97). It points to the Climate and Environmental Protection Policy, which carries two circular economy commitments: cut waste in the production cycle, with a focus on reducing the share of waste sent for disposal that is no longer recyclable or reusable, and minimize the raw materials and products used in production, for example by reusing materials internally and adopting anti-waste procedures (page 97). The Group will consider defining or updating policies to meet the requirements (page 97).

Actions and resources related to resource use and circular economy

Reference: page 97.

The Group says it has not yet undertaken actions that fully meet the ESRS Standard, because several 2022-2025 Plan actions lacked defined quantitative targets and timeframes (page 97). Strategies listed: apply circular economy and eco-design from product and packaging design, analyze product life-cycle impact with customers, prefer low-impact materials, cut the weight and volume of materials, reduce logistics impact, extend shelf life and reduce end-of-life impact. Purchasing criteria favor recycled raw materials, products designed to be repaired, reused or recycled, longer shelf life and eco-efficient products compared through declarations such as EPDs or Ecolabel. Waste goes to authorized operators, with special care for hazardous waste. In 2025 the Group installed printers with an ECMA Eco Declaration (page 97).

Targets related to resource use and circular economy

Reference: pages 55, 57, 98.

The Group says it has not yet identified targets that fully meet the ESRS Standard, and that its internal circular economy targets are voluntary and not legally binding (page 98). The 2022-2025 Plan target was to raise the Waste-to-Recovery Rate (waste sent for recovery as a share of total waste) against a 2022 baseline: 15.2% in 2025 against 12.6% in 2022, up 20.6% (page 55). The packaging Life Cycle Assessment project was not repeated in 2025 (page 98). 2026-2028 goals: cut waste intensity by 10% from a 2024 baseline, run a waste volume reduction project at one plant, and create internal guidelines for packaging that meets sustainability and quality standards (page 57).

Resource inflows

Reference: pages 98-99.

Total resource inflows (raw and packaging materials purchased) were 27,273.50 tons in 2025 against 23,943.49 in 2024, about 14% more (Tables 18-19, pages 98-99). In 2025: raw materials 18,465.81 tons and packaging materials 8,807.70 tons; organic materials 8,288.62 tons (30.39%); reused or recycled secondary materials 3,029.78 tons (11.01%) (pages 98-99). Recycled wood, paper and cardboard made up about 34.4% of packaging purchases and FSC-certified materials 4.58% (403.50 tons) (page 99). Technical raw materials include plant and animal proteins 4,089.41 tons, sugars 3,250.02 and additives and chemicals 3,489.03 (page 99). No 2024 organic or recycled split is given. The Group says it will refine this data in 2026 (page 99).

Resource outflows

Reference: pages 69, 99-100.

The "Resource outflows" paragraph covers waste only. It gives quantities of hazardous and non-hazardous waste, split into waste sent for recovery and waste sent for disposal, and notes that no radioactive waste was recorded (page 99). Most waste is process water from cleaning production line equipment, stored in tanks and sent to an authorized operator as special waste, with a procedure for hazardous spills that could contaminate discharged water (page 100). The statement gives no data on products and materials flowing out of the Group, such as expected durability, repairability or recyclable content of products and packaging. The IRO-2 table lists the sub-topic as "Waste and resource outflows related to products and services" (page 69). The waste figures are set out under E5-5-Waste.

Waste

Reference: pages 99-101.

Total waste generated: 19,670.6 tons in 2025 (17,673.9 in 2024), of which hazardous 10,889.0 tons (8,603.9) and non-hazardous 8,871.6 as printed (9,069.9) (Table 20, page 100). Sent for recovery 3,002.0 tons (15%; 2,809.5 or 16% in 2024); sent for disposal 16,668.7 tons (85%). By type: hazardous 601.6 tons recovered (6%) and 10,287.4 disposed of (94%); non-hazardous 2,400.3 recovered (27%) and 6,381.3 disposed of (73%). No radioactive waste (page 99). Most waste is process water from cleaning equipment, sent to an authorized operator as special waste (page 100). The report lists hazardous waste types by EWC code (inks, solvents, aqueous washing solutions, contaminated packaging, laboratory chemicals, batteries and others) and non-hazardous types (paper, plastic, wood and glass packaging, organic waste, iron and steel and others) (pages 100-101).

Policies related to own workforce

Reference: pages 103-105, 108-111.

Policies: the Health, Safety, Well-being and Inclusion Policy, the Environmental and Safety Policy and the Code of Ethics, grounded in the UN Universal Declaration of Human Rights, the ILO core conventions, the UN 2030 Agenda and the Global Compact (page 103). Safety runs through an ISO 45001-certified occupational health and safety system with Worker Safety Representatives and a hazard and risk assessment method under Legislative Decree 81/2008 (pages 103-104). Gender equality follows UNI/PdR 125:2022, with a Steering Committee formed in 2025 and a 2026 target to set specific policies and procedures (page 104). The Group condemns human trafficking, forced labor and child labor, but "no policy has been formally adopted on this matter" beyond the supplier Code of Conduct (page 103). The datapoint table lists the S1-1 human rights, ILO, trafficking and accident prevention datapoints as "Material" (pages 73-74).

Taking action on material impacts on own workforce

Reference: pages 104, 106-111.

Safety: an ISO 45001 system, periodic checks, accident and near-miss analysis, protective equipment and health monitoring, and an annual SMETA audit through Sedex covering health and safety and labor standards (pages 104, 107). Well-being: the Lombardy WHP Network program, with Zingonia recognized for the fourth consecutive year in 2025 and first-year certificates for Brembate and Trenzano; a nutritionist desk that supported 92 employees over 401 hours; and a psychological support service that supported 142 people over 465 hours (pages 108, 110). Working hours: flexible start and finish times, one hour less every Friday and remote work up to two days a week (page 107). Pay: employees receive at least the national collective agreement minimum, and a living wage benchmark analysis was run (page 107). Inclusion and growth: Valore D training and mentoring on unconscious bias, harassment and disability (page 111). Child labor is addressed by verifying candidates' ages; forced labor and trafficking by monitoring whistleblowing reports and the SMETA audit (page 107).

Targets related to own workforce

Reference: pages 54, 57, 111.

Targets come from the sustainability plans, agreed with area managers and monitored by the ESG Committee (page 111). 2022-2025 Plan, with the 2025 audit (page 54): ISO 45001 certification for all sites (Fine Cosmetics still in progress); an injury rate below the 2022-2024 average (met); keeping Lombardy WHP accreditation (confirmed for Zingonia, Brembate and Trenzano); a management training project on feedback culture (launched in 2025). 2026-2028 Plan (page 57): ISO 45001 at all sites; an accident rate below the 2024 baseline of 14; a monitoring system for DE&I, living wage, training and corporate welfare; WHP certification at all plants; Employer Branding certification; a gender equality training module each year; UNI/PdR 125:2022 certification for the Parent Company; and a feasibility analysis for a company performance review system. Most 2026-2028 objectives are qualitative.

Characteristics of employees

Reference: pages 111-115.

At 31 December 2025 the Group had 839 employees (779 in 2024): 429 men and 410 women, none reported as other or not disclosed (Table 22, page 112). By site: Zingonia 385, Brembate 325, Trenzano 129 (page 112). Contracts: 834 permanent (406 women, 428 men) and five fixed-term; none on variable hours (page 113). 44 employees (5%) are foreign nationals (page 112). By position: 22 executives, 23 middle managers, 293 white-collar and 501 blue-collar workers (page 115). 62 people left, an outgoing turnover rate of 7.39% (8.86% in 2024), and there were 116 new hires, a 13.83% hiring rate (13.35%) (page 114). Employee figures count headcount at year end and exclude temporary workers (page 113).

Diversity metrics

Reference: pages 49, 114-115.

Senior management (first and second level below the Board) had 22 members in 2025: 15 men (68%) and seven women (32%). In 2024 it had 20: 14 men (70%) and six women (30%) (Table 27, page 114). The Board has 40% women (page 49). Employees by age: under 30, 147 (18%); 30-50, 484 (58%); over 50, 208 (25%); the under-30 share is up from 15% in 2024 (Table 28, page 114). Average age is about 40 (page 114). By position, executives are seven women and 15 men, middle managers 13 women and 10 men, white-collar workers 181 women and 112 men, and blue-collar workers 209 women and 292 men (Table 29, page 115).

Adequate wages

Reference: pages 107, 115-116.

The statement does not label this section with the DR code. It compares pay with the Wage Indicator minimum living wage index for Lombardy: as of 31 December 2025 all employees received a basic salary above the benchmark, and average gross annual pay is about 2.15 times the benchmark (pages 115-116). Salaries follow the applicable national collective labor agreements, the Food agreement for Fine Foods and the Chemical agreement for Fine Cosmetics (page 115). A Living Wage Benchmark analysis was run to see which job categories sit below, in line with or above market levels (page 107). The 2026-2028 Plan adds a monitoring system for living wage (page 57).

Training and skills development metrics

Reference: pages 57, 118-119.

Training hours are tabled by position, gender and course type (Tables 34-35, pages 118-119). The table total for 2025 is 34,864.2 hours: 13,485.5 for women and 21,378.7 for men. Average hours per employee are 41.6 overall, 32.9 for women and 49.8 for men (38 on average in 2024) (page 119). The text separately cites 43,881.5 hours in 2025 against 29,434 in 2024, a rise of about 18.5% (page 118), and the two totals do not match. Course areas are quality, health, safety and environment, technical skills, soft skills and DE&I, IT, GDPR and cybersecurity, and the 231 System, Code of Ethics, anti-corruption and whistleblowing (page 119). The report gives no share of employees receiving regular performance reviews; the 2026-2028 Plan includes establishing a company performance review system (page 57).

Health and safety metrics

Reference: pages 117-118.

2025: nine recordable accidents among employees (eight at Fine Foods, one at Fine Cosmetics) over 1,372,535 hours worked, a recordable accident rate of 7, and 129 days lost. In 2024 there were 17 accidents over 1,177,079 hours, a rate of 14 (Table 33, page 118). For temporary staff there were five recordable accidents (three at Fine Foods, two at Fine Cosmetics) over 265,518 hours, a rate of 19 (page 118). Neither company had an accident causing absence longer than 90 days in 2024-2025 (page 117). Three occupational disease claims were filed in 2025 by people who had left more than two years earlier; INAIL did not recognize one and two are pending (page 117). There were no serious accidents with serious injuries where company liability was established (page 117).

Work-life balance metrics

Reference: pages 105, 107.

The statement does not label this section with the DR code. Employees are entitled to mandatory maternity or paternity leave, optional parental leave and caregiving leave. Share of employees in service at 31 December 2025 who took leave: 32.51% of women, 14.73% of men and 22.82% overall (Table 21, page 105). Each rate divides leave-takers by all employees of that group (page 105). Supporting measures: psychological support for new mothers returning to work, flexible hours with a focus on parents of children under three, extra childcare leave, part-time options, smart working agreements and family services on the welfare platform (page 105). Working-time arrangements: flexible start and finish within a one-hour window, one hour less every Friday and remote work up to two days a week (page 107).

Compensation metrics (pay gap and total compensation)

Reference: pages 116-117.

Group average gross hourly pay in 2025: men EUR 27.54 and women EUR 25.32, a gender pay gap of 8% (13% in 2024). By level the Group gap is 10% for executives, 6% for middle managers, 6% for white-collar and 7% for blue-collar workers (Table 32, page 116). Fine Foods alone shows 9% (12% for executives, 6% for blue-collar), and Fine Cosmetics 8% after salary adjustments cut a 25% gap in 2024; its blue-collar gap stays at 13% (page 116). The annual total remuneration ratio, highest-paid individual against the median of all other employees, is 14.04 for the Group, and the Group median gross annual salary is about EUR 31,000 (page 117).

Incidents, complaints and severe human rights impacts

Reference: pages 74, 117.

The report states that in 2025 "no work-related incidents, discrimination, or human rights complaints were reported", including child and forced labor, and that none of the Group companies received fines or penalties during the period (page 117). This is a nil return with no table. The Supervisory Body found no anomalies in the application of the Organization, Management and Control System under Legislative Decree 231/2001 in 2025 (page 117). The datapoint table lists the S1-17 incidents of discrimination and non-compliance with UN Guiding Principles and OECD datapoints as "Material" (page 74).

Policies related to value chain workers

Reference: pages 121-122.

The Group says that as a precaution it has no policy on value chain workers that fully meets the ESRS Standard (page 121). Its main instrument is the supplier Code of Conduct, written into new contracts and referenced in orders. By 31 December 2025 almost all raw and packaging material suppliers and more than 70% of service and asset suppliers had signed it (page 121). The Code refers to the UN Universal Declaration of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, the UN Global Compact and the Pharmaceutical Supply Chain Initiative, and sets rules on forced labor, child labor and young workers, non-discrimination, fair treatment, wages and hours, freedom of association, privacy, and health and safety (pages 121-122). Supplier choice follows objective, merit-based criteria (page 122). The datapoint table lists the S2-1 human rights policy datapoints as "Material" (pages 74-75).

Taking action on material impacts on value chain workers

Reference: pages 121, 123.

Action runs through supplier ESG assessment. In 2025, 85% of the value of raw and packaging materials ordered came from suppliers rated above 40/100 on EcoVadis ESG criteria, and 95% from suppliers positively evaluated by EcoVadis or through the Group's ESG questionnaire (pages 121, 123). Procurement and ESG staff review supplier conduct assessment results (page 123). Corrective action plans sit in the EcoVadis platform, where the Group tracks whether actions are in progress, completed or archived (page 123). The Group says it has taken no specific initiative to create positive impacts for supply chain workers, sees no dependency-related risks for them, and is not aware of serious incidents or human rights violations upstream or downstream (page 123). The datapoint table lists the S2-4 human rights incidents datapoint as "Material" (page 75).

Targets related to value chain workers

Reference: pages 55-56, 58, 123.

The report refers readers to the 2026-2028 Sustainability Plan for supply chain targets, set with area managers without involving supply chain workers (page 123). 2022-2025 Plan targets and 2025 results (pages 55-56): all suppliers assessed under ESG criteria (85% of raw and packaging materials value from suppliers rated above 40/100 on EcoVadis; 95% positively assessed by EcoVadis or the ESG questionnaire) and all suppliers signing the Code of Conduct (98% of raw and packaging spend, 71% of services spend). 2026-2028 Plan (page 58): supplier engagement and capacity-building programs covering at least 80% of spending over three years, with a minimum expenditure cut-off of EUR 50,000; an ESG rating system for the supply chain; updated supplier monitoring procedures; and annual sustainable procurement training for purchasing staff (100% in 2025).

Policies related to consumers and end-users

Reference: pages 75, 124.

Product safety is covered by the Quality Policy under an ISO 9001-compliant Quality Management System at Fine Foods and Fine Cosmetics; the Managing Director approved it and the latest update was in November 2024 (page 124). The policy commits to product safety, which "indirectly safeguards the end consumer" (page 124). The Group is a B2B subcontractor and does not deal with end consumers, so it has no end-user human rights policy (page 124). Two privacy policies protect customer data: one for pharmacovigilance data on adverse events reported by patients, and one for customers and suppliers (page 124). The datapoint table lists the S4-1 policy and UN Guiding Principles non-respect datapoints as "Material" (page 75).

Taking action on material impacts on consumers and end-users

Reference: pages 54, 57, 125-127.

The plants hold certifications by sector: ISO 9001 at all three; ISO 13485, FSSC 22000 and a food supplements GMP certificate at Zingonia; an AIFA GMP certificate and ministerial authorization for narcotics at Brembate; ISO 22716 and IFS-HPC at Trenzano (pages 125-126). The Group applies EU current Good Manufacturing Practices, audits suppliers of active ingredients, excipients and packaging, and follows the Falsified Medicines Directive serialization rules (page 126). Effectiveness is shown by renewing the certifications; actions are decided from internal, certifier and customer audits reviewed annually in the Management Review (page 126). No actions give end consumers benefits beyond the product's function (page 126). The report dates a pharmaceutical recall after a Spanish authority audit to 2024 on page 126 and to 2025 on pages 54 and 57.

Targets related to consumers and end-users

Reference: pages 57, 127-128.

Quality targets are set each year in a Management Review attended by the Chairman, the Managing Director and the Quality Unit Manager, and tied to KPIs for each business unit (page 127). 2025 results and 2026 objectives (Tables 36-38, page 127): Pharmaceuticals, defects per million units -20% and complaints per million units -70%, audits 95%, with a 10% reduction objective for each in 2026; Nutraceuticals, defects -44% and complaints -18%, audits 99%; Cosmetics, 0.85% non-conformities on manufactured batches against a 2026 objective below 0.84%. Quantitative targets also cover external complaints, non-conformities in batches and supplies, and the cost of reprocessing or destruction against EBITDA. End users are not involved in setting targets (page 127). The 2026-2028 Plan sets zero product recalls, against one recall in 2025 (page 57).

Business conduct policies and corporate culture

Reference: pages 76, 129-131.

Policies: the Code of Ethics (approved and regularly updated by the Board since 2019), the Anti-Corruption Policy (implemented in 2022, approved by the Board), an anti-retaliation policy for whistleblowing, and a procedure for donations, gifts and sponsorships (effective since 2022) (page 129). Five privacy policies cover website users, whistleblowing, investors, customers and suppliers, and pharmacovigilance (page 129). Under its Legislative Decree 231/2001 management system the Group regularly updates risk assessments on corruption, conflicts of interest, fraud, money laundering and information security (page 129). Whistleblowing routes: an internal TESEO channel, an external ANAC channel, public disclosure and direct report to national authorities, with confidentiality safeguards (pages 130-131). The Code and the policy apply to directors, employees, agents, co-workers, distributors and business partners (page 131). The datapoint table lists the G1-1 UN Convention against corruption and whistleblower protection datapoints as "Material" (page 76).

Targets related to business conduct

Back-filled from the business conduct targets in the sustainability plan tables (pages 54, 58). G1-3 became a standalone DR only in the 2025/2026 ESRS; this statement was prepared under the 2023 ESRS and its G1 chapter has no targets section.

The Group states business conduct targets in its plans, mostly qualitative. 2025 targets and audit (page 54): update the Code of Ethics and implement the Anti-Corruption Policy (done in 2024), train all staff on anti-corruption and whistleblowing (done on the Fine Foods Academy portal in 2025), maintain the ESG-based MBO system, ensure Legislative Decree 231/01 compliance, and keep data security with no non-conformities.

2026-2028 Plan (page 58): process whistleblowing reports within six months, uphold the 231 system and revise the Code of Ethics, apply an ESG-based MBO system to all directors and managers who influence ESG outcomes (100% in 2025), keep data security with no non-conformities, and retain suppliers who commit to the supplier Code of Conduct (98% in 2025).

Incidents of corruption or bribery

Reference: pages 76, 132.

The report states there have been no reported violations of anti-corruption and bribery laws, so there are no convictions or fines to disclose, and that no breaches of internal anti-corruption and bribery procedures were identified and no corrective actions were required (page 132). 2025 training on the Code of Ethics, anti-money laundering policies, whistleblowing and related topics totaled 456 hours, about 42% below the 783 hours of 2024, largely because whistleblowing training fell after an exceptional rise driven by a major policy update (page 132). The datapoint table lists the G1-4 fines and anti-corruption standards datapoints as "Material" (page 76).

Payment practices

Reference: pages 131-132.

The Parent Company pays suppliers on average 2.0 days after the invoice due date, based on its 2025 supplier invoices compared with payment dates as of 20 January 2026. 76% of payments met the agreed terms, allowing a tolerance of up to two days when due dates fell on non-working days and counting early payments (page 132). A precise figure for Fine Cosmetics was not possible, and the Group estimates a similar delay (page 132). Payment terms: raw and packaging material suppliers 60 days end of month, 30 days from invoice date and 90 days end of month; service and asset suppliers 60 days end of month. No disputes over late or non-payment are ongoing (page 132). The Group has no specific policy to prevent late payments (page 131).