Finnair

The role of the administrative, management and supervisory bodies

Reference: page 44; pages 44-46.

The Board "is composed entirely of non-executive and independent members" and has no employee or other worker representatives. In 2025 three of its eight members were women (37.5%) and five were men (62.5%) (page 44).

The Board is the most senior body overseeing the sustainability reporting process. It approves Finnair's sustainability targets and significant sustainability matters following the double materiality assessment (DMA), and reviews the energy transition plan. It delegated oversight of sustainability reporting quality, the reporting auditor and related internal control to the Audit Committee, which meets quarterly and reports to the Board (pages 44-45).

Below the Board (pages 45-46):

• Executive Board and CEO, accountable for running the business in line with company values and policies; the Executive Board sets sustainability targets and priorities
• Sustainability Leadership Team (SLT): six Executive Board members in 2025 plus the Vice President Sustainability; develops policies and targets and updates the DMA
• Business area Leadership Teams and cross-organizational environmental, social and governance working groups, which carry out targets and report progress to the SLT

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

Reference: page 46; pages 45-46.

The Board and its Audit Committee are briefed by the Executive Board at least quarterly on sustainability matters and sustainability reporting, to confirm that administrative, risk management and compliance procedures are in place (page 46). The SLT also meets at least quarterly to review material matters and progress against targets and adjusts priorities where needed (page 46).

Sustainability matters put to the Board, Audit Committee and Executive Board for review and approval during 2025 (page 46):

• Environmental and Energy Efficiency Policy update
• Preparation of the Sustainability Report under ESRS, with the related risk management and internal controls
• Energy transition and decarbonization roadmap
• Quarterly review of selected internal sustainability KPIs
• Human rights due diligence process
• Supply chain risk management
• Privacy matters

The Audit Committee also oversees the feasibility of the energy transition plan and its link to long-term business resilience (page 45).

Integration of sustainability-related performance in incentive schemes

Reference: page 46.

Performance targets for the CEO and other Executive Board members are set by the Board. Short-term incentive (STI) plans are set annually and "include select targets related to financial, operational, personnel, customer or environmental impacts" (page 46).

In 2025 the Board decided the long-term incentive (LTI) plan for 2025-2027, with a maximum of 75 participants. Its two sustainability metrics are carbon emissions per revenue tonne kilometer (CO2/RTK), weighted 10%, and the employee engagement score, weighted 10% (page 46). The report describes CO2/RTK as a fuel efficiency metric for aviation and points to S1-5 for the engagement score. Finnair's ESRS content index also lists GOV-3 under E1 (page 60).

Statement on due diligence

Reference: page 47; page 49.

Page 47 presents a table mapping the core elements of due diligence to where each is covered in the statement:

• Embedding due diligence in governance, strategy and business model: ESRS 2 GOV-1, GOV-2, GOV-3, SBM-3; topical S1-1, S2-1, S3-1, S4-1, G1-1
• Engaging with affected stakeholders: ESRS 2 GOV-2, SBM-2, IRO-1; topical S1-2, S2-2, S3-2, S4-2
• Identifying and assessing adverse impacts: ESRS 2 IRO-1, SBM-3
• Taking action: E1-3, E4-3, E5-2, S1-4, S2-4, S3-4, S4-4, G1-2, G1-3
• Tracking effectiveness and communicating: E1-5, E4-4, E4-5, E5-3, S1-5, S2-5, S3-5, S4-5, G1-3

Finnair published its Policy Commitment to Human Rights in January 2025, based on the UN Guiding Principles on Business and Human Rights and the OECD Guidelines. It describes a due diligence process integrated into the Internal Control Framework and covering own workforce, value chain workers, affected communities and consumers (page 49). The report calls due diligence "an inherently iterative process" (page 49).

Risk management and internal controls over sustainability reporting

Reference: page 47.

An assessment of the risk management and internal control system over sustainability reporting under the CSRD was carried out in 2024. It identified three risks: information silos affecting the timeliness and completeness of reporting, a possible lack of internal controls and management approval for sustainability reporting, and unclear roles and responsibilities for data ownership (page 47).

In response, Finnair set up an internal governance model for sustainability reporting that defines roles and responsibilities and the timing of each actor's involvement. The Finance unit's group accounting function gathers data, compiles and publishes the statements and facilitates assurance, supported by business units and by the sustainability team led by the Vice President Sustainability. The group accounting function reports on progress, risk management and internal controls to the Board's Audit Committee, which oversees the quality of sustainability reporting (page 47).

Strategy, business model and value chain

Reference: page 47; pages 47-50.

Finnair's principal products and services are passenger and cargo transport across Europe, North America, Asia and the Middle East, plus package tours under its Oy Aurinkomatkat - Suntours Ltd Ab brand (Aurinkomatkat). During the reporting period there were no significant changes to products, services, markets or customer groups, and no bans on its products or services in the markets it operates in (page 47).

The workforce is mainly in Finland, with employees also in Estonia, South Korea and Japan and out-stationed workers globally. Own employees by region at year-end: Europe 5,481, Asia 195, North America 7, Oceania 1, South America 0, Africa 0 (page 47).

Strategy (pages 48-49): the report names direct aircraft emissions (Scope 1) as Finnair's most significant environmental impact, with an SBTi-validated target to cut emissions intensity 34.5% by 2033 from a 2023 baseline through SAF, fleet modernization and operational efficiency. It lists uncertainties around SAF availability and price, new-generation aircraft and policy frameworks. Social impacts on own workforce, value chain workers, affected communities and customers are also material. The business model is built around the Helsinki-Vantaa hub, oneworld and joint businesses; subsidiary Norra flies 24 leased aircraft under a purchased traffic agreement (page 49). Page 50 shows the value chain and where the material impacts, risks and opportunities sit.

Interests and views of stakeholders

Reference: page 51; pages 51-53.

A table on pages 51-52 sets out, for nine stakeholder groups, how engagement is organized, its purpose and how outcomes are used:

• Own workforce: elected OHS and employee representatives, the Corporate Council, townhalls and the biannual Finnair Voice survey; outcomes feed policies such as the One Crew People Plan and the occupational health and safety action plan
• Customers: service channels, surveys, the Finnair Customer Community and Finnair Plus events
• Suppliers and value chain workers: contract management, the Supplier Code of Conduct, screening, surveys and audits
• Affected communities: Aurinkomatkat destination programs, and noise monitoring and an airport cooperation group at Helsinki-Vantaa
• Shareholders and investors, authorities, industry partners, media, and non-profit organizations (including WWF, UNICEF, the Finnish Red Cross and All For Blue)

The Board, its committees, the Executive Board and the SLT are regularly informed of stakeholder views through the briefings described under GOV-2 (page 53). Stakeholder input to the DMA itself is described under IRO-1 (page 53).

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

Reference: page 53; pages 53-55.

Pages 53-55 list the material sustainability matters, each typed as negative impact, positive impact, risk or opportunity. The topical chapters repeat them with descriptions (E1 pages 84-85, E4 page 104, E5 page 106, S1 page 111, S2 page 125, S3 page 129, S4 pages 134-135, G1 page 142). By this review's count there are 46 rows: E1 13, E4 2, E5 3, S1 7, S2 3, S3 5, S4 8 and G1 5. The report states no total.

• E1 Climate change: negative impacts from Scope 1 and 2 emissions, Scope 3 emissions, non-CO2 emissions and fuel use; risks from regulation, the transition to fossil-free aviation, fines and litigation, reputation and demand, and operations in vulnerable areas; four opportunities (page 53)
• E4 and E5: feedstock production for renewable fuel, and use of virgin resources and waste (page 54)
• S1 and S2: shiftwork and strike risk, wellbeing and employer brand; supply chain human rights impacts (page 54)
• S3: overtourism and aircraft noise, set against regional development and local jobs (page 55)
• S4: accessibility, sustainability communication, punctuality, data breaches, passenger safety and human trafficking (page 55)
• G1: illegal wildlife trafficking, unethical conduct, government relations and supplier relationships (page 55)

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

Reference: page 56; pages 56-59.

Finnair ran its first DMA in 2023 and has since reviewed it internally twice, with changes approved by the Board (page 56). The 2024 review moved aircraft noise under S3, which left E2 Pollution not material, separated Scope 1 and 2 from Scope 3 emissions, added non-CO2 emissions as a material E1 impact, and moved overtourism to S3 (page 56).

Process (page 57): a contextual analysis of public and internal sources; interviews and surveys with employees, consumers and corporate customers, suppliers, investors, authorities and non-governmental organizations; then scoring. Severity or magnitude and likelihood were each scored 1 to 5 and multiplied. The median of all scores was the starting cut-off, followed by qualitative adjustments in validation meetings with the Executive Board, and Board validation.

Climate: enterprise risk management based on the COSO ERM framework, a certified Environmental Management System (IATA IEnvA), and scenario-based climate risk assessments (pages 57-58; see E1-2 back-fill). E4: SAF feedstock land-use change was the material issue (page 59). E5: food and beverage and chemicals were the largest material categories by weight (page 59). E2 and E3 were found not material (page 59).

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

Reference: page 60; pages 60-71.

Pages 60-63 give the ESRS content index, "List of the Disclosure Requirements complied with in preparing the Sustainability Report", with section and page for every disclosure requirement (page 60). Pages 64-71 hold Appendix B, the list of datapoints that derive from other EU legislation, each with a section and page or a marker.

The index marks as "Determined non-material" all of E2 Pollution and E3 Water and marine resources, including their IRO-1 rows (page 61). It marks as "omitted as per ESRS 1 General requirements Appendix C": E1-9, E4-6, E5-6, S1-7, S1-11 and S1-12 (pages 61-62). Appendix B marks the E1-9 datapoints as omitted and the E2-4 and E3 datapoints as non-material (pages 66-68).

The basis of preparation says no information was omitted because it contained intellectual property, know-how or innovation results, and nothing was incorporated by reference (pages 43-44). Finnair applied the Appendix C phase-in and Delegated Act (EU) 2025/1416 (page 44).

Transition plan for climate change mitigation

Reference: page 81; pages 81-83.

The report states plainly that Finnair "does not claim to have a valid transition plan for climate change mitigation at this time" because it lacks all required elements approved by the Board and documented under the CSRD; further planning is underway (page 81).

What exists is a ten-year target validated by the SBTi in September 2024: a 34.5% cut in well-to-wake Scope 1 and 3 jet fuel GHG emissions per revenue tonne kilometer by 2033 from a 2023 base year, about 13% in absolute terms; non-CO2 effects are excluded (page 81). SAF is expected to deliver 60-70% of the reductions over the next ten years, with fleet renewal and network and operational efficiency as further levers (page 81).

Funding: Finnair "has not determined the financial capital and operational investments needed" and made no allocation decisions. It allocated 2.6 FTE to its environmental management system and 2.8 FTE to climate actions in 2025, and paid about EUR 104.0 million in environmental costs, EUR 71.6 million of it for emissions trading (page 82). It is not excluded from the EU Paris-aligned benchmarks (page 82). Locked-in emissions: average fleet age 15.1 years against an economic life of about 25 years (page 83).

Identification of climate-related risks and scenario analysis

Reference: page 58; pages 56-59.

Back-filled from ESRS 2 IRO-1 (pages 56-59), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

A scenario-based climate risk assessment "was conducted in 2022 and updated in 2023 and 2024" (page 58). Four scenarios were used: IEA NetZero 2050, IEA APS, IPCC RCP2.6 and IPCC RCP8.5 (page 58).

Physical risk (page 58): assessed on RCP2.6 and RCP8.5 over short- (2023-2040), medium- (2041-2060) and long-term (2061-2100) horizons, with focus on 2030-2050. RCP8.5 is described as leading to 4.5 degrees of temperature change; RCP2.6 is aligned with the Paris Agreement. The report says "No quantitative analysis of the effects of physical climate change has been performed." The risks assessed are mainly sudden extreme weather affecting punctuality, such as heavy snowfall, and chronic change that may require parts of the network to be re-evaluated.

Transition risk (page 58): assessed on IEA World Energy Outlook scenarios, mainly NetZero 2050 plus Stated Policies and Sustainable Development, over 2023-2025, 2026-2030 and 2031-2040, covering aircraft energy efficiency, renewable fuels, consumer behavior, policy and aircraft technology. Finnair also reports to CDP, which is aligned with TCFD (page 56).

Resilience in relation to climate change

Reference: page 86; pages 56, 83-90.

Back-filled from ESRS 2 IRO-1 (page 56), SBM-3 (pages 84-89) and the resilience text on pages 83 and 90, where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Finnair says it has "not performed qualitative or quantitative analysis" of its business model and strategy's resilience across all identified impacts and risks. It has built an understanding of resilience to specific climate impacts, risks and opportunities through CDP reporting, which is aligned with TCFD (page 56).

Tables 1 and 2 (pages 86-89) rate each climate risk and opportunity by annual financial effect over 0-1, 2-5 and 6-10 years, with Low under EUR 5 million, Medium EUR 5-20 million and High over EUR 20 million. Technology risk is Low in the short and medium term and High in the long term; the policy and legal risk (EU ETS changes, SAF mandates) is rated High; the market risk is "Not assessed" (pages 86-87).

Capacity to adapt is limited by fleet age (15.1 years average, about 25-year economic life, locked-in emissions risk, page 83) and by uncertainty over SAF availability and price, new-generation aircraft and policy (page 48).

Policies related to climate change mitigation and adaptation

Reference: page 91.

Finnair's Environmental and Energy Efficiency Policy sets its commitment to manage the most material environmental and energy efficiency impacts. It covers climate change mitigation and adaptation, energy efficiency, renewable energy deployment and collaboration, and also addresses biodiversity. The CEO owns the policy and the Executive Board approves it. It applies across all units, functions and subsidiaries and is communicated to personnel and key suppliers (page 91).

The policy is delivered through an Environmental Management System certified under the IATA Environmental Assessment (IEnvA), and the Finnair Environmental Manual sets the environmental rules (page 91). Its priority is to reduce energy consumption before considering other emission measures (page 92).

Adaptation: the Sustainability Leadership Team ensures environmental risks are assessed and managed (page 91). The report links the policy to the 2024-2033 intensity goal of 34.5% and to the transition drivers in its scenario analysis: aircraft technology, energy infrastructure at airports, and renewable fuels (page 91).

Actions and resources in relation to climate change policies

Reference: page 92; pages 92-93.

Over 80% of Finnair's GHG emissions come from flight operations, so actions focus there (page 92).

Renewable energy: Finnair used 16,360 tonnes of SAF in 2025, about 1.6% of total kerosene use. Of this, 2,259 tonnes were funded voluntarily by Finnair and its customers and 14,100 tonnes came from the EU fuel supplier mandate. SAF cut CO2e emissions by 52,986 tonnes on a life-cycle basis. Staff business flights are covered 100% with SAF under the book and claim principle (page 92).

Efficiency: a cross-organizational fuel efficiency group saved about 1,059 tonnes of fuel and 3,855 tonnes of CO2 through measures such as new tools for flight profile optimization, tuned use of auxiliary power units and more efficient aircraft turnarounds (page 93). Traffic rose 2.7% in revenue tonne kilometers (page 92).

Table 3 counts initiatives per lever: renewable energy 3 implemented, fuel efficiency 2, aircraft technology 0 and other 0 (page 93).

Ground operations: 27% of ground vehicles are electric, 98% of ground fuels were renewable, and 100% of electricity and 98% of district heating at Helsinki-Vantaa were emission-free (page 92). Resources: 2.6 FTE for the environmental management system and 2.8 FTE for climate actions; no investment amounts determined (page 82).

Targets related to climate change mitigation and adaptation

Reference: page 93; pages 93-95.

Finnair's SBTi-validated target is a 34.5% reduction in well-to-wake Scope 1 and 3 jet fuel GHG emissions per revenue tonne kilometer (RTK) by 2033 from 2023, from 976 to 639 g CO2e/RTK (page 95, table 31). In absolute terms that is about 13%, from 3,492,214 to 3,043,254 tonnes CO2e (the table prints the unit as "ktons"). Non-CO2 effects such as contrails are outside the target under current SBTi guidance (page 94).

The target rests on the SBTi 1.5-degree aviation sector pathway, derived from the aviation scenario in the ICCT's Aviation Vision 2050 report (page 94). Levers are SAF, fuel efficiency and aircraft technology improvements; the report adds that the weight of each depends on network shape, fleet renewal and operational efficiency (pages 94-95).

Other targets: carbon neutrality of its own ground operations at Helsinki-Vantaa since 2023, with 331 tonnes of residual CO2 compensated in 2025 (page 95); and an internal operating model for contrail management by the end of 2027 (page 94).

Progress: emission intensity of flying was 976.4 g CO2e/RTK in 2025 (995.2 in 2024), down 1.9% (pages 92-93).

Energy consumption and mix

Reference: page 96.

Total energy consumption was 13,270,646 MWh in 2025 (13,181,187 MWh in 2024; 12,094,019 MWh in the 2023 base year). Fossil sources were 13,019,284 MWh (98.1%), nuclear 21,435 MWh (0.2%) and renewable and low-carbon sources 229,926 MWh (1.7%) (page 96, table AR 34).

Fossil jet fuel accounts for almost all of it, 13,018,882 MWh; the report says jet fuel use is "over 99% of Finnair's total energy use, including wet lease out operations" (page 85). The renewable fuel line is SAF at 207,693 MWh (59,748 MWh in 2024). Purchased renewable electricity and heat were 21,497 MWh, self-generated solar 737 MWh, and purchased fossil-source energy 402 MWh. Facility energy fell 8.5% on a warmer winter (page 93).

Energy intensity was 4,272.3 MWh per EUR million of net revenue in 2025 (4,323.4 in 2024), on net revenue of EUR 3,106.2 million (pages 96-97).

A footnote says Normec-Verifavia SAS verified the conventional aviation fuel figures with reasonable assurance and the SAF figures with limited assurance (page 96).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: page 97; pages 97-100.

Gross emissions, tCO2e (page 98, table AR 48):

Scope 1 covers Finnair-operated flights and ground equipment (3,266,019 t) plus flights wet-leased to other operators (178,233 t); 38.6% falls under regulated emissions trading schemes (page 98). The largest Scope 3 source is category 3, fuel and energy-related activities (538,025 t), followed by purchased goods and services (205,499 t), capital goods (66,666 t) and upstream transport (29,080 t). 63.1% of Scope 3 was calculated with primary data (page 98).

Intensity: 1,390.1 tCO2e per EUR million of net revenue location-based and 1,388.8 market-based (page 97). Biogenic CO2e from SAF and renewable ground fuel, 53,704 t, is reported separately (page 98). Scope 3 methods and relevance by category are in table 5 (pages 99-100).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 101.

Finnair reports carbon credits but no GHG removals. It cancelled 331 tCO2e of credits in 2025 (3,423 tCO2e in 2024), all from reduction projects, none from removal projects, all under the Verified Carbon Standard, none from projects within the EU and none qualifying as corresponding adjustments. No further credits are planned to be cancelled until 2026 (page 101, table AR 64).

The credits compensate residual emissions of Finnair's ground operations at Helsinki-Vantaa, which the company says have been carbon neutral since 2023: in 2025 these were emissions from renewable fuel production and from gasoline use. The projects are externally certified voluntary emission reduction projects outside Finnair's value chain (page 101).

The report states that "Finnair does not have an internal procedure to manage the risk of non-permanence of the GHG removals". It dropped the removals table (AR 60) used in the 2024 report because removals within the value chain have not been used (page 101).

Internal carbon pricing

Reference: page 102.

Finnair uses the regulatory costs of jet fuel, meaning EU ETS, CORSIA and SAF mandate costs, as an internal carbon price in financial planning. Whenever jet fuel cost calculations are run, for example weight reduction campaigns, fleet and network planning or SAF investments, the price is applied automatically. It is reviewed at least quarterly to follow the EU ETS and CORSIA price and the estimated SAF mandate cost (page 102).

Table AR 66: the internal carbon cost applies to Scope 1, with a volume at stake of 3,263,833 tCO2e at EUR 70 per tCO2e, the average price across all emissions trading schemes in 2025. The scheme covers over 99% of Scope 1 emissions (page 102).

The report warns that the regulation-based price is volatile and can make financial planning difficult (page 102). Environmental costs actually paid in 2025 were about EUR 104.0 million (page 82).

Transition plan on biodiversity and ecosystems

Reference: page 103; pages 103-104.

Finnair states that it "does not have a formalised transition plan, nor has it conducted a resilience analysis" of its business model and strategy for biodiversity and ecosystem-related risks (page 103).

The biodiversity issue the report treats as material is upstream: SAF demand could drive land-use change to grow feedstock for SAF production, and the potential adverse impact falls in the medium and long term as SAF demand and supply grow. A linked risk is that regulation of renewable feedstock supply and a lack of transparency in SAF production could restrict supply, raise prices and carry reputational risk (pages 103-104).

Finnair's environmental working group is tasked with evaluating how its own operations and its upstream value chain affect biodiversity, as part of the SAF strategy (page 103). The DMA found no positive impacts, opportunities or direct material dependencies on biodiversity and ecosystem services, and the Helsinki-Vantaa hub is not considered a biodiversity-sensitive area (page 59).

Policies related to biodiversity and ecosystems

Reference: page 104.

Biodiversity is covered by Finnair's Environmental and Energy Efficiency Policy, approved by the Executive Board and owned by the CEO. The policy sets an Environmental Management System (EMS), says Finnair will explore the sustainable deployment of renewable fuels with its business partners, and states the aim to protect biodiversity and ecosystems and minimize impacts on them (page 104).

Specific measures are not set in the policy but "in SAF procurement guidelines and processes". Finnair commits to buying SAF that meets the sustainability criteria of the EU Renewable Energy Directive and the ReFuelEU Aviation regulation, and all purchased SAF must be validated by an external certification body such as ISCC or RSB against recognized sustainability standards (page 104).

Finnair does not tolerate illegal wildlife trade and supports industry action against it; see G1 (page 104). Appendix B points the E4-2 datapoints on sustainable land, oceans and deforestation policies to this page (page 68).

Actions and resources related to biodiversity and ecosystems

Reference: page 104.

The material biodiversity impacts and risks are connected to sourcing biogenic SAF. Finnair's actions (page 104):

• Continuous dialogue with SAF providers to confirm that purchased SAF is compatible with the sustainability criteria
• Engagement with fuel providers and regulators on sustainable, large-scale production of non-biogenic SAF
• In 2025, joining a Finnish collaboration project piloting an ecosystem and value chain for synthetic SAF (eSAF) made from biogenic CO2 and green hydrogen
• Purchase of SAF only where it meets EU RED criteria and carries external certification (for example ISCC or RSB)

The report states that in 2025 "no biodiversity offsets were utilised" and local or indigenous knowledge and nature-based solutions were not built into decisions. Finnair has not quantified the current or future operating and capital expenditure related to biodiversity and ecosystem impacts (page 104).

Targets related to biodiversity and ecosystems

Reference: page 105.

Finnair has not set targets for biodiversity and ecosystems. The report gives its reason: there is "not a mature enough understanding of SAF's biodiversity and ecosystem impacts to put in place measurable and outcome-oriented targets" (page 105).

Its stated continuing objective is to protect biodiversity and ecosystems and minimize its impacts on them, which it pursues by following sustainable purchasing guidelines for all procured SAF (page 105).

Impact metrics related to biodiversity and ecosystems change

Reference: page 105.

Finnair does not follow quantitative impact metrics for biodiversity and ecosystems change. The reason given is the same as for targets: there is not yet a mature enough understanding of the biodiversity and ecosystem impacts of SAF (page 105).

It aims to build that understanding, for example by taking part in training and forums on the topic. The report expects the potential impacts of SAF production on biodiversity to appear in the long term, so that understanding among SAF producers, regulators and airlines is likely to grow (page 105).

Policies related to resource use and circular economy

Reference: page 106.

Finnair has a Circular Economy Policy for resource use and waste management in its own operations at the Helsinki-Vantaa hub, with specific objectives for Finnair Kitchen, Technical Operations and Cargo. It follows the EU Waste Framework Directive (2008/98/EC): reduce material use, reuse where possible, recycle and recover (page 106).

Finnair aims to have a material management process in its own operations by the end of 2025, covering critical material and waste flows, ways to reduce them, measures and follow-up. The circular economy working group reports progress monthly to the Sustainability Leadership Team on two measures: waste per passenger and recycling rate at the Helsinki-Vantaa hub (page 106).

Policy guidelines include reducing over-catering in Finnair Kitchen and single-use packaging in Cargo, and designing service elements to be light, durable and repairable. Technical Operations repairs aircraft and components for reuse. Aurinkomatkat is excluded because its resource use is insignificant (page 106). The page also lists the E5 impacts and opportunity: use of virgin resources, decreased need for virgin resources, and waste generation and non-recycling (page 106).

Actions and resources related to resource use and circular economy

Reference: page 107; pages 107-108.

The circular economy working group oversees objectives for material management, waste reduction and recycling; action plans are approved and monitored in each unit's Leadership Team. Implementation is not expected to need significant financial investment in the short term (page 107).

Actions reported for 2025:

• A continuous process to adjust in-flight catering and avoid over-catering, estimated to cut annual catering waste by 11 tonnes (page 107)
• A trial of durable headrest covers in place of single-use ones, with savings of up to 13 tonnes a year (page 107)
• Recycled PET cups on flights from September 2025, expected to avoid 22 tonnes of virgin material a year (page 107)
• Cabin interiors refurbished on seven aircraft, and seats from five of them sold for reuse, saving about 6 tonnes of resources (page 107)
• Wood waste recycling from Cargo and Technical Operations, about 24 tonnes diverted from energy recovery (page 107)
• Cardboard recycling on all arriving flights from 2026, about 40 tonnes a year, and donation of damaged fish, about 10 tonnes a year (page 108)

Recycling of international catering waste is prohibited under Regulation 1069/2009/EC, which limits what Finnair can recycle (page 107).

Targets related to resource use and circular economy

Reference: page 108.

Finnair has not set public targets for resource use and circular economy. The Circular Economy Policy objectives are followed through two quantitative indicators, with internal targets set for 2021 to 2025 (page 108):

• Waste per passenger: 0.34 kg in the 2021 base year, 0.24 kg in 2025
• Recycling rate: 22% in the 2021 base year, 29% in 2025

Both cover waste generated at Finnair's own operations at Helsinki-Vantaa and from returning flights, and exclude waste left at outstations. The report says the target period has ended but Finnair will continue to monitor and develop these measures (page 108). Passenger numbers are the total carried on Finnair flights in the year.

Resource inflows

Reference: page 108.

Finnair identified two material resource inflow categories, which together make up about 90% of inflows (page 108):

Critical raw materials weigh 714 kilograms in total and consist of nickel, copper, titanium and lithium. Certified biological material and recycled material are 0 in all categories and both years. Food and beverage is the largest category, mainly juices, bottled water and ready-made meals; chemicals are second, with dry ice and nitrogen the largest items (page 108).

Method: food and beverage uses measured weights, including wet-lease catering based on average menu weights; about half of the chemicals weights are estimates. Materials in the value chain and leased assets are excluded, and Finnair uses the ESRS 1 transitional provisions for value chain information (page 108).

Resource outflows

Reference: page 109.

In 2025 Finnair generated 4,155 tonnes of waste in its own operations, 132 tonnes of it hazardous and none radioactive. Non-recycled waste was 3,329 tonnes, 80% of the total (page 109). Hazardous waste is mainly oils, lubricants and kerosene.

The largest stream is international catering waste at 58% of total waste mass. It includes food waste and food-contact packaging from flights returning from outside the EU, which animal health regulation 1069/2009/EC requires to be incinerated rather than recycled (page 109). Other streams above 2% are metal, cardboard, plastic, food waste from intra-European flights, wood, glass and waste chemicals (page 109).

The section reports waste flows. It gives no separate figures for products or materials leaving the company. Appendix B points the non-recycled waste and hazardous waste datapoints to this page (page 68). See E5-5-Waste for the breakdown by disposal route.

Waste

Reference: page 109.

Waste by treatment route, tonnes (page 109):

Scope and method: figures cover own operations at Helsinki-Vantaa and waste from long-haul flights disposed of at outstations. Amounts come from waste treatment partners as direct measurements, except outstation waste, which uses an average weight per returning passenger and assumes all of it goes to landfill. This differs from the E5-3 indicators, which exclude outstation waste (page 109). Finnair says it has no verifiable information on waste handling at outstations (page 44).

Policies related to own workforce

Reference: page 112; pages 112-113.

Finnair's human rights commitments for its own workforce rest on the Code of Conduct, which follows the UN Universal Declaration of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work and covers employees and non-employees. The Policy Commitment to Human Rights was published in January 2025 (page 112).

Policies by theme (pages 112-113):

• Health and safety: an occupational health and safety policy approved by the Executive Board and owned by the Chief Operating Officer, an occupational safety plan and an occupational health care action plan
• Working conditions: the One Crew People Plan, updated in 2025 and owned by the Chief People Officer; a Working in Harmony model on handling inappropriate treatment
• Collective bargaining: respect for freedom of association and collective agreements with unions
• Equal treatment: the Code of Conduct, a biannual equality and non-discrimination plan under the Finnish Equality Act, and equal pay principles
• Training: an annual work community development plan agreed with employee representatives

Locations outside Finland follow local law (page 112). Appendix B points the S1-1 human rights, ILO, trafficking and accident prevention datapoints here (page 69).

Taking action on material impacts on own workforce

Reference: page 115; pages 115-117.

Actions are guided by the One Crew People Plan, the work community development plan, the equality and non-discrimination plan, and the occupational health and safety and health care action plans (page 115).

Health, safety and working conditions (pages 115-116):

• Occupational health care tailored to shift work, including statutory health checks for night work and fatigue and sleep training for flying crew
• Mental Health and Wellbeing month in October and a 24/7 Crew Café at Helsinki Airport
• 2025 safety priorities: preventing workplace and commuting accidents, safety walks, risk assessments and more safety observations per hours worked

Collective bargaining (page 116): negotiations with pilots and ground service staff involved industrial action that caused disruption. Agreements were reached in mid-June and mid-July. The industrial action had "a direct negative impact of around 68 MEUR on the comparable operating result".

Diversity and inclusion (pages 116-117): DEI eLearning offered to all employees, a pilot DEI employee group, and Helsinki Pride partnership. Preparation for the EU Pay Transparency Directive continued (page 117). Training and skills development actions, including the My Journey process and AI training, are on page 118.

Targets related to own workforce

Reference: page 118.

Two targets are named for the own workforce (page 118):

• Engagement Score: target of 7.5 by the end of 2029. The score is the average rating of three statements in the Finnair Voice survey (likelihood of recommending Finnair as a workplace, staying if offered a similar role elsewhere, and overall satisfaction). It was 7.0 at year-end 2025 (H2/2024: 6.7).
• Lost Time Incident Frequency (LTIF): target of 4.0 for 2029. LTIF was 5.2 in 2025 (5.4 in 2024).

Progress on both is monitored by top management and the business units, and the target levels are reviewed annually (page 118). Effectiveness of actions is otherwise tracked through the Finnair Voice results, which the report says showed improved health and wellbeing indicators in H2/2025 against H2/2024 (page 118). The engagement score also feeds the long-term incentive plan (page 46). More health and safety figures are under S1-14.

Characteristics of the undertaking's employees

Reference: page 119.

Finnair had 5,684 own employees at 31 December 2025 (5,535 in 2024), counted by headcount (page 119).

Permanent employees numbered 5,540 and temporary employees 144 in 2025 (male 2,508 and 53; female 3,032 and 91). Finnair reports no employees with non-guaranteed hours. 459 employees left in 2025, a turnover rate of 8.2% (391 and 7.6% in 2024); the count includes retirements, voluntary departures and expired fixed-term contracts (page 119).

Non-employees such as consultants, leave substitutes and leased cabin crew are excluded here and fall under S1-7 (page 119). Finland is the only country with significant employment as the ESRS defines it (page 119).

Collective bargaining coverage and social dialogue

Reference: page 120.

90.96% of Finnair's own employees were covered by collective bargaining agreements in 2025 (89.67% in 2024), measured on total headcount (page 120). In Finland, where Finnair has significant employment, coverage was 97.96% (97.56%); the only employees outside agreements are executives and Aurinkomatkat travel guides. Where agreements do not apply, Finnair complies with applicable labor law in each country of employment (page 120).

Finnair reports no significant employment in non-EEA countries or in EEA countries other than Finland, where significant employment is defined as at least 50 employees representing at least 10% of the workforce. In Finland, 97.96% of employees are covered by workers' representatives, because everyone under a collective agreement also has a representative (page 120).

Diversity metrics

Reference: page 120.

Top management (Executive Board members and Senior Vice Presidents, Vice Presidents, Directors and Heads of teams): 106 men (63.5%) and 61 women (36.5%) in 2025, against 95 (62.5%) and 57 (37.5%) in 2024 (page 120).

Employees by age (page 120):

Women are about 55% of all employees (3,123 of 5,684, page 119) but 36.5% of top management. The report links the pay gap to the workforce mix, noting that 97% of Finnair pilots are male (page 123).

Adequate wages

Reference: page 121.

Finnair states that "All Finnair employees are paid an adequate wage". It reviews office employees' wages against salary and compensation benchmark data from global organizational consultancies. For other employee groups, wages are set through collective bargaining agreements, which Finnair reviews regularly (page 121).

In preparation for the EU Pay Transparency Directive, Finnair is examining existing pay structures, setting up transparent reporting systems and encouraging open discussion about remuneration (page 121). The section gives no figures.

Training and skills development metrics

Reference: page 121.

Average training hours per employee (page 121):

The hours include classroom training, online training and examinations. The report says the gap between men and women is partly explained by the mandatory training pilots receive, and 97% of Finnair pilots are male (page 121).

Finnair opted to omit the datapoints on performance and career development reviews under this requirement, citing ESRS 1 Appendix C and Delegated Act (EU) 2025/1416 (page 121). Qualitative content on training and development, including the My Journey process and the Learning@Finnair platform, is under S1-2 and S1-4 (pages 114 and 118).

Health and safety metrics

Reference: page 122.

Finnair's own workforce health and safety figures (page 122):

LTIF counts accidents leading to at least one day of absence. The 333 recordable accidents include all reported accidents, whether or not they caused absence; the report says the number is partly explained by active reporting, including minor accidents (page 122). All own employees fall under the Occupational Safety Management System, modeled on Finnish regulation (page 122). No cases of recordable ill health were found for current or former employees. Fatalities among other workers on Finnair sites were also 0 (page 122). Appendix B points datapoints to this page (page 69).

Work-life balance metrics

Reference: page 122.

All own employees are entitled to take family-related leave, covering maternal, paternal, parental and carer's leave (page 122).

In Finland, Finnair follows Finnish law for family-related leave and abroad it follows local law. The calculation uses total headcount and includes all types of family-related leave (page 122). Finnair separately describes work-life balance measures such as influence over working hours and remote work, in S1-1 (page 112), and a scheduling system under development in response to survey feedback (page 116).

Compensation metrics (pay gap and total compensation)

Reference: page 123.

The unadjusted gender pay gap was -48.6% in 2025 (-47.0% in 2024), defined as the difference between average female and male pay as a percentage of average male pay. The annual total remuneration ratio of the highest-paid individual, the CEO, to the median employee was 19.1 (18.8 in 2024) (page 123).

Finnair explains the gap by workforce composition and says it is not caused by unequal pay for comparable positions. Men hold most high-paying roles: 97% of Finnair pilots are male and pilots are among the highest-earning groups, and more men hold top management positions (page 123). The gap is based on average monthly pay using the methodology in ESRS S1 AR 98, and the pay ratio uses AR 101 (page 123). Appendix B points both datapoints to this page (page 69).

Incidents, complaints and severe human rights impacts

Reference: page 123.

Figures for 2025 (2024 in brackets), page 123:

• Incidents of discrimination, including harassment: 2 (1)
• Complaints filed through channels for own workforce to raise concerns: 14 (32); the report says 2 concerned employee data privacy, 7 concerned collective labor agreement matters and 5 other topics
• Complaints filed to OECD National Contact Points: 0 (0)
• Fines, penalties and compensation for discrimination incidents and complaints: EUR 0 (EUR 0)
• Severe human rights issues and incidents connected to own workforce: 0 (0); the report states none were reported in 2025
• Cases of non-respect of the UN Guiding Principles and OECD Guidelines: 0 (0)
• Fines for severe human rights incidents: EUR 0 (EUR 0)

The discrimination figure counts all harassment or discrimination cases raised through the established reporting channels, or that led to a written warning or termination of employment. The data covers incidents and complaints brought to Finnair's attention through the reporting channels; the process is described under G1-1 (page 123).

Policies related to value chain workers

Reference: page 125; pages 124-126.

Value chain workers include outsourced cabin crew and service workers at Helsinki-Vantaa and network airports (maintenance, cleaning, catering, ground handling), Aurinkomatkat hotel, transport and tour workers, and, most exposed, upstream workers in high-risk regions such as Asia and the Middle East and in raw material extraction, food production and low-skilled labor (page 124).

Guided by its Code of Conduct, Finnair commits to respect internationally recognized human rights, including freedom of association and collective bargaining, and opposes child and forced labor. Its Policy Commitment to Human Rights, published in January 2025, also covers value chain workers (page 125). Finnair states it does not accept, use or benefit from modern slavery, forced or bonded labor or human trafficking and does not work with suppliers or subcontractors that do (page 125).

The Supplier Code of Conduct covers all supplier types and sets expectations on legal compliance, responsible business practices and respect for human and labor rights; suppliers under a purchase contract must follow it or give a written commitment to an equivalent code (page 126). The SpeakUp channel takes human rights concerns with confidentiality and non-retaliation (page 125). Appendix B points the S2-1 datapoints here (page 70).

Taking action on material impacts on value chain workers

Reference: page 127; pages 126-127.

Actions in 2025 (pages 126-127):

• Supplier risk process: Finnair built a process for supplier sustainability risk management and adopted an AI-enabled tool to support it. All procurement managers, relevant vendor managers and Aurinkomatkat personnel who use it (100% of current users) were trained to identify social and environmental risks, run risk analyses and engage suppliers, in 13 training events.
• Audits: an on-site sustainability audit of a Tier-2 fabric supplier focused on labor and human rights, with no negative findings. After a 2024 audit of a main outsourcing partner, a joint human rights working group with the supplier met twice in 2025 to follow a continuous improvement plan.
• Human rights due diligence: development continued, with the outcome to be an updated list of salient human rights risks, key controls and action plans.
• Industry work: participation in an IATA pilot of a sustainable procurement standard, with a structured procurement framework expected in 2026.
• Aurinkomatkat training: the Sustainable Tourism eLearning reached 144 people at year-end 2025 (110 destination management company representatives and 34 hotel representatives).

No cases of severe human rights issues or incidents involving value chain workers were reported (page 127).

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

Reference: page 127.

Finnair states that it "has not set public targets related to value chain workers" for 2025 but "nevertheless tracks key performance indicators related to the topic" (page 127).

The indicators it names (page 127):

• Supplier Code of Conduct coverage of the supply chain: 90% of total spend at year-end 2025
• Completion of the Sustainable Tourism eLearning by Aurinkomatkat partners: one representative from each of 17 destination management companies (110 representatives) and 34 hotel partner representatives, 144 trained individuals in total

Related material is in the supplier relationship content, where strategic and key suppliers, accounting for 40% of Finnair's spending, get enhanced oversight (page 143). The report names no target level for these indicators.

Policies related to affected communities

Reference: page 130.

Finnair's policies for affected communities start with the Code of Conduct, which commits it to respect internationally recognized human rights and expects business partners to do the same, and the Policy Commitment to Human Rights published in January 2025, which also covers affected communities (page 130).

The Environmental and Energy Efficiency Policy, owned by the CEO and reviewed annually by the Executive Board, sets the principles of the Environmental Management System (EMS) and its roles and responsibilities. Aircraft noise is a module of the EMS, with a dedicated Environmental Management Plan (EMP) for applying noise management measures in daily operations and meeting regulations (page 130).

Aurinkomatkat provides training and materials on sustainable tourism to its destination management company and hotel partners (page 130). Appendix B points the S3-1 human rights datapoint here (page 71).

Taking action on material impacts on affected communities

Reference: page 131; pages 131-132.

Positive impacts: air travel is core to Finnair's value creation. It runs year-round regional flights in Finland, carries cargo, supports repatriation and supply security in crises, and promotes Finland as a destination through a long-term partnership with Visit Finland (page 131).

Noise (page 132): Finnair applies continuous descent approaches (CDA) with a target of at least 85% of landings at Helsinki-Vantaa, trains pilots in noise-reducing practice, and modified its narrow-body fleet to remove the whistling sound at the Fuel Over Pressure Protector cavities, cutting A320 landing noise by about 1 dB at a certain point in the landing. A noise Environmental Management Plan working group reviews risks and key performance indicators and reports to the Sustainability Leadership Team.

Overtourism (page 131): Aurinkomatkat monitors destinations, introduced a risk assessment tool in 2025 for environmental, human rights and governance risks, arranged two beach cleanups in Greece with All for Blue, and took part in two in Turkey organized by a destination management partner.

Finnair has not quantified current or future operating and capital expenditure for these actions. It does not systematically track their effectiveness, "apart from aircraft noise management" where measured noise levels at Helsinki-Vantaa allow it (page 131).

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

Reference: page 132.

Finnair says it "has not set targets related to affected communities" for 2025 but "nevertheless tracks key performance indicators related to the topic of aircraft noise management" (page 132).

The Environmental Management Plan for aircraft noise sets a key performance indicator of keeping continuous descent approaches at 85% of landings at Helsinki-Vantaa. In 2025 the level was 86.4% (84.2% in 2024). Finavia, as airport operator, measures aircraft noise levels at the airport, and the levels are reviewed regularly with Finnair (page 132).

The only indicator the section describes is the noise one; none is described for overtourism or for the positive contributions to regional development and local economic activity (pages 129, 131-132).

Policies related to consumers and end-users

Reference: page 135; pages 135-136.

Finnair's Code of Conduct commits it to respect internationally recognized human rights in all operations, and its Policy Commitment to Human Rights published in January 2025 also covers consumers and end-users (page 135). Specific policies by topic:

• Accessibility and non-discrimination: a Policy on Accessibility of Products and Services, approved by the Executive Board, covering assistance, design and employee training (page 135)
• Sustainability communication and SAF marketing: the Code of Conduct and internal principles updated for consumer law; Finnair Communications, led by the Senior Vice President of Communications, is most senior (page 135)
• Punctuality: customer courtesy under the Code of Conduct and the EU Passenger Rights Regulation (EC 261/2004) (page 136)
• Health and safety: the Safety Management System and Security Management System, with the Chief Operating Officer as Accountable Manager, and IATA Operational Safety Audit compliance (page 136)
• Privacy: the Data Privacy Policy, Data Governance Policy and Information Security Policy (page 136)
• Human trafficking: signatory to the IATA resolution against trafficking, and a Modern Slavery and Human Trafficking Statement that sets out the approach (page 136)

Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions

Reference: page 138; pages 138-139.

Actions in 2025 (pages 138-139):

• Accessibility: continued the Hidden Disabilities Sunflower scheme at Helsinki-Vantaa and expanded a mobile interpreting service for Finnish sign language to all Finnair touch points at Finnish airports
• Sustainability communication: updated internal principles for decarbonization communication and SAF marketing, expanded website content on flight emissions and non-CO2 impacts, and launched the Finnair for Business SAF service in September, where corporate customers track emissions, co-fund SAF and receive third-party verified SAF certificates
• Punctuality: flight regularity reached 96.8% after industrial action in 2025 had disrupted customers' journeys; Finnair added a hotel booking tool, extended digital meal vouchers to more airports (over 80% of customers) and launched the first phase of a claim-automation tool
• Privacy: preventive and detective security measures, a continuous development program and threat monitoring
• Health and safety: continuous monitoring of safety and security performance and training for all personnel
• Human trafficking: mandatory training for flying crew, a compulsory online course for ground handling managers and supervisors and for check-in, gate and arrival agents at Helsinki-Vantaa

Finnair has not quantified current or future operating and capital expenditure for these actions (page 138).

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

Reference: page 140.

Finnair states that it "has not set public targets related to consumers and end-users" for 2025 but "nevertheless tracks key performance indicators related to the topic" because customer-centricity is a key strategic objective (page 140).

How effectiveness is tracked (page 140):

• Customer satisfaction: the net promoter score (NPS) is monitored continuously
• Accessibility: the accessibility working group follows the aNPS, and the volume of reports from customers and authorities about discrimination is monitored
• Sustainability communication: Finnair monitors consumer legislation, especially emerging green claims rules, and is open to stakeholder feedback
• Privacy: the number of reported or suspected data breaches is monitored
• Safety and security: internal objectives with associated targets are monitored quarterly by the Finnair Safety Review Board, chaired by the Accountable Manager
• Human trafficking: Finnair says it cannot monitor effectiveness because it is not told whether reported suspected cases were actual cases, but it tracks the number and type of suspected cases reported by employees and updates training accordingly

Business conduct policies and corporate culture

Reference: page 141; pages 141-143.

Internal control and risk management are integral to management's duty to ensure Finnair meets its strategic objectives, and business conduct requirements are integrated into the management system through policies, rules, procedures, key controls and ongoing compliance monitoring (page 141). The two top-level policies, the Code of Conduct and the Internal Control and Risk Management Policy, are confirmed annually by the Board, and both stress a corporate culture of transparency, honesty, integrity and ethical behavior (page 141).

More detailed policies cover anti-bribery and corruption, fair competition, conflicts of interest, whistleblower protection, occupational health and safety, environmental and energy efficiency, accessibility, trade sanctions, data governance and privacy, information security, procurement and business continuity (page 141). The Code of Conduct follows the UN Universal Declaration of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work (page 141).

Culture: the Code of Conduct eLearning is mandatory recurring training for all employees on a two-year cycle, with completion rates monitored (page 142). Whistleblowing: the SpeakUp channel allows anonymous reports and is run by the Risk & Compliance function, which reports to the Audit Committee; Finnair applies a strict non-retaliation policy (page 143). Appendix B points two G1-1 datapoints here (page 71).

Targets related to business conduct

Reference: page 144; pages 141-145.

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

Finnair sets no numeric business conduct target in the G1 chapter. On political influence it says it "has not defined specific, ESRS-aligned, metrics or targets related to this topic" (page 145).

Effectiveness is tracked in other ways:

• Code of Conduct eLearning completion rates are "regularly monitored", and 100% of functions at risk were covered at year-end 2025 (page 144)
• The Risk & Compliance function continuously monitors compliance with the internal control requirements (page 143)
• A summary of all SpeakUp reports goes to the Audit Committee in anonymized, aggregated form (pages 144-145)
• The Board confirms the top-level conduct policies annually (page 141)
• Payment practice is measured: 98.01% of payments within 60 days (page 145)

Incidents of corruption or bribery

Reference: page 144.

In 2025, 28 reports came in through the SpeakUp channel (30 in 2024), and one report was sent directly to the Risk & Compliance function's email (none in 2024). "No suspected or confirmed incidents of corruption or bribery were brought to Finnair's attention during the reporting period", and there were no convictions or fines for breaching anti-corruption and anti-bribery laws (page 144).

A summary of all reports is given to the Board's Audit Committee in anonymized, aggregated form (pages 144-145). Procedures for preventing, detecting and investigating corruption are under G1-3 (page 144). Appendix B points the G1-4 fines and standards datapoints here (page 71).

Political influence and lobbying activities

Reference: page 145.

Finnair is a network carrier in a highly regulated industry and engages regularly with governments, EU institutions, trade unions and other stakeholders to secure market access and traffic rights. A Public Affairs team of 3 FTEs coordinates its advocacy and reports to the CEO (page 145).

The Code of Conduct bars political donations or other support to political parties, organizations or people in the political system. In 2025 Finnair made no political funding or direct, indirect or in-kind political contributions (page 145). It is registered in the Finnish Transparency Register (identification number 0108023-3) and the EU Transparency Register (419027043263-15) (page 145).

Finnair belongs to industry bodies such as Airlines for Europe (A4E) and IATA and has lobbied for more available and affordable SAF, citing ReFuelEU Aviation, the EU Emissions Trading System and the Energy Transition Taxation Directive, and on revisions to Air Passenger Rights Regulation (EC) No 261/2004 (page 145). The report says it has not defined ESRS-aligned metrics or targets for this topic (page 145).

Payment practices

Reference: page 145.

Finnair's standard payment term is 60 days net under its Group Standard Terms for Procurement; for small and medium-sized suppliers, terms may be agreed case by case (page 145).

In 2025, 98.01% of payments were made within 60 days, and the average time to pay invoices was about 28 days. Finnair had no ongoing legal proceedings due to late payments in 2025 (page 145).

The Procurement Policy commits to fast invoice processing and on-time payments, supported by a purchase-to-pay process with electronic invoicing and continuous performance monitoring, applied to all suppliers including small and medium-sized ones (page 143).