Fiskars Group

Reference: pages 35-36. Listed in the ESRS content index (pages 28-32).

Fiskars Corporation's statutory bodies are the General Meeting, the Board of Directors, the Managing Director (President and CEO) and the Auditor (page 35). The Board has five to ten members; all are non-executive and "All members of the Board of Directors are considered to be independent of the Company (100% independent)". "Currently, there is no representation of employees in the members of the Fiskars Group's administrative, management, and supervisory bodies."

Diversity (page 35): "Currently, both genders account for 50% of members of the Board, and from other perspectives, the current status of diversity is considered reasonably balanced." Diversity is handled by the Nomination Committee across gender, age, nationality, cultural background and experience.

Sustainability governance (page 36): the ESG strategy is approved by the Board. "The Company's Board of Directors and Audit Committee possess expertise in ESG matters through both experience and education." The EVP, Group Operations and Sustainability leads the ESG Strategy team and "has the overall responsibility for driving the sustainability agenda in the FGLT"; the CFO "holds ultimate accountability for the integrity and reliability of the reporting process". The chain runs Board and Audit Committee, FGLT, ESG Steering Team, Group ESG Strategy Team, and Fiskars and Vita QEHS.

Change on FY2024: the ESG Strategy team lead moved from the CFO to the EVP, Group Operations and Sustainability.

Reference: pages 36, 39. Listed in the ESRS content index (pages 28-32).

"The Board of Directors (Board) and Audit Committee approve and review the ESG and sustainability ambition level, commitments, and targets annually. The Board also follows up on progress toward Fiskars Group's commitments and targets on a quarterly basis" (page 36). The Audit Committee "has an advisory role regarding ESG strategy and management... and proposes items to the Board for approval", and "receives regular updates, led by the CFO, from internal and external parties regarding Corporate Sustainability Reporting Directive (CSRD) and other relevant topics". The FGLT reviews progress "as part of the regular monthly agenda" and "owns the targets".

What reaches them (page 39): "The Fiskars Group Leadership Team (FGLT), the Audit Committee, and the Board of Directors are regularly informed about key ESG-related KPIs, which represent part of the IROs derived from the DMA process, and the progress made toward set targets. ESG-related KPIs are also reviewed in relation to the Company's other strategic objectives. This monitoring occurs on a quarterly basis."

Named escalations elsewhere: governance action plans for the top ten ERM risks go to the Audit Committee, and climate risks are "consolidated and reviewed annually by the Fiskars Group Leadership Team and the Board's Audit Committee" (page 66); all misconduct cases are submitted quarterly to the Ethics Advisory Group and Audit Committee (page 118).

Reference: page 37. Listed in the ESRS content index (pages 28-32).

Compensation for most employees "consists of three elements: base salary; bonus; and benefits" (page 37).

The one quantified link is circularity, not climate. "In 2023, a measure related to the circular economy was added to the Fiskars Group Performance Share Plans... The circularity advancement KPI is the ability to reach the target set in the Company's ESG metrics. The percentage of the circularity target has been 10% of the potential total reward in the performance plans starting in 2023-2025" (page 37). Each plan runs a three-year performance period; the Board decides commencement, performance criteria, targets, participants and reward range.

Beyond that: "Employees working specifically with sustainability and environmental topics have various sustainability-linked incentives. In addition, Business Areas and other parts of the organization have targets and incentives linked to sustainability... tailored to the job descriptions and the specific areas where different parts of the organization can best contribute."

Gaps a reader should note. No percentage of total remuneration is linked to climate, and no GHG metric appears in any incentive scheme. E1 cites the same circularity KPI as evidence of embedding: "Advancing circular products and services is included as a KPI in Fiskars Group's share-based long-term incentive plan for key employees" (page 64).

Reference: pages 38-39. Listed in the ESRS content index (pages 28-32).

Page 38 carries the full table, "Mapping of the information provided in Fiskars Group's sustainability reporting regarding the due diligence process", splitting each of the five core elements across General Governance, Environmental and Social references: (a) embedding due diligence, mapped to ESRS 2 Governance and Business model and strategy, G1 policies and corporate culture, E1 Climate resilience in strategy and Scenario analysis, E5 Framework for enhancing circularity, and the S1, S2 and S4 introductions; (b) engaging with affected stakeholders, mapped to SBM-2, G1 Remediation and whistleblowing and supplier management, and the S1/S2/S4 engagement sections; (c) identifying and assessing adverse impacts, mapped to IRO-1 and the topical Actions sections; (d) taking actions and (e) tracking effectiveness, mapped to the Actions and Targets sections plus the EU Taxonomy disclosures.

Human rights due diligence in 2025 (page 39): "due to the changing regulatory landscape, expansion into new product categories, and developing business models, the Company initiated a human rights due diligence assessment", in four phases - a current-state assessment of due diligence and policies in Q2-Q3, "a human rights impact assessment... with a focus on the Company's own operations, as well as sourcing operations", formulation of a human rights policy in Q4, and implementation "across the organization... during 2026".

Reference: page 39. Listed in the ESRS content index (pages 28-32).

"The objective of risk management is to identify, assess, manage, and monitor risks that may compromise the achievement of the Company's business goals and commitments" (page 39). "Internal controls for sustainability reporting vary, depending on the specific reporting area, as multiple internal functions contribute to the preparation of the report. At the consolidated level, control measures and assurance processes are in place to ensure accurate and comprehensive (quarterly) ESG reporting and the comprehensive Sustainability Statement."

Audit Committee tasks are set out explicitly (page 39): presenting to the Board "the results of sustainability reporting assurance, how sustainability reporting assurance has increased the integrity of reporting, and the committee's role during the sustainability reporting assurance process"; and monitoring "the procedures for sustainability reporting, procedures for identifying information to be reported... the effectiveness of internal control and audit, as well as risk management... the performance of sustainability reporting assurance, and the independence of the sustainability reporting assurance provider."

The Board "has approved the principles of internal control, risk management, and internal auditing to be followed within the Company" (page 36).

Limitation: no control-failure findings, risk-assessment results or remediation actions for the reporting process itself are quantified.

Reference: pages 39-43. Listed in the ESRS content index (pages 28-32).

Fiskars Group is "the global home of design-driven brands for indoor and outdoor living", present in "more than 100 countries", with 13 own manufacturing units in Europe, Asia and the U.S. and "approximately 6,600 employees based in 29 countries" (pages 39-40). Net sales EUR 1,140.2 million, comparable EBIT EUR 76.4 million, R&D EUR 22.9 million, employee wages and benefits EUR 288 million (page 41).

Two Business Areas (page 40): BA Vita (Georg Jensen, Royal Copenhagen, Wedgwood, Moomin Arabia, Iittala, Waterford) at ~54% of net sales, supply base ~60% own manufacturing; BA Fiskars (Fiskars, Gerber) at ~46%, ~60% finished goods suppliers, with wholesale >90% of its sales. All ~500 own stores are Vita brand stores.

Value chain (page 41): upstream, approximately 140 finished goods suppliers, fuels 128,702 MWh and purchased energy 70,761 MWh; own operations, 13 manufacturing units and 14,000 hectares of managed forest; downstream, ~500 stores and ~60 e-commerce sites, direct-to-consumer 30% of net sales. Outputs shown alongside: Scope 1 and 2 33,362 tCO2eq, Scope 3 138,886 tCO2eq, 553 t to landfill, 7,110 t recycled, 92 supplier audits, 27% of net sales from circular products and services.

Structural change (page 42): since February 2025 the Business Areas "have operated independently with their own CEOs"; legal separation "is expected to be finalized by the end of the first quarter of 2026", with a new strategy due at a Capital Markets Day on May 12, 2026.

Reference: pages 45-46. Listed in the ESRS content index (pages 28-32).

Stakeholders are "entities or individuals that have an impact on the business or are affected by the Company's activities, products, and services, presenting both risks and opportunities" (page 45).

Eight groups with named channels (page 46): consumers (consumer service and care, surveys, social media); customers (dedicated account teams, and interviews "with its customers on their sustainability expectations during its materiality assessment"); employees and potential employees (surveys, town halls, training); suppliers and subcontractors ("site visits, annual supplier days, questionnaires, training (regarding setting science-based targets, for example) and the Company's Supplier Audit Program"); shareholders and investors; NGOs; media; and research institutes and universities. Page 46 also tabulates seven stated stakeholder expectations against the Company's response.

How views reach the Board (page 45): "The views, interests, and expectations of affected stakeholders are communicated to internal stakeholders (including administrative bodies) in accordance with the ESG management model and as a part of the strategy process, as well as ERM and DMA processes."

Evidence base: the 2022 impact materiality survey drew 1,136 responses from almost 40 countries in English, Finnish, Swedish, Japanese and Chinese, plus five in-depth interviews with investors, board members, NGOs and corporate customers (page 54). Affected communities are not among the listed stakeholder groups.

Reference: pages 47-52. Listed in the ESRS content index (pages 28-32).

DMA outcome (page 47): "the critical topics for Fiskars Group are E1, E5, S1, and S4, while significant topics include E4, S2, and G1. Topics that received an overall assessment of minimal, informative, or important are not considered material... Topics E2, E3, and S3 scored under the threshold of significant and critical, and are therefore not included in this report."

Change in 2025 (page 48): "In the DMA conducted in 2023, negative impacts on workers in the value chain (S2) did not score above the threshold level. Due to the introduction of new product categories and sourcing countries, Fiskars Group reviewed the impact drivers... The re-evaluation resulted in two new negative impacts evaluated as significant (4), and hence added to the reporting scope" - child labor and forced labor in the value chain.

33 typed IRO rows are tabulated on pages 49-52 by sub-topic, with type, value chain phase, score and time horizon. E5 carries the most (nine); E1 carries five.

Time horizons and financial effects (page 48): "For material impacts, the expected time horizon is medium-term (1-5 years) but also short-term, as they are already taking place. For the material risks and opportunities, no considerable financial effects on the Company's financial position, financial performance, or cash flows have currently been identified."

Climate-specific risk identification and scenario analysis is also presented under E1-2, and climate resilience under E1-3 (2025 ESRS numbering).

Reference: pages 53-57. Listed in the ESRS content index (pages 28-32).

Sequence (page 53). An Impact Materiality Assessment was run in 2022 and a Financial Materiality Assessment in 2023 to complete the DMA. "At the time of conducting the assessment, EFRAG's IG 1 Materiality Assessment Guidance had yet to be published. Fiskars Group applied the ESRS 1 principles in the DMA. During 2025, Fiskars Group reviewed its DMA, which resulted in the addition of negative impacts under S2 Workers in the value chain."

Impact side (pages 53-54): desktop and benchmark study; a global online survey in five languages drawing 1,136 responses from almost 40 countries; five in-depth stakeholder interviews; an internal prioritisation workshop; FGLT approval. "The GRI's approach to determining material topics was taken into account throughout the process."

Financial side (pages 54-55): nine internal key decision-makers from Finance, Business Areas, Supply Chain, Risk and the Audit Committee were interviewed, followed by a financial materiality workshop focused on "risks and opportunities with a material influence on Fiskars Group's cashflows, development, performance, position, costs of capital, or access to finance". Results were validated by the FGLT and presented to the Audit Committee and Board.

Scoring (pages 55-57): 1-5 on both lenses. "severity precedes likelihood, meaning that a topic with a high severity score may become material even with a low likelihood, but a topic with high likelihood and low severity is not deemed material." "all sub-topics reaching a score of 4 or 5 were deemed to be material".

Company-stated limitation (page 55): the process "includes activities, business relationships, and geographies that may contribute to adverse impacts, but there was no specific focus on them."''

Reference: pages 28-32 (ESRS content index), 34-35 (basis of preparation and omissions).

The statement "is prepared in accordance with the European Sustainability Reporting Standards (ESRS) issued by... EFRAG. All datapoints included in this statement have been assessed as material according to the Company's Double Materiality Assessment" (page 34).

A real ESRS content index is printed on pages 28-32, mapping each disclosure requirement to the section carrying it. Its scope note: "Fiskars Group has omitted all the disclosure requirements in topical standards E2, E3, and S3, as these are below the set materiality thresholds" (page 28). Pages 121-125 list the datapoints deriving from other EU legislation, marking every E1-9 datapoint "Voluntary, omitted 2025" and the E2-4, E3-1, E3-4, S3-1 and S3-4 datapoints "Not material".

Omissions (pages 34-35): "Fiskars Group has partially utilized the general list of phased-in disclosure requirements from ESRS 1 Appendix C... Fiskars Group has applied the Quick Fix principles to omit anticipated financial effects for the 2025 financial year." Two items are withheld as sensitive: "the monetary amount of its investment plans for climate transition" and "the list of material suppliers' sites assessed for E4". No Article 19a(3)/29a(3) exemptions are used; no disclosures are incorporated by reference.

Discrepancy a reader should check. Six S1 requirements are absent from the index yet printed in full under their own DR headings with the required datapoints: S1-7 (page 98), S1-8 (99), S1-11 (100), S1-12 (101), S1-13 (101) and S1-15 (102). Each carries the note "Data collection for this disclosure was initiated for the 2025 reporting", suggesting the index was not refreshed when the phase-in reliefs were dropped. They are recorded here as reported on the strength of the labelled disclosures themselves.

Reference: pages 67-68 (the transition plan sits under E1-3 Actions), page 64. Listed in the ESRS content index (pages 28-32).

"Fiskars Group's climate transition plan is compatible with the Paris Agreement's target of limiting global warming to 1.5 °C... as it aligns with SBTi criteria for the 1.5 °C pathway. The transition plan includes a tangible investment plan for Scope 1 and 2 for reaching the Company's science-based emissions reduction targets for 2030 and initial plans for the net-zero target toward 2049. For Scope 3, the investment plan is under development" (page 67).

Levers (page 68): "The main decarbonization levers include industrial energy efficiency, building energy efficiency, industrial electrification, use of renewables, and other levers. Priority manufacturing units are glass and ceramic factories."

Construction and governance (page 67): "all manufacturing units and distribution centers have been involved in compiling the 2030 transition plan... The key risks include the availability of renewable energy and technological development required for emissions reduction." Ownership now sits with each Business Area, but "the approval mandate for changes to the transition plan remains with the FGLT and the Board of Directors. Typically, the plan is reviewed annually." BA Vita's plan "is on track"; BA Fiskars, already ~90% down on Scopes 1 and 2, "is now focusing more on Scope 3".

Locked-in emissions (page 67): "Some sites currently have locked-in or unavoidable emissions until a solution for transition is found or developed."

Amount withheld (page 68): "Fiskars Group does not disclose the total planned investment requirement to achieve the 2030 targets, as it is considered sensitive information." "Fiskars Group has not been excluded from the EU's Paris-aligned Benchmarks" (page 67).

Back-filled from the E1 "Scenario analysis" subsection and ESRS 2 IRO-1, where this content is disclosed in the FY2025 report (pages 64-66). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risk classification (pages 63, 65). The E1 IRO table carries four actual negative impacts and one potential financial risk ("Disruptions due to extreme weather conditions"). Page 65 splits risks into explicit physical and transition tables.

Scenario (pages 64-65). Earlier TCFD work in 2021 was qualitative; "The Company initiated an update to its scenario analysis during 2025, conducting a quantitative scenario analysis of physical climate risks for its own manufacturing units globally." "Fiskars Group applied the global warming scenario SSP5-8.5... The high emission scenario SSP5-8.5 relies heavily on fossil fuels, corresponding to a 4.4 °C warming by the end of 2100."

Methodology (pages 65-66): "The first step of the assessment was exposure screening, identifying climate hazards and events for each site, and determining the sites' sensitivity to each hazard", using insurance risk survey reports and a climate risk assessment tool. The scenario "is consistent with the key climate-related assumptions reflected in the financial statements".

Seven physical hazards with trend direction (page 65): drought, sea level rise (one site, decreasing), heavy precipitation, storm surges/cyclones, heatwave, cold wave (decreasing, "deemed low in materiality"), wildfire. Four transition items: an ETS price risk ("Assessment ongoing whether Iittala factory will be subject to ETS"), a technology risk on natural gas, and two opportunities.

Stated gaps (pages 65-66): "Fiskars Group bases this year's report on one scenario... a long-term scenario analysis has not yet been conducted." No 1.5°C-aligned transition scenario is named, and the value chain is not yet covered.

Back-filled from the E1 "Climate resilience in strategy" subsection and ESRS 2 SBM-3, where this content is disclosed in the FY2025 report (pages 64, 66, 43). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The conclusion is stated plainly (page 66): "Based on the 2025 analysis, Fiskars Group's current operations and business model are considered resilient to the identified physical and transition climate risks in the short and medium terms." The long term is not covered, because "a long-term scenario analysis has not yet been conducted" (page 65).

How resilience is built (page 64): "It combines its own factories and distribution centers with a globally diversified supplier network to enhance resilience and flexibility. Business Areas continuously assess exposure to climate-related risks across key sites - for example, Fiskars Group's own manufacturing unit in Indonesia, which is prone to extreme weather risk drivers such as heavy precipitation, wildfires, and extreme heat."

Seasonality is named as a vulnerability (page 64): "Fiskars Group's business model is inherently seasonal and sensitive to weather variability, particularly in product categories linked to gardening and winter activities... demand for gardening tools peaks in the first half of the year and is highly dependent on spring weather conditions."

Capacity to adjust (pages 43, 64): safety stocks as a buffer, multiple source contracts, a broad portfolio and geography; "Comprehensive insurance coverage mitigates potential losses from property damage and business interruptions, while climate-related risks and opportunities are systematically incorporated into capital expenditure and investment decisions."

Uncertainty is not set out as a distinct section; the nearest statement is that results "display climate risks and opportunities of low and medium materiality" (page 66).

Reference: pages 66-67 ("E1-2 Approach and policies"). Listed in the ESRS content index (pages 28-32).

"Fiskars Group's Environmental Policy establishes common targets and principles across the value chain... It outlines the Company's commitment to reducing emissions, including climate change mitigation efforts, which are centered around energy efficiency initiatives, the use of renewable energy, supplier engagement, and reducing the environmental impact of logistics" (page 66).

Scope and accountability: "All employees working under the Fiskars Group's direction must comply with the Environmental Policy, which is approved by the Fiskars Group Leadership Team." The policy records that the supply chain function, the new product development process "and most of Fiskars Group's factories and distribution centers, are multisite certified in accordance with the ISO 14001 standard". It is published on the Company's website.

Adaptation gap, disclosed by the company (page 66): "While Fiskars Group has established clear policies on energy efficiency and renewable energy, it currently does not have a formal policy on climate change adaptation. However, climate-related physical risks and related adaptation requirements are assessed and addressed through the Company's Enterprise Risk Management processes and site-level Environmental Risk Assessments, and capital planning decisions... Fiskars Group... will evaluate the establishment of a dedicated adaptation policy as appropriate."

Value chain: "The Fiskars Group Supplier Code of Conduct also outlines expectations regarding the Company's suppliers' energy and emissions management, and every supplier must sign and commit to it if they are to do business with Fiskars Group."''

Reference: pages 67-69 ("E1-3 Actions"), page 59. Listed in the ESRS content index (pages 28-32).

Quantified 2025 outcome (page 68): "In 2025, Fiskars Group improved its energy efficiency through a range of energy-saving initiatives, resulting in a reduction of 10,200 MWh in energy consumption. These efforts included measures such as optimizing the utilization rate of equipment and shutting down the redundant industrial machines... Altogether, these actions have cut annual emissions by 2,366 tonnes of CO2e."

Named site actions. At Rogaška, Slovenia, "a new solar power system was installed and aging oil-cooled transformer units replaced with modern air-cooled transformers, totaling investments of approximately EUR 1,075,000" (page 59), producing "meaningful reductions in greenhouse gas emissions due to a shift from natural gas to renewable energy sources" (page 68). Royal Copenhagen's Danish unit "has transitioned to using certified biogas in its kilns"; solar panels are installed at seven named sites (page 71).

Value chain (page 69): a supplier call to action with "direct local support, guidance materials, and emissions calculation tools"; "emission-minimized stainless steel" in All Steel frying pans with "a 92% smaller carbon footprint than the global average"; and logistics efficiency through packaging and delivery frequency.

Carbon removals - a nil return (page 68): "In 2025, Fiskars Group did not participate in the removal of GHG emissions from the atmosphere in its own operations or upstream and downstream value chain."

Resourcing (page 68): investments above EUR 100,000 are tracked for potential Taxonomy alignment, but "Fiskars Group does not disclose the total planned investment requirement to achieve the 2030 targets, as it is considered sensitive information", and "For operational expenditure, there is no direct link between EU Taxonomy indicators and the transition plan."''

Reference: page 70 ("E1-4 Targets"), progress panel page 44. Listed in the ESRS content index (pages 28-32).

Three near-term targets, all SBTi-validated (page 70):

1. "reducing greenhouse gas emissions from its own operations (Scopes 1 and 2) by 60% by 2030 from a 2017 base year"; Scope 2 is market-based and "The target covers 100% of the Company's Scopes 1 and 2 emissions."
2. "reducing greenhouse gas emissions from upstream transportation and distribution (Scope 3) by 30% by 2030 from a 2018 base year... covers 100% of the Scope 3 category 4 emissions."
3. "80% of its suppliers by spend covering purchased goods and services having science-based targets by 2029."

Long term: "reduce climate emissions in its operations and the entire value chain to net-zero by the end of 2049. The net-zero emission target has been submitted for SBTi's validation."

Progress (pages 44, 70): Scopes 1 and 2 -62% (target -60%), upstream transport -18% (target -30%), supplier coverage 72% (target 80%). The supplier target was reset in 2025 because "the previous SBTi validated target of having 60% of suppliers by spend with science-based targets by the end of 2024 was reached".

Ambition is being raised: "Fiskars Group is currently in the process of resetting its targets to increase the level of ambition. The new targets have been approved by the Board of Directors and are now undergoing validation by the SBTi."

Stated limitations (page 70): "Fiskars Group has not published external milestones or interim targets for its main emissions reduction targets"; and "Broader external stakeholder involvement in target-setting has not been part of the process to date." Scope 1 and Scope 2 are tracked as one combined target (page 73).

Reference: pages 71-72 ("E1-5 Energy consumption"). Listed in the ESRS content index (pages 28-32).

Total energy consumption fell to 203,541 MWh (2024: 237,674; 2023: 229,326; 2017: 311,361) (page 71).

Coal is nil in every year. The fossil share fell from 73% to 71%, the renewable share rose from 27% to 29%. "Within the renewable energy consumption, 6%, which amounts to 3,608 MWh, comes from Fiskars Group-owned solar power plants on manufacturing sites."

Energy intensity: 179 MWh per EUR million net revenue (2024: 205; 2017: 262). Twenty-six NACE codes are listed as the high climate impact sectors, and "a negligible amount of revenue is derived from sectors that are excluded from HCIS categorization" (page 72).

"In 2025, 82% of the purchased electricity was from renewable sources", sourced in Finland, Slovenia, Poland, Ireland, the UK and selected US and Danish locations (page 71). Note: page 63 states 81% for the same metric. Data comes from "meter readings and invoices provided by external service partners" (page 72).

Reference: pages 73-75 ("E1-6 Greenhouse gas emissions"). Listed in the ESRS content index (pages 28-32).

"In 2025, Fiskars Group's GHG emissions decreased by 16% compared to the previous year. Compared to the 2017 base year, Fiskars Group has achieved a reduction of 62%" (page 73). 19% of gross Scope 1 falls under regulated emission trading schemes; one factory reports under the EU ETS.

Scope 3 by category, 2025 (page 73): purchased goods and services 96,117; upstream transport and distribution 21,320 (2030 milestone 7,800, -6% a year); fuel and energy-related 5,283; employee commuting 6,020; use of sold products 4,899; leased assets 3,857; business travel 1,337; waste 52.

Method caveats (pages 73, 75): "30% of the disclosed Scope 3 emissions has been calculated using primary data sources"; categories 10 and 14 "are not relevant" and categories 2, 9, 12, 13 and 15 "have minor impacts and not included"; for categories 1, 4 and 8 "the reporting period is October 2023 to September 2024, due to reporting time constraints".

Intensity (page 74): 164 tCO2eq/EUR million location-based (2024: 169), 151 market-based (2024: 155). Biogenic emissions 266 tCO2eq, outside the table. By Business Area, Vita is the larger emitter on both Scope 1 and market-based Scope 2.

Reference: pages 68, 74. Listed in the ESRS content index (page 29) with the note "(Section is mainly omitted due to Fiskars Group not utilising carbon removals or credits)".

This is a nil return, stated twice. "In 2025, Fiskars Group did not participate in the removal of GHG emissions from the atmosphere in its own operations or upstream and downstream value chain" (page 68). And under the emissions tables: "Fiskars Group did not engage in any carbon removal or neutralization activities during the reporting year" (page 74).

The targets are correspondingly gross: the three near-term targets and the 2049 net-zero target are absolute reductions with no removals or credits component (page 70).

Removals are part of the stated long-term toolbox (page 68): "The final toolbox for achieving the net-zero target and carbon-neutral production includes beyond-value chain mitigation actions such as carbon removals and neutralization of residual process emissions." No volume, price, quality standard, supplier or start date is given.

Related but distinct. The Group's 14,000 hectares of FSC- and PEFC-certified Finnish forest carry "a total combined carbon stock of trees, other biomass, and soils [of] 5.7 million tonnes of CO2 equivalent" and "a current annual carbon sink... [of] 18,000 tonnes of CO2 equivalent" (pages 59-60). These are disclosed under the EU Taxonomy and E4, and are not claimed as removals against the climate targets.

Reference: pages 76-77. Listed in the ESRS content index (pages 28-32). The index maps E4-1 to "ESRS 2: Business model and strategy" and "ESRS E4: Introduction to the topic".

"Operating across numerous and diverse regions, Fiskars Group has a significant role in addressing the global nature crisis... Recognizing and mitigating nature-related impacts is essential not only to preserve natural habitats but also to secure long-term business resilience, safeguard supply chain stability, and meet the growing expectations of stakeholders and regulatory bodies" (page 76).

Two material IROs, both actual negative impacts scored significant (4) across upstream, own operations and downstream: "Biodiversity impacts across the value chain" and "Reliance on ecosystem services" (page 76).

The company is explicit that this is early-stage work (page 76): "The Double Materiality Assessment (DMA) conducted in 2024 confirmed that Fiskars Group has both significant biodiversity impacts and dependencies on ecosystem services. While mitigating actions are in place, the Company recognizes the need for a deeper understanding of them across its operations and value chain."

"The year 2024 marked the first Company-wide biodiversity assessment... In 2025, biodiversity considerations were integrated more thoroughly into the Company's environmental risk assessments of owned sites" (page 77).

No transition plan in the ESRS sense is claimed. "Fiskars Group has not established quantified biodiversity targets, applied the mitigation hierarchy, or used biodiversity offsets", and "A full resilience analysis has yet to be conducted, but the initial assessments provide the foundation for such work" (page 77).

Reference: page 77 ("E4-2 Approach and policies"). Listed in the ESRS content index (pages 28-32).

"The Fiskars Group Environmental Policy outlines the principles to mitigate the environmental impact of all Fiskars Group operations, including in the area of biodiversity. The policy states the commitment to take action to conserve biodiversity by sustainably managing the Company-owned forests and by collaborating in projects with local communities and NGOs where action is assessed as required" (page 77).

The company then states the gap against ESRS E4 in unusually direct terms (page 77): "At this stage, the Environmental Policy does not explicitly address the specific matters covered by the ESRS E4 policy-related disclosure requirements, including biodiversity-related dependencies and risks, traceability, ecosystem-specific sourcing practices, social aspects of biodiversity impacts, or site-specific provisions for protected or sensitive areas. Neither does it currently provide explicit coverage of the matters listed under ESRS E4 AR4, such as land-use change, direct exploitation, or invasive species. These areas may be further considered as the policy framework develops."

Adjacent coverage that does exist (page 83): "Fiskars Group aims only to use wood from certified sustainable forests and certified organic cotton in cotton-based products. Fiskars Group does not use restricted or endangered wood species. Regarding metals, Fiskars Group only uses responsible suppliers which comply with the appropriate standards and conflict mineral regulations." The Supplier Code of Conduct binds all raw material, component and packaging suppliers.

The Appendix of EU-derived datapoints maps E4-2 paragraphs 24(b), 24(c) and 24(d) to "E4 Biodiversity and ecosystems, Approach and policies" (page 123).

Reference: pages 77-80 ("E4-3 Actions"). Listed in the ESRS content index (pages 28-32).

"Actions related to biodiversity and ecosystems have focused mainly on resource use and the circular economy, the surroundings of operational sites, and local initiatives such as forest management in Finland... These actions are resourced through existing Environmental Management Systems and site-level processes, with no dedicated budgets or personnel allocated specifically to biodiversity" (page 77).

The 2025 assessment (pages 77-78). "In 2025, the biodiversity assessment first carried out in 2024 was updated. It covers all fully owned factories and distribution centers worldwide, along with key suppliers representing more than 70% of finished goods expenditure in 2024. The scope also includes Fiskars Village in Finland. The assessment applies to the WWF Biodiversity Risk Filter, the World Database for Key Biodiversity Areas, and the Natura 2000 platform." Nineteen own material sites are named by country (page 78). "Supplier lists are not disclosed, as they are considered sensitive information, but the Company's relevant own sites are named."

Three phases: annual desk research by exact geolocation; site-manager surveys "on proximity to biodiversity-sensitive areas, habitat loss and degradation, resource and ecosystem dependencies, and species and pollution impacts"; and analysis to prioritise next steps.

Named local actions (page 79): "Fiskars Group's Gerber factory in Oregon has supported restoration of native plants along two protected streams to reduce erosion. The Georg Jensen factory in Chiang Mai, Thailand, co-built a check dam with the local community to reduce erosion, store rainwater, and limit wildfire severity."

Stated boundaries (pages 77-78): "Downstream impacts have not been included." "No consultations with stakeholders in nearby affected communities have been conducted... Nor has local or indigenous knowledge been included."''

Reference: page 80 ("E4-4 Targets"). Listed in the ESRS content index (pages 28-32).

The disclosure is a stated absence of targets. "The Company has not established quantified targets for biodiversity or biodiversity loss; current actions are guided by the Environmental Policy and site-level Management Systems. Actions and targets related to resource use and the circular economy are presented in section E5 Resource Use and Circular Economy" (page 80). The same position appears under Actions: "Fiskars Group has not established quantified biodiversity targets, applied the mitigation hierarchy, or used biodiversity offsets" (page 77).

What is tracked instead (pages 78-79). "Fiskars Group does not currently monitor biodiversity-specific performance indicators beyond ISO 14001 certification rates, the management of 14,000 hectares of sustainably certified forest, and the associated annual carbon sink of approximately 18,000 tonnes of CO2 equivalent." Ninety percent of own manufacturing sites are ISO 14001-certified and "ISO 14001-certified locations are regularly audited by internal or external auditors".

Effectiveness is judged qualitatively through the annually updated Biodiversity Risk Filter assessment and site-level environmental reviews, with the company noting that "further work is required to improve understanding of location-specific risks and site-level ecosystem dependencies, as interdependencies across Company operations and suppliers remain only partly understood" (page 78).

The E5 circularity and zero-waste-to-landfill targets are the nearest quantified proxies, and the company cross-refers to them explicitly.

Reference: pages 78-80. Listed in the ESRS content index (pages 28-32). The index maps E4-5 to "ESRS E4: Actions".

Sites in or near protected areas (page 78): "Thirteen assessed sites are located within two kilometers of a protected or conserved area, and four are located directly inside such areas. These include Fiskars Group's Royal Copenhagen manufacturing unit in Thailand and three supplier sites. The areas of concern are the Lower Central Basin in Thailand (approx. 1,420,000 ha) and the Qingdao-Rizhao coastal wetlands and islands in China (approx. 8,760 ha). There is no indication of significant harm to these areas caused by the activities of the assessed sites."

Pressures (page 79): "For Fiskars Group, tree cover loss and pollution are identified as critical, placing sites in high to very high-risk areas. Tree cover loss is considered very high in Southern Finland, where Fiskars Group owns and manages forests." "91% of assessed sites... are in areas at risk of pollution."

Dependencies (page 80): the five most relevant CICES V5.1 ecosystem services are water regulation and purification, raw material supply, climate regulation, waste decomposition and detoxification, and soil fertility and nutrient cycling. "No dependencies on ecosystem services causing significant harm to local biodiversity and ecosystems were identified for Fiskars Group's own sites or those of its suppliers."

Negative impacts (page 80): "The assessment identifies no significant negative impacts in relation to biodiversity-sensitive areas near Fiskars Group's sites, including impacts on threatened species, land degradation, desertification, or soil sealing."

Standing limitation: no biodiversity-specific performance indicators are monitored beyond ISO 14001 certification rates, forest hectares and the forest carbon sink (pages 78-79).

Reference: pages 82-83 ("E5-1 Approach and policies"). Listed in the ESRS content index (pages 28-32).

Three policies plus a guideline (page 82): "Fiskars Group's main policies to manage material impacts, risks and opportunities related to resource use and the circular economy are comprised of the Fiskars Group Environmental Policy, the Fiskars Group Supplier Code of Conduct, and the Fiskars Group Quality Policy. The environmental and quality policies are approved by the Fiskars Group Leadership Team, while the Supplier Code of Conduct is approved by the Board of Directors." A Guideline for Recycled Plastics "defines the specific requirements for recycled plastics" (page 83).

Two stated limbs (page 82): "1. Design for circularity and longevity... The Company is constantly expanding its use of recycled, renewable, recirculated, and recyclable materials... Fiskars Group designs products to be repairable and offers spare parts whenever feasible. 2. Resource efficiency and waste management... adapting new technologies to reduce scrap in production processes, internal circulation of materials, and diverting waste from landfill."

Waste hierarchy (page 83): "The policy highlights the Company's aim to have no waste from its operations... going to landfill. Fiskars Group prioritizes waste reduction activities and management in accordance with the European waste hierarchy." On materials: "The Company aims to replace virgin fossil-based raw materials in products with recycled or other more circular alternatives whenever possible."

Effectiveness measure (page 83): the strategic shift "is reflected in Fiskars Group's Circularity KPI, which has improved from 26% in 2024 to 27% in 2025, representing a relative increase of 4%."''

Reference: pages 83-85 ("E5-2 Actions"). Listed in the ESRS content index (pages 28-32).

The circularity framework (pages 83-84). "Fiskars Group has a cross-functional Circular Economy Task Force, which brings together sustainability professionals, business and offerings, product design, sourcing, and the Company's own manufacturing. The task force was initiated in 2023" and "has created Fiskars Group's circularity framework and criteria." Three options define a circular product: recycled and/or renewable materials; a design that "enables repairing"; or full recyclability, which "requires that the product also fulfills other circularity principles". Circular services count too: "spare parts, the Vintage service, and repair services such as the Fiskars Pan-Care service and Georg Jensen jewelry and watch repairs."

Alternative materials (page 84): "During 2025, Fiskars Group was audited for the Global Recycled Standard (GRS) and Recycled Claim Standard (RCS) certifications... to enhance the tracking and tracing of recycled input materials." The constraint is stated honestly: "New material compositions may not always be sufficiently strong to meet Fiskars Group's standards in terms of functionality and durability, and are therefore not chosen."

Minimizing waste (page 84): "Fiskars Group's manufacturing unit PT Doulton in Indonesia has pioneered feeding fired ceramic waste back into its manufacturing process since 2021... the manufacturing unit has been able to eliminate its landfill waste... In 2025, new brands such as Moomin Arabia have started utilizing this type of recirculated ceramic."

Value chain gap acknowledged (page 84): "The Company plans to initiate the gathering of more information about this matter from its partners in the coming years." Resourcing is described but not budgeted: "Securing the required raw materials, infrastructure, and changing ways of working requires human and monetary capital."''

Reference: page 85 ("E5-3 Targets"), progress panel page 44. Listed in the ESRS content index (pages 28-32).

1. Circular net sales. "A majority of our net sales comes from circular products and services by 2030", shown against a 2021 base year and a 50% target in 2030. "Fiskars Group's performance in circular products and services net sales has improved from 26% in 2024 to 27% in 2025." The measurement basis is defined by the circularity framework, and "The target directly supports the top three layers of the EU Waste Hierarchy - prevention, preparing for reuse, and recycling." It "has voluntarily been set by Fiskars Group, and includes products made by Fiskars Group and sourced finished goods."

2. Zero waste to landfill by 2030. "Fiskars Group has established a goal for 2030 to ensure all waste from its operations, including factories, distribution centers, retail locations, and offices, is recovered or recycled, with no waste sent to landfill... Waste to landfill has decreased by 32% compared to 2024 and by 86% compared to 2017" (page 85).

Reading the progress. The circularity target needs 23 percentage points in five years against one point delivered in 2025. On waste, the underlying tables (page 89) show 355 t non-hazardous plus 198 t hazardous to landfill in 2025 against 340 t and 471 t in 2024 - the fall is driven entirely by hazardous waste, while non-hazardous landfill rose slightly.

The circularity KPI is also the sustainability measure in the Performance Share Plan, at 10% of the potential total reward (page 37).

Reference: page 86 ("E5-4 Resource inflows"). Listed in the ESRS content index (pages 28-32).

"Fiskars Group utilizes various raw materials in its operations to produce its products, with key materials including inorganic substances for glass and ceramic production, as well as steel, aluminum, and plastic. Additionally, the Company uses packaging materials for primary, secondary, and tertiary packaging such as cardboard, plastic, and wood" (page 86).

Total material use fell 13% year on year. The biological share rose from 16% to 20%, while the secondary/recycled share fell from 23% to 20%, and by 1,753 tonnes in absolute terms.

Stated boundaries (page 86): "Currently Fiskars Group is not able to report the total weight of materials used in its suppliers' operations to produce packaging, components or finished goods." "Biological materials include materials derived from biological sources, such as wood, cardboard, and paper. In 2025, Fiskars Group did not source bio-based plastics."

Accounting policy (page 86): figures cover "the October 2024 to September 2025 reporting period... primarily derived from purchase documentation, with certain estimates applied where exact data is unavailable... The recycling rates are based on the information provided by the raw material and component suppliers."''

Reference: pages 87-88 ("E5-5 Resource outflows"). Listed in the ESRS content index (pages 28-32).

Key product groups designed on circular principles (page 87) are tabulated with products, principles and materials: jewelry (100% recycled gold and silver), tableware (recirculated fired ceramic; repairable recycled silver serveware), gardening and landscaping (repairable, spare parts, recycled steel), cooking (recycled steel, FSC-certified wood), scissors and creating (repairable creating tools, recycled steel) and interior (repairable silver, recycled steel vases, recirculated ceramics, GOTS-certified fibres). The table carries its own caveat: "The table presented does not claim all products under the stated product groups are designed according to the circularity principles applied."

Durability (pages 87-88). Named warranties: "The Fiskars brand offers an extended 25-year warranty for certain products such as Norden Axes, PowerGear X Cutting Tools, and Classic Scissors"; in the US, a warranty valid "for as long as the original end-user purchaser or giftee owns the product"; and 12-24 month breakage warranties from Georg Jensen, Royal Copenhagen, Waterford and Wedgwood. On benchmarking: "Industry averages to assess product durability may be utilized for benchmarking if available, but not systematically, as they are not feasible for many products."

Repairability (page 88): "Since 2021, the Fiskars brand has offered a pan-recoating service... and Georg Jensen provides repair services for jewelry and watches."

Recyclable content (page 88): "The rate of recyclable content (metals and precious metals) in products manufactured by Fiskars Group during 2025 was approximately 60% (2024: 59%). Regarding packaging... approximately 88% in 2025 (2024: 80%)." The policy notes "calculation methodologies may differ" between sites.

Reference: page 89. Waste is disclosed within E5-5 Resource outflows, which is listed in the ESRS content index (page 30).

"Most of the waste consists of production scrap, including metal, clay, and glass, which are key waste streams relevant to the sector in which Fiskars Group operates" (page 89).

Non-hazardous routes 2025: preparation for reuse 113 t, recycling 7,079 t, other recovery 551 t; incineration 5 t, landfill 355 t, other disposal 272 t. Hazardous routes 2025: recycling 31 t, other recovery 25 t, preparation for reuse 0 t; incineration 129 t, landfill 198 t, other disposal 236 t.

Total landfill is 553 tonnes and total recycled 7,110 tonnes - the same figures carried in the value creation model on page 41, where landfill is shown as "-86% compared to 2017". "No radioactive waste is generated in Fiskars Group's operations."

Accounting policy (page 89): "Waste data is collected monthly based on invoices from external waste-treatment partners, all of whom hold the necessary permits... The reported data is derived from direct measurements."

Against the 2030 zero-landfill target, hazardous landfill more than halved while non-hazardous landfill edged up from 340 t to 355 t.

Reference: pages 92-93 ("S1-1 Approach and policies"). Listed in the ESRS content index (pages 28-32).

Named policies with named owners (page 92). "The Fiskars Group Code of Conduct, the Violation Response Policy, the Fiskars Group Employment Policy, the Fiskars Group Recruitment and Resourcing Policy, the Fiskars Group Data Privacy Policy, and the Fiskars Group's Human Rights Statement are owned by the Chief Legal Officer, while the Fiskars Group Health & Safety Policy and the Health and Safety Management Manual (HSMM) are owned by the Executive Vice President of Group Operations and Sustainability. The Fiskars Group Travel Policy is owned by the Chief Finance Officer. Policy owners are accountable for the implementation of the policies."

Policies are available on the intranet "as well as in physical form at the factory and distribution centers", with mandatory online training for the Code of Conduct and Health and Safety Policy.

New in 2025 (pages 92-93): the HSMM "was introduced in 2025", describing the Occupational Health and Safety Management System and "defining authorities, responsibilities, and guidelines for meeting ISO 45001 standards", developed with the site Health & Safety Teams.

Human rights (page 93): "Fundamental labor rights, including freedom of association and collective bargaining, must be upheld in all operations... Fiskars Group has zero tolerance for child labor and forced labor, and ensures vulnerable workers are safeguarded from abuse and exploitation, regardless of employment contract or immigration status." Alignment is claimed with the International Bill of Human Rights, the UNGPs, the ILO Declaration, the OECD Guidelines and the UN Global Compact. The Employment Policy lists 15 protected grounds for non-discrimination (page 92).

Reference: pages 93-94 ("S1-2 Engagement with the Company's own employees"). Listed in the ESRS content index (pages 28-32).

"Engagement with worker councils and employee representatives takes place regularly in accordance with regulatory requirements and local practices. Employee representatives participate in regular Health & Safety committee meetings at the factories and distribution centers... In addition, the Company engages in collaboration with labor unions and works councils to ensure that broader workforce perspectives are integrated in organizational decision-making" (pages 93-94).

Accountability (page 94): "The CEO and Leadership Teams, with support from the Human Resources Teams, focus on engagement. Ongoing information-sharing and open dialog... is shared during regular town hall gatherings and location-specific meetings."

The measured instrument (page 94). "the annual 'Our Voice' employee survey is an essential part of capturing engagement, guiding decisions on where improvements are needed, and helping with measuring progress over time. The overall engagement score during this year's Our Voice survey in May 2025 was 72 out of 100 (2024: 73). Among office employees alone, the engagement score was 63 out of 100 (2024: 65)." Both scores fell year on year.

Vulnerable groups (page 94): "All employees, including those who may be particularly vulnerable or marginalized, are equally included in the Company-wide annual engagement survey... Fiskars Group ensures that the voices of all employees are heard and considered in decision-making and improvement actions."

Limitations. No response rate is disclosed, no engagement frequency beyond annual is given, and no single senior person is named as operationally accountable for acting on results. Collective bargaining coverage is quantified separately under S1-8.

Reference: page 94 ("S1-3 Process to remediate negative impacts"), with the mechanics in G1 (pages 117-118). Listed in the ESRS content index (pages 28-32). The index maps S1-3 to both the S1 section and "ESRS G1: Remediation and whistleblowing channel".

"Employees can voice their concerns or report grievances through a variety of channels, including their manager, HR, and the Legal and Compliance function, as well as an anonymous Ethics & Compliance Helpline... the Company has country-specific anonymous hotline numbers available in regions where it has manufacturing units, distribution centers, or significant suppliers" (page 94). "Concerns can also be voiced during global and local town halls, as well as during All-Hands calls. Further, employee representatives, elected locally by the employees, represent employee concerns in department-specific meetings."

Independence (pages 117-118): "Both the Ethics & Compliance Helpline and the various hotlines are provided by an external partner, NAVEX WhistleB, to ensure anonymity... Reports are responded to within seven days of filing." "Fiskars Group maintains a zero-tolerance policy against any form of retaliation."

Awareness (page 117): channels are taught in biennial mandatory Code of Conduct training with a 97% completion rate for 2025; a direct link sits on the intranet landing page; and "Posters for the Ethics & Compliance Hotline are displayed in manufacturing units and distribution centers to reach employees without regular computer access", carrying a QR code and toll-free numbers.

Tracking (page 118): all reported cases "are submitted quarterly to Fiskars Corporation's Ethics Advisory Group and the Audit Committee", which "conducts follow-up reviews on a quarterly basis". 2025 volumes are given under S1-17.

Reference: pages 94-95 ("S1-4 Actions"). Listed in the ESRS content index (pages 28-32).

Health and safety. "Fiskars Group is committed to achieving a zero-harm workplace and aims to achieve a zero lost time accident frequency (LTAF) by 2030... In 2025, 100% of the Company's sites were covered by the Management System, and 90% of the Company's manufacturing sites and distribution centers were ISO 45001-certified" (page 94). The process "includes regular internal and external audits, safety walks, risk assessments, site-specific training sessions, and safety committee monitoring".

Who is at risk (pages 94-95): "employees who work at the manufacturing and distribution facilities doing manual work and operating machinery... Through workplace observations, employee feedback, and safety audits, the Company has gained a clear understanding of which groups are most vulnerable to harm." Employees are "empowered to stop work if concerned about safety", and remedies follow "the hierarchy of controls".

Safety Week (page 95): "In 2025, Fiskars Group celebrated its 8th annual Safety Week from September 15-19 under the theme 'See the Risk. Protect What Matters. Start with You.'"

Inclusion and wellbeing (page 95): career development, mentorship and parental leave policies, "supported by dedicated resources within the HR organization and targeted investments... including funding for mental health programs, diversity, equity, and inclusion (DEI) training. Additionally, specialized roles such as DEI leaders and health and safety officers are in place." Vulnerable employees - "new or young employees, aging employees, expectant mothers, and employees with disabilities" - "are included in the H&S Risk Assessments and must receive special protection in their work if required".

Effectiveness (page 95): measured via engagement scores, inclusion experience, leadership diversity and safety metrics, with "monthly safety reports... discussed in leadership meetings and safety committees". No monetary amount is disclosed for any action.

Reference: page 96 ("S1-5 Targets"), progress panel page 44. Listed in the ESRS content index (pages 28-32).

1. Zero harm - zero LTAF by 2030. Performance moved the wrong way. "LTAF in Fiskars Group's own manufacturing units and distribution centers increased to 4.0 in 2025 (2024: 2.5). During 2025, contractor LTAF has remained at 0. LTAF increased by 58% in 2025" (page 96).

The company explains rather than deflects: "The increase... is associated with several factors including incidents that require a longer down time to allow for proper healing, as well as an increased awareness to report LTA's as a result of training and information campaigns, such as the Safety Week and quarterly safety network meetings. In the coming year, enhanced Group and site-level QEHS governance will be implemented, including reinforced oversight, clearer roles and responsibilities, and more structured follow-up on risk management activities."

2. Inclusive workplace. "By setting the open-ended inclusive workplace target, Fiskars Group aspires to be positioned among the top 10% of high-performing companies globally in terms of inclusion. The target score, and benchmark, as of June 2024 is 80. In May 2025, Fiskars Group had a score of 77 (2024: 77)" - flat, three points short.

An internal target alongside them: "internal targets have been set to achieve 25% leadership representation from diverse nationalities by 2030. As of the end of 2025, 27% (2024: 20%) of Fiskars Group's leaders come from diverse national backgrounds", leaders being those at compensation grade F9 or above. The 2024 figure is restated: "2024 Sustainability Statement disclosed 16,4% due to a manual processing error."''

Reference: pages 97-98. Listed in the ESRS content index (pages 28-32).

Headcount at 31 December 2025: 6,594 (2024: 6,851), a fall of 257. Female 3,748, male 2,844, other 2 (page 97).

By region (page 98): Europe 3,238, Asia-Pacific 2,869, North America 485. Countries with 50 or more employees representing at least 10% of the total are Thailand 1,101, Finland 1,023 and Indonesia 761 (page 97).

Turnover (page 98): "During the 2025 reporting period, a total of 1,201 (2024: 1,421) people left the Company. Employee turnover was 18% (2024: 20.7%)."

Definitions and boundaries (page 97). "Externals (non-employees such as agency workers, subcontractors or service providers, outsourced workers, or gig workers) are not employed by Fiskars Group and are outside the scope of the Employment Policy." Data is "reported in terms of headcount, reflecting values at the end of the reporting period (December 31, 2025)".

One exclusion is stated and quantified (page 97): "Inactive employees, including those on leaves such as study leave, long-term sick leave, or parental leave, have not been included in the reported numbers. The proportion of inactive employees in relation to the total number of employees is 3%."

Data is "largely maintained in a global HR system used worldwide", with some items in local systems. Both FTE and headcount are cross-referenced to the financial statements.

Reference: page 98 ("S1-7 Non-employees in own workforce"). Not in the ESRS content index, but disclosed under this DR heading in the S1 chapter. See IRO-2.

First-year disclosure with no comparative. "Data collection for this disclosure was initiated for the 2025 reporting. Thus, comparable data is not yet available" (page 98).

The categories are defined (page 98): "Non-employee workers have been identified as including: Contractors: Self-employed individuals or businesses; Agency staff: Non-employees hired through staffing agencies; Gig workers: Non-employees performing task-based and short-term work; Seconded personnel: Non-employees temporarily assigned from another company, and Outsourced workers: Non-employees employed by an external company working on our sites or projects."

Method (page 98): "Non-employee data has been stored and maintained by local HR departments, which has in turn been consolidated at a global level. Implementing standardized data collection practices across all regions ensured consistency and reliability."

Governance (page 97): externals sit outside the Employment Policy, but "Employers of externals are obligated to fulfill the ethical standards described in the Fiskars Group Supplier Code of Conduct. Fiskars Group's supervision of externals is subject to the same principles, leadership guidelines, ethical and sustainability expectations, and values as applied to the Company's own employees."

"All Fiskars Group employees and non-employees are included in the consideration of potential impact" (page 91). This is a change from FY2024, when the figure was not published.

Reference: page 99 ("S1-8 Collective bargaining coverage and social dialog"). Not in the ESRS content index, but disclosed under this DR heading in the S1 chapter. See IRO-2.

Headline figure: "A total of 45% of Fiskars Group employees globally were covered by collective bargaining agreements. Collective agreements within the EEA vary by region and according to each country's standards" (page 99). "Data collection for this disclosure was initiated for the 2025 reporting", so there is no 2024 comparative.

Works councils - a clear nil return (page 99): "Fiskars Group has no agreements in place with employees for representation by a European Works Council (EWC), a Societas Europaea (SE) Works Council, or a Societas Cooperativa Europaea (SCE) Works Council."

Disaggregation is presented as banded coverage rates (0-19%, 20-39%, 40-59%, 60-79%, 80-100%) for EEA employees, non-EEA employees "for regions with >50 empl. representing >10% total empl.", and EEA workplace representation. Finland is named against the EEA coverage band and workplace representation, APAC against the non-EEA estimate.

A caveat on reading this. The band labels appear in the source but each region's band assignment is presented graphically, so the precise EEA and non-EEA coverage rates cannot be read reliably from the text. The 45% global figure and the works-council nil return are the dependable data points.

Supporting commitments elsewhere. "Fundamental labor rights, including freedom of association and collective bargaining, must be upheld in all operations" (page 93). Family-related leave arises "either through national social policy or provisions set out in collective bargaining agreements" (page 102). Employee representatives sit on site Health & Safety committees (pages 93-94), and there is no employee representation on the Board (page 35).

Reference: page 100 ("S1-9 Diversity metrics"). Listed in the ESRS content index (pages 28-32).

Top management became all-male in 2025. Top management "comprises the CEO and the other members of the Fiskars Group Leadership Team".

Age distribution of the whole workforce:

Related figures elsewhere. The Board is evenly split: "both genders account for 50% of members of the Board" (page 35). At leadership level, "27% (2024: 20%) of Fiskars Group's leaders come from diverse national backgrounds", against an internal 25%-by-2030 target (page 96). Across the whole workforce women are the majority, 3,748 of 6,594 (page 97). Disability disclosure sits under S1-12 and the pay gap under S1-16.

"the Company regularly monitors and reports key DEI metrics, including gender representation, and generational and nationality diversity. These metrics are analyzed across key markets, employee groups, and organizational levels" (page 96).

A reader should note the report offers no commentary on the fall from two women to none in top management, and the figure is a point-in-time head count of five people.

Reference: page 100 ("S1-10 Adequate wages"). Listed in the ESRS content index (pages 28-32).

"Fiskars Group pays adequate wages in all countries where the Company operates in line with applicable benchmarks. The Company utilizes Mercer market data each year to monitor both competitiveness and wage level and adequacy" (page 100).

"Fiskars Group is committed to fair and competitive compensation for all employees, combining base salary, incentives, non-monetary rewards and benefits such as learning and career development opportunities. Base salaries are tailored to geographical location, role function, responsibility, experience, and performance."

Non-discrimination in pay: "The Company prioritizes non-discrimination in pay, with compensation determined based on job performance and responsibility, regardless of gender, age, ethnicity, or other personal characteristics. The Company regularly monitors the labor market, participates in salary surveys, and adjusts its pay structures to remain competitive."

Forward commitment: "Fiskars Group is committed to ensure adequate wages and continues to actively work to refine the benchmark for adequate wages in all countries of operations, specifically to align with the EU Pay Transparency Directive."

What is not disclosed. The statement asserts compliance without giving the percentage of employees paid below the applicable benchmark, without naming the benchmark used per country beyond the Mercer reference, and without a country-by-country breakdown or identification of any shortfall. The quantified pay outcomes sit under S1-16: a gender pay gap of -0.2% and a highest-paid-to-median ratio of 33.4 (page 102).

Reference: page 100 ("S1-11 Social protection"). Not in the ESRS content index, but disclosed under this DR heading in the S1 chapter. See IRO-2.

First-year disclosure. "Data collection for this disclosure was initiated for the 2025 reporting. Thus, comparable data is not yet available."

The gaps are named country by country (page 100). "The countries where not all Fiskars Group employees are covered for all the following - sickness, unemployment, employment injury and acquired disability, parental leave, and retirement - are Australia, Denmark, Japan, Sweden, Thailand, and the United States."

• "In Australia, social protection for unemployment is the responsibility of the individual employee, with no employer contributions required as is the case in Denmark and Sweden."
• "In Japan, employees who do not meet the eligibility criteria for social insurance, such as working fewer than 20 hours per week, earning less than 88,000 yen per month, being students, or holding short-term contracts, are not enrolled and therefore not covered."
• "In terms of parental leave, coverage in Thailand is limited to maternity leave."
• "In the United States, social benefits are not universally guaranteed and vary by state."

"Fiskars Group is continuously working towards reviewing and improving access to social benefits in all the regions in which it operates." Thailand is the Group's largest single employee country at 1,101 people (page 97), which gives the parental-leave gap real scale.

Reference: page 101 ("S1-12 Persons with disabilities"). Not in the ESRS content index, but disclosed under this DR heading in the S1 chapter. See IRO-2.

Headline figure: "The proportion of Fiskars Group employees that have disclosed information about a disability is 2% (2024: not reported)", with the footnote "Data collection for this disclosure was initiated for the 2025 reporting. Thus, comparable data is not yet available."

Why the figure is a floor, not a count (page 101). "Disclosure of disability status is not required by the Company in any of the countries where Fiskars Group operates unless the disability poses a health or safety risk in an operational environment. As such, the Company treats this information as voluntary... As the disclosure of disability status is voluntary, Fiskars Group acknowledges that the reported data may not fully capture the actual representation of persons with disabilities within the organization."

Definition and method (page 101): "The collection of the total number of employees with disabilities was undertaken through the local HR departments and consolidated at a Company level. In the collection of this data, disabilities were defined as long-term conditions affecting an individual's physical, mental, intellectual, or sensory functions, thereby affecting their everyday lives and work."

Related protections elsewhere. Vulnerable employees including "employees with disabilities" are explicitly included in health and safety risk assessments and "must receive special protection in their work if required" (page 95). The Employment Policy prevents discrimination on grounds including "physical or mental ability, health status" (page 92). Social protection for "employment injury and acquired disability" is reported at 100% (page 100).

Not disclosed: any breakdown by gender, region or employee category, and no accessibility or accommodation metrics.

Reference: page 101 ("S1-13 Training and skills development metrics"). Not in the ESRS content index, but disclosed under this DR heading in the S1 chapter. See IRO-2.

Performance reviews. "All Fiskars Group office employees, constituting 31% of the Company workforce, receive regular mid- and full-year reviews... During the reporting period, performance reviews were conducted for 82% of office employees, out of the total eligible employee population." By gender: male 81%, female 84%, other 100%.

Average training hours, 2025: male 0.4, female 0.4, other 0.5.

Both metrics carry material scope limits, stated by the company.

• Coverage: "local HR departments implement their own performance review processes for operative and retail employees" but "The Company does not currently track the proportion of performance reviews conducted among non-office employees" - so the 82% applies only to the 31% of the workforce who are office employees.
• Training hours: "The trainings represented are a sum average of mandatory training conducted through Fiskars Group's Learning Management System and Enterprise Resource Planning System and represent the trainings logged via those systems." An average of 0.4 hours per person per year therefore captures logged mandatory e-learning only, not site, induction, safety or on-the-job training described elsewhere (pages 92, 95).
• "Data collection for this disclosure was initiated for the 2025 reporting", so neither metric has a 2024 comparative.

Context: mandatory Code of Conduct training reached 97% completion and anti-bribery training 95.2% in 2025 (pages 116, 119) - neither converted into hours in this table.

Reference: pages 101-103 ("S1-14 Health and safety metrics"). Listed in the ESRS content index (pages 28-32).

"Fiskars Group has an occupational Health and Safety Management System covering 100% of its employees, and 90% of its factories and distribution centers are ISO 45001-certified" (page 101).

Accidents rose 22% and days lost 56% year on year. Work-related ill-health cases are disclosed for the first time (7); FY2024 did not report this figure.

Scope caveats (page 102). Recordable injuries "include all facility types, including office and retail sites, at the tempo in which they were included in the reporting system starting from 2023. In 2025 a total of 56 shops and offices were included in the reported figures (2024: 30, 2023: 24)" - so part of the rise reflects widening coverage. The rate is "calculated only for the Company's own factories and distribution centers, excluding office and retail".

A cap applies to days lost (page 103): "A maximum of 50 days lost is recorded per accident in the Safety Reporting System... Without a cap, the data could reflect several hundred lost days."

Assurance limitation (page 103): "Employee, and health and safety metrics are not continuously verified by external partners, but are included in internal quality, environment, and Health and Safety Management System audits."''

Reference: page 102 ("S1-15 Work-life balance"). Not in the ESRS content index, but disclosed under this DR heading in the S1 chapter. See IRO-2.

Entitlement and take-up. "97% of Fiskars Group employees are entitled to family-related leave, with 100% of employees being entitled to maternity leave, and 94% of employees being entitled to paternity leave. Of the entitled employees, 9% of women and 12% of men took family related leave, constituting 10% of the total Fiskars Group workforce."

"The employees are entitled to family-related leave either through national social policy or provisions set out in collective bargaining agreements. Since 2022, Fiskars Group U.S.-based full-time employees are offered extended paid parental leave, as well as paid military leave."

Two limitations stated in the footnotes (page 102).

• "Data collection for this disclosure was initiated for the 2025 reporting. Thus, comparable data is not yet available" - no 2024 comparative.
• "Due to the structure of the Swedish payroll system, December data was not yet available at the time of data extraction. Consequently, the figures for Sweden reflect maternity and paternity leave recorded from January to November 2025 only."

Reading the take-up. Proportionally more men than women took family-related leave (12% against 9%) in a workforce that is 57% female (page 97). The three percentage points with no entitlement is consistent with the S1-11 country gaps, where "coverage in Thailand is limited to maternity leave" and Thailand is the largest employee country at 1,101 people (pages 97, 100).

Related: "The Company offers career-development programs, mentorship opportunities, and parental leave policies designed to support work-life balance" (page 95).

Reference: page 102 ("S1-16 Compensation metrics"). Listed in the ESRS content index (pages 28-32).

Gender pay gap: -0.2% in 2025 (2024: 3.1%). "This is calculated as the difference of average base pay levels between female and male employees, expressed as a percentage of the average pay level of male employees." A negative figure means average female base pay slightly exceeded average male base pay.

Total remuneration ratio: 33.4 (2024: 18.7). "This is calculated as the ratio between the highest paid individual's base salary and the median base salary for all employees (excluding the highest-paid individual)." The ratio rose 79% year on year and the report gives no explanation for that movement.

Explanation offered for the pay gap (page 102): "The year-on-year differences can be explained by our continued efforts to reduce pay gaps - specifically, more balanced pay levels for new employees. This is also impacted by significant organization restructures and currency fluctuations."

Method and its limits (pages 102-103): "The data has been compiled through standard HR reporting extracted from HRIS System... No changes to the underlying data have been made beyond this standardized reporting process." But the accounting policy adds: "Reported gender pay gap is calculated as an average gross hourly pay due to lack of full hourly pay information". Both metrics use base salary only, excluding bonuses, share-based awards and benefits - which is where the Performance Share Plan and short-term incentives sit (pages 37, 100).

Assurance: these metrics fall inside Ernst & Young Oy's limited assurance engagement, but "Employee... metrics are not continuously verified by external partners" during the year (page 103).

Reference: page 118 (G1 Remediation and whistleblowing channel). Listed in the ESRS content index (pages 28-32). The index maps S1-17 to "ESRS G1 - Remediation and whistleblowing channel".

Volume and routing (page 118). "During 2025, Fiskars Group had a total of 89 reported misconduct cases. Fifty-nine reports were made anonymously through the Ethics & Compliance Helpline and hotlines, six cases were received via management, 16 cases were received via HR, and eight were reported via the compliance email address."

Subject matter: "leadership issues, unethical behavior, misuse of employee benefits, breaches of policies and guidelines, discrimination, bullying, harassment, conflicts of interest, health and safety, fraud, information security, retaliation, misuse of company assets, environmental issue, accounting and financial reporting and competition compliance."

Outcomes: "78 of these cases were investigated, resolved, and closed during 2025, while 10 remain under investigation or are being followed up. The substantiation rate for 2025 was 44%, and the global report volume per 100 employees was 1.30."

Named categories: "During 2025, Fiskars Group had six cases regarding discrimination and 14 cases of harassment and bullying."

Severe human rights impacts - a nil return: "Fiskars Group had no significant cases of non-compliance related to human rights or complaints filed to National Contact Points for OECD Multinational Enterprises", and "no cases of severe human rights incidents (e.g., forced labor, human trafficking, or child labor) or significant non-compliance with laws and/or regulations that resulted in fines or non-monetary sanctions."

No fines or compensation amounts are disclosed. A reader should note that 78 closed plus 10 open equals 88, one short of the stated 89 total.

Reference: page 105 ("S2-1 Approach and policies"). Listed in the ESRS content index (pages 28-32).

"Fiskars Group's main policies for managing material impacts and risks related to workers in the value chain are the Supplier Code of Conduct and the Code of Conduct Violation Response Policy" (page 105), with the Code of Conduct and Human Rights Statement setting the underlying commitment.

Commitments (page 105): "In all Fiskars Group operations, fundamental labor rights must be respected, including freedom of association and collective bargaining. Fiskars Group is committed to opposing slavery, servitude, human trafficking, and the elimination of all forms of forced, indentured, or compulsory labor... The policies and processes in place aim to safeguard vulnerable workers from abuse or exploitation, regardless of their employment contract or immigration status."

The Supplier Code of Conduct has teeth (page 105): it "is reviewed thoroughly every second year with key stakeholders", and "states that business consequences will be applied if a supplier fails to meet the minimum compliance level. The Supplier Code of Conduct implementation process describes the steps taken when an audit results in a fail. Such cases are escalated to the Sourcing Leadership Team for a decision on business consequences or business termination."

Its content is set out under G1: "minimum obligations regarding labor and human rights, overall health and safety, environmental consciousness, due diligence, business ethics and integrity, Management Systems, commitments, and a speak-up culture", including "requirements on labor and human rights, including child labor, forced or involuntary labor, and any form of human trafficking" (page 119).

Whistleblowing reach: the Violation Response Policy "complies with the EU Whistleblowing Directive (EU) 2019/1937", and the anonymous channels are open to suppliers and business partners (pages 105-106).

Reference: pages 105-106 ("S2-2 Engaging with value chain workers"). Listed in the ESRS content index (pages 28-32).

"Fiskars Group engages with direct suppliers and workers in the value chain through site visits, questionnaires, training, and the program following the audit process. The frequency depends on the annual plan for site visits, audits, and other activities."

Worker interviews are the substantive channel, and they carry consequences (page 106): "In supplier audits, the auditor interviews selected workers at the supplier's premises to verify the supplier's compliance. Worker interviews during audits impact the audit result, and the audit result impacts Fiskars Group's business decisions in relation to the supplier." Audits are run "by either an internal supplier sustainability auditor or by third-party auditing parties under the overall responsibility of the EVP, Group Operations and Sustainability."

Selection reaches vulnerable workers (page 106): "Skilled auditors are required to select workers for interview based on the risk mapping of the supplier, type of business, and workers employed, including potentially vulnerable workers, as well as visually observing the workers on site."

Direct channels (page 106): "A Supplier Code of Conduct email account is open for contacting the Fiskars Group Audit Team to report misconduct... Suppliers must ensure that the reporting channels are communicated to their employees." The Ethics and Compliance Helpline and local hotlines are "open to suppliers and business partners".

How input travels upward: "Monthly Supplier Code of Conduct reports are compiled based on the findings and conclusions of the audits, including input from value chain worker interviews, and shared internally with Fiskars Group's Sourcing and Supply Chain Leadership Teams."

Limitation: no worker representatives or trade unions are named as counterparties; engagement is mediated through the audit programme rather than with workers' own organisations.

Reference: page 106 ("S2-3 Remediation"). Listed in the ESRS content index (pages 28-32).

"The Supplier Code of Conduct email account, which is open for external partners, ensures the possibility of reporting any potential or actual impact in the value chain. The Fiskars Group Audit Team investigates any concern raised and discusses findings internally and with the supplier. The supplier must assist with any such investigation and provide access to any information reasonably requested. If remediation is required, the supplier will create and inform Fiskars Group of their corrective actions and implementation plans and timeline to effectively and promptly resolve the breach."

Human rights breaches route to Legal: "Remediation to human rights breaches identified via the Ethics and Compliance Helpline is managed by the Legal Team, as described in G1 Business Conduct, Remediation and whistleblowing channel."

2025 volumes (page 106): "During the reporting year, 3 emails were received through the Supplier Code of Conduct email account and handed over to Legal and Compliance for assessment, while no human rights breaches were found during the year's SCoC audits."

Trust in the channel is explicitly monitored: "It is important to the Company that workers throughout the value chain trust the process if they have concerns to report. Fiskars Group therefore evaluates the feedback from workers and the outcome of the process itself during regular SCoC and ISO management meetings."

The channels are the same as for the own workforce - the NAVEX WhistleB Helpline and country hotlines, a seven-day response commitment, and zero tolerance for retaliation (pages 117-118), published "on the Fiskars Group website and in the Supplier Code of Conduct".

What is not disclosed: no breach was substantiated in 2025, so no example of remedy delivered is given, and no independent assessment of worker awareness or trust in the channels is provided.

Reference: pages 106-107 ("S2-4 Actions"). Listed in the ESRS content index (pages 28-32).

The mechanism is the Supplier Code of Conduct Assessment Program (page 106). "All suppliers and service providers to Fiskars Group are required to sign the Fiskars Group Supplier Code of Conduct (SCoC) prior to entering a business relationship... New suppliers are checked in a due-diligence process prior to new vendor approval and are audited to minimum compliance." It cascades: "The requirement for a supplier's Management System includes management of their upstream supply chain, and that they apply similar requirements to their subcontractors and sub-suppliers."

Zero-tolerance items are named (page 107): "Child labor, forced labor, and life-threatening health and safety conditions are considered zero-tolerance violations in the audits." "Any zero-tolerance findings lead to a failed audit result, regardless of the overall score... Any potentially new suppliers with a failed audit result will be rejected as suppliers."

2025 outcome (pages 107, 118): "An audit priority formula is applied, including the latest audit results, and country and industry risks... During the 2025 reporting year, a total of 92 audits were completed through BSCI or SMETA. No supplier relationships were exited due to social or SCoC zero-tolerance findings." Coverage: "During 2025, 71% of the Company's spending on active finished-goods suppliers was audited." Ownership sits with "The Sourcing Team and dedicated Sourcing Sustainability Manager".

New in 2025 (page 107): "During 2025, a human rights risk mapping and due diligence current state assessment were conducted in collaboration with an external partner... The project has helped clarify key strengths and key development areas to be prioritized for short-, medium-, and long-term actions."

Risk geography is stated: "The risk of child or forced labor is highest in the regions of South and Southeast Asia and China" (page 104). Fiskars Group is a member of SEDEX and AMFORI.

Reference: pages 107-108 ("S2-5 Targets"). Listed in the ESRS content index (pages 28-32).

"Fiskars Group ensures risk mitigation and drives improvement by setting annual supplier sustainability targets... During the reporting year, two internal targets were set to monitor performance and drive actions."

KPI 1 - spend with low-risk suppliers, target 80% (page 108). "The annual global spend with suppliers either from low-risk countries or receiving a low-risk result in the latest audit is set at 80%... Below low-risk, the results can be medium-risk, high-risk, or fail. Medium-risk is also acceptable, depending on supplier improvement actions which are closely followed by the lead auditor." The rationale is stated in worker terms: "the Company actively steers procurement toward suppliers with stronger labor standards and better working conditions. This reduces the risk of worker exploitation, unsafe environments, or labor rights violations."

KPI 2 - zero failed audits (page 108). "The second KPI relates to fail audit results resulting from a zero-tolerance finding due to a score below 60% and/or any zero-tolerance finding. The target level for this KPI is always zero."

Monitoring: "Both KPIs are internally updated monthly, and the updated result is shared in business reviews with the Supply Chain Leadership Teams."

Two limitations a reader should note.

1. No 2025 outturn is given against either KPI in this section. The nearest data points sit under S2-4 and G1-2: 92 audits, 71% of finished-goods supplier spend audited, no relationships exited.
2. Value chain workers had no say in setting them. "The process for setting and tracking these KPIs is internally driven... and does not include direct input from value chain workers or their representatives" (pages 107-108).

Reference: pages 110-111 ("S4-1 Approach and policies"). Listed in the ESRS content index (pages 28-32).

"Fiskars Group's main policies for managing material impacts, risks and opportunities directly related to consumers and end-users are the Fiskars Group Quality Policy, Environmental Policy, Product Recall Policy, Privacy Policy, and Marketing Policy" (page 110), supported by the New Product Development process, the circularity framework, the Guideline for Recycled Plastics and the Antitrust Policy.

• New Product Development process (page 111): "defines cross-functional ways of working in the development of new products, including packaging, labeling, and product information for consumers and end-users, and takes into account the most stringent legal and internal requirements."
• Product Recall Policy (page 111): "designed to guide Fiskars Group in the event of a potential compliance issue in the market place. The objective is to protect the customer and ensure compliance with the relevant product safety regulations. The scope of the document covers all product categories and all Fiskars Group brands."
• Antitrust Policy (page 111): "was updated in May 2025 and was implemented for all office employees through mandatory online training."
• Marketing Policy (page 111): commits to claims "which are legal, decent, and truthful, and which do not include misleading facts or statements"... "The policy follows the International Chamber of Commerce (ICC) in assuring that all environmental claims in marketing are clear and appropriately substantiated by sound scientific evidence."

Human rights reach downstream (page 110): "The Fiskars Group commitment to human rights, detailed in S1 Approach and Policies, extends to the downstream value chain, including the consumers and end-users of Fiskars Group's products and services", with alignment claimed to the International Bill of Human Rights, the UNGPs, the ILO Declaration, the OECD Guidelines and the UN Global Compact.

Reference: page 112 ("S4-2 Engaging with consumers and end-users"). Listed in the ESRS content index (pages 28-32).

Ownership is named at CEO level: "Engagement with the consumers and end-users of Fiskars Group's products and services is owned by the CEOs of the Business Areas and takes place in continued communication that informs decision-making from initial product scoping to new product development, marketing and claims, or consumer service communication."

Frequency and method: "The engagement to gain insights takes place in an ad-hoc fashion, predominantly prior to the design phase once or twice a month... The aim is to include participants of national representation in the research to ensure all voices are heard and to provide data in disaggregated views to see nuances among consumers and end-users."

Children are handled as a distinct group: "The creative product portfolio, which also contains scissors, includes products for children and requires segmentation accordingly to ensure insights into safety measures and the required durability."

How input changes products: "Consumer perspectives may directly influence the product design, whether by adding, changing, or removing the final product's features... Customer claims handling and root cause analysis, which take place monthly, feed into continuous improvements and mitigating activities."

Post-launch: feedback arrives via social media and consumer support, led by "the Consumer Care Director (Vita Business Brands) and Sales Operations processes Manager"; "all contacts are registered in the Case Management System", with monthly summaries to the Business Units.

Effectiveness: "measured with the target of claims rates", and "As a pilot initiative in selected markets, consumer care engagement... is assessed via a Net Promoter Score survey". Vulnerability is addressed but not segmented: "The risks, impacts and opportunities are not identified to apply specifically to vulnerable groups" (page 110).

Reference: pages 112-113 ("S4-3 Remediation"). Listed in the ESRS content index (pages 28-32).

"Fiskars Group has established procedures to address and rectify negative impacts that consumers or end-users may face" (page 112).

Channels (page 113): "Consumers and end-users can reach the staff of Fiskars Group Consumer Care Services by phone, email, and web forms... Social media is monitored for consumer and end-user contact, which is referred to consumer care for handling, while the staff in Fiskars Group stores can receive inquiries and concerns and direct people to the appropriate function."

Anonymous escalation is open to consumers: "consumers and end-users can submit concerns to the Company anonymously by writing to the Ethics & Compliance Helpline or calling the anonymous Ethics & Compliance Hotline numbers" - the NAVEX WhistleB channels with a seven-day response commitment (page 117).

Product safety claims: "handled by the Business Areas, where any claims are handled and analyzed under the specific targets set for claims. The Customer Care Team monitors case-closure rate and first-contact resolution."

Data privacy: "The Fiskars Group Consumer Privacy Policy is available on the Company's website and is linked to from all relevant brand-specific websites to detail how Fiskars Group handles and protects its consumers' and end-users' personal data, and how they can raise any concerns or report breaches." Effectiveness is measured "in key markets via the Customer Care Net Promoter Score survey".

2025 outcome - a nil return: "During 2025, no severe human rights breaches, incidents or cases of non-respect of the UN Guiding Principles on Business and Human Rights, the ILO Declaration... or the OECD Guidelines... connected to consumers and end-users were reported via the Ethics & Compliance Hotline, or Consumer Service."

No claims volume, recall count or NPS score is published.

Reference: pages 113-114 ("S4-4 Actions"). Listed in the ESRS content index (pages 28-32).

Accountability (page 113): "The Business Areas' Management Teams and Quality and Compliance Teams are responsible for ensuring safe-to-use and high-quality products."

Product safety through the NPD process (pages 113-114): "Product testing is completed, considering both the intended use of the product and all potential uses to ensure that the mitigating decisions cover the wider risks identified beyond the intended product use." And: "Substances of concern that could potentially harm the environment or human health are identified, and actions are structured to reduce or eliminate their use."

A named example of inclusive design (page 113): "Fiskars Group offers a variety of left-handed scissors for adults and children that incorporate both reversed stainless steel blades for high performance and ergonomically designed handles for comfort... with safety-edge blades and an easy-to-hold, ergonomically designed handle. Ergonomic spring-assisted handles are continuously developed to reduce hand fatigue and enhance dexterity for specific consumer groups."

Green claims and labelling (page 114): "A legislation pipeline ensures that new legal requirements, both national and regional, are captured and included in the continued labeling and communication decisions." "The Business Area's Compliance Teams monitor labeling and marketing requirements for the different markets." In 2025 the Company "was audited for the Global Recycled Standard (GRS) and Recycled Claim Standard (RCS) certifications" (page 113).

Data security and privacy (page 114): "The effectiveness of data security and privacy controls is evaluated through internal audits and security testing... Objectives and measures... are adopted from the relevant legislation, standards, and best practices such as the NIST Cyber Security Framework and ISO 27001."

No resources or budget are quantified, and no recall, safety incident or data breach count is disclosed for 2025.

Reference: page 114 ("S4-5 Targets"). Listed in the ESRS content index (pages 28-32).

The headline target is borrowed from E5. "The ambition is supported by a Company-wide circular economy target, which equally supports the opportunity to meet the increasing demand for durable and sustainable products and maintain a strong Company reputation. The target and performance are disclosed under E5 Resource use and circular economy standard." That target is a majority of net sales from circular products and services by 2030, at 27% in 2025 against 26% in 2024 (page 85).

Quality and safety targets exist but are not quantified here. "To measure performance in quality, product safety, and labeling compliance, quality, compliance, and service-level targets are set under the Quality Management System, monitored via monthly review meetings and reporting, and further evaluated by the Supply Chain Management Teams in annual Management Reviews." Elsewhere, "Effectiveness of engagement is measured with the target of claims rates" (page 112) and the Customer Care Team "monitors case-closure rate and first-contact resolution" (page 113). No target level or 2025 outturn is published for any of these.

Stakeholder involvement is expressly limited: "Fiskars Group does not involve stakeholders directly in setting or tracking internal targets, as they are internally set and managed. However, consumers and end-users are indirectly involved via the processes for engagement described in S4-2."

Reading this against the material IROs. S4 carries five material IROs including two critical-scored items - product safety as an actual positive impact and communications and labeling as an actual financial risk (page 109). Neither has a measurable outcome-oriented target attached.

Reference: pages 116-118. Listed in the ESRS content index (pages 28-32).

Corporate culture (pages 116-117). "Fiskars Group's purpose is to pioneer design to make the everyday extraordinary... The purpose will be achieved by living the values, maintaining the Company's reputation and iconic brands, and growing the business sustainably and with integrity." The values are "Creating change, Celebrating the everyday and Growing with compassion".

Code of Conduct scope and training. The Code applies "to all individuals within Fiskars Group, including employees, managers, directors, officers, board members, consultants, and any other personnel working under Fiskars Group worldwide, even when the Code requires a higher standard of behavior than is required by national laws and local regulations". Leaders "have an increased responsibility to abide by and uphold the Code of Conduct and assist employees in doing the same". Training "is updated and conducted biennially for all Fiskars Group employees, including office, operative, and retail personnel. The completion rate for the 2025 training is 97%" (page 117).

Whistleblower protection (pages 117-118). "Fiskars Group has implemented a global Code of Conduct Violation Response Policy, which complies with the EU Whistleblowing Directive (EU) 2019/1937", covering "the confidentiality of reporting, the prohibition of retaliation and freedom from liability, the rights of the subject of investigation, consequences of malicious reports". Channels run through external partner NAVEX WhistleB with a seven-day response commitment, and "Posters for the Ethics & Compliance Hotline are displayed in manufacturing units and distribution centers to reach employees without regular computer access", carrying a QR code.

Oversight (page 118): all reported cases "are submitted quarterly to Fiskars Corporation's Ethics Advisory Group and the Audit Committee". Incident volumes are given under S1-17.

Reference: pages 118-119 ("G1-2 Management of relationships with suppliers"). Listed in the ESRS content index (pages 28-32).

Sourcing footprint (page 118): "Fiskars Group sources finished goods from suppliers located in Europe, Americas, and Asia, with the biggest sourcing countries being China, Thailand, and Vietnam." The value creation model records "approximately 140 finished goods suppliers" (page 41).

Policy architecture (page 118). "The Fiskars Group Procurement & Supply Management Policy describes the principles applied in all the sourcing and purchasing activities of Fiskars Group globally. The main objectives... are to provide value through ethical sourcing that supports growth sustainably." A separate Sourcing and Purchasing Policy governs "managing, spending, and buying goods and services".

Screening and onboarding: "The Supplier Code of Conduct criteria, including social and environmental, are applied in the supplier pre-approval process, after which the supplier is requested to sign the Supplier Code of Conduct. All suppliers are required to sign." The SCoC covers "minimum obligations regarding labor and human rights, overall health and safety, environmental consciousness, due diligence, business ethics and integrity, Management Systems, commitments, and a speak-up culture" (page 119).

Audit coverage: "During 2025, 71% of the Company's spending on active finished-goods suppliers was audited" (page 118); 92 audits were completed through BSCI or SMETA (page 107).

Payment practices (page 119): "Fiskars Group prioritizes timely payments to all its partners... leveraging advanced system automation to further ensure on-time payments... Clear internal guidelines define each step of invoice review, approval, and settlement to meet contractual payment terms." The Procurement Policy and Credit Policy define "targeted payment terms", which are not published - see G1-6.

Not disclosed: the share of SME suppliers or of suppliers at social or environmental risk.

Reference: page 119 ("G1-3 Prevention and detection of corruption and bribery"). Listed in the ESRS content index (pages 28-32).

"Fiskars Group is committed to preventing any form of bribery or corruption. Originally introduced in 2016, Fiskars Group's global Anti-Bribery and Anti-Corruption Policy was updated and approved by the Fiskars Group Leadership Team in 2023. All employees are required to follow the... Policy to prevent and detect bribery and corruption. The policy provides clear guidance... on how to distinguish between acceptable practices and prohibited actions."

Reach: "the policy has been translated into all 20 languages spoken within Fiskars Group. Additionally, comprehensive online anti-bribery and anti-corruption training, also available in 20 languages, was launched in 2023." It "is mandatory for all office employees globally, including sales, direct and indirect sourcing, and supply chain employees, as well as administrative and management personnel."

Risk-based targeting is explicitly not applied: "Training has been assigned to all office employees because no single function has been assessed as riskier than others. The training completion rate is monitored collectively as a whole, rather than by individual functions." A reader should note the corollary: the training covers office employees, who are 31% of the workforce (page 101), and no function-level risk assessment underpins the allocation.

Investigative independence: "in the event of any corruption or bribery allegations, the investigators are a separate team from the chain of management involved in the matter."

Reporting channels, the seven-day response commitment and quarterly reporting to the Ethics Advisory Group and Audit Committee are set out on pages 117-118. Whether the Board receives anti-corruption training is not stated.

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

Fiskars Group discloses no measurable outcome-oriented business conduct targets. No target level, target year or base year appears anywhere in the G1 chapter (pages 116-119), and business conduct is not among the five Company-level ESG targets on page 44, which cover circularity, own emissions, supplier emissions, safety and inclusion.

Consistent with MDR-T's alternative limb, effectiveness is tracked in the absence of targets.

• Training completion is measured and rising: Code of Conduct training completion "for the 2025 training is 97%" (page 117); anti-corruption and bribery training completion is 95.2% in 2025 against 80.2% in 2024 (pages 116, 119). Code of Conduct training runs "biennially for all Fiskars Group employees, including office, operative, and retail personnel".
• Case handling is measured: 89 reported misconduct cases, 78 closed in year, a substantiation rate of 44% and a report volume of 1.30 per 100 employees (page 118).
• Periodic governance review: all cases "are submitted quarterly to Fiskars Corporation's Ethics Advisory Group and the Audit Committee. The Ethics Advisory Group conducts follow-up reviews on a quarterly basis" (page 118).
• Outcome metrics: zero convictions, zero fines and zero actions taken on anti-corruption breaches in 2025 (page 119).

The one quantified target adjacent to business conduct sits in the supply chain, under S2-5: 80% of annual global spend with low-risk suppliers, and zero failed audits from zero-tolerance findings (page 108). Fiskars Group presents these as supplier sustainability targets, and gives no 2025 outturn against either. All four material G1 IROs are scored significant (4), and none has a target attached (page 116).

Reference: page 119 ("G1-4 Incidents of corruption and bribery"). Listed in the ESRS content index (pages 28-32).

A complete nil return for 2025 on all three datapoints, and a fall from three actions taken in 2024 to none.

How incidents would be caught (page 119). "Fiskars Group manages corruption- and bribery-related risks through its Anti-Bribery and Anti-Corruption Policy, Code of Conduct, and mandatory training embedded in daily operations. The Legal & Compliance function oversees implementation... The reporting and investigation procedures described in the Remediation and whistleblowing channel section serve as a critical mechanism for identifying and mitigating potential risks and impacts."

Context from the wider case data (page 118). The nil return sits against 89 reported misconduct cases with a 44% substantiation rate, 10 of them still under investigation at year end. Reported categories include "conflicts of interest... fraud, information security, retaliation, misuse of company assets, accounting and financial reporting and competition compliance", but none is categorised as corruption or bribery, and there was "no... significant non-compliance with laws and/or regulations that resulted in fines or non-monetary sanctions".

Not disclosed: the number of confirmed incidents leading to dismissal or discipline, the number leading to terminated or non-renewed business partner contracts, and details of any public legal cases. The 10 open cases are not broken down by category.