FLSmidth & Co. A/S

Reference: pages 41-45 (Corporate Governance), page 61.

The Board has ten members: seven elected at the AGM and three elected by employees (p.41). All AGM-elected members are independent (p.41), and the statement says "All members of the board are independent and non-executive members" (p.61). The underrepresented gender is 28.57% among AGM-elected members and 33.33% among employee-elected members (p.44).

On sustainability, Board activities include "quarterly reviews of sustainability matters, including progress against targets" (p.61). The Audit, Risk and ESG Reporting Committee "oversees the effectiveness of the risk control and management systems and assesses the potential impact of material sustainability IROs" (p.61). The Executive Leadership Team acts as the Sustainability Board and holds overall accountability. The Head of ESG develops and implements the strategy and reports to it, and the Group CFO is accountable for CSRD regulatory and data requirements (p.61).

Reference: pages 41-45, 59, 61-62.

The Executive Leadership Team "receives quarterly reports on specific sustainability KPIs" (p.61), and the Board holds quarterly reviews of sustainability matters (p.61). The Audit, Risk and ESG Reporting Committee receives reports on "progress in key sustainability metrics and activities, including the results of our double materiality assessment" (p.59).

In 2025 "the results of the review of the DMA were presented to the Executive Leadership Team and the Audit, Risk and ESG Committee", and the Board "received documentation, process descriptions and results of the DMA process for relevant decision-making" (p.61). The committee's 2025 focus also covered ESG reporting (CSRD), ESG risks and EU Taxonomy (p.43). Management and the Board receive information and training on regulatory matters and material sustainability IROs (p.61). The report incorporates GOV-1 and GOV-2 by reference from pages 41-45 (p.62).

Reference: page 61.

The long-term incentive program ties the Executive Leadership Team's pay to sustainability. The statement says "For the 2025 programme, 15% of achievement is linked to four sustainability KPIs: scope 1 & 2 emissions, economic intensity, total recordable injury rate (TRIR), and the proportion of women in the workforce."

Each KPI is "measured against a three-year average target improvement for 2025-2027 and assigned a 3,75% weighting" (as printed). The KPIs are included in the remuneration policy. The Board reviews the schemes annually for consistency with the sustainability strategy and current practices, "aiming to balance sustainability and financial considerations" (p.61).

Reference: page 61.

The statement on due diligence is a table that maps each core element of due diligence to report pages (p.61):

• Embedding due diligence in governance, strategy and business model: pages 56, 61, 91, 101, 106
• Engaging with affected stakeholders in all key steps of the due diligence: pages 57, 59, 74, 76, 79, 82, 91, 92-93, 103, 109
• Identifying and assessing adverse impacts: pages 57, 65-66, 73-74, 76, 79-82, 91, 101, 106, 109
• Taking actions to address those adverse impacts: pages 67-68, 75, 77, 80, 83-86, 93-100, 103-105, 107, 110-113
• Tracking the effectiveness of these efforts and communicating: pages 68-69, 75, 77-78, 80, 86, 100, 103-105, 107, 113

The ESRS index flags the statement on due diligence data point as derived from SFDR (p.115).

Reference: page 61.

"Internal control systems are in place to identify and manage risks in financial and sustainability reporting, guided by set policies, procedures, and controls." The statement names the key risks as "reliance on manual processes and maintaining completeness of new data points".

Actions listed: standardizing tools to reduce manual work and improving data validation through analytical data processes and the ESG consolidation system. Risks are prioritized by severity. A dedicated ESG data team and a separate ESG Finance team handle the record-to-report process for ESG data and its risk controls (p.61). The Audit, Risk and ESG Reporting Committee oversees the risk control and management systems (p.61). Sustainability risks are scored with the enterprise risk management method, and a footnote on p.58 states that sustainability risks are not prioritized relative to other business risks under it.

Reference: pages 56, 95 (business model on pages 17-19).

FLSmidth calls itself "a pure play supplier of technologies and services to the mining industry" and completed the divestment of its cement business in 2025 (p.56). It serves customers in about 125 countries, has a local presence in about 40 and employs 5,494 people (p.56). Countries with more than 10% of the workforce are the USA (978), India (987) and Chile (700) (p.95).

On fossil fuel exposure, coal-related activities were 7% of 2025 revenue (about DKK 1 bn, down DKK 0.4 bn on 2024) and other fossil fuel sectors about 1%. The company states "We have pledged not to pursue any new greenfield projects connected to coal" (p.56). The report says 98% of emissions across the value chain arise from customers' use of its products (p.56).

Reference: page 59 (also page 91).

The report lists its key stakeholder groups and how it engages each (p.59): investors (regular discussion of sustainability ambitions and strategy); the Audit, Risk and ESG Reporting Committee (progress reports and DMA results); suppliers and supply chain workers (risk-based onsite assessments of key suppliers); current and future employees (anonymous quarterly surveys, quarterly townhalls, internships and PhD programs); customers (continuous dialogue on expectations); policy makers (industry associations and advocacy groups); and local communities, media and NGOs (the Social Action Programme).

Stakeholder interests and views are fed into the impact, risk and opportunity assessments, "informing the strategic decisions of our management and Board of Directors" (p.59). For own workforce, employee interests inform strategy "through worker representation in our Board of Directors" (p.91).

Reference: page 60 (value chain overview), with detail in each topic chapter.

The report numbers 23 material impacts, risks and opportunities (IROs) and places each upstream, in own operations or downstream (p.60). E1 climate: IRO 1 CO2e emissions, IRO 2 energy optimization, IRO 3 MissionZero portfolio and environmental stewardship. E2 pollution: IRO 4 air pollution from production, IRO 5 tailings solution offerings. E3 water: IRO 6 water withdrawal (and IRO 3). E4 biodiversity: IRO 7 to 9. E5 circularity: IRO 10 to 14. S1 own workforce: IRO 15 to 18. S2 value chain workers: IRO 19 and 20. S3 affected communities: IRO 8 license to operate. G1 business conduct: IRO 21 to 23.

The company states "We have not identified any current or future financial effects for which there is significant risk of material adjustment" (p.58) and that its climate assessment "indicates no material climate-related risks to our operations" (p.65). Changes against the 2024 DMA are on pages 120-121.

Reference: pages 57-58.

The DMA covers impacts, risks and opportunities in own operations and across the upstream and downstream value chain (p.57). Inputs included workshops and interviews with internal experts, environmental impact assessments, whistleblower reports, industry networks and employee surveys. Downstream impacts were assessed through "direct engagement with a major mining customer and through proxies" (p.57).

Impacts are scored on the average of scale, scope and irremediable character (each 0 to 5), then likelihood; a human rights impact scoring 5 on any of the three is treated as material (p.58). Risks and opportunities are scored with the enterprise risk management method against seven value drivers, qualitatively where money values were not possible. "Materiality thresholds were set at 'significant'" (p.58).

The 2025 review was simplified. Affected communities moved to being "only financially material as a 'license to operate' risk", and the cement divestment had no significant effect as "no IROs were identified specifically for cement in the original DMA" (p.57).

Reference: pages 115-119 (index), page 62.

The report has a "Disclosure requirement reference table and other information" on pages 115-119. For each ESRS 2 and topical disclosure requirement it gives the section (SS sustainability statement, CG corporate governance), the page, and notes on data points derived from SFDR, Pillar 3, the Benchmark Regulation or the EU Climate Law.

Rows marked "Not applicable" are E1-7, E1-9, E2-3 to E2-6, E3-5, E4 SBM-3 and E4-3 to E4-6. S1-11 (social protection) and S1-12 (persons with disabilities) are marked "Not material", and the index says "ESRS S4 is not material" (pp.115-118). Page 119 lists KPI changes, including the discontinued substances of concern KPI, and new phase-in KPIs on collective bargaining coverage and family-related leave.

The statement was prepared for the second year of CSRD reporting (p.54) and says "For information on where to find each disclosure on ESRS, see pages 115-119" (p.62).

Reference: page 66 (with pages 67-69 and 71).

The transition plan rests on near-term targets validated by the Science Based Targets initiative and aligned with the 1.5°C scenario, plus a 2025 long-term target for total carbon footprint with "an emissions reduction ambition of 90% by 2050" (p.66). The main decarbonization drivers for Scope 1 and 2 are electricity and transport: renewable electricity through RECs and PPAs, on-site solar, efficiency improvements and electric vehicles and forklifts (p.66).

"Our climate transition plan is aligned with our overall business strategy and financial planning. It is approved and monitored by the Executive Leadership Team." Progress goes to the Audit, Risk and ESG Reporting Committee (p.66). The company says it assessed its product portfolio for locked-in GHG emissions and "all products have the ability to run from renewable energy sources", made "no investments in coal, oil, or gas-related activities in 2025", and had DKK 120 million of climate mitigation CAPEX (pp.66-67).

Reference: pages 65, 73 (with pages 57-58).

Back-filled from the climate assessment in E1-IRO-1 (p.65) and the climate risk and opportunity table (p.73). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Climate IROs were assessed by screening activities "in alignment with the TCFD recommendations, in different scenarios, in the short, medium and long-term", covering physical and transition risks with Paris-aligned (1.5°C) and higher-temperature pathways informed by IPCC and IEA models (p.65). Page 73 names the scenarios: an RCP8.5 business-as-usual scenario with third-party tools for physical risk, and an RCP2.6 scenario with a delayed transition for transition risk (footnoted as a temperature rise below 2°C by 2100).

The table classifies each risk as transitional (carbon taxes and regulation, demand for green products, reputational impact, access to capital) or physical (storms and cyclones, drought, flooding), with exposure, time horizon and actions (p.73). No temperature projection is given for the RCP8.5 scenario, and pages 65 and 73 do not say when the analysis was done.

Reference: pages 58, 65, 73.

Back-filled from ESRS 2 SBM-3, "Resilience of our strategy" on p.58, which the company's index lists as E1-SBM-3 (p.115). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"Last year, we conducted an organisation-wide resilience analysis, covering all aspects of the company's operations and strategic planning." It tested the strategy and the capacity of the business model to address material impacts and risks and use material opportunities, and concluded the product and service portfolio helps customers reduce environmental and safety impacts (p.58).

The report finds no climate-related financial effects with significant risk of material adjustment (p.58) and no material climate-related risks to operations (pp.65, 73). Adaptation capacity is described only for energy, where shifting to renewables is said to be "increasing energy resilience" and to reduce exposure to grid price volatility (p.66). The analysis is dated "last year", and no refresh in 2025 or list of areas of uncertainty is given.

Reference: pages 66-67.

The Climate Action Policy "outlines our commitments and ambition to reach our climate targets across all our own operations, reducing emissions through energy efficiency and deployment of renewable energy, and throughout our value chain" (p.66). The value chain element covers working with suppliers and enabling the mining industry's transition through the product and service portfolio.

On renewable energy the policy commits to move from fossil fuels to renewable fuels or electrify internal transport, expand on-site renewable generation and, where feasible, develop renewable supply through power purchase agreements and certificates (p.66). It applies to the whole company, its employees and subsidiaries, and to anyone acting for FLSmidth, who must advocate consistent commitments to suppliers and business partners (pp.66-67). The Chief People Officer and Global Business Services EVP is accountable for implementation (p.67). The company does not pursue new coal greenfield projects and supports existing customers through their transition (p.66).

Reference: pages 67-68.

Own operations: energy reduction guidelines through "environmental blueprints" for all sites, energy management procedures at the most energy-intensive sites, and a move to more efficient compressors, welding and assembly machinery (p.67). A new electric autoclave for mill liners at the Casablanca plant cut manufacturing-process emissions by 56%, and the Casablanca plant and Renca Supercenter footprints were verified to ISO 14064 (pp.67-68). In 2025, 6% of electricity was self-generated, 19% of energy came from renewable sources, and 36% of Scope 2 energy was covered by certificates, PPAs and supplier agreements (p.68). Climate mitigation CAPEX was DKK 120 million (p.67).

Upstream: more scrap steel, composite mill liners that are on average 50% lighter, and supplier science-based target engagement, with 25.0% of spend with such suppliers (p.67). Downstream: 76% of R&D spend went to energy and emissions solutions, and Reflux Flotation uses up to 70% less energy than traditional flotation (p.68).

Reference: pages 68-69 (data on p.71).

Near-term targets are validated by the SBTi (p.68). Own operations: cut absolute Scope 1 and 2 (market-based) emissions by 100% by 2030 from 2019. The 2025 milestone was 32,871 tCO2e; emissions fell 8.8% to 27,221 tCO2e, 44% below 2019 (p.69).

Value chain: an economic intensity target of a 56% cut by 2030 against 2019 (Scope 3 category 11 emissions per order intake), a 30% Scope 3 reduction target by 2030 set in 2025, and a 2025 goal of 30% of spend with suppliers holding science-based targets, missed at 25.0% (2024: 22.5%) (pp.68-69). A long-term target of a 90% cut in total footprint by 2050 was set in 2025 (p.68). The 2019 baseline will be updated in 2026 for the cement divestment (p.68).

Page 69 says economic intensity rose 22.8% to 3,455 tCO2e/DKKm, while the p.71 table shows 3,455 against 2,985 in 2024 (+15.8%).

Reference: page 70.

Total energy consumption was 98,866 MWh in 2025 (2024: 105,586 MWh restated), down 6.4%, with 89,634 MWh for continuing activities. Fossil sources supplied 81% (2024: 83%): crude oil and petroleum products 19,085 MWh, natural gas 28,513 MWh, and purchased non-renewable electricity, heat, steam and cooling 32,966 MWh. No coal or nuclear energy was used.

Renewable sources supplied 18,303 MWh, 19% of the total (2024: 17%), made up of 15,642 MWh purchased renewable electricity, heat, steam or cooling and 2,645 MWh self-generated non-fuel renewable energy. All consumption and revenue is attributed to a high climate impact sector, NACE C28.9 (manufacture of other special-purpose machinery). 2024 figures were restated for additional renewable energy certificates. Data come from invoices, meter readings and supplier reports; offices under 10 people and customer sites are excluded.

Reference: pages 71-72.

2025 gross emissions in tCO2e: Scope 1 11,244 (2024: 11,464); Scope 2 location-based 20,463 and market-based 15,978 (2024 restated 18,383); Scope 1 and 2 market-based 27,221, down 8.8% from 29,847 (restated). Scope 3 totals 63,317,625 (2024: 58,429,852, +8.4%), of which category 11 use of sold products is 61,800,000, category 1 purchased goods and services 1,500,000 and category 6 business travel 17,625. Total market-based GHG emissions are 63,344,846. Scope 1 and 2 market-based intensity is 1.5 tCO2e per DKKm of revenue. No Scope 1 emissions fall under emissions trading schemes (0%).

Scope 3 figures are rounded to the nearest hundred thousand tonnes, categories below 0.1% of Scope 3 are excluded except business travel, and category 11 covers expected lifetime emissions of products sold (p.72). The 2024 market-based figure was restated for additional certificates (previous value 30,638). The report says 98% of value chain emissions arise from product use (p.56).

Reference: page 69.

"We apply an implicit internal price on carbon to support energy efficiency and the reduction of scope 2 emissions." The price "is based on regional renewable energy procurement costs and calculated as the marginal cost per tonne of CO2 equivalent avoided", reflecting the avoided-emissions cost of renewable energy certificates. The company says this gives "a practical, geographically tailored incentive to prioritise low-carbon solutions and track progress toward full scope 2 decarbonisation by 2030".

It is "currently evolving this approach to establish a more comprehensive internal carbon pricing framework to inform long-term investment decisions across our operations". The page gives no price level per tonne and no share of emissions covered.

Reference: pages 74-75.

Policies map to the two pollution IROs. Upstream (IRO 4, air pollution from steel and other inputs): the Supplier Code of Conduct sets the expectation that suppliers work with pollution prevention "by minimising or eliminating emissions and discharges of pollutants at the source or by adding pollution control equipment; modifying production, maintenance, and facility processes; or by other means" (p.74). Downstream (IRO 5, tailings solution offerings): the Environmental policy commits to "developing tailings management solutions to prevent water and soil pollution in the mining industry" (p.75).

For own operations, the 2025 DMA review judged pollution not material, so it is no longer a material topic at group level, though "pollution and substances of concern will still be managed and controlled at a facility level" under the ISO 14001 environmental management system (p.74).

Reference: page 75.

Upstream (IRO 4): all suppliers must commit to the Supplier Code of Conduct, which sets expectations for preventing and reducing pollution and discharge of pollutants to wastewater in suppliers' manufacturing. The company also runs onsite supplier assessments where employees record environmental, social or governance concerns, and is working to raise its share of procured scrap steel, with the ABON steel reuse program described on p.85.

Downstream (IRO 5): continued investment in tailings and water management technologies "with the aim of reducing pollution of local water sources and surrounding environments that can potentially occur from tailings breaches and wastewater discharge". Through dry stack tailings technology, "we eliminate the use of tailings dams and thereby reduce the impacts associated with tailings dam breaches" (p.75). No amounts of resources are quantified on the page.

Reference: pages 76-77.

Water management sits in the Environmental Policy through "specific commitments concerning water withdrawal, with a special focus on water-stressed areas": reuse and recycle water where feasible to cut consumption and withdrawal, and prevent and treat possible water pollution from operations (IRO 6, p.77). For customers (IRO 3), the policy commits the company to develop technologies and services that help mining companies reduce water use and maximize water recovery (p.77).

The water risk assessment drew on the EU Water Framework Directive, the WRI Aqueduct Water Risk Atlas and the WWF Water Risk Filter, covering all own locations and main suppliers (p.76). The environmental management system is ISO 14001 certified (p.76).

Reference: page 77.

Own operations (IRO 6): a focus on cutting withdrawal at sites, especially those in water-stressed areas. Some sites have water treatment facilities whose output is reused in processes or for gardening, and others source stormwater or rainwater. At Tucson, USA, in a water-stressed area, a new recycling system with "a 360-gallon retention wall and holding tank" captures and reuses pump test water and rainwater in a closed loop. Smart water meters are being installed at manufacturing sites, service centers and larger offices to find leaks earlier, new water metrics were added to monthly reporting, and awareness campaigns and training are run for relevant employees.

Downstream (IRO 3): water-efficient technologies in grinding, classification, flotation and dewatering; dry stacked tailings using filtration and dewatering "enabling up to 95% of process water recovery"; and the coarseAIR flotation cell launched in 2025, which saves water through better dewatering of tailings (p.77).

Reference: pages 77-78.

Own operations (IRO 6): 2030 targets set against a 2019 baseline of a 50% cut in freshwater withdrawal and a 50% cut in withdrawal in water-stressed areas. In 2025 withdrawal was 139,007 m3, with 114,497 m3 in water-stressed areas, a 37% and 11% reduction from baseline. Total withdrawal is ahead of schedule, while withdrawal in stressed areas has fallen more slowly, partly because of the footprint and more regions becoming water-stressed (p.77).

After the cement divestment the company says "We re-establish our baseline to reflect our 2025 figures for continuing business" and sets a goal of a 25% reduction in withdrawal and in withdrawal in water-stressed areas by 2030 (p.77). The table on p.78 carries 2025 and 2030 target columns. No numeric target for customers' water use is stated (p.78).

Reference: page 78.

Total water withdrawal was 139,007 m3 in 2025 (2024: 156,022 m3), an 11% fall, with 128,618 m3 for continuing activities. Of this, 114,497 m3 (82%) was in water-stressed areas (2024: 129,295 m3, 83%). Withdrawal intensity was 7.8 m3 per DKKm of revenue.

Water consumption was 60,611 m3 (2024: 15,292 m3), with 59,874 m3 (99%) in water-stressed areas. The rise is put down to better primary data from the new environmental reporting system, so 2024 numbers are "not comparable". Water recycled and re-used was 31,583 m3, the first year wastewater data is reported. Water-stressed areas are sites scoring 4 or above for baseline water stress in the WWF Water Risk Filter, adopted in 2025 in place of the WRI Aqueduct Water Risk Atlas. Data are measured from invoices and meter readings, with estimates for shared offices and missing data (p.78).

Reference: pages 79-81 (index entry on p.116).

The company's index lists the biodiversity transition plan at p.80. FLSmidth's sites "are placed in developed commercial and industrial areas", and none is in or near a Key Biodiversity Area, so the biodiversity IROs "stem from our business relationships" and the focus is "strategically supporting our customers to address these impacts" (p.80). It used the WWF Water and Biodiversity Risk Filter and the LEAP approach; most facilities fall in medium, low or very low biodiversity risk categories (p.79).

The strategy is to help customers reduce the drivers of biodiversity loss (GHG emissions, land-use change, water consumption, pollution). Examples are Delta Stak clarifiers with a patented design that reduces space needs and filters that allow dry stacking and a smaller tailings pond footprint (p.80). The company is "continuously evaluating the resilience of this strategy with a value chain perspective" (p.80). Page 81 maps its solutions to six mineral processing steps using TNFD sector guidance.

Reference: page 80.

The Environmental Policy "outlines our commitment to develop solutions enabling our customers to address impact drivers on biodiversity loss, including products to maximise yields within a smaller land footprint, thus reducing land use" (p.80). The Climate Action policy commits the company to provide full-flowsheet mineral processing equipment and services designed for sustainable mining operations, with a product range built for energy efficiency and operation on renewable energy (p.80).

Both policies point at customers' footprint. The index lists the SFDR-derived data points on sustainable land and agriculture practices, sustainable oceans and seas practices, and policies to address deforestation as additional information against E4-2 (p.117).

Reference: page 83.

The Environmental policy sets circularity commitments by IRO. Upstream (IRO 10 and 11): increase sourcing of recycled materials to move away from virgin resources; the Supplier Code of Conduct expects suppliers to identify their environmental impacts and minimize adverse effects on communities, the environment and natural resources. Own operations (IRO 12): reduce waste, prioritizing hazardous waste and applying the waste hierarchy "with waste prevention being top-priority and sending waste to landfill as the last resort".

Downstream (IRO 13 and 14): develop circularity solutions for mining, including better separation technologies to recover metals, technologies that cut water use, reprocessing of old waste where economically viable, and products designed to be durable, repairable, modular, lightweight and recyclable. Products are to be kept in use longer through digital monitoring, predictive maintenance, reconditioning, repair, refurbishment and remanufacturing (p.83).

Reference: pages 83-86.

Upstream (IRO 10 and 11): raising the share of recycled raw materials such as scrap steel, extending product life in design, and lightweighting components (p.83). Own operations (IRO 12): waste segregation guidelines and analysis of global waste data by disposal type; sand is reused several times at an Indian facility, and sites in Welshpool and Henderson, Australia send mixed waste to a nearby waste-to-energy plant (pp.83-84). Waste is handled outside sites by authorized third parties (p.83).

Downstream (IRO 13 and 14): roll crushers 30% lighter than conventional hard rock primary crushers, and High-Pressure Grinding rolls whose service life can be extended up to 30% (p.85). A mill liner recycling service launched in Antofagasta, Chile in 2025, with carbon savings of up to 61% versus virgin materials; a Rebuild and Exchange program for pumps, cyclones and valves; and a steel reuse program for ABON products in Melbourne, Australia (p.85).

Reference: page 86 (also pages 68-69).

Own operations (IRO 12): "voluntary targets for reducing landfill waste", a 50% cut in landfill waste by 2030 from a 2022 baseline through more waste segregation, material efficiency, reuse, recovery and recycling (p.86).

Upstream (IRO 10 and 11): the supplier science-based target spend goal of 30% (see E1-4), plus an aim to integrate circularity principles into purchasing decisions for product materials and packaging (p.86). Downstream (IRO 13 and 14): the 2030 target to reduce the economic intensity of emissions by 56% against 2019 (p.69), and targets for products and services in better metal recovery, reprocessing of tailings, and lowering water consumption in mining (p.86). The report gives no numeric value for the downstream circularity items beyond the economic intensity target.

Reference: page 83.

The resource inflows table reports a total weight of materials of 1,299,168 tonnes in 2025 (2024: 1,074,305). Recycled content was 713,949 tonnes, 55% of total weight (2024: 286,072 tonnes, 27%). The share of biological materials that are sustainably sourced is reported as 0%, which the company calls conservative because it has no information on certification schemes used by suppliers.

Weights are estimates: purchased goods and services are allocated to raw materials from spend categories, supply chain expert weightings and traded commodity prices; packaging is scaled up from a supplier sample; and recycled content is estimated from monitored scrap steel, assuming no recycled content in other material types (p.83).

Reference: pages 85-86.

Resource outflows are reported through product-design indicators (p.86). Durability is measured against an industry-average baseline of 100%: comminution, separation and classification, dewatering and filtration and other products are at 100%, and pumps, cyclones and valves at 120%, based on public case studies of longer wear part life. Repairability is rated on an A to E scale adapted from the EU Joint Research Centre scheme. Recyclable content of products and packaging is 97% (2024: 93%), estimated from the possibility of recycling, not from amounts actually recycled.

Related actions: roll crushers 30% lighter than conventional crushers, up to 30% longer life for High-Pressure Grinding rolls, a mill liner recycling service launched in Antofagasta, Chile in 2025, and a Rebuild and Exchange program for pumps, cyclones and valves (p.85). Waste data are recorded separately under E5-5-Waste.

Reference: page 84.

Total waste generated was 14,540 tonnes in 2025 (2024: 15,189), with 14,203 tonnes for continuing activities. Hazardous waste was 532 tonnes (2024: 573) and non-hazardous 14,008 tonnes. Recovered waste was 9,443 tonnes (65%, 2024: 63%) and non-recovered 5,097 tonnes (35%); landfill took 4,948 tonnes, of which 271 tonnes hazardous and 4,678 tonnes non-hazardous.

By material, metal was 48% of waste and mixed waste 18%. The report attributes the fall in waste to "a reduction in our global footprint", with the recycled share rising to 65% in 2025. Figures come from invoices, supplier reports or local logbooks, collected monthly for entities under financial control, with estimates from waste density and volume where data are missing. Waste data are labeled "Resource outflows" in the report (p.84).

Reference: page 92.

Several policies cover the whole workforce: the People Policy, the Human Rights Policy (recently updated), the Working Hours Policy, the Diversity, Equity and Inclusion Policy, the Remuneration policy (with a focus on pay equity), the Harassment and Discrimination Prevention Policy and the Health, Safety and Environment Policy, which sets a commitment to zero harm. In 2025 the bereavement policy gained a global minimum standard.

The company says it respects the UN Universal Declaration of Human Rights, the two UN Covenants and the ILO Declaration on Fundamental Principles and Rights at Work, and commits to align its policies and due diligence with the UN Guiding Principles and the OECD Guidelines (p.92). It is a UN Global Compact member and has committed to the Diversity Pledge with the Confederation of Danish Industry. The Chief People Officer and Global Business Services EVP is responsible for implementation, except the harassment policy, which sits with Legal and Compliance (p.92).

Reference: pages 93-100.

Actions are set out by IRO. Working conditions (IRO 15): a pure-play business transformation with workforce adjustments, roundtables and quarterly surveys; headcount fell 29%, with divestments accounting for 21 percentage points of that (p.94). Living wage analysis across all geographies shows more than 95% of headcount earn a living wage (p.94). Equal treatment (IRO 16): global talent acquisition standards to limit bias, a global DE&I Council and a yearly gender pay gap analysis (p.94). Talent attraction and retention (IRO 17): leadership programs such as "Leading in FLSmidth", development reviews, mentoring, and e-learning and in-person training (pp.94, 97-98).

Health and safety (IRO 18): an ISO 45001 certified management system at all operational sites, Safety Cardinal Rules, a Manager's Safety Walk Programme, the "Go Look See" observation program, an Ergo Cup competition and a hand safety campaign (pp.99-100). Resources come from legal, people, sustainability and communication functions (p.93).

Reference: pages 96, 99-100.

The report sets targets on diversity, gender equality and health and safety, each with annual targets to track progress toward 2030 (p.100): zero harm by 2030 as an aspirational target, 25% women in the total workforce, 30% female white collar employees and 25% female managers.

The p.96 table shows 2025 results of 20.7% women in total, 30.0% in white collar roles, 16.0% among managers and 7.6% in blue collar roles, each below its 2025 target. The report says it did not meet its 2025 targets for female employees overall (p.94). Safety figures on p.99 show the accident rate behind its 2025 target. Workforce representatives are involved in tracking progress through quarterly presentation of results to all employees and publicly available quarterly reports (p.100). The targets are "based on our own performance as well as that of industry peers" (p.100).

Reference: page 95.

FLSmidth had 5,494 employees (2024: 7,739), a 29% fall (p.94). By gender: 1,146 female, 4,341 male, 0 other and 7 not disclosed. By contract: 5,296 permanent, 174 temporary and 24 non-guaranteed hours. Countries with more than 10% of the workforce are the USA (978), India (987) and Chile (700).

There were 1,724 terminations in 2025 (2024: 2,575) and a turnover rate of 26% (2024: 30%); people leaving through a divestment are not counted as terminations. Headcount is used rather than FTE, and employees are those paid through the company payroll and active at the report date (p.95).

Reference: page 95.

Non-employees numbered 178 in 2025 (2024: 192), giving a total workforce of 5,672 (2024: 7,931). The report defines non-employees as "all contingent workers who are not part of the FLSmidth payroll". Total workforce includes both employees and non-employees (p.95).

The own workforce chapter says it includes "non-employees including sub-contractors and contingent workers supporting us on specific projects" (p.91). The page gives no breakdown of non-employees by type or gender.

Reference: pages 92, 94.

"In 2025, 10% of our workforce was covered by collective bargaining agreements" (p.94). The company says all employees, whether or not represented by a union, get equivalent protections through global policies, and that terms negotiated in collective agreements are respected and built into its compensation framework (p.94). Employee representatives act as liaisons for concerns and the company states it respects freedom of association and the right to collective bargaining (p.92).

Collective bargaining coverage is listed among the new phase-in KPIs on p.119. The pages give no coverage split by country.

Reference: pages 94, 96.

Top management (the first two levels with manager responsibilities) had 9 people in 2025: 2 women (22%) and 7 men (78%). Including extended management it was 46 people: 4 women (9%), 41 men (89%) and 1 not disclosed (2024: 65 people, 14 women, 22%). The report says the fall reflects cuts in shared functions, where women have historically been more heavily represented (p.94).

Age distribution: under 30, 746 (14%); 30 to 50, 3,291 (60%); over 50, 1,347 (25%); not disclosed, 110 (2%). Headcount by job category: 3,985 white collar and 1,509 blue collar (p.96). Women made up 20.7% of employees on a 12-month rolling average, against a 2030 target of 25% (p.96).

Reference: page 94.

"We analyse living wages across all geographies on an annual basis, ensuring all our workers are paid an adequate and fair wage." As of 2025, "above 95% of headcount" earn a living wage as defined by the Living Wage Institute, and those who do not "still receive compensation that exceeds the state-defined minimum wage". A standardized job catalog supports market-based salary ranges, and terms from collective bargaining agreements are respected in the compensation framework (p.94). A specialist team works on benefits and employment packages "to help ensure equity" (p.94). The page does not break down the share below a living wage by country.

Reference: page 98.

6,678 employees took part in performance and career development reviews in 2025 (2024: 7,554), 87% of headcount at end-March (2024: 86%): 85% of female and 88% of male employees. On the company's "adjusted participation" measure, which counts only eligible employees, participation was 98% (2024: 96%).

Training hours totaled 7,974 (2024: 21,641), or 1.2 hours per employee (2024: 2.5), with 1.6 hours for female and 1.1 for male employees. The report says the drop "has been impacted by the reduction in workforce over the year". Training is offered through e-learning and live and in-person sessions, with a global learning management system tracking progress (pp.97-98). The headcount for reviews is taken at end-March 2025, which is why it exceeds the year-end employee total (p.98).

Reference: pages 99-100.

A Health and Safety Management System certified to ISO 45001 is implemented at all operational sites and covers 100% of the own workforce. There were 0 fatalities in 2025 (2024: 0). The rate of recordable work-related accidents including contractors stayed at 2.3 per million working hours, and the number of recordable accidents was 43 (2024: 50) (continuing activities: 38). The rate of days lost to work-related accidents fell to 0.7 per million hours (2024: 1.0).

The company says it was "behind our 2025 targets" but sees "a positive long-term trend in both measures", with an aspirational zero-harm target for 2030 (p.99). An Incident Review Board reviews major injuries monthly. Subcontractor hours are calculated from supplier-reported hours, tender hours or estimates (p.99).

Reference: page 95 (also page 94).

100% of employees are entitled to take family-related leave, in line with local standards. 6% of employees took family-related leave in 2025: 10% of women and 5% of men (p.95). The measure covers maternity leave including adoption, paternity leave, and carer's leave (p.95).

The company also offers flexible work options, including remote work and adjusted hours where possible, and monitors the effectiveness of these initiatives through engagement surveys (p.94). The p.119 KPI overview lists employees entitled to family-related leave and employees who took it as new phase-in KPIs.

Reference: page 96 (also page 94).

The gender pay gap ratio was 18% in 2025 (2024: 12%), defined as the difference in gross average hourly pay between female and male employees as a share of male pay. The "pay equality ratio" was 40 (2024: 39), defined as the ratio of the annual total remuneration of the highest paid employee to the median annual total remuneration for all other employees (p.96).

The report says its rewards team "continues to bridge the gender pay gap and evaluate progress through a yearly analysis" and that pay equity work focuses on gender equity and employees in lower quartile salary segments (p.94). The index flags the unadjusted gender pay gap and excessive CEO pay ratio data points as derived from SFDR (p.118).

Reference: page 97 (also page 111).

The company reports 42 incidents of discrimination, including harassment, in 2025 (2024: 40). "No severe human rights issues and incidents have been reported during the year" (as printed, before a footnote marker). It also states that no complaints were filed to OECD National Contact Points and no fines or penalties were incurred (p.97).

Page 97 says 110 investigations were opened in 2025, "77 of these were substantiated and 42 were harassment cases"; the whistleblower table on p.111 lists 110 reports submitted and 77 "admissible", and 0 severe human rights incidents. The company enforces "zero-tolerance towards any form of violence, harassment or discrimination" and runs periodic harassment surveys and training (p.97).

Reference: pages 102-103.

Policies for value chain workers are the Supplier Code of Conduct, the Due Diligence Policy, the Human Rights Policy and a Conflict Minerals Sub-Policy (IRO 19, p.102). The Supplier Code has specific provisions on child labor, young workers, forced labor, wages and benefits, and health and safety, applies to all types of workers including temporary and migrant workers, and follows the Responsible Business Alliance Code (p.102). The Human Rights Policy prohibits forced labor, child labor and trafficking, and pays special attention to vulnerable groups including indigenous people, women and children.

For downstream workers (IRO 20), the policy is to deliver products that at minimum meet essential health and safety requirements wherever delivered, with safety assessments covering design, construction, servicing and disposal (p.102). The report notes no cases of non-respect of the UN Guiding Principles, ILO Declaration or OECD Guidelines involving value chain workers (p.102).

Reference: pages 103-105.

The company updated its human rights salience assessment in 2025 and used it to confirm material IROs (p.103). Upstream (IRO 19): a supplier scorecard launched in 2025, supply chain due diligence reinforced across selection, onboarding and performance management, and onsite assessments of selected suppliers prioritizing high-risk countries for child and forced labor. The completion rate of planned onsite assessments was 100% (2024: 92%), 36% of supplier spend was categorized as high risk of forced labor by country (2024: 32%), and 37.5% of suppliers with red flags had implemented corrective actions by year end (p.104). 22 of 66 relevant procurement employees were trained in responsible conduct in the supply chain (p.104).

Downstream (IRO 20): product safety by design, a quality management system certified to ISO 9001, risk assessments to EN ISO 12100, and a secure development lifecycle certified to IEC 62443-4-1 (pp.104-105). Resources include budget for an IT platform, training and audits and staff from procurement, sales, quality and sustainability (p.105).

Reference: pages 104-105.

The human rights training target is shown beside the results: 78% of white-collar employees had completed human rights training in 2025 (2024: 60%), against a 2025 target of 85% and a 2030 target of 98%. The report says "Despite the increase in training we did not meet our 2025 target" (p.104).

On supply chain, the company says that in 2026 it "will track assessed suppliers and their scores to measure progress against our targets" (p.104). For product safety it aims for zero product-related incidents annually (p.105). The Audit, Risk and ESG Reporting Committee reviews the effectiveness of these actions and the human rights risk management, including grievance mechanisms and impact assessments (p.105). From 2026 the human rights impact assessment will be reviewed annually (p.105).

Reference: pages 106 (also pages 57, 76).

Affected communities are material for the company only on financial grounds, as a "license to operate" risk (IRO 8, downstream): mining projects "can affect communities including indigenous peoples through land impacts", which can bring restrictions or delays in customer permits and slow order intake (p.106; p.57).

Policies cited are the Environmental Policy and the Climate Action policy, which commit the company to solutions that let customers maximize yields within a smaller land footprint, and the Human Rights Policy, which applies to own operations and the whole value chain and addresses the rights of vulnerable groups including indigenous peoples (p.106).

Reference: page 107.

The report says mining companies increasingly need to address land-related impacts and secure free, prior and informed consent; failure "could lead to the loss of a license to operate", so the company's response is to develop environmentally responsible and socially conscious solutions for customers (p.107).

In 2025 it set up a Social Action Strategy to fund social initiatives in its operational areas in four domains: health and safety, humanitarian, environment and education. Volunteer-led Social Committees at each location develop local activities, and a monitoring and evaluation framework includes KPI tracking and impact assessments when initiatives finish. The Chief People Officer and Global Business Services EVP oversees the strategy (p.107). No resources or amounts are quantified on the page.

Reference: page 107.

"Our target is to fully implement the Social Action Strategy process by 2026." This is the only target in the affected communities chapter. It covers the process of putting the Social Action Strategy in place, not an outcome measure for communities. The strategy includes a monitoring and evaluation framework with KPI tracking (p.107).

Reference: page 110 (also pages 41-45, 61).

The company's culture rests on five core values, trust, empowerment, accountability, collaboration and honesty (TEACH), discussed in Executive Leadership Team meetings led by the Chief People Officer and Global Business Services EVP. The Code of Conduct "serves as the cornerstone of our business activities", and employees get compliance training on sanctions, bribery and anti-corruption, human rights and the whistleblower hotline (p.110).

The Board and Executive Leadership Team are "deeply involved in our compliance programme", with regular updates from Compliance to the Audit, Risk and ESG Reporting Committee, the Board and the CEO (p.110). Whistleblower protection follows Directive (EU) 2019/1937, and retaliation is not tolerated (pp.110-111). The report says the 2024 survey found 87% of respondents would feel comfortable reporting through the hotline (p.111).

Reference: page 113.

Back-filled from the business conduct chapter, where a target is shown beside the anti-corruption training KPIs. G1-3 became a standalone disclosure requirement only in the 2025/2026 ESRS; the company's index covers this chapter under a combined G1-3 and G1-4 row (p.119).

The anti-corruption training table on p.113 shows targets of 85% for 2025 and 95% for 2030 against the share of white-collar employees who completed e-learning on anti-corruption. Completion was 72% (2024: 79%), below the 2025 target. In-person training reached 62% (2024: 76%), and no target is shown for it. The report says it "will maintain a strong focus on training our employees and providing awareness campaigns related to corruption and bribery to mitigate any potential negative impacts or risks". Effectiveness is also followed through operational assessments of anti-corruption adherence and reporting of findings to the Executive Leadership Team and the Board (p.113).

Reference: pages 111-113.

The corruption and bribery table shows 0 convictions for violations related to corruption and bribery and 0 in fines in both 2025 and 2024 (p.112). The report states "No incidents of corruption or bribery and related fines have occurred throughout the year" (p.113), and "No cases have been reported concerning potential negative impacts on value chain workers, corruption, or bribery" (p.111).

Whistleblower reports submitted totaled 110 in 2025 (2024: 146), of which 77 were admissible; by category, 10 compliance, 17 finance, 71 human resources and 12 other (p.111). The company says it monitors the effectiveness of its processes and remains committed to continuous improvement (p.111).

Reference: page 113.

"We engage with international organisations to provide expertise, share experience, exchange ideas and inform policymakers." FLSmidth is a member of, or engages with, industry associations and advocacy groups to promote policy frameworks and regulations that support the green transition, is "a founding member of the Compliance in Mining Network" and takes part in the Women in Mining initiative. It states "We do not provide support, financial or otherwise, to political or lobbying organisations" (p.113).

The related IRO is an opportunity (IRO 23, partnerships with industry groups to support the future of mining) rated medium-term (p.109). The page gives no lobbying spend and no list of associations or positions.

Reference: page 112.

"FLSmidth's standard contract payment terms are a minimum of 90 days for all supplier categories", though alternative terms can apply depending on the service and region. Average days to payment were 61 in 2025 (2024: 59), and there were 7 outstanding legal proceedings over payment delays (2024: 0). Average days payment is calculated from supplier invoicing data using the span between the upper and lower quartile to remove dispute-related outliers.

Accounts payable has been outsourced to a specialist third party, overseen by the global business center, to improve efficiency and pay suppliers on time, and a supplier financing program lets suppliers receive faster payment (p.112). The related IRO is a negative impact in own operations from delayed supplier payments (IRO 21, p.109).