Fortaco Group Holdco Oyj

Governance roles

Reference: pages 40-41.

Fortaco has a Supervisory Board, which oversees management, and a Board of Directors (the management board). The Supervisory Board has three to six members elected by the General Meeting and "does not include workers' representatives". In 2025 the Board of Directors had one ordinary member, the President and CEO, and one deputy member, the Senior Executive Vice President and CFO.

The Board of Directors is "Fortaco's highest body overseeing sustainability" and approves policies. The Group Leadership Team approves strategic sustainability targets, and the Director of Group Sustainability is responsible for implementing them.

Composition (page 41): the Supervisory Board had 5 members in 2025 (4 in 2024), all non-executive. The Board of Directors had 2 members in both years, both executive. Female members: 0% on both bodies in both years. Independent members: 0% on both. Fortaco notes it adopted a more conservative approach to assessing independence in 2025 and updated the 2024 figures. All members of the Group Leadership Team and Senior Leadership Team took sustainability training in 2025 (page 40).

Information provided to the governing bodies

Reference: pages 40-41, 43.

In 2025, progress toward sustainability targets went to the Group Leadership Team quarterly and to the Board of Directors "sporadically", while key performance indicators were reported more often. Business sites report a selection of sustainability indicators monthly to the Senior Leadership Team. Sustainability reaches the Supervisory Board at least once a year (page 40).

Sustainability is a standing item on Group Leadership Team agendas, presented by the Group Director of Sustainability. In 2025 the Board of Directors and Group Leadership Team worked on sustainability targets and policies, finalizing the climate program, employee wellbeing and development, occupational safety, information security and regulatory change (page 41). The Group Sustainability Director reports identified skill gaps to the Group Leadership Team. The material impacts, risks and opportunities from the spring 2024 assessment were reviewed and "no changes has been made" (page 41). Stakeholder views reach the Group Leadership Team at least twice a year (page 43).

Sustainability in incentive schemes

Reference: pages 41, 54.

Fortaco states that no sustainability-related performance measure sits in its incentive schemes or remuneration policies yet. It says it will develop its target-setting model and look at how remuneration could encourage continuous assessment and improvement of sustainability matters (page 41).

For climate, the E1 chapter says climate-related factors "are not yet considered in the remuneration", and that Fortaco will investigate how to do this in the future (page 54). The content index lists GOV-3 under both ESRS 2 and E1 (pages 85-86).

Statement on due diligence

Reference: pages 41-42.

Fortaco "carries out sustainability due diligence to identify and monitor its impacts on the environment and people connected to the business". It states that environmental, human rights and governance due diligence is part of its management systems and key processes (page 41).

A table maps the five core elements of due diligence to sections of the statement. Embedding due diligence in governance, strategy and business model maps to ESRS 2 and G1. Engaging affected stakeholders maps to ESRS 2, S1, S2, S3 and G1. Identifying and assessing adverse impacts, taking action on them, and tracking effectiveness each map to ESRS 2, E1, E2, E4, E5, S1, S2, S3 and G1 (page 41).

Risk management and internal controls over sustainability reporting

Reference: pages 41-42.

In 2025 Fortaco added all identified sustainability impacts, risks and opportunities to its group-wide risk management system, which assesses probability and impact on a regular cycle. The Risk Management Handbook sets roles, responsibilities and processes (page 42).

Fortaco names these risks to its sustainability reporting: "limited visibility into the upstream value chain, particularly beyond first-tier suppliers, scattered data, and sustainability reporting process under constant development". Suppliers are not yet required, or able, to share the complex data needed for emission calculations (pages 41-42).

Its responses are closer supplier dialogue, clearer supplier expectations, building internal sustainability skills, and limited assurance by an external auditor (page 42). Reporting is coordinated by the Group Sustainability Director, part of Group Finance, and site and function experts collect the data. 77% of operations hold ISO 14001 and ISO 9001 certification and 36% hold ISO 45001 (page 42).

Strategy, business model and value chain

Reference: pages 42, 46.

Fortaco describes itself as "the leading brand-independent strategic partner to the heavy off-highway equipment". It serves OEMs in agriculture, construction equipment, container handling, defense, forestry, marine and energy, material handling and mining. The offering covers assemblies, vehicle cabins and steel fabricated components, plus technology services and zero emission solutions (page 42).

It runs nine business sites in Austria, Estonia, Finland, France, Poland and Slovakia (page 63). The group had 2,567 employees at year-end 2025 (page 72) and 348 MEUR of turnover in the EU Taxonomy table (page 53). Purchases come "predominantly" from European suppliers, and steel parts are about 50% of purchases by spend (page 66).

Fortaco says it has not set sustainability-related goals for specific products, services, customer categories or geographical areas (page 42). A value chain diagram marks where the material impacts, risks and opportunities sit (page 46).

Interests and views of stakeholders

Reference: pages 42-43.

A table (page 43) lists eight stakeholder groups, how Fortaco engages each, the purpose, and example outcomes: employees, customers, suppliers, owners and investors, governments and regulators, civic and non-profit organizations, industry and sustainability associations, and local communities. Channels include employee surveys and European Works Council dialogues, customer data requests, supplier self-assessments and on-site audits, investor calls, and joint community projects.

The views of affected stakeholders reach the Group Leadership Team at least twice a year, from the Group Sustainability Director, the Senior Vice President People and HR, and the Group QHSE Director. The Supervisory Board is informed annually by the CEO and CFO (page 43).

Fortaco states: "In 2025, strategy and business model has not been amended because of interest or views of its stakeholders" (page 43). It notes that owners, investors, customers and regulators are raising their expectations on sustainability performance.

Material impacts, risks and opportunities

Reference: pages 42, 44-51.

Fortaco states that the material impacts, risks and opportunities "identified as material for Fortaco are 42" (page 45). E1, E2, E4, E5, S1, S2, S3 and G1 are material; E3 and S4 are not (pages 45, 51). The tables on pages 47-51 list 7 entries for E1, 6 for E2, 2 for E4, 4 for E5, 8 for S1, 6 for S2, 3 for S3 and 6 for G1. Each carries a type, a location (own operations, upstream or downstream value chain) and a time horizon. A value chain diagram on page 46 places them.

Fortaco says they "do not change our business model or strategy significantly" (page 42). The 2025 climate scenario analysis updated the E1 entries (page 44). Most entries sit in own operations and the upstream value chain: raw material extraction and steel production, and Fortaco's own welding, painting and e-coating.

Page 42 says "20 material risks were identified". The tables on pages 47-51 show 18 entries typed as risks (our count).

Process to identify and assess material impacts, risks and opportunities

Reference: pages 44-45.

Fortaco ran its first double materiality assessment in spring 2024 with external guidance, following ESRS and EFRAG guidance and building on a 2022 assessment. It covers impacts (inside-out) and financial exposure (outside-in) across the upstream value chain, own operations and downstream. The process has 6 steps (page 45): value chain and stakeholder definition, identification of impacts, risks and opportunities, materiality assessment, financial assessment, and review and validation.

Scoring uses scale, scope, irremediability and, for potential items, likelihood. Fortaco's cut-off for materiality: "if any of the parameter scores was identified as 4 or higher on a scale from 1-5, the sustainability matter has been defined as material" (page 44).

Internal experts from sites and group functions took part. Customers, suppliers and an industry association were consulted, but "External stakeholders were not directly consulted to the same extent as internal experts" (page 44). In 2025 the results were reviewed and the climate analysis updated E1; "No other changes have been significant enough to amend the previously reported DMA results" (page 44). Fortaco plans an annual review and a fuller re-assessment at least every five years (page 45).

Page 45 states both a "final list of 24 material matters" and a total of 42; the 42 matches the tables.

Disclosure requirements covered by the sustainability statement

Reference: pages 82-88.

The appendix "ESRS disclosure requirements complied with" (pages 85-88) lists the disclosure requirements Fortaco treats as material, with page references. It states that "Topical standards E3 and S4 are below our materiality thresholds and have therefor been omitted" (page 85).

The index lists: ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2); E1-1 to E1-6; E2-1 to E2-5; E4-1 to E4-4; E5-1 to E5-5; S1-1 to S1-6, S1-13, S1-14 and S1-17; S2-1 to S2-5; S3-1 to S3-5; and G1-1, G1-2, G1-3, G1-4 and G1-6.

It does not list E1-7 to E1-9, E2-6, E4-5, E4-6, E5-6, S1-7 to S1-12, S1-15, S1-16 or G1-5. A separate appendix (pages 82-84) lists datapoints derived from other EU legislation, each flagged "Material", "Not material" or "Phased in".

Transition plan for climate change mitigation

Reference: pages 57, 59, 61.

Fortaco has no adopted transition plan. It states it has "prepared science-based targets and transition plans in accordance with ESRS E1-1 DR 17 that will be approved by the Supervisory Board and can then be submitted to the SBTi". The aim is for the Supervisory Board to approve the climate program in 2026. The plan is to cover "decarbonisation actions related to our own operations and our value chain" (page 57).

Actions in 2025 "did not require significant Capex or Opex", and a site-level cost analysis needed before Board approval is planned for 2026 (page 57). The GHG table's milestone columns for 2030 and 2050 are empty (page 59). Page 61 says science-based decarbonization targets "have been set" in December 2025, with monitoring from 2026; no target values are disclosed anywhere in the statement.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 climate scenario analysis, where this content is disclosed in the FY2025 report (pages 54-56). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Fortaco ran a climate risk and scenario analysis in autumn 2025 covering upstream, own operations and downstream. It says the analysis followed "ESRS E1-2 requirements" (page 55). Risks are split into physical (acute and chronic) and transition; the E1 table on page 54 types the extreme weather item as a physical risk and the steel price item as a transition risk.

Scenarios (page 55): IPCC RCP4.5 and RCP8.5 for physical risk, described as warming of "over 2°C and 4°C", and IEA Net Zero by 2050 for transition risk. Data sources were IPCC reports and the IPCC Interactive Atlas, plus a literature review. Time horizons are short (up to 1 year), medium (2-5 years) and long (over 5 years).

A panel of Fortaco operational and financial specialists scored likelihood and financial impact on a 0-5 magnitude scale. Hazards considered: temperature, wind and precipitation changes, storms and floods. The report gives no scenario-by-scenario temperature projection beyond that wording.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the E1 resilience text, where this content is disclosed in the FY2025 report (pages 42, 55-56). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Fortaco states it ran a resilience analysis of its material climate risks and opportunities in 2025, through scenario analysis, with operational and financial specialists and external experts (pages 42, 55). For extreme weather it expects investment in cooling systems and renewable energy in the medium term, and changes to transport routes and sourcing in the long term (page 55).

Uncertainty (page 55): "The frequency and severity of extreme weather events may differ from scenario assumptions, and the timing of chronic hazards such as heatwaves is uncertain."

Result (page 56): planned measures are expected to cut the magnitude of risks by about 20% and their likelihood by about 50% in the long term. "None of the risks exceed manageable level (magnitude 3) and the actions to mitigate them are resourced already in investment plans." Fortaco concludes its operations are resilient under the analyzed scenarios. One sentence on page 56 still refers to a scenario analysis as something to be done in the future.

Policies related to climate change mitigation and adaptation

Reference: pages 54, 56.

Fortaco has no climate policy: it "has not yet a policy for climate change or included in its current policies how to manage impacts and risks related to climate change". Work on adding climate to policies started in 2024 and continues (page 54). Accountability sits with the Group Leadership Team, steered by the Group Sustainability Director.

Page 56 sets out levers across the value chain instead. Upstream, Fortaco engages first-tier suppliers on science-based targets, climate reporting and decarbonization, and supports fossil-free steel. In own operations, Scope 1 and 2 are about 10% of emissions and upstream Scope 3 about 90%. Downstream, a Zero Emission Solutions team works on green steel, lightweight components and electrification products.

Actions and resources in relation to climate change policies

Reference: pages 57-58.

Actions in 2025 focused on own operations and the upstream value chain, and each business site is accountable for its own. Named actions (page 57):

• Compressed air systems replaced with higher efficiency units, with waste heat recovery at Wrocław and Janów Lubelski.
• Remaining sites converted to LED lighting; all units use LED as the primary lighting by year-end.
• Building controls and heating settings improved at Wrocław and Kurikka, cutting energy use outside operating hours.
• At Narva, an older building was repurposed as unheated storage.
• At Sablé, a heat pump replaced gas-based heating.

Realized energy savings were 4,461 MWh in 2025 (page 58). On resources: "Actions taken in 2025 did not require significant Capex or Opex as disclosed in the Financial Statements", and a fuller cost analysis is planned for 2026. Fortaco reports no EU Taxonomy-eligible activities for climate change mitigation or adaptation (page 57).

Targets related to climate change mitigation and adaptation

Reference: pages 57-59.

The one group-level climate-related target is for energy: cumulative savings of 10% of the 2022 baseline over 2023-2025. The baseline was 69,358 MWh across nine sites and 52,592 MWh after excluding divested sites, giving a target of 5,259 MWh (page 57). The target "is not linked to a specific policy" and covers own operations.

Achieved savings: 2,221 MWh (2023), 3,417 MWh (2024), 4,461 MWh (2025), 10,099 MWh in total, which Fortaco says exceeds the target by 92% (page 58). Total energy consumption fell 2% against 2022 and 9% against 2024.

There is no published GHG reduction target. Fortaco says science-based targets are prepared and await Supervisory Board approval, and that new energy targets will be set with the climate program (page 57). The GHG table's target-year columns are empty (page 59).

Energy consumption and mix

Reference: pages 58-59.

Total energy consumption was 68,162 MWh in 2025 (2024: 74,702 MWh), or 196 MWh per MEUR of net revenue (210).

Fossil: 46,408 MWh (38,569), a 68% share (52%). This includes natural gas 17,289 MWh, crude oil and petroleum products 1,937 MWh, other fossil fuels 2,944 MWh, and fossil-sourced electricity, heat, steam and cooling 24,238 MWh (13,871). Nuclear: 6,211 MWh (11,378), 9% (15%). Renewable: 15,543 MWh (24,755), 23% (33%), of which purchased renewable electricity, heat, steam and cooling 14,984 MWh, self-generated 518 MWh and renewable fuels 41 MWh.

Purchased electricity for the Gliwice site is estimated. Fortaco classes itself in the manufacturing sector (NACE section C), a high climate impact sector (page 58).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 58-59.

2025 (2024), tCO2eq: Scope 1 4,933 (6,107), down 19%. Scope 2 location-based 15,877 (17,408); market-based 18,507 (17,203), up 8%. Scope 3 282,909 (313,161), down 10%, of which purchased goods and services 281,153, fuel- and energy-related activities 6 and upstream transportation and distribution 1,750. Total 303,719 location-based and 306,349 market-based (336,676 and 336,470). Intensity: 872 location-based and 880 market-based tCO2eq per MEUR of net revenue (944 in 2024) (pages 58-59).

Fortaco says only one of the 15 Scope 3 categories is material, and it also reports categories 3 and 4. Product-specific emission factors cover 18% of materials with known weight; 37% of emissions use OpenCO2 factors; the 63% where no physical quantity exists uses Exiobase spend-based factors (page 59). The 2024 figures were recalculated. Biogenic emissions were not calculated separately, with separate disclosure planned for 2026.

Policies related to pollution

Reference: pages 60-61.

Fortaco's commitment on environmental matters is set out in its EHS Handbook, which it calls its policy. The stated aims are to be "in harmony with our environment", improve resource efficiency and fully comply with legal requirements (page 60). Each business site runs an ISO 14001 environmental management system, except Breitenau (Austria), acquired in 2023, where one is scheduled for 2027. Environmental permits set emission limits at some sites, and internal audits cover all sites on a 3-year schedule.

The focus is own operations. For the value chain, Fortaco says that specific policies on emissions to air, soil, water and noise "has not yet been established" and are covered only generally in the Supplier Handbook and Code of Conduct (page 61). Accountability sits with the Group Leadership Team, steered by the Group QHSE Director with the Group Sustainability Director (page 60).

Actions and resources related to pollution

Reference: pages 61-62.

Fortaco lists standing actions run by the business sites, with Group EHS monitoring: reviewing legal requirements, updating environmental goals, evaluating impacts and risks each year, testing emergency procedures, identifying training needs, and exploring "less hazardous chemicals products" with chemical and paint suppliers (page 61).

For welding fumes, past investments went into source exhaust and background ventilation with filtering; no further investment in indoor air quality or air emissions was made in 2025 because installed filters perform as expected (page 61). In 2025 Fortaco invested in both e-coating and wet painting at Breitenau (Austria), mainly for efficiency and continuity, and the new equipment also cut pollutant emissions (page 62). No amounts are given.

Targets related to pollution

Reference: pages 61-62.

Fortaco states: "On group level Fortaco has not set specific targets for decreasing pollution." Permits are set country by country with different limits, so no group consolidation exists. Site-level targets are expected to bring emissions close to the limit values (page 61).

The only monitored group-level target linked to air emissions is the energy reduction target (10% from the 2022 base year by end of 2025), which affects CO2eq emissions. Science-based decarbonization targets were set in December 2025, with monitoring from 2026 (page 61). No environmental claims, compensation or media coverage on pollution were recorded in 2025, and there was no deviation from environmental permits (page 61).

Pollution of air, water and soil

Reference: pages 61-62.

Air emissions in own operations come mainly from welding (fumes, dust particles, heavy metals) and from painting (VOCs). Fortaco says that none of its air pollutants "reaches disclosing threshold set in Annex II of Regulation (EC) No 166/2006" (the E-PRTR Regulation) (page 61). No pollutant amounts are tabulated, although the appendix lists the E2-4 E-PRTR pollutant amounts datapoint (paragraph 28) as "Material" at page 61 (page 83). Ozone and nitrogen oxides from welding "have not been estimated" because the amounts are small.

VOCs from wet painting are calculated from paint supplier templates and actual paint consumption. Sites in Estonia, Poland and Slovakia report consumption of welding wire, paints and solvents to authorities through an online portal, and pollutants such as VOCs, solid particles and TOC are calculated from it (page 62). In Slovakia an external air-emission measurement is required every six years; it was done in September 2025 and "no emission limits were exceeded" (page 62). Pollution of water and soil appears only in the upstream supply chain (page 60).

Substances of concern and substances of very high concern

Reference: page 62, as listed in the content index (page 86).

The content index lists E2-5 at page 62. That page covers VOC emissions from wet painting, the Breitenau e-coating and wet painting investment, and emission monitoring in Estonia, Poland and Slovakia, then starts the E4 chapter. The statement has no section on substances of concern or substances of very high concern, and gives no amounts generated, used, procured or leaving its facilities, split by hazard class.

The nearest content is on E2 and E5. The E2 impact table covers pollution of air, water and soil only, and none of its entries names substances of concern (page 60). Fortaco says it will "explore opportunities with chemical and paint suppliers to use less hazardous chemicals products" (page 61), and the Supplier Handbook "covers themes such as material certifications and materials of concern" (page 64). Hazardous waste of 471 tonnes is reported under E5-5 (page 66).

Transition plan and consideration of biodiversity in strategy and business model

Reference: pages 62-63.

Fortaco has no biodiversity transition plan. It says its material impact on biodiversity "is located upstream in the value chain, connected to mining and extraction of raw materials", and that it has "not yet assessed the resilience of our business model and strategy to biodiversity and ecosystems-related risks" (page 62).

It found no material negative impact from land degradation, desertification, soil sealing or threatened species in its own operations. A 2025 update of the biodiversity assessment confirmed that none of the nine sites is inside a protected area. Two are near one: Janów Lubelski (Poland), less than 1 km from Lasy Janowskie Landscape Park, and Breitenau (Austria), about 1 km from Feuchte Ebene. A 2018 third-party assessment of Janów Lubelski found no negative effect under normal conditions (page 62). Fortaco will reassess own-operations impact in 2026 as part of updating the DMA (page 63).

Policies related to biodiversity and ecosystems

Reference: pages 62-63.

Fortaco states that "Biodiversity related to our material risk and impact is not yet addressed in our policies and related actions" (page 62). In 2025 it reviewed the policies covering its supply chain with the direct drivers of biodiversity loss in mind, but "no changes were yet made in reviewed policies".

Biodiversity and ecosystem protection "has not been addressed in policies yet" (page 63). Fortaco plans to clarify its biodiversity ambition, add KPIs to its reporting, and look at putting biodiversity into supplier requirements. Accountability for outlining policies lies with the Group Leadership Team, steered by the Group Sustainability Director.

Actions and resources related to biodiversity and ecosystems

Reference: pages 62-63.

Fortaco has no dedicated biodiversity actions. It says it has "adopted actions that indirectly mitigates our impacts and risks": local environmental permits and ISO certifications in own production, and supplier selection criteria, screenings and audits that include environmental aspects (page 63). The 2018 Janów Lubelski assessment and the 2025 protected-area check are the site-level work described (page 62).

Planned for 2026 onward, if biodiversity stays material: identify which materials have the greatest biodiversity impact, review the biodiversity risk of those supply chains, and work with suppliers on cutting negative impacts (page 63). No resources or amounts are stated.

Targets related to biodiversity and ecosystems

Reference: page 63.

"Fortaco's current target is to maintain the local environmental permits and certifications in own operations. No specific targets have yet been set for upstream biodiversity impacts and risks." Fortaco says it will look at the need to set targets for its own locations, and in the long term aims to set specific biodiversity targets and plan actions for the upstream value chain.

Policies related to resource use and circular economy

Reference: pages 64-65.

Fortaco's approach to circularity rests on three principles (page 64): reduce resource use through design and offering; maximize the value of components and products through repair, refurbishment and reuse; and repair, recover or recycle all possible materials before end of life in manufacturing.

Policy coverage: the Supplier Handbook "covers themes such as material certifications and materials of concern", and the EHS Handbook sets expectations and tools for resource efficiency and waste management (pages 64, 65). Targets and waste are managed at business sites, with the Group QHSE Director monitoring. Accountability for circularity in product design lies with VSP Technology, and for sourcing with VSP Sourcing and IT (page 64).

Actions and resources related to resource use and circular economy

Reference: pages 65-66.

Actions in 2025 (page 65): steel material efficiency metrics were introduced to track steel used in finished products against scrap, with reported site performance of 68-78%; collaboration with steel suppliers on low-emission steel grew, and the share of low-emission steel purchased increased; waste handling facilities at Janów, Narva and Wrocław were rearranged to limit mixing of wastes and spills; waste guidelines and training were improved at all sites; and at Narva broken wooden pallets are now repaired and reused, with more than 22,000 pallets, close to 100%, taken back into use.

Fortaco plans to keep working on material efficiency in product design, supply chain and own operations in 2026 and beyond. No resource amounts are stated.

Targets related to resource use and circular economy

Reference: pages 65-66.

Fortaco says it has "voluntarily set targets" (page 65) on two measures. First, a 65% recycling rate by 2028, defined as recycled waste out of total waste excluding scrap steel; the rate was 43% in 2025, up from 34% in 2024. Second, steel material efficiency of 80% by 2030, defined as steel used in products over total steel purchased; Fortaco says measurement and monitoring for this are "yet to be defined and implemented".

Each business site sets its own supporting targets, which sit in the EHS Handbook. No numerical targets are set for waste categories or hazardous waste volumes. Measurable targets for circularity in the value chain (inflows and product circularity) are "yet to be set" (page 66).

Resource inflows

Reference: pages 64, 66.

Total products and materials used came to 81,200 tonnes in 2025 (2024: 74,400, restated), with weight data available for 74% of direct spend (57% in 2024) and the rest estimated. Technical materials were 1,990 tonnes in 2025; no 2024 figure is given because of limited data. No biological materials, recycled or reused inflows are reported (page 66).

Steel parts are about 50% of purchases by spend, electrical components about 20% and mechanical components about 20% (page 66). Steel is 63% of sourced materials (page 64). Fortaco says it "has in 2025 not collected information on amounts of recycled and used components on group level", with monitoring planned from 2025 now pushed into 2026 (page 66).

Resource outflows

Reference: page 66.

Fortaco's main waste is steel scrap from production, plus plastics and packaging. Total waste was 11,320 tonnes in 2025 (2024: 10,924). Of that, 9,625 tonnes (9,250) was diverted from disposal, all as recycling, and 1,696 tonnes (1,674) went to disposal: 875 tonnes incinerated (648), 349 landfilled (366) and 471 hazardous (660), none of it radioactive. The non-recycled share was 15% in both years.

Fortaco says products are tailored to customers and designed with them, and that it is working to make products recyclable (page 64). The statement gives no product durability or recyclable-content figures. Waste detail is in the E5-5 waste entry.

Waste

Reference: page 66.

Waste in tonnes, 2025 (2024): total 11,320 (10,924). Diverted from disposal 9,625 (9,250), all recycled. Directed to disposal 1,696 (1,674): hazardous 471 (660), non-hazardous 1,225 (1,014), of which incinerated 875 (648) and landfilled 349 (366). Non-recycled waste is 15% of the total in both years; hazardous waste is 471 tonnes, none radioactive.

Hazardous waste comes mainly from the paint shop, machining and cutting oils. Amounts come from invoices from waste companies and are sorted into landfill, recycled and incinerated. Fortaco says it "does not currently collect and consolidate Group-level data for each waste category as defined in the European Commission's List of Waste". Most waste goes to external companies whose operations are subject to environmental permits (page 65).

Policies related to own workforce

Reference: pages 67-71.

Own-workforce topics are covered by the Code of Conduct, EHS Handbook, Safety Handbook, the HR policy (People Handbook) and the HR Manual. The Group Leadership Team approved them, and together they cover "all employees and contractors" at business sites (page 68). Fortaco says it respects the International Bill of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work, guided by the UN Guiding Principles and OECD Guidelines (pages 68-69). The Code of Conduct and People policy cover freedom of association, collective bargaining, forced and child labor, and discrimination (page 68).

On safety, the Safety Handbook covers all employees and facilities, and nine Golden Safety Rules apply to all employees. The Group QHSE Director is accountable and site General Managers implement locally (page 69). The occupational health and safety system meets ISO 45001 requirements at all sites except those in Austria and France; certificates exist at Narva and Kurikka, with one more site planned each year (page 69). Since the sale of the Serbian operations in July 2025, all entities operate within the EEA (page 67).

Taking action on material impacts on own workforce

Reference: pages 68-71.

Safety and health (pages 68-69, 74): Safety Days, risk assessments, accident and incident analysis, personal risk dialogues, emergency drills and safety trainings. Fortaco trained six mental health ambassadors (page 69), and page 74 says seven health ambassadors were trained in 2025 as part of its Mental Health Program, which also runs webinars and local-language mental health protocols.

Skills and employment (pages 69-70): training programs, mentoring and change management to build "enough competent and resilience workforce" (page 69). Actions in 2025 centered on leadership development, a mentoring program for production employees, and succession and skill matrix apps. September 2025 was a group-wide Training Month with Code of Conduct, anti-harassment, anti-bribery and whistleblowing courses.

Fortaco says the People & HR team allocates targeted financial resources to safety, training, wellbeing and health initiatives; no amounts are given (page 68).

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

Reference: pages 71-72.

Fortaco states that its workforce targets "are long-term goals to improve health, safety and wellbeing of our employees" and that "Not all are yet time-bound with set baseline and monitored action plan" (page 71).

Safety: a target to continuously decrease the lost time injury frequency (LTIF), reported monthly to group management. A second measure is safety action frequency: preventive safety actions rose 14% to 5,697 in 2025, about 3 per employee, and the target is to extend the practice to new sites and increase the count. Engagement: a target to improve the Pulse survey score, with no set baseline, monitored annually (page 71).

Fortaco says targets are set with employees and union representatives and that progress is shared with them (page 72).

Characteristics of the undertaking's employees

Reference: pages 72-73.

At year-end 2025 Fortaco had 2,567 employees (2024: 2,299): 307 women and 2,260 men, with none recorded as other or not disclosed. Of these, 2,234 are permanent (285 women, 1,949 men) and 333 are temporary (22 women, 311 men). All non-guaranteed hours employees are also temporary employees (page 73).

By country, 2025: Poland 926, Finland 487, Estonia 429, France 355, Austria 244, Slovakia 126. In 2024 the count also included Serbia (92), sold in 2025 (page 72).

437 employees left in 2025 against 576 in 2024, a turnover rate of 17% (25%), calculated against average employee numbers. Fortaco describes the headcount increase as 12% (page 72). Headcount comes from People & HR system records at 31 December (page 73).

Training and skills development metrics

Reference: pages 69-70.

The index lists S1-13 at pages 69-70. The one metric given is that "In 2025, 100 percent of our white-collar employees had all their planned development discussions with a superior" (page 70). Development discussions are held twice a year.

The rest is descriptive: an onboarding process in all local languages, the Apprix e-learning portal, a Fortaco Group Training Procedure for external training, a group-wide Training Month in September 2025 with Code of Conduct, anti-harassment, anti-bribery and whistleblowing courses, and leadership, mentoring and succession programs (page 70). The statement gives no average training hours per employee and no breakdown by gender or employee category.

Health and safety metrics

Reference: page 74.

2025 (2024): fatalities 0 (0); total recordable injuries 42 (49); total recordable injury rate 11 (12), measured per one million hours worked; recordable work-related ill health cases 0 (2); lost days 745 (723). The fatality count includes external workers such as contractors and covers work-related travel including commuting.

36% of own and external workers are covered by an ISO 45001-certified management system (35%), although Fortaco says its health and safety management system "covers 100% of business sites including also external workers". Lost time injury frequency (LTIF) is named as the primary safety indicator (page 71), and the S1 tables carry the recordable injury rate instead.

Incidents, complaints and severe human rights impacts

Reference: page 74.

2025 (2024): substantiated discrimination incidents, including harassment, 0 (1); severe human rights incidents 0 (0); complaints filed through internal channels 21 (19), counting all categories whether substantiated or not; monetary penalties paid for damages EUR 0 (0).

Fortaco says it "does not yet have a separate process for monitoring complaints filed externally with national contact points under the OECD Guidelines". Incidents on suppliers' employees are covered under S2 (page 74).

Policies related to value chain workers

Reference: pages 75-76.

Fortaco states it "has not yet publicly outlined a formal policy to uphold human rights, including labour rights in the value chain" for value chain workers (page 75). In its place, the Code of Conduct and the Supplier Handbook (the supplier policy) cover ethical conduct, labor and human rights, and safe working conditions, and set expectations tied to the UN Guiding Principles, OECD Guidelines and ILO Declaration (pages 75-76).

The Code of Conduct is attached to the general terms and conditions of supplier contracts. In 2025 Fortaco prepared a separate Supplier Code of Conduct, planned for introduction to suppliers in 2026 (page 76). Fortaco also says "management of identified material risks related to value chain workers will be reviewed and mitigation actions developed further in the future". Dependencies on value chain workers have not been identified (page 75).

Taking action on material impacts on value chain workers

Reference: pages 75-76.

The material impacts and risks were first identified in the 2024 assessment. Fortaco says initial work on an approach and policy, targets and actions began that year, but "progress in 2025 was limited due to competing priorities" (page 76).

The 2025 action named is the Supplier Code of Conduct, which sets expectations and asks for grievance mechanisms for suppliers' workers, with use planned in 2026. Supplier screenings, assessments and audits continue (see G1). Fortaco notes its ability to affect treatment of workers beyond direct suppliers is limited, and says it will look at higher expectations of direct suppliers and ask for more information on how its materials are sourced (page 75). No resources are stated.

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

Reference: page 76.

Fortaco reports no targets for value chain workers: "we have not yet set targets for in relation to the material topics". It says it will review current processes, identify gaps, and plan targets and actions for the material risks, with no date given.

Policies related to affected communities

Reference: page 77.

Fortaco's commitment to uphold human rights and engage with communities is set out in its Code of Conduct, with the Supplier Handbook setting expectations of suppliers (page 77). It also states that "Indigenous people are not addressed specifically in the policies".

The statement says the work to "outline a general approach and policy, set targets and plan actions has not been priority during this reporting period". The material impacts sit upstream, in raw material extraction and production in countries such as China, Australia and Brazil (page 77).

Taking action on material impacts on affected communities

Reference: pages 77-78.

Fortaco's stated approach is to avoid and mitigate impacts on communities by choosing business partners carefully, strengthening supply chain monitoring and supporting suppliers in meeting ESG requirements (page 78). Management of these impacts sits with the Group Sustainability Director, with the Group Leadership Team members for People & HR and for Supply Chain and IT (page 77).

Fortaco states that the work to set up a general approach, targets and actions "has not been priority during this reporting period" (page 77). It points to actions in E1, E2, E4, E5 and S2 that have upstream effects (page 78). No resources are stated.

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

Reference: page 78.

Fortaco states that it "had not yet in 2025 set specific targets and actions linked directly to material impacts and risks related to affected communities". Its stated vision is to operate with minimal negative impact and maximal positive impact on communities in its value chain, and it points to its environmental and supplier engagement work as having upstream effects.

Business conduct policies and corporate culture

Reference: pages 79-81.

Business conduct is guided by the Code of Conduct and policies approved by the Group Leadership Team, overseen by the Group Legal Director and reported to the Board of Directors. The code covers fair business, anti-bribery and anti-corruption, working with political decision makers and civil servants, entertainment, and reporting suspected misconduct. Legal compliance policies on anti-bribery and anti-corruption, whistleblowing, competition, data protection and trade compliance were approved in 2024 and continued to be put in place in 2025 (page 79). Policies do not cover animal welfare, which Fortaco does not see as material (page 79).

All employees complete a Code of Conduct e-learning course on joining and at least every second year; September 2025 was a group-wide Training Month with four modules (page 79). The whistleblowing channel runs in ten languages on the intranet and takes anonymous reports, with a standard operating procedure for investigation (page 80). Internal audit reports to the Board and does not yet have sustainability as a separate topic (page 79).

Targets related to business conduct

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

Fortaco states: "At Fortaco we have set targets and KPIs to measure business conduct and ethical operations" (page 81). Two are described:

• All employees complete Code of Conduct training on joining and at least every second year (page 81).
• By 2030, 80% of direct suppliers committed to Fortaco's Code of Conduct. A baseline assessment began in 2025, but "the project was not finalised but continues in 2026" (page 81).

Fortaco also says it plans to investigate targets for suppliers in high-risk corruption countries while the baseline is assessed (page 81). It began tracking the whistleblowing substantiation rate in 2025.

Incidents of corruption or bribery

Reference: pages 80-81.

2025 (2024): convictions 0 (0); fines for violation of anti-corruption and anti-bribery laws EUR 0 (0) (page 80). Fortaco states it "has not been fined or convicted for violating any anti-bribery or anti-corruption laws" in 2025 (page 81).

Whistleblowing reports covered bribery, fraud and other inappropriate conduct. Each was investigated, none was critical to the business or changed financial results, and none led to convictions (page 81).

Payment practices

Reference: page 81.

In 2025 it took Fortaco on average 50-52 days to pay an invoice from receipt or full delivery. The standard payment term in its general terms and conditions is 48 days on average for all main supplier categories, and can differ for smaller suppliers.

Fortaco says there was no regular follow-up in 2025 of how actual payments compared with the contractual terms. Based on a selected scope it estimates that 30% of payments followed the contractual payment terms. Fortaco "is not party to any legal proceedings due to late payments".