Framery Group Oyj

Reference: pages 23-24 (Sustainability governance; Board composition table).

All five Board members are non-executive. One is a woman (20%). All are independent of the Company and 60% are independent of significant shareholders. No employees or other workers are represented on the Board (page 23). Board experience cited includes US markets and the office furniture industry (Gregory Bylsma) and digital products (Timo Toikkanen).

There is no separate sustainability committee: "sustainability oversight is carried out by the full Board". Reporting oversight sits with the Audit Committee of three Board members (page 24). The Board sets the sustainability ambition level, approves the sustainability program at least annually and confirms the key targets the Management Team proposes (page 24).

The Management Team (the CEO and nine Function Leaders) is accountable for execution. A Sustainability Steering Group meets monthly. The Sustainability Manager reports operationally to the Head of R&D and functionally to the Management Team (page 24).

Reference: page 24 (Information provided to and sustainability matters addressed by Framery's administrative, management, and supervisory bodies).

At a minimum the Board gets an annual sustainability update covering progress on ESG targets, a review of the coming Sustainability Statement, the Principal Adverse Impact indicators for Vaaka Partners (the largest owner at listing), and regulatory updates.

Topics in front of the Board in 2025: a review of the 2024 Sustainability Report; an update of the Sustainability Program with a focus on climate actions; achieved and planned GHG reductions against the Science Based Targets; employee well-being and safety performance; and the outcome of the updated DMA, including stakeholder inputs and the list of material topics. The Board approved Framery's continuing commitment to the SBTi, and as a whole reviews the Sustainability Statement and the external assurance findings.

The Management Team discusses sustainability progress at least annually before the Board meets.

Reference: page 24 (Sustainability-related performance in incentive schemes). The index lists GOV-3 under both ESRS 2 and E1 (page 20).

"As of 2025, Framery has not integrated specific sustainability metrics into executive compensation schemes." Executive and employee bonuses are tied to financial and operational performance. The overall performance appraisal includes adherence to Framery's values and Code of Conduct, which the report says influences leadership compensation indirectly.

The report gives no percentage of variable pay linked to climate or other sustainability targets, because none is linked.

Reference: pages 24-25 (Statement on due diligence; due diligence approach by topic).

A table on page 24 maps the five core elements of due diligence (embedding in governance, strategy and business model; stakeholder engagement; identifying and assessing adverse impacts; taking action; tracking and communicating effectiveness) to sections of the statement in general governance, E1 and S1.

Framery says it is committed to due diligence on human rights, the environment and good governance across its operations and value chain, supported by its Culture Handbook, Code of Conduct, Environmental Policy, Sustainability Program, DEI Policy, OHS Policy, Personnel Policy and Whistleblowing Policy (page 24).

Page 25 splits the approach by topic. Environmental: an ISO 14001 environmental management system. Social: onboarding reviews, the Supplier Code of Conduct and periodic audits, plus a whistleblowing channel. Governance: Code of Conduct training and a supplier risk analysis tool introduced in 2024, where "high-risk findings trigger deeper audits or engagement". Scope covers own operations, the upstream supply chain and key downstream partners such as distributors.

Reference: pages 23 and 25 (Risk management and internal controls over sustainability reporting).

Controls described on page 25: each sustainability topic and data point has a named Function Leader as owner (for example the Head of R&D owns energy and emissions data and the Head of People & Culture owns employee metrics); ownership of the Sustainability Statement lies with the Finance function, and the CFO reviews the compiled data before the Board does; documented procedures and standard templates; multi-level sign-off, with the Audit Committee reviewing sustainability disclosures alongside the financial statements.

Sustainability risks sit within the wider risk framework, and DMA findings "will be incorporated into the Company's risk register in the future".

Framery says a detailed sustainability risk management internal controls framework and a climate scenario analysis are "still under development" and are to be formalized in 2026 (page 23).

Reference: pages 25-26 (Strategy, business model, and value chain; Table SBM-1.1).

Framery designs and manufactures soundproof pods and smart office solutions. 2025 revenue was EUR 222.1 million. It had 484 employees in 18 countries at year end: Finland 424, EMEA 24, Americas 31, APAC 5 (page 25).

Pods are assembled at the Tampere, Finland factory and delivered to customers in over 80 countries, mainly through dealers. Upstream, "over 70% of the product value and environmental footprint originates from Framery's supplier network"; key suppliers provide glass, metal frames, electronics and acoustic materials. Downstream covers delivery, installation, maintenance, spare parts and Framery Subscribed, a rental model. The report says Framery has no operations or revenue connected to fossil fuels, chemical production, weapons or tobacco (page 25).

Page 26 sets out four strategic elements: climate (1.5°C-aligned targets), circular economy, people and culture, and fair business in the value chain.

Reference: page 26 (Interests and views of stakeholders).

Stakeholder groups named: customers and end users, dealers, employees, shareholders, suppliers and the wider community. Channels named: account managers, feedback surveys and user studies for customers; monthly employee cooperation group meetings, regular experience surveys and the quarterly OHS Committee for employees; the Supplier Code of Conduct (renewed in 2025) and a 2024 Supplier Day for suppliers; and the UN Global Compact Finland network.

Insights are processed by managers and presented at least annually to the Management Team and the Board as part of the strategy review. Framery plans to deepen engagement with suppliers, customers and dealers. The report notes that external stakeholders were not specifically involved in the DMA itself (page 28).

Reference: pages 27-28 (Table SBM-3.1; narrative), with IRO tables on page 33 (E1), page 38 (S1) and page 45 (G1).

Material per Table SBM-3.1: E1 climate change adaptation, mitigation and energy; S1 working conditions and equal treatment and opportunities; S2 working conditions ("Yes (phased-in)"); G1 corporate culture and protection of whistleblowers. Every sub-topic of E2, E3, E4, E5, S3 and S4 is marked "No", as are S1 other work-related rights and four G1 sub-topics (page 27).

The tables show 16 material IROs (E1 six, S1 seven, G1 three; counted from the tables, the company states no total). S2 IROs are not tabulated.

Strategy effect: the climate IROs "validated the Company's strategic decision to bundle its pod offering with digital solutions and circular (or product-as-a-service) business models" (page 28). No material current financial effects were identified, and no significant adjustments to carrying amounts are expected in the next reporting period (page 28).

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

Reference: pages 28-29 (Process to identify and assess sustainability impacts, risks, and opportunities).

Framery updated its DMA in 2024-2025 across own operations and the value chain. Steps: value chain mapping; a topic list built from ESRS, GRI, peer benchmarking and internal brainstorming; impact scoring from 1 to 5 on scale, scope, irremediability and likelihood; risk and opportunity scoring from 1 to 5 on magnitude and likelihood; and workshops with Function Leaders and some non-management staff.

"External stakeholders were not specifically involved in the DMA process" (page 28); their views came through inquiries from prospective clients and supplier questionnaires. A cut-off on each IRO's average score decided materiality after cross-functional discussion; the report does not state the value. The Sustainability Steering Group reviewed the result, the Management Team approved the list, and the Board was briefed (pages 28-29).

Material risks above risk appetite go into the company-wide risk register. Further steps to integrate the DMA with enterprise risk management "are being planned" (page 29).

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

Reference: pages 20-21 (ESRS disclosure requirements and incorporation by reference); page 27 (Table SBM-3.1); page 29; pages 48-52 (datapoints that derive from other EU legislation).

The statement prints an ESRS content index. It lists each requirement against a section name, with no page numbers. Listed: ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2, MDR-P, MDR-A, MDR-M, MDR-T); E1 (E1-1 to E1-6); S1 (S1-1 to S1-6, S1-9, S1-11, S1-13, S1-14, S1-15, S1-17); G1 (G1-1). Not listed: E1-7 to E1-9, S1-7, S1-8, S1-10, S1-12, S1-16, all of S2, and G1-2 to G1-6.

Not material per the DMA: E2, E3, E4, E5, S3 and S4 (page 27). "ESRS E2, E3, E4, and E5 are considered non-material for the reporting period" (page 29). S2 working conditions is material but not reported in the first two years under the phase-in (page 23).

Pages 48-52 list the datapoints derived from other EU legislation, each with a section reference or a "Not material" or "Phase-in used" marker.

Reference: page 32 (Developing a transition plan).

Framery says plainly that it "does not yet have a transition plan according to the ESRS definition" and that it "plans to adopt a formal transition plan during 2026". The section describes ambition, actions and accountability instead.

Framery has been in the SBTi since 2020 with a 1.5°C goal. Life cycle assessments show that making a pod accounts for more than 70% of its life cycle emissions, with use-phase electricity second. Levers named: product redesign and material substitution (fossil-free steel, low-carbon glass, recycled aluminum), more efficient ventilation and lighting, and zero-emission electricity for pods. Own operations moved to renewable district heating in 2025.

Locked-in emissions "are assessed to be insignificant". The Management Team approved the sustainability program and the Board is updated annually. "Framery is not excluded from the EU Paris-aligned Benchmarks." Targets and actions are detailed on page 34.

Reference: page 33.

Back-filled from ESRS 2 IRO-1 and the E1 climate section, where this content is disclosed in the FY2025 report (pages 23 and 33). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The report describes "a climate scenario analysis consisting of two scenarios": a High-Carbon Scenario (warming above 3°C) and a Low-Carbon Scenario (warming limited to 1.5°C), over short (1 year or less), medium (1-5 years) and long (5+ years) horizons. It then says Framery "has not yet conducted a distinct climate scenario analysis", so it made no assessment of how the scenarios fit the assumptions in the financial statements. The report names no external pathway or model for either scenario and describes each only in qualitative terms (for example, "aggressive decarbonization" and "strong environmental policies" in the Low-Carbon Scenario).

Physical risk: most tier 1 suppliers sit near Tampere, but raw material origins "have not been mapped against projected climate-related hazards"; dual sourcing applies for other reasons. Transition risk: dependence on the steel, glass and aluminum industries decarbonizing, with low-carbon materials limited in supply and priced at a premium. Framery calls the scenario analysis "still under development" (page 23).

Reference: page 33.

Back-filled from ESRS 2 SBM-3 and the E1 climate section, where this content is disclosed in the FY2025 report (page 33). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Framery states that "no distinct resilience analysis has been conducted" and that resilience "has not yet been thoroughly analyzed". It adds that while the analysis is underway, "the areas of uncertainty and ability to adjust or adapt the strategy and business model will be studied".

General conclusions drawn from the DMA discussion: the strategy and business model are "considered relatively resilient in both climate scenarios"; physical risks are higher in the High-Carbon Scenario and transition risks are significant in the Low-Carbon Scenario; mitigation levers exist for both. Reliance on high-emitting materials (steel, glass, aluminum) is a significant transition risk if those industries fail to decarbonize. The report gives no assessment of capacity to adjust or adapt over time.

Reference: page 34 (Policies related to climate change).

Policies named: the Code of Conduct, the Supplier Code of Conduct and the Environmental Policy. The Environmental Policy "recognizes climate change, resource scarcity, and loss of biodiversity as serious environmental threats" and commits Framery to continuous improvement through an ISO 14001 environmental management system across the value chain. It applies to all operations and covers upstream and downstream activities. Internal experts developed it, the Sustainability Steering Group accepted it and the CEO signed it; Function Leaders own implementation. It is public on the website.

The sustainability program aims to decarbonize the offering by using less material, raising the share of recycled and low-carbon materials and switching to low-carbon energy, and to promote circular use (utilization, repairability, reusability and lifetime). Framery takes part in the UN Global Compact and SBTi and expects suppliers to support those commitments.

Reference: pages 34-35 (Targets and actions related to climate change); page 26.

Actions cover Scopes 1, 2 and 3. Scope 1 and 2: the main action is switching to zero-emission district heating, "considered a simple and low-cost measure", with an expected cut above 80% and "no material annual OpEx associated with the target" (page 34). The Tampere factory moved from nuclear to renewable wind electricity at the start of 2025 and to renewable district heating in late 2025 (page 35).

Scope 3: levers are low-carbon materials (the largest), lower use-phase emissions through ventilation and lighting optimization and customer guidance, smart office solutions, and product redesign (modular pods). The 2024 smart pod range cut product CO2e footprint by 16% on average against 2023 (page 26).

Actions "are integrated into routine operations, and no significant additional CapEx or OpEx is expected" (page 34). The Sustainability Steering Group allocates resources; product and supply chain functions carry out the actions.

Reference: pages 34 and 36 (Targets and actions related to climate change; Emissions).

Two targets were set in 2025 on a 2024 base year, approved by the Management Team and awaiting SBTi validation. (1) Cut absolute Scope 1 and 2 (market-based) emissions 50% by 2030 from 196 tCO2e, described as consistent with the 1.5°C pathway. (2) Cut Scope 3 emissions 52% per EUR of value added by 2030, from 647 to 311 tCO2e/MEUR, an economic-intensity target "aligned with a well-below-2°C trajectory". Value added is EBITDA plus all personnel costs. Framery will not use removals, carbon credits or avoided emissions to meet either target (page 34).

Progress in 2025 (page 36): Scope 1+2 market-based 94 tCO2e, down 52%; Scope 3 intensity 516 tCO2e/MEUR, down 20%. Stakeholders were not directly involved in setting the targets.

Reference: page 35 (Energy; Table E1-5.1).

Total energy consumption was 2,941 MWh in 2025 against 2,921 MWh in 2024 (+1%). Fossil energy fell from 550 to 219 MWh (share 19% to 7%). Renewable energy rose from 1,588 to 2,711 MWh (share 54% to 92%). Nuclear-sourced electricity fell from 783 to 11 MWh. Petroleum fuel for company vehicles was 16 MWh in 2024 and 13 MWh in 2025; there is no coal or natural gas use.

Energy intensity for activities in high climate impact sectors fell from 18 to 13 MWh per MEUR of net revenue (net revenue EUR 222.1 million in 2025).

Scope: company vehicles, the Tampere factory and office, and the Helsinki showroom. Overseas hubs and showrooms are excluded because they sit outside the organizational boundary, which follows IFRS 16 reporting. The report says the data was covered by the auditor's limited assurance.

Reference: page 36 (Emissions; Table E1-6.1).

2025 against 2024 (tCO2e): Scope 1 3.5 (4.5); Scope 2 location-based 160 (200); Scope 2 market-based 90 (190); Scope 1+2 market-based 94 (196); Scope 3 47,100 (42,200); total market-based 47,100 (42,400). Scope 3 is about 99% of the total. 2024 Scope 3 was restated after EPDs were updated.

Scope 3 categories reported: 1 purchased goods and services (33,800; over 70% of Scope 3), 4 and 9 transport and distribution (2,700), 11 use of sold products (9,400) and 12 end-of-life (1,200). Categories 2, 3, 5, 6 and 7 were calculated and excluded as insignificant; 8, 10, 13, 14 and 15 are not relevant.

GHG intensity per net revenue: 213 tCO2e/MEUR location-based and 212 market-based, both down 19%. Biogenic emissions: 0.8 tCO2e in Scope 1 and 510 tCO2e in Scope 2. Framery plans to report value chain biogenic emissions in its 2026 statement.

Reference: page 39 (Policies related to own workforce).

Five company-wide policies cover all employees globally: the Personnel Policy (updated in 2025), Code of Conduct, Occupational Health & Safety Policy, Diversity, Equity and Inclusion Policy and Whistleblowing Policy. The Management Team holds the most senior accountability. Policies are shared through onboarding, the intranet Wiki, team meetings and training, with translations for production staff without daily computer access.

Human rights commitments follow the UN Guiding Principles and the UN Global Compact ten principles, and cover freedom of association and collective bargaining. The Code of Conduct prohibits child labor and forced or compulsory labor; human trafficking is not named but the report says the prohibition extends to it. The OHS Policy commits to zero accidents under an ISO 45001-certified system.

Framery "found no significant risk of forced labor or child labor in its own operations", and no workforce risks from its decarbonization efforts were identified, so it has no just transition policy.

Reference: pages 40-41 (Actions related to own workforce).

Framery runs an ISO 45001-certified OHS system that covers 100% of employees and contractors on its premises. 2025 actions: frequent risk assessments and safety walks, ergonomic coaching in production, team leader training on early support (the EBIM model), and a wider occupational health service with short-term psychotherapy, introduced in late 2024 and continued in 2025. Contractors who assemble pods get training materials and safety expectations.

Outcome: LTIF was a record-low 2.7 in 2024 but rose to 11.38 in 2025, with nine lost-time injuries and 49 days of absence (page 40). The report says this "highlights a clear need to strengthen the safety management protocols" (page 41).

Resources come from the annual planning and budget cycle; the report names training, ergonomics, incident investigation, occupational health services and well-being initiatives but gives no amounts. Actions are owned by Operations, People & Culture, team leaders and the OHS Committee.

Reference: page 41 (Targets related to own workforce).

Safety: LTIF of 0 by 2035; 5 or lower by 2026; step-downs to 4 or lower in 2027-28, 3 in 2029-30, 2 in 2031-32 and 1 in 2033-34. Baseline: LTIF 2.7 in 2024. Scope: all own employees, global.

Sickness absence: by 2028, production 8.0% or lower and office 1.8% or lower of theoretical working time. Baselines in 2024: production 10.1%, office 2.6%. Scope: Finland employees, to widen as data systems mature.

2025 results, both marked "Off track": LTIF 11.38 (9 recordable injuries, 49 days lost); production absence 10.26%; office absence 2.43%. The report says Framery did not meet its near-term LTIF target and names corrective actions: better safety training, daily management in production, early support and ergonomics training. Targets are proposed by People & Culture and approved by the Management Team; the Board is briefed annually. Employee surveys and safety observations inform priorities.

Reference: page 42 (Characteristics of Framery's employees; Tables S1-6.1 and S1-6.2); page 25.

Headcount at 31 December 2025 was 484 (not FTE): 298 male, 150 female, 36 gender not disclosed, none non-binary. By contract: 421 permanent (257 male, 139 female, 25 not disclosed), 63 temporary (41, 11, 11) and 24 on non-guaranteed hours. By time: 455 full-time and 5 part-time. Of the temporary roles, 49 were due to demand instability in production, 7 were project workers and 6 were substitutions.

By country: Finland 424, EMEA 24, Americas 31, APAC 5 (Table SBM-1.1, page 25).

Attrition: 38 permanent employees left in 2025, a 9.35% rate on an average of 406 permanent employees. The report says the data was covered by the auditor's limited assurance. Agency workers are in the policy scope but not in the headcount (page 39).

Reference: page 42 (Diversity; Tables S1-9.1 and S1-9.2); pages 23-24.

Senior management here means the Management Team of 11: 7 men (64%) and 4 women (36%), none non-binary or undisclosed (Table S1-9.2). Board: 1 woman among 5 members, 20% (page 23).

All employees by gender: 298 male, 150 female, 36 not disclosed, 0 non-binary (Table S1-6.1). Table S1-9.1 gives the gender split within three age groups (under 30, 30-50, over 50). The HR system offers Female, Male, Non-binary and Prefer not to respond, and not every employee has chosen to disclose a gender.

The report says the data was covered by the auditor's limited assurance.

Reference: page 42 (Social protection).

"All employees are covered by social protection against loss of income due to major life events through public programs or through benefits offered by Framery." Coverage in every country of operation was confirmed by a legal review of public social security programs and national regulations. The text gives no breakdown by type of life event. The data was collected internally and covered by the auditor's limited assurance.

Reference: pages 42-43 (Training and skills development; Table S1-13.1).

The average was 3.4 training hours per employee in 2025. The report notes its performance enablement tools hold no personal data, so figures by gender or employee category could not be given for development discussions, and says the "numbers do not reflect reality" for those because reporting is not mandatory (page 43).

Annual review or Personal Development one-to-one confirmed as completed in 2025: 56% of production employees (the rest finished it in January 2026), 56% of officials and 65% of team leaders including senior management (page 42). Other activity: 6 internal transfers, 10 employees in fixed-term job rotation, 24 pairs in Job Shadowing Days, and a new leadership framework with team leader training (pages 42-43). The data was covered by the auditor's limited assurance.

Reference: page 43 (Health and safety; Table S1-14.1); pages 40-41.

100% of the own workforce is covered by a health and safety management system, certified to ISO 45001. In 2025: 9 recordable work-related accidents; a rate of 11.38 (LTIF, lost-time injuries per 1,000,000 hours worked); 49 days lost, with individual absences of 2 to 15 days; 0 fatalities; 0 recordable cases of work-related ill health (based on occupational diseases confirmed by the insurer). No work-related injuries involved non-employee workers.

The 2024 LTIF was 2.7, with 5 days lost (page 40). The 2025 rise is a clear deterioration and the report says so, with corrective actions (page 41). The paragraph closing this section says the data "has not been subject to external validation, and its accuracy remains the sole responsibility of the Company" (page 43).

Reference: page 43 (Work-life balance; Table S1-15.1).

100% of employees are entitled to family-related leave under local regulations and collective agreements. In total, 12.6% of entitled employees took it in 2025; the report says only females and males took leave and that figures for the US are incomplete because leave is not systematically recorded there. The share is calculated as employees who took leave over total headcount. The data came from the HR system and was covered by the auditor's limited assurance.

Reference: page 43 (Incidents, complaints, and severe human rights impacts; Table S1-17.1).

2025: 1 incident of discrimination (including harassment) and 4 complaints through the channels for the workforce to raise concerns; no fatalities. The report says the reports "did not constitute severe human rights impacts" and that the cases "did not involve any legal violations, fines, sanctions, or compensation".

The four reports all concerned internally reported inappropriate behavior by individual employees. Two were about the same issue and one was classified as discrimination. The report says the behavior was verbal in nature, each case was handled confidentially under the Whistleblowing Policy, investigated and resolved. The report says the data is collected internally from the whistleblowing channel and was covered by the auditor's limited assurance.

Reference: pages 45-46 (Corporate culture and business conduct policies; Protection of whistleblowers; Policies on anti-corruption and anti-bribery). The datapoints table lists G1-1 paragraphs 10(b) (UN Convention against Corruption) and 10(d) (protection of whistleblowers) here (page 49).

Culture rests on the Culture Handbook ("Being Framerian") and the Code of Conduct. Values: Respect, Courage & Curiosity, Transparency, Responsibility, Good Judgment. The Board reviews culture and business conduct at least once a year; the Management Team holds the most senior accountability (page 46). Code of Conduct e-learning is part of onboarding for all new employees.

Whistleblowing: a secure platform run by an external partner, anonymous reporting allowed, acknowledgment within seven calendar days, feedback within three months, protection under the Finnish Whistleblower Act (1171/2022), and a ban on retaliation (page 46). Anti-corruption policies are described as consistent with the UN Convention against Corruption, with strict rules on gifts and hospitality. The functions most at risk are Sourcing, Purchasing, Sales, Global Logistics and Finance.