GRK Infra Oyj

Reference: pages 26-30 (GOV-1 and GOV-2 are presented together).

GRK Infra Oyj's Board of Directors is responsible for governance and approves the Group's strategic sustainability targets and monitors their delivery (page 27). In 2025 the Board had seven members: 3 women (43%) and 4 men (57%). 86% of members were independent of the company and significant shareholders, and none were executives (page 28). The Board has three permanent committees: the Audit Committee, the Personnel and Remuneration Committee and the Tender Stage and Project Committee (page 27). The Audit Committee monitors the sustainability reporting process and the assurance of that reporting; the report says it is not responsible for the identified impacts, risks and opportunities themselves (page 27).

Day-to-day ownership sits with the Group Management Team (11 members, 36% women), and the Chief Business Development Officer is responsible for sustainability reporting (pages 29, 27). Management Team job descriptions carry no impact-, risk- or opportunity-level duties; those are set through policies (page 27). The Board had sustainability training in autumn 2025, and two members have prior experience preparing a double materiality analysis and sustainability report (page 28). Competence matrices for the Board and Management Team are on pages 28-30.

Reference: pages 27, 29, 53.

The Board and the Audit Committee receive regular information on GRK's material sustainability impacts, risks and opportunities (page 27). All material and non-material topics from the double materiality analysis were reviewed by the Board during the reporting process, and the Board has discussed the material impacts, risks and opportunities in its meetings, including in relation to strategy (page 27). The Chief Business Development Officer brings the material impacts, risks and opportunities to the Audit Committee, which follows them as part of the sustainability reporting process (page 27).

The Management Team monitors the set sustainability metrics annually and their achievement quarterly, and prepares a detailed action plan when targets need one (page 29). The Board and Management Team reviewed and approved the double materiality assessment process, and the Board approves the sustainability statement after the Audit Committee's review (page 53). The report says the Management Team's sustainability competence will be supplemented with training during 2026 (page 29).

Reference: page 31.

GRK has a remuneration policy for the Board and the CEO, approved by the Annual General Meeting in 2025. The report says "Sustainability-related objectives affect remuneration indirectly", because GRK's projects are subject to customers' ESG criteria (safety, quality and environment) and meeting them is a prerequisite for project success (page 31). The CEO's variable pay includes one sustainability-related element, occupational safety: the short-term incentive scheme has a health and safety gate that lets the Board moderate or reduce the bonus if serious occupational safety deviations occur, with a deduction of 10% for each serious occupational accident (page 31).

The Board approves the structure, performance measures and terms of the remuneration systems, supported by the Personnel and Remuneration Committee (page 31). According to the report, Board members and other administrative, management or supervisory bodies have no incentives linked to variable remuneration, and their remuneration is not tied to sustainability. The page states no percentage of variable pay linked to sustainability and no climate-related incentive.

Reference: page 31 (also page 62).

GRK states that it "does not have a separate due diligence process". Internal audits related to sustainability "are carried out as necessary in accordance with GRK's governance principles" (page 31). In place of a process description, the report maps the five core elements of due diligence to sections of the statement:

• embedding due diligence in governance, strategy and business model: GOV-1, GOV-2, GOV-3, SBM-1, SBM-3;
• engaging affected stakeholders: GOV-2, SBM-2, IRO-1, S1-2, S1-3, G1-2;
• identifying and assessing adverse impacts: SBM-3, IRO-1, E1-2, E2-1, E5-1, S1-1, S1-3, G1-1, G1-2;
• taking action: E1-3, E2-2, E5-2, S1-3, S1-4, G1-1, G1-2, G1-3, G1-5;
• tracking effectiveness: E1-5, E1-6, E5-4, E5-5, S1-5, S1-6, S1-8, S1-9, S1-14, S1-16, S1-17, G1-4, G1-6.

In the EU Taxonomy section GRK adds that "the company does not have a documented human rights due diligence process" and therefore interprets the minimum safeguards as not met (page 62).

Reference: page 31 (also page 53).

GRK treats sustainability reporting risk as part of its overall risk management, and the requirements have been added to the annual risk assessment for the Group Management Team (page 31). The two main risks named are accuracy of the information and, given how much has to be reported, the risk that not all relevant information is reported fully and reliably. The report says collecting the data "requires manual steps, which increases the possibility of errors". Controls named: clear responsibilities for collecting, checking and reporting each item; a person designated for each reported item; and reconciliations where possible. The risk from the extent of reporting is handled by using phase-in to cut the number of first-year disclosures (page 31).

Risk assessments are run twice a year with a risk assessment tool, involving senior management and construction managers (page 53). The Audit Committee reviews the reporting process and the effectiveness of internal control, and meets the auditor and the sustainability assurance provider each year; the Board approves the sustainability statement after that review (page 53). The CEOs and finance teams of the Group companies must make sure controls are defined and working (page 53).

Reference: pages 31-34.

GRK is a Finnish infrastructure construction group operating in Finland, Sweden and Estonia, with 1,222 employees at the end of 2025 (page 34). Its business covers civil engineering and road construction and paving, rail construction (design, construction and maintenance) and environmental technology. In 2025 it launched a Power business for 110/400 kV transmission networks, substations and renewable energy construction, which the report calls minor in its first year (page 34). Customers are the state administration, municipalities, cities and the private sector (page 34). Turnover in the EU Taxonomy table is EUR 872.3 million (page 63).

The 2025-2028 strategy is to grow profitably and, by 2028, be a "forerunner in sustainable construction" with "the most competitive team"; the priorities named are critical infrastructure and defense projects, green transition projects, expansion in Sweden and recruiting skilled labor (pages 31-33). The Nature and Climate Roadmap targets zero emissions by 2050 and a 50% reduction by 2040 (page 32). The value chain has three parts: upstream (material producers, manufacturers, transport, subcontractors), own operations, and downstream (customers and the neighbors of sites) (page 34). GRK applies the phase-in for the revenue breakdown by ESRS sector (SBM-1 paragraphs 40(b) and 40(c)) (page 25).

Reference: pages 34-35.

GRK describes stakeholder engagement as a mutual exchange of information. Each Management Team member reports at Management Team meetings on the stakeholder views in their area, and the CEO passes significant observations to the Board (page 34). The report adds that in 2025 "no changes were made to the business model or strategy based on stakeholder engagement" (page 34).

The table on page 35 covers nine groups: personnel, workers in the value chain, trainees and students, suppliers and subcontractors, customers, partners, end-users, owners and financiers, and authorities and decision makers. For each it lists the engagement channels (for example the personnel survey, whistleblowing channel, site safety rounds, audits, EIA procedures and investor meetings), the stakeholder's expectations (a safe working environment, punctual payment, safe and functional infrastructure, compliance with legislation) and how GRK responds, such as the Corporate Sustainability Requirements for Suppliers, contractor liability audits, the ISO-certified operating system and the Principles of Fair Operations. Stakeholder surveys also fed the double materiality analysis (page 51).

Reference: pages 36-50 (IRO tables pages 36-48; summary pages 49-50).

GRK presents its material impacts, risks and opportunities in one table per topic: E1 climate change (12 rows), E2 pollution (6), E4 biodiversity (2), E5 resource use and circular economy (6), S1 own workforce (11), S2 workers in the value chain (12), G1 business conduct (7) and two entity-specific positive impacts on social and industrial infrastructure (pages 36-48). Each row gives the type (actual or potential impact, risk, opportunity), where it sits in the value chain, the time horizon and GRK's response.

The summary on pages 49-50 traces most negative impacts to GRK's own operations and business model: emissions, energy and materials use (E1, E5), waste and spill risk (E2), land-use change (E4), and physical strain, accident risk and seasonality for workers (S1, S2). Positive impacts named are low-emission construction solutions, stable employment, training and the infrastructure GRK builds. On financial effects, GRK saw no material effects on the income statement, balance sheet or cash flows in 2025, and it "has not analysed the resilience of the company's strategy or business model" (page 50). SBM-3 paragraph 48(e) (anticipated financial effects) is phased in (page 25). Topics assessed as not material are E3, S3 and S4 (page 50).

Reference: pages 50-53.

GRK's double materiality analysis uses the Upright Project model. The first analysis was done in 2023; for 2025 it was expanded to follow the ESRS, with stakeholder interviews and internal expert assessments added for the first time (pages 50, 53). The data platform draws on the CORE database of scientific articles and third-party data, GRK's product and service portfolio and revenue split, supplier, site and customer locations, and stakeholder surveys. A model library of more than 1,000 combinations of impacts, risk drivers and affected financial items produced the long list (pages 51-52).

Impacts were scored 1-4 on scale, scope, irremediable character (negative impacts only) and likelihood, with actual impacts always given likelihood 4. The score is the product of these, and an impact scoring at least 20 was treated as material. For risks and opportunities, financial effect = likelihood x magnitude x value of the affected financial item, and an effect of at least 0.5% of Group equity was material (page 52). Likelihood is raised for potential human rights impacts (page 52). Surveys went to employees, suppliers and investors and to support functions; consultations with affected communities were not held (page 52). Climate risks (floods, drought, extreme weather) were screened separately from the DMA, and no climate scenario analysis has been prepared (page 51). The Management Team and Board approved the process (page 53).

Reference: pages 54-61 (content index pages 54-55; EU-legislation datapoint list pages 55-61); phase-in pages 25-26; non-material topics page 50.

GRK's "ESRS Content Index" lists the disclosure requirements it reports and their pages: 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 E2-3, E5-1 to E5-5, S1-1 to S1-6, S1-8, S1-9, S1-14, S1-16, S1-17, G1-1 to G1-6, and an entity-specific section on impacts on social and industrial infrastructure. For E4 and S2 the index lists only BP-2. It has no entries for E3, S3 or S4.

A second table lists the datapoints derived from other EU legislation, each with a page number, "Not material" or "Phase-in". It marks "Not material" the SBM-1 fossil fuel, chemical, controversial weapons and tobacco datapoints, E1-7, E2-4, the E3 datapoints, the S3 and S4 datapoints and the G1-1 UN Convention against Corruption datapoint, and marks "Phase-in" the E1-9, E4 and S2 datapoints (pages 56-60). The double materiality analysis found E3, S3 and S4 not material (page 50). Phase-in under ESRS 1 Appendix C, as amended by Delegated Regulation 2025/1416, is used for E1-9, E2-6, E4, E5-6, S1-11, S1-13, the ill-health and days-lost datapoints of S1-14, S2, SBM-1 paragraphs 40(b)-(c), SBM-3 paragraph 48(e) and comparative information (pages 25-26). GRK says it "has not omitted disclosures related to intellectual property, know-how, innovation results, ongoing development or matters under negotiation" (page 25).

Reference: page 69 (see also pages 32, 71).

GRK says plainly: "GRK does not yet have a transition plan in accordance with the ESRS standard." Its goal is "to prepare a transition plan for climate change mitigation by 2028 as scheduled" (page 69). Steps named: Scope 1 and 2 emissions were calculated in 2025; in 2028 GRK will apply for SBTi approval of its emission reduction targets, which "serves as the basis for the transition plan", and GRK commits to making the plan's targets science-based and compatible with the 1.5°C target of the Paris Agreement (pages 69-70). The report says the current measures and objectives support the transition but "do not yet contain enough information to prepare a transition plan" (page 70).

The existing commitment is climate neutrality by 2050, described as in line with EU climate goals and the Paris Agreement; the targets "have not yet been assessed in detail" against the 1.5°C goal (page 69). GRK is not excluded from the EU Paris-aligned Benchmark (page 69). Effects of a transition plan on the workforce have not been considered because no plan has been implemented (page 90). E1-1 is in GRK's content index at page 69.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and SBM-3, where this content is disclosed in the FY2025 report (pages 51 and 69). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

GRK's climate risk analysis "has been carried out separately from the double materiality analysis process", and its results were reviewed as part of the DMA. It covers own operations and the value chain (page 51). Physical risks identified: floods, storms, fires, drought, heat waves and extreme weather that can disrupt suppliers and logistics and make site work unsafe and costlier (pages 37, 69). Transition risks: investment needs and added reporting under the low-carbon transition, and dependence on fossil fuels and raw materials (pages 36-37).

No scenario analysis exists: "A climate scenario analysis has not yet been prepared, but its deployment is planned as part of the development of sustainability reporting" (page 51). The report names no climate scenarios, temperature projections or assumptions. None of the identified climate risks produced a financial effect in 2025 (page 69).

Resilience in relation to climate change

Back-filled from ESRS 2 IRO-1 and SBM-3, where this content is disclosed in the FY2025 report (pages 50 and 69). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

GRK reports that it has not done a resilience analysis. SBM-3 says GRK "has not analysed the resilience of the company's strategy or business model" (page 50), and the E1 section says a climate resilience analysis "has not yet been carried out", with the analysis due alongside the transition plan, which is targeted for 2028 (page 69).

Related content: physical hazards are handled through procurement and own operations, with risks and costs considered at the tender and contract stages and work instructions updated regularly (page 69). Replacing climate-sensitive material deliveries with sustainable alternatives and diversifying procurement is named as an opportunity (page 69). None of the identified climate-related risks was realized as a financial effect in 2025 (page 69). The report gives no assessment of uncertainty or of the capacity to adapt.

Reference: page 70.

Climate policy sits in the Group environmental policy, which rests on the ISO 14001:2015 certified environmental management system, and in the Corporate Sustainability Requirements for Suppliers. The environmental policy aims to cut GHG emissions, improve energy efficiency, increase renewable energy, promote the circular economy and prepare for physical climate risks such as extreme weather (page 70). Key actions listed: (a) mitigation, including lower emissions at sites, equipment and offices, a carbon footprint reporting requirement for key suppliers (steel, cement, aggregate, bitumen, aluminum, copper, wood) and the Circular Economy Green Deal commitment; (b) adaptation, such as preparing sites for extreme weather; (c) energy efficiency; (d) renewable energy, including electrified equipment and biofuels; (e) biodiversity and resource efficiency.

The Chief Risk Officer is responsible for implementation. The HSEQ team tracks CO2 intensity (tCO2eq/MEUR), energy consumption (MWh) and renewable share (%) monthly and reports quarterly to the Board (page 70). The policies cover all operating countries and key suppliers, and the Chief Legal Officer prepares the supplier requirements, which are on GRK's website and shared during procurement (page 70).

Reference: page 71.

Actions rest on the environmental policy, the ISO 14001:2015 system and the Nature and Climate Roadmap, which sets measures such as more renewable energy, better energy efficiency and more recycled materials (page 71). Carried out in 2025: renewable electricity at all construction sites in Finland; renewable fuel in GRK's own diesel-powered production and company cars; energy efficiency measures such as avoiding idling, machine control and efficient working methods; more recycled materials; and a network of circular economy sites for reuse and processing. GRK also started work with key suppliers on climate and biodiversity principles and developed nature-based solutions such as biochar from recycled materials (page 71).

Planned: applying for SBTi approval in 2028 and drawing up a transition plan with decarbonization levers and technology solutions (page 71). The emission reduction from the 2025 measures "has not yet been quantified, but the impact has been estimated to be significant". On resources, the measures "are part of GRK's day-to-day business, and no separate budget has been set aside for them" (page 71). The page gives no monetary amounts for climate action.

Reference: pages 71-72.

Targets cover own operations (Scopes 1 and 2) and material value chain emissions (Scope 3) in Finland, Sweden and Estonia (page 71). The long-term goal is climate neutrality by 2050. Milestones: an absolute target of net zero Scope 1 and 2 emissions by 2035, and a relative target to cut Scope 1, 2 and 3 emissions by 50% by 2040 compared with 2030 emissions. GRK "has not set a short-term target for 2030". Supporting entity-specific targets from the Circular Economy Green Deal: triple the use of recycled materials from 487,000 tonnes (2023) to 1.5 million tonnes by 2035, with 1.0 million tonnes as a 2030 milestone, and triple the environmental technology unit's revenue from EUR 10 million (2024) by 2035 (page 71).

The report is direct about limits: the targets "have not been assessed against science based criteria (SBTi), nor have they been evaluated in relation to the Paris Agreement. As a result, the ESRS disclosure requirements related to targets are not met" (page 71). Levers named: energy efficiency, fuel switching, renewable energy and material efficiency (page 72). No time-bound adaptation targets exist, and in 2025 GRK did not specifically monitor the effectiveness of policies and measures (page 72). Targets are set annually by the Management Team; stakeholders did not take part (page 72).

Reference: pages 72-73.

Total energy consumption in 2025 was 87,067 MWh. Fossil sources were 67,565 MWh (78%), nuclear 674 MWh (0.8%) and renewable sources 18,828 MWh (22%) (page 73). Fossil use was crude oil and petroleum products 35,197 MWh, other fossil sources 29,556 MWh and purchased fossil-based electricity, heat, steam and cooling 2,812 MWh; coal and natural gas were zero. Renewable energy was 12,158 MWh of fuel consumption (including biomass) and 6,669 MWh of purchased renewable electricity, heat, steam and cooling, with no self-generated non-fuel renewable energy. Energy intensity was 100 MWh per EUR million of net revenue (page 73).

The data covers fuel and purchased electricity, heat and steam for all construction sites and offices in the three countries. The most energy-consuming work phases named are piling, soil replacement, stabilization, concreting of bridges, keeping excavations dry, site upkeep (heating, lighting, machinery), track superstructure work and asphalt production (page 72). For leased premises without consumption data, use was estimated from floor area (page 76).

Reference: pages 74-77.

2025 gross Scope 1 emissions were 16,766 tCO2e, 35% of them under emission trading schemes (the paving business). Scope 2 was 533 tCO2e location-based and 1,094 tCO2e market-based. Scope 3 was 316,350 tCO2e: purchased goods and services 280,858 (category 1), upstream transport 29,362 (4), fuel and energy-related activities 3,446 (3), capital goods 1,184 (2), business travel 730 (6), employee commuting 678 (7) and waste 91 (5). Totals were 333,648 tCO2e location-based and 334,210 tCO2e market-based, or 382 and 383 tCO2e per EUR million of revenue (pages 75-76). Biogenic CO2e under Scope 1 was 3,367 tonnes and is excluded from the Scope 1 figure (page 74).

GRK gives no 2024 comparatives, no base year and no milestones, because "a transition plan, including the base year and the definition of milestones, has not been prepared" and its calculations changed (page 74). Primary data supports 54% of Scope 3; for category 1, 67% rests on supplier-specific data and 33% on cost-based estimates (page 76). Categories 8-15 were judged immaterial or not applicable (page 77). Market-based Scope 2 reflects guarantees of origin covering all purchased renewable electricity (page 74).

Reference: page 79.

Pollution policy sits in the Group environmental policy, which rests on the ISO 14001:2015 certified environmental management system and on national and international environmental legislation, and in the Corporate Sustainability Requirements for Suppliers, which commit value chain actors to the same operating principles (page 79). The policies cover three things: prevention and control of pollution of air, water and soil; substitution and minimization of substances of concern and phasing out of substances of very high concern; and avoiding significant investments driven by the transition to a non-polluting economy (page 79). Pollutant control follows environmental permit regulations, and monitoring rests on regulatory requirements and permit conditions, with spot measurements and corrective handling of deviations (page 79).

In 2025 operations met the permit conditions and "no violations of environmental permits were observed" (page 79). The scope, responsibilities, stakeholder consideration and availability of the policies are described under E1-2 (page 79).

Reference: pages 79-80.

Actions support the environmental policy and the strategic objective "No significant environmental accidents", and rest on the ISO 14001:2015 system and country-specific environmental guidelines for construction sites (page 79). The main step in 2025 was reviewing those guidelines in the induction at all sites. An environmental officer was appointed for each site, and a site-specific environmental plan is drawn up before work starts, mapping the site's risks (page 80). Chemicals are controlled through a system holding safety data sheets, an up-to-date chemical list, safety cards and labels, with software that detects restricted substances; documents are archived for 10 years (page 80). A weekly site measurement covers cleanliness and order, and incidents go through the Group reporting procedure (page 80).

Suppliers and subcontractors must report pollution. In 2025 "we did not receive any information related to pollution from our suppliers" (page 80). The measures cover own operations, upstream and downstream partners and all countries; all were short-term actions (page 80). GRK states it "has not had any approved or planned future measures related to the pollution of air, water and soil" and that no separate plan or funds are needed, because the costs sit in business operations (page 80).

Reference: pages 80-81.

GRK's pollution target is "No significant environmental accidents": an entity-specific, absolute, voluntary target with a target level of zero environmental damage accidents. It covers own operations and the value chain in all operating countries and is assessed annually (pages 80-81). The HSEQ team prepared the target and the Board approved it (page 80); the report also says the Group Management Team set the targets and that stakeholders did not take part (page 81).

2025 results: 187 environmental observations, 58 environmental deviations and 0 environmental accidents (page 81). Definitions: an accident is a significant incident that causes permanent damage; a deviation is remediable, for example a broken hose spilling hydraulic oil into soil that can be cleaned; an observation is something noticed before anything has happened (page 81). Measurements stayed within permit conditions with no overruns (page 81). Data come from the electronic incident reporting system and site observations, alongside ISO 14001:2015 certification (page 81). No target is stated for individual pollutants or substances.

Reference: page 83.

Resource use and circular economy policy sits in the Group environmental policy, based on the ISO 14001:2015 certified system. Its key content is reducing energy use and moving to renewable energy, replacing raw materials with renewable and recycled alternatives where feasible, promoting reuse and recycling, offering circular economy services to customers, and cutting waste through site sorting and common requirements with clients and suppliers (page 83). In practice the policy is applied in site planning, orientation and country-specific environmental guidelines; for suppliers and contractors it is part of contract terms, procurement policies and the Corporate Sustainability Requirements for Suppliers (page 83).

Implementation is monitored through procurement and site reporting. Key metrics are tonnes of secondary materials used and the recovery rate of waste, reported quarterly to management and annually in the sustainability report (page 83). GRK also promotes circularity through the voluntary Circular Economy Green Deal commitment (page 83). The scope, responsibilities and availability of the policies are described under E1-2 (page 83).

Reference: pages 83-84.

Measures in 2025 aimed at using fewer resources and promoting circularity: more recycled materials in infrastructure projects and growth of the circular economy services (page 83). GRK used secondary materials such as crushed concrete, ash and slag, and a significant amount of recycled asphalt in paving (page 83). The circular economy business has 19 sites in Finland, and in 2025 it was extended by seven new regions through an acquisition (page 83). At sites, GRK orders only the necessary raw material to limit waste, crushes concrete structures on site, moves surplus soil to nearby sites, and sorts waste for licensed treatment (page 84). The bioproduct business runs two plants (biochar, and pellets from forest industry by-products); it was minor in 2025 while the development of the plant continued (pages 83-84).

On resources, the report says they "are covered through business operations, and separate provisions have not been considered necessary" (page 84). It adds that no detailed plan for the strategic targets was drawn up in 2025 and that guidelines for low-carbon design solutions are due by 2026 (page 84). Scope covers all operating countries and the upstream and downstream value chain (page 84).

Reference: pages 84-85.

GRK's resource and waste targets, all voluntary, support the Circular Economy Green Deal and the Group strategy (page 84). Recycled materials: triple annual use to 1.5 million tonnes by 2035 from 487,000 tonnes in 2023, with 1.0 million tonnes as the 2030 milestone; 2025 use was 882,045 tonnes (pages 84-85). Environmental technology revenue: triple from EUR 10 million (2024) by 2035, with a 2030 milestone of double that; 2025 revenue was EUR 13 million against a EUR 20 million milestone (pages 84-85). Workwear: only workwear made from recycled materials by 2028, from a 2025 baseline of 0% (page 85).

Waste: a recovery rate above 70% in 2026 and above 90% by 2035, excluding soil materials and aggregates; the 2025 recovery rate was 94% and the recycling rate (excluding incineration and recovery for earthworks) was 55%, with no numerical recycling target (page 85). The resource use targets cover the whole Group and the upstream value chain, draw on industry best practice and the Green Deal requirements, were set by the HSEQ team and approved by the Group Management Team, and assume that enough recycled material is available on the market and that technology develops as planned (page 85). The waste target was set by the HSEQ team and approved by the Board (page 85).

Reference: pages 85-86.

GRK says infrastructure construction is material-intensive and that material availability and prices strongly affect project costs. It assessed the most material flows in 2025: concrete and steel products, aggregates, bitumen and wood (page 85). Materials used, in tonnes (page 86): steel 29,905; cement and ready-mixed concrete 381,652; prefabricated concrete and other concrete products 27,191; bitumen 36,066; asphalt 40,913; aggregate 6,461,836; wood 1,378. The share of recycled raw materials and biological materials in these materials was 0.0% (page 85).

Recycled input is reported separately as an entity-specific metric: 882,045 tonnes of secondary materials in 2025, mainly crushed concrete, ash, slag, gravel and tires, plus recycled asphalt in paving (pages 83, 85). GRK also manages more than 650 machine units (about 500 vehicles and about 200 machines) and six asphalt stations, three fixed and three mobile (page 86). Basis: quantities mix supplier-specific data with cost-based estimates from procurement data (supplier-specific for Finland, about 90% of categories for Sweden, entirely cost-based for Estonia), and the figures exclude environmental technology activities (page 87). GRK has no practice of using certification systems such as PEFC or FSC for biological materials (page 86).

Reference: pages 86-87.

GRK's content index lists E5-5 under the heading "Waste" (page 55), and its resource outflow disclosure is the waste section. Operations mainly generate waste from construction sites, and the report says waste management is a key part of promoting the circular economy; efficient sorting cuts unrecycled waste and costs (page 86). Total waste generated in 2025 was 10,707 tonnes, of which 9,533 tonnes were diverted from disposal and 1,175 tonnes went to disposal. No radioactive waste was generated (pages 86-87).

Outflows of products and materials are not quantified separately. The circular economy outputs GRK names are crushed concrete, recycled fertilizers, biochar and pellets, with low production volumes in 2025 because operations at the installations were starting up (page 86). Full waste tables are under E5-5-Waste.

Waste

Reference: pages 86-87.

Total waste generated, 2025: 10,707 tonnes. Diverted from disposal: 9,533 tonnes, of which non-hazardous waste 9,503 tonnes (preparation for reuse 225, recycling 5,689, other recovery 3,589). Directed to disposal: 1,175 tonnes, of which hazardous 39 tonnes (incineration 8, landfill 0, other disposal 31) and non-hazardous 1,136 tonnes (incineration 474, landfill 504, other disposal 157); by operation, incineration 482, landfill 505 and other disposal 188 tonnes.

Non-recycled waste: 4,778 tonnes, or 44.6% of waste generated (page 87). The recovery rate counts waste recovered through incineration and earthworks, while the recycling rate excludes them (page 86). Types of treatment follow the waste hierarchy (page 86).

Basis (page 87): direct measurements from the electronic reporting tools of GRK's waste management companies and site reporting; the total covers waste from construction sites and offices in Finland, Sweden and Estonia; office waste is estimated at 200 kg per full-time equivalent, a default based on the EU's EMAS best practice benchmark of under 200 kg per person-year; environmental technology activities are excluded. No radioactive waste arose (page 86).

Reference: pages 91-94 (index page 91).

GRK's own-workforce policies are the human rights policy, the HR policy, the safety, quality and environmental policy, the risk management policy and the Principles of Fair Operations (the Group code of conduct). The Board approved all five; the Chief Legal Officer is responsible for the Principles, the HR Director for the HR and human rights policies, and the Chief Risk Officer for the safety and risk policies (pages 91-93). The human rights policy draws on the UN Universal Declaration of Human Rights, the UN Global Compact, the ILO Declaration on Fundamental Principles and Rights at Work and the OECD Guidelines for Multinational Enterprises, and says forced labor, child labor, trafficking in human beings, discrimination, violence and harassment are not tolerated (page 91). Safety work follows an ISO 45001:2018 certified system covering every employee (page 91).

The HR policy covers recruitment, pay, equality, well-being and skills; permanent full-time contracts are the default, and part-time only at the employee's request (page 91). Policies are drafted with employee representatives, published on the internal channel and reviewed at least yearly by the responsible Management Team member (page 91). GRK "has no separate Group-level policy regarding inclusion or positive actions for people from groups at particular risk of vulnerability"; equity and inclusion sit in equality and non-discrimination plans (page 94).

Reference: pages 96-98.

Employment security: GRK aims for full-time contracts valid until further notice, reviews non-guaranteed-hours contracts and runs pay comparisons (page 96). Change negotiations at GRK Suomi Oy's rail construction business ran from 12 to 30 September 2025, and all affected staff were offered change security services (page 96).

Health and safety, under the ISO 45001:2018 system (page 96): safety observations and weekly briefings; internal audits in all country companies; the 2025 Group safety campaign "Kaverin puolesta" with seven safety theses; leisure-time group accident insurance at GRK Suomi Oy from 2025; investigation of every accident and near miss; an early support model for sickness absence; a substance-free workplace with drug testing of new employees from 2025; and a safety reward model at GRK Suomi Oy (pages 96-97). A non-employee working for a GRK partner died at a GRK site; GRK helped the authorities, started studying reversing cameras and automatic stop sensors for similar machines and gave crisis support (pages 96-97).

Training: induction, online training, mentoring, rail construction driver and supervisor training, information security training and a first AI training (page 97). Diversity training began in 2025 (page 98). Effectiveness is tracked through the survey, whistleblowing reports and training metrics (page 98).

Reference: pages 98-99.

GRK says it "has not yet set measurable result-oriented targets" for several identified impacts: employment security, gender equality, equal pay for work of equal value, training and skills development, and measures against violence and harassment; target setting will be reviewed again in 2026 (page 98). Targets that exist, with 2025 results (pages 98-99):

• accident frequency below 7 for employees and subcontractors (2024 baseline 7.9): 7.3, not reached; long-term goal below 5 by 2028;
• lost working days down 50% from 113: 103, not reached;
• sickness absence at most 2.5% of working time: 2.3%, reached;
• more than 2,500 safety observations: 2,388, not reached;
• employee eNPS above 40: 35 for the Group; trainee eNPS 61;
• more than 100 trainees: 108, reached;
• zero serious discrimination or human rights incidents: reached;
• 100% training on the Principles of Fair Operations: 64% completed.

The Management Team sets strategic targets annually and the Board approves them; personnel are consulted mainly through the internal channel and information sessions, and stakeholders did not take part in setting the targets (pages 98-99). Accident frequency is lost-time accidents times one million divided by hours worked, and it covers both GRK's employees and subcontractors' employees (page 99).

Reference: page 100 (basis of preparation page 101).

At the end of 2025 GRK had 1,222 employees (headcount): 138 women and 1,084 men, none recorded as other or not reported, because the three countries do not allow a gender-neutral registration (pages 100-101). By contract: 1,126 permanent (122 women, 1,004 men) and 96 temporary (16 women, 80 men); 57 on non-guaranteed hours (11 women, 46 men); 1,156 full-time (122 women, 1,034 men) and 9 part-time (5 women, 4 men) (page 100). By country: Finland 936, Sweden 140, Estonia 146; temporary employees were 37 in Finland, 51 in Sweden and 8 in Estonia (page 100).

Employee turnover was 22.8% (279 leavers), and the report notes it counts fixed-term contracts that ended, including 108 trainees; resignations alone were 5.0% (page 100). Headcount is taken at 31 December 2025 from the HR systems, while the financial statements use the average number of employees (page 101). The small gender table on the same page labels 138 as male and 1,084 as female, which conflicts with the text and the larger table (page 100).

Reference: page 101.

88% of GRK's employees are covered by collective bargaining agreements at Group level (page 101). Estonia has 146 employees and 0% coverage: the report says Estonia's labor market legislation differs from Finland and Sweden and that there is no sector collective agreement (page 101). Finland (936) and Sweden (140) together make up 1,076 of 1,222 employees, which matches the 88% Group figure. The report's coverage table puts Estonia in the 0-19% band and Finland and Sweden in the 80-100% band; for workplace representation it puts Finland in the 80-100% band and Sweden and Estonia in the 0-19% band (page 101).

GRK is an organized employer, and the Finnish company is a member of Infra ry. Local labor laws and collective agreements apply in all operating countries, and cooperation follows each country's legislation (page 101). The report states that GRK has no agreement on representation by a European Works Council, a Societas Europaea Works Council or a Societas Cooperativa Europaea Works Council (page 101). The figures come from the HR systems of the country companies at the end of the period (page 102).

Reference: page 102.

GRK counts the CEO, the Board and the Management Team as top management. At the end of 2025 that group had 18 members: 7 women (39%) and 11 men (61%), with none recorded as other or not disclosed (page 102). Gender is taken from the personal identity code.

Age distribution of all 1,222 employees: under 30 years, 209; 30-50 years, 752; over 50 years, 261 (page 102). The age data come from the HR systems at the end of the reporting period (page 102). The Board itself had 3 women (43%) and 4 men (57%) in 2025, with a gender ratio of 0.75 (page 28). The Management Team was 36% women and 64% men (page 29). The report names the low share of women in the workforce and in senior management as a material negative impact typical of construction (pages 42, 89).

Reference: page 102 (see also pages 98-99).

100% of GRK's own workforce is covered by the health and safety management system, which is certified under ISO 45001:2018 (page 102). In 2025 there were no work-related fatalities among own employees and 1 fatality of another worker at a GRK construction site (a partner's non-employee) (page 102). Own workforce had 48 recordable work-related accidents, a rate of 26.0 per million hours worked; this includes accidents that caused no absence (page 102). The lost-time accident frequency used for targets was 7.3 and covers own and subcontractor employees (page 98). Lost working days among own personnel were 103, down from 113, and the sickness absence rate was 2.3% (pages 98-99).

The ill-health and days-lost datapoints of S1-14 are among the provisions GRK phases in (page 25), and the report gives no case count for work-related ill health. Basis: the recordable accident rate divides recordable accidents of own personnel by hours worked in the Group, times one million (page 102).

Reference: page 102.

The gender pay gap, calculated on gross pay, was 14.5%, and the total remuneration ratio was 18.1 (page 102). The metrics include all employees during the reporting period. Basis: HR system data on wages paid, including all bonuses, divided by hours used for payroll, with the gender pay gap based on gross pay (page 102). The total remuneration ratio is the annual total remuneration of the highest-earning individual divided by the annual median remuneration of employees, using gross pay (page 102).

Context: pay at GRK is set by the local collective agreement, the job grade and the employee's experience, and HR runs salary comparisons and reviews the situation of employees with varying working hours (page 89). The SBM-3 table names the low share of women in the workforce and in senior management, which it calls typical of construction, as a negative impact on gender equality and the possibility of equal pay (pages 42, 89). The report gives no breakdown of the pay gap by employee category or country.

Reference: page 103.

The whistleblowing channel is open to internal and external stakeholders. The table shows the following for 2025: incidents of discrimination (including harassment) 10; complaints through channels for own workers to raise concerns 0; complaints to National Contact Points for the OECD 0; fines, penalties and compensation for damages EUR 0 (page 103). The text says no reports related to S1-17 came through the whistleblowing channel, and 10 reports came through other channels, which were not related to severe human rights impacts (page 103). It also says "no cases of discrimination were observed" and no incidents of harassment were observed (page 103).

The basis note explains that the reports of potential harassment arose in the personnel survey and not through the official process, "Thus, it has not been possible to investigate individual cases" (page 103). No serious human rights violations were observed, such as forced labor, trafficking in human beings or child labor, and no breaches of the UN Guiding Principles, the ILO Declaration or the OECD Guidelines (page 103). The table value of 10 and the statement that no cases of discrimination were observed are both printed on page 103, and the report does not reconcile them.

Reference: pages 106-107 (index page 106).

GRK's ethics rules are collected in the Principles of Fair Operations, which include the Group Code of Conduct and rest on legislation, official regulations and company values (page 106). They apply to all country companies, the Board and every employee. Each employee must complete online training on them every year, and GRK asks partners to commit to them (page 106). A "fair operations tour" of sites and offices ran in all three countries in 2024-2025 and reached more than 900 GRK and subcontractor employees (page 106). GRK checks culture through personnel survey statements such as "Managers act in accordance with the organisation's values and culture" (page 106). The Chief Legal Officer is responsible for the Principles (page 92), and an anti-corruption policy sits alongside them (page 108).

Whistleblowing: a confidential channel with anonymous chat, open to staff and other stakeholders, is run through a third-party mechanism. The Chief Legal Officer and an external expert service process reports; the reporter gets confirmation within seven days and an account of actions within three months; the Chief Legal Officer reports quarterly to the CEO and the Audit Committee (page 107). EU Whistleblower Protection Directive requirements were taken into account (page 107). Training completion: 94% of Board members and senior management and 64% of all personnel (page 107).

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are set out under G1-1 and G1-4 as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

GRK sets two business conduct targets. Corporate culture: raise awareness of the Principles of Fair Operations and coverage of the online training, with a continuous target of 100% of personnel each year; coverage was first surveyed in 2025 and stood at 64% (94% for Board members and senior management), and work continues in 2026 (page 107). Corruption: "keeping the number of incidents of corruption and bribery at the company at zero"; there have been no cases since reporting began in 2022, and the target was achieved in 2025 (page 109). The Management Team set both targets and stakeholders did not take part (pages 107, 109).

GRK also says it "has not yet set measurable, result-oriented or time-bound targets" for whistleblower protection, supplier relations or political influence and lobbying, and that target setting will be reviewed in 2026 (page 106).

Reference: page 109.

In 2025 no violations related to corruption or bribery were observed at GRK, GRK was not fined or sentenced for such violations, and there were no disciplinary measures, contract terminations or legal proceedings (page 109). Reports received through the whistleblowing channel were processed or are still being processed, and none led to findings of corruption or bribery requiring action; no cases involved actors in the value chain (page 109). Suppliers must report ethical violations as agreed, and GRK could also learn of cases through the media (page 109).

Competition law matter: in May 2025 the Finnish Competition and Consumer Authority began an unannounced inspection at the premises of GRK Suomi Oy, to establish whether there had been cooperation between competitors prohibited by competition law in the asphalt sector in Finland. GRK says it does not yet know the outcome, is cooperating fully and cannot comment further (page 109).

Reference: page 109.

GRK sees political influence and lobbying as a material potential negative impact and a regulatory compliance risk, because large infrastructure projects can be subject to political influence from many stakeholders (pages 47, 109). Its stated position: GRK "does not engage in politics, does not participate in political activities and refrains from all support for political activities", and made no monetary or other political donations in the reporting period (page 109). Because of that, GRK says it has no main topics or views of lobbying activities that interact with the impacts identified in the DMA (page 109).

The Chief Legal Officer monitors this, and the legal function keeps records of events with employee representatives taking part in an expert role (page 109). In 2025 GRK joined an event on a proposed decree amending the Waste Act (circular economy), as an expert on the current state of the circular economy and without seeking to influence the decree (page 109). No Board or Management Team member held a comparable public administration position in the two years before appointment. GRK Suomi Oy is in the Finnish Transparency Register (GRK-25-1582-R) (page 109).

Reference: page 109.

GRK's average time to pay an invoice in 2025 was 23.3 days from the start of the contractual or statutory payment term. 95% of payments were in line with standard payment terms, and there were no legal proceedings over late payments (page 109). The report gives the usual term as 30 days, varying by agreement and country: in Finland suppliers can choose 14 days net against a 2% discount, Sweden uses 30 days with shorter terms agreed case by case for smaller suppliers, and Estonia ranges from 7 to 30 days with shorter terms usually agreed for smaller suppliers (page 109). In Finland 36% of invoices were paid within 14 days and 59% within 30 days (excluding payments with a 14-day term) (page 109).

GRK has no separate policy to prevent late payment to small and medium-sized companies; the general policy is to pay all invoices on time (page 109). Basis: calculated from invoice date to payment date, using a representative sample of January-November 2025 invoices of GRK Suomi Oy, GRK Sverige AB and GRK Eesti AS, with the 2025 acquisitions and the parent company excluded as insignificant (page 109). The 95% figure counts invoices paid within 30 days (page 109).