Grupa Kęty S.A.

The role of the administrative, management and supervisory bodies

Reference: page 77; pages 77-79.

The governing bodies are those of the parent company, Grupa Kęty S.A. (page 77). The Management Board changed during 2025: two members left on 28 May and one joined on 29 May. The Supervisory Board has six members, all described as independent. No employee representatives sit on either body, and there were no women on the Management Board or the Supervisory Board (page 77).

Oversight of sustainability: the Management Board, with the Steering Committee for Sustainable Development and Corporate Social Responsibility, prepares the strategy and submits it to the Supervisory Board for opinion. The Supervisory Board's Audit Committee oversees sustainability matters. In 2025 oversight of ESG reporting sat with the Investor Relations Department, which reports to the CFO. The Steering Committee meets at least four times a year (pages 77-78).

Table 34 (pages 78-79) assigns each ESG target to a named role: the Environmental Policy Director (reporting to the COO) for the emissions, scrap, billet, certified-building and recyclable-packaging targets, the HR Director for the promotion, retention and pay targets, the Internal Audit Director for supplier ESG audits, and the Compliance and Risk Management Director for ethics training.

Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies

Reference: page 80.

The Steering Committee for Sustainable Development and Corporate Social Responsibility, which includes all Management Board members, sets direction and oversees the ESG strategy. It held four meetings in 2025, covering the targets of the new ESG strategy, regulatory changes, ethics processes, indicator reporting in E, S and G, and follow-up on gaps found the year before.

Management and Supervisory Board members received 10 internal newsletters ("Sustainability Flash") and ESG topics were discussed at two Management Board meetings. The Audit Committee covered sustainability legal requirements on 21 May and 14 November 2025, and on 5 December Ernst & Young Audyt Polska presented the status of attestation of the sustainability statement. Board members also attended internal training titled "Sustainable Development 2025 for Management Boards and Supervisory Boards: regulations, risks, liability" (page 80).

Integration of sustainability-related performance in incentive schemes

Reference: page 80.

Pay for Management Board members has fixed and variable parts plus in-kind benefits. The variable part depends, among other things, on non-financial objectives for GHG emissions reduction, projects for local communities and reduction of the Total Recordable Incident Rate (TRIR). ESG targets made up 10% of the maximum value of annual incentives for each Management Board member.

The rules sit in the Remuneration Policy for Management and Supervisory Board members, adopted on 20 August 2020 by AGM Resolution 19/20 and amended by Resolution 18/2022. The Policy is published on the company website. E1.GOV-3 (page 104) refers back to this section.

Statement on due diligence

Reference: page 81.

Table 35 maps the elements of the due diligence process to the sections where each is described: governance and strategy (GOV-1, GOV-2, SBM-3), engagement with affected stakeholders (SBM-2 dialogue for the double materiality analysis, MDR-P descriptions of S1, S2 and G1 policies), identification and assessment of adverse impacts (IRO-1, SBM-3), mitigation actions (E1-3, E2-2, E3-2, E5-2, S1-4), and monitoring effectiveness and sharing information (S2-2, SBM-2).

The table is a cross-reference list only; the statement does not describe the due diligence process in a separate narrative on this page.

Risk management and internal controls over sustainability reporting

Reference: page 81.

ESG risk is managed inside the group's general risk management system, which is based on ISO 31000:2018 and run under a policy, a Risk and Compliance Committee and a Risk Management System Procedure (page 81).

On sustainability reporting itself: in 2025 the Internal Audit Department reviewed the reporting system. The main risk it found was a lack of tools to support collecting, verifying and consolidating data, which come from dispersed sources and several IT systems. The company says it will examine whether IT support for data collection is feasible and justified in the coming years (page 81).

The risk assessment procedure is described in Section 3.4 of the report (page 81), which sits outside the sustainability statement.

Strategy, business model and value chain

Reference: page 82; pages 82-86.

Operations are based mainly in Poland, with plants also in Slovenia and Ukraine and sales offices in 10 countries (page 82). Four segments: Extruded Products, Architectural Systems, Sun-shading Systems and Flexible Packaging (pages 82, 84). Table 36 lists products, customer industries and sales markets per segment; Table 37 (page 85) sets out the value chain from bauxite, aluminium and plastic granulate inputs through own operations to customers in construction, automotive and food production.

Upstream: suppliers by value are 30% Polish, 61% from other European countries and 9% from other continents (page 82). Water comes from supply networks (about 30%) and own intakes (about 70%) (page 83).

The group states it does not gain profits from the sale of fossil fuels, gas, weapons, chemicals or tobacco, and sells no products banned in any market (page 82). Segment sustainability goals are listed in Table 36 (page 84). The value creation model is in Chart 2, Section 3.1 (page 86).

Interests and views of stakeholders

Reference: page 86; pages 86-88.

Table 38 (page 86) lists stakeholders affected by the group and users of the statement. For the 2025 double materiality analysis the group ran anonymous surveys between June and July 2025, plus interviews with a labor union representative, a local community representative in Bielsko-Biała, a key Architectural Systems customer and a key Flexible Packaging supplier. It also held workshops on climate and biodiversity and on human rights due diligence (page 87).

Employee, labor union, customer, community and supplier channels are described on pages 87-88. The group says the dialogue did not change its strategy or business model; topics such as climate, circular economy and employee safety were already in the strategy, and others will feed into later policy updates (page 86). Demand for recycled-content products and for recyclable packaging is given as an example of stakeholder views shaping the business (page 86).

Material impacts, risks and opportunities and their interaction with strategy and business model

Reference: page 88; pages 88-92.

The double materiality analysis found 30 material impacts: 9 potentially negative, 6 potentially positive, 12 actually negative and 3 actually positive (page 88). Tables 39-41 (pages 89-91) list them by place in the value chain and time horizon: 20 environmental rows (the report numbers E1-E19 and uses E8 twice), 5 own-workforce and value chain worker rows (S1-S5) and 5 business conduct rows (G1-G5). Table 42 (page 91) lists five material risks: R1 loss of competitiveness from climate neutrality regulation, R2 cyber attacks, R3 malfeasance, R4 personal data breach, R5 staff shortage. R2 and R3 are labeled company-specific, and the report notes they are not exclusively ESG risks.

No significant impacts were found for consumers, end users or affected communities (page 88). No resilience analysis of strategy and business model was done except for climate (page 88). The statement says it did not use the option to omit anticipated financial effects under Appendix C (page 77).

Climate resilience is also presented under E1-3 (2025 ESRS numbering).

Description of the processes to identify and assess material impacts, risks and opportunities

Reference: page 92; pages 92-93.

The group repeated its double materiality analysis in 2025 after its structure changed. It reviewed the value chain and stakeholder list, drew on internal documents, regulation, competitor and industry sources, and ran stakeholder surveys, interviews and workshops with internal staff and external experts. All Management Board members reviewed and approved the process and result (page 92).

Impact assessment used four parameters (scale, scope, probability and irreversibility), with scale and scope scored 1-5. Cut-off points for actual impacts were the category means, 2.87 for negative and 3.65 for positive impacts; potential impacts used EFRAG matrices adjusted to the group's view, and borderline topics were decided case by case (page 93). Risks and opportunities follow the group's enterprise risk management system (page 93).

Tools named: countryrisk.io, riskfilter.org, wageindicator.org, the TNFD LEAP approach, IUCN Red List, Global Forest Watch, ENCORE and Aqueduct. Climate used an IPCC high-emission scenario and the IEA Net Zero Emissions by 2050 scenario (page 93). An annual review is planned (page 92).

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

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Reference: page 153.

Section 9.23 (page 153) carries the IRO-2 heading and one table: Table 77, the list of datapoints in cross-cutting and topical standards that derive from other EU legislation (ESRS 2 Appendix B), with a page reference column (pages 153-156).

The report prints no table listing the 84 disclosure requirements it covers. Which requirements are covered has to be read from the section headings and the datapoint tags such as [E1-5_01] that appear inline throughout the statement.

The page references in Table 77 do not always match the printed pages: for example the GHG intensity table (Table 53) is cited as page 121 and sits on page 116 (pages 116, 154). The materiality cut-off points are tagged IRO-2_13 on page 93.

Transition plan for climate change mitigation

Reference: page 105; pages 104-105.

The report states that the group "has not formally adopted the Transition Plan for climate change mitigation" with targets compatible with 1.5°C (page 105). What exists instead: a Development Strategy for 2025-2029, adopted by the Management Board on 22 April 2025 and approved by the Supervisory Board, which sets emission reduction targets (page 104), and a new Group Climate Policy approved in December 2025 (page 105).

The absolute Scope 1 and 2 target is described as science-based and compatible with "well below 2°C". The report says 1.5°C-aligned cuts are not possible without radical change for companies in fossil-based grids, and that a 1.5°C pathway is being considered for after 2029. Natural gas is treated as a transition fuel until 2029 (page 104). In December 2025 the group signed a power purchase agreement with Tauron Sprzedaż, partly from a named wind farm (page 104). Decarbonization levers are in Table 47 (page 105). Future activities, time horizons and financial assumptions "will be specified in the transition plan" (page 108).

Identification of climate-related risks and scenario analysis

Reference: pages 93, 102-103.

Back-filled from ESRS 2 IRO-1 and E1.SBM-3, where this content is disclosed in the FY2025 report (pages 93 and 102-103). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Scenario analysis was used, following the TCFD guidance for non-financial companies (page 93). Physical risk, acute and chronic (heat waves, storms, droughts, thermal stress, water shortage, land degradation), was assessed in the high-emission IPCC SSP5-8.5 scenario, described as about 4°C of warming by the end of the century (page 102). Transition risk was analyzed in a low-carbon scenario limiting warming to 1.5°C (page 103); the report names the IEA Net Zero Emissions by 2050 scenario among those used (pages 93, 102).

Scope: Europe, where own operations and downstream sales sit, plus the main bauxite and aluminium regions upstream: Australia, China, the Middle East, South America and Central America. Horizons: short under 1 year, medium 1-10 years, long over 10 years. The work was done in the first half of 2025 inside the double materiality analysis (page 102).

Result: no physical risk with a material impact on own or downstream operations; sudden weather events could damage upstream raw material infrastructure. Transition risks proved more material (pages 102-103).

Resilience in relation to climate change

Reference: pages 88, 102-104.

Back-filled from ESRS 2 SBM-3 and E1.SBM-3, where this content is disclosed in the FY2025 report (pages 88 and 102-104). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The resilience of strategy and business model to climate risk was analyzed in the first half of 2025 within the double materiality analysis. No resilience analysis was done for other topics (pages 88, 102).

Transition risks named as significant: the high share of fossil fuels in Polish electricity (energy prices and product carbon footprint), early-stage decarbonization technologies (CCU/CCS, hydrogen, synthetic fuels), a shortage of aluminium scrap, and detailed legislation including CBAM (page 103). Factors said to reduce exposure: recycled aluminium from the group's own foundry (recycling uses 5% of the energy of primary production), sales to construction and automotive where aluminium cuts energy use, recyclable packaging, natural gas as a transition fuel with options for biogas or green hydrogen, and renewable supply under power purchase agreements (pages 103-104). Modernization of plants, fire protection and water networks is the stated physical adaptation (page 103). The group says it can obtain financing and has diversified sources (page 108).

Policies related to climate change mitigation and adaptation

Reference: page 106.

A Climate Policy covering the new 2025-2029 strategy was approved by the Management Board in 2025 and implemented in December 2025. It applies to all group companies; the COO is responsible. Its aim is a management system across the value chain supporting a low- and zero-carbon economy (page 106).

Stated emphases: climate change mitigation, renewable energy use and circular economy. Commitments: aluminium recovery, support for sustainable construction, use of renewable materials, packaging fit for recycling, and renewable power under PPAs or own sources. The policy covers ESRS E1 and E5; pollution, water and biodiversity sit in a separate Environmental Policy. The report says it plans CCS or CCU tools after 2029 (page 106).

Because it was implemented in December 2025, the policy will be consulted with stakeholders in 2026. It is published on the company website, social media and at sector events, and internally on the OrangeBook platform and intranet. Progress is tracked by indicators and the ISO 9001, 14001 and 45001 management system (page 106).

Actions and resources in relation to climate change policies

Reference: page 107; pages 107-108.

Scope 1 is 3.1% of total emissions, Scope 2 is 8.4% and Scope 3 is 88.5%, mostly purchased materials, goods and services (page 107). The group therefore focuses on energy efficiency and on recycled content.

The key 2025 action was a power purchase agreement with Tauron Sprzedaż, with part of the volume from a specific wind farm. Other value chain actions: deliveries from Kęty to Aluprof plants by electric truck, which avoided over 14 tons of CO2 from June to the end of 2025, and the "Trucks on Tracks" intermodal project, which avoided 104 tons of GHG emissions. Plant-level actions are listed by segment (pages 107-108), such as inverter systems on pumps, a higher-efficiency compressor with heat recovery, LED lighting, a 21-kW photovoltaic carport, EV chargers, a new heat pump and gas boiler house at Złotów, and heat recovery on the BOPP1 line.

The actions "neither required significant operating or capital expenditure". Future activities with time horizons and financial assumptions will be specified in the transition plan (page 108).

Targets related to climate change mitigation and adaptation

Reference: page 108; pages 108-109.

The Climate Policy sets a Scope 1 and 2 absolute reduction target (market-based, base year 2024, target year 2029) and a goal of climate neutrality by 2050 (page 108). Table 48 (page 109): 12.5% reduction by 2029; 3.96% achieved in 2025, calculated with 2024 and 2023 Scope 2 factors because suppliers publish 2025 factors only in the first quarter of 2026.

Two further targets: scrap share of billets cast in Kęty, 77% by 2029 (75.9% in 2025); low-carbon billets (below 4 tons CO2e per ton of aluminium) 40% by 2029 (42.6% in 2025). The company says the 40% value turned out too low and will be updated (page 109).

The target is based on a "well below 2°C" approach; the SBTi 1.5°C pathway is being considered after 2029. No quantitative Scope 3 target exists; the billet and scrap targets are expected to lower category 1, and suppliers must now declare carbon footprint and recycled content as a purchasing criterion (page 108).

Energy consumption and mix

Reference: page 109; pages 109-111.

Table 49 (page 110): total energy consumption 417,391 MWh in 2025 (392,812 MWh in 2024). Fossil sources were 412,517 MWh, 98.8% of the total, including 185,440 MWh of natural gas and 212,438 MWh of purchased electricity, heat, steam and cooling from fossil sources. Renewable and low-emission energy was 4,874 MWh, 1.2% (4,059 MWh renewable fuels, 816 MWh self-generated, none purchased). No coal and no nuclear. Energy intensity was 75.96 MWh per PLN million of net income (76.36 in 2024), on net income of PLN 5,494 million.

The company counts only electricity whose origin is specified in supplier contracts as renewable and excludes guarantees of origin bought on the Polish Power Exchange (page 110). An Energy Transformation Team coordinates efficiency audits and renewable projects. Energy efficiency certificates were obtained for eight projects in 2025: 277,890 toe in 2025 and 1,440,661 toe cumulatively since 2019 (page 111).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: page 111; pages 111-116.

Table 50 (page 112), tons CO2e, 2025 versus 2024: Scope 1 41,938 (37,712); Scope 2 location-based 112,196 (117,367); Scope 2 market-based 118,957 (129,823); Scope 3 1,179,718 (1,171,113). Total 1,333,852 location-based and 1,340,613 market-based. Category 1 purchased goods and services is 884,010 tons. Scope shares: 3.1%, 8.4% and 88.5% (page 115). Scope 1 is not covered by the emissions trading scheme (0%).

GHG intensity was 242.7 tons per PLN million of net income, down 5.86% (page 116). Scope 3 is spend-based for the largest categories, with EPA, DESNZ and International Aluminium Institute factors; categories 8, 11, 13, 14 and 15 are treated as not applicable, and five categories (1, 2, 3, 4, 10) are said to make up over 99% of Scope 3 (pages 113-115). Some Scope 3 data are estimated (page 76). 2024 includes the acquired SELT sp. z o.o. only from 2 September 2024 and was not recalculated (page 111).

Policies related to pollution

Reference: page 116; pages 116-117.

The group adopted a common Environmental Policy in 2025 that covers pollution and also ESRS E3 and E4. The COO oversees it, and the OrangeBook processes management system provides the platform for control. The policy focuses on minimizing emissions to air. Separate environmental policies are still kept in the operating segments, overseen by each company's management board (pages 116-117).

Commitments listed include recycling aluminium, low-VOC packaging technology, legal compliance with continuous improvement of the ISO 14001 system, monitoring air, water and soil pollution, minimizing waste, eliminating impacts from hazardous substances, and assessing environmental impact before new activities (page 117). Operational control of pollution-related processes is formalized in procedures, the group tries to use less hazardous chemicals, and contingency plans cover contamination, including chemical neutralization and groundwater and soil protection (page 117). The Code of Ethics also addresses environmental impact (page 117).

Actions and resources related to pollution

Reference: page 117; pages 117-118.

Dust and gas emissions are monitored and reported by all plants, and the group states the limits set by law and permits were kept (page 117). Main pollutants differ by segment: sulphur dioxide, nitrogen oxides, carbon monoxide and dust in the extrusion and architectural segments, and volatile organic compounds in flexible packaging (page 117). Integrated permits follow the best available techniques conclusions for non-ferrous metals (page 117).

Wastewater: Grupa Kęty S.A., AK EMMI and the Złotów plant discharge to surface waters under a water permit, using neutralization-based treatment; other sites discharge to third-party sewers after pre-treatment (pages 117-118). 2025 actions: an automatic pH and temperature measurement kit at the Kęty outlet, a closed cooling circuit for the SecoAlmex line, a new gas boiler house at Złotów, afterburner tuning to cut VOCs, and reuse of paint residues (page 118). No malfunctions caused contamination in 2025. Suppliers are screened through the supplier code and a 2025 dialogue with suppliers on environmental aspects (page 118).

Targets related to pollution

Reference: page 118; pages 118-119.

The group says non-GHG pollutant emission is not a key challenge for its business model, but the 2025 Environmental Policy sets one measurable target: a 5% reduction by 2029, against base year 2024, in total dust and non-GHG gas emissions relative to net income (Table 54, page 119). The target is voluntary.

Progress at the end of 2025 was a 15.57% reduction against the 5% set for 2029, driven by lower VOC emissions in Flexible Packaging and a 6.82% rise in net income. The company says a decision will be made to update the target (page 118). Effectiveness is verified within external and internal audit programs (page 119).

Pollution of air, water and soil

Reference: page 119; pages 119-120.

The group reports that each pollutant (excluding greenhouse gases), consolidated across all facilities, stayed below the Annex II threshold value in Regulation (EC) No 166/2006 (page 119). Air emissions fell 9.81% against 2024; water emissions were similar (page 119).

Table 55, air, kg per year, 2025: carbon monoxide 16,304.9; non-methane VOCs 75,096.1 (down 19.67%, against an Annex II value of 100,000); nitrogen oxides 36,967.4; sulphur oxides 2,151.0; PM10 3,669.2. Table 56, water, kg per year, 2025: total nitrogen 3,848.4; chlorides 131,954.9; total phosphorus 46.1; zinc 38.8; fluorides 260.8, up from 50.0 in 2024 (page 120).

Microplastics, which concern Flexible Packaging only: 5,034,500 kg produced and 73,669,361 kg used in 2025 (Table 57, page 120). The company says BOPP and PE granulate falls under the Article 5 exemption of Regulation 2023/2055, with over 95% retention in closed processes (page 120). 2024 includes SELT from 2 September 2024 (page 119).

Substances of concern and substances of very high concern

Reference: page 120; pages 120-121.

The Aluprof S.A. plant in Bielsko-Biała is classed as an increased-risk plant for serious industrial accidents because it uses chromium oxide, a substance of very high concern (page 120). Other hazardous substances present do not create that risk (page 121).

Table 58 (page 121), tons generated, used in production or purchased, 2025 against 2024: carcinogenicity categories 1 and 2, 954.3 (834.3); germ cell mutagenicity, 12.6 (34.2); reproductive toxicity, 0 (16.5); skin sensitization, 1,328.6 (1,330.1); long-term aquatic hazard, 585.3 (681.7); repeated-exposure target organ toxicity, 0 (46.6). Table 59: chromium (VI) oxide, a substance of very high concern, 11.7 tons (7.9).

The company says it ceased using chemicals classified for reproductive toxicity or target organ toxicity in 2025, and that its products fall under REACH and contain no substance on the current ECHA list of substances of very high concern (page 121). The tables cover substances generated, used in production or purchased. No amounts are given for substances leaving in products; the REACH sentence is the only statement on products.

Policies related to water and marine resources

Reference: page 121; pages 121-122.

In 2025 the group adopted a policy covering ESRS E3 (the common Environmental Policy), with the COO responsible for implementation (pages 121-122). Its primary objective is to reduce water consumption; on water treatment and pollution it is general and sets no measurable targets (page 121). It commits the group to manage and reuse water and improve environmental performance, and the Code of Conduct for Suppliers asks suppliers to reduce water consumption (page 122).

The policy has no commitment on water scarcity areas because the companies are not in high-scarcity areas, and no policy on seas and oceans because the group does not use marine resources (page 122). Because it took effect late in 2025, it was not consulted with stakeholders and consultation is planned for 2026 (page 122). ISO 14001 documentation covers the water management requirements (page 122).

Actions and resources related to water and marine resources

Reference: page 122.

Grupa Kęty S.A. withdraws water from its own intakes, a well and ground drainage, under a water permit; the other group companies buy water from third-party operators. The main action is extending the closed-circuit cooling water system used in aluminium melting and processing. In 2025 the casting line serving two melting furnaces was connected to the plant's closed circuit, which removed the separate cooling system and the electric motors, maintenance and chemical dosing it needed (page 122).

Elsewhere the practice is to replace faulty devices quickly, install water-saving devices and monitor consumption within ISO 14001 procedures. No cases needed remedies for people harmed by water-related impacts, the actions involved no significant operating or capital expenditure, and the companies do not operate in flood-threatened areas (page 122).

Targets related to water and marine resources

Reference: page 122; pages 122-123.

The Environmental Policy sets a measurable water intensity target: reduce total water consumption within own operations per PLN million of net income by 6% by 2029, against base year 2024 (Table 60, page 123). In 2025 intensity fell 1.94%, and the company says this confirms the target is achievable (page 123). The target is described as voluntary and was approved in the reporting period (page 123).

When setting it, the group did not rely on scientific evidence and did not involve stakeholders; it analyzed consumption at its companies and identified high-demand processes (page 122). The target relates only indirectly to the impact identified in the analysis, depletion of water resources through water use in the value chain, particularly primary aluminium production, and is not related to marine resources (page 123). Progress is monitored annually (page 123).

Water consumption

Reference: page 123; pages 123-124.

Table 61 (page 123): total water consumption 702,079 m3 in 2025 (670,229 in 2024, up 4.8%). Consumption in areas at water risk: 0. Water recycled and reused: 2,723,893 m3 (2,716,355). Water stored and changes in storage: 1,650 m3 (1,723).

Water intensity: 127.8 m3 per PLN million of net income (130.3 in 2024, down 1.9%), or 541.4 m3 per EUR million (561.2), on net income of PLN 5,495 million (EUR 1,297 million). Data come from water meters with automatic or manual reading, and are checked for accuracy (page 124). About 70% of withdrawal is from own intakes and about 30% from supply networks (page 83).

Transition plan on biodiversity and ecosystems

Reference: page 124; pages 124-125.

The report states that in 2025 the group did not have a transition plan for biodiversity and ecosystems (page 124). Its analysis covered own operations and the upstream value chain, including the main bauxite-extracting and aluminium-producing countries, in three horizons (page 124). It assumes a fall in demand for primary aluminium is not linearly tied to aluminium scrap supply and will not have a major effect within 10 years (page 124).

All new projects go through an environmental permit procedure applying the mitigation hierarchy, siting is chosen to limit biodiversity impact, and environmental impact assessments are prepared early, with compensatory measures where biodiversity loss is possible (page 125). The analysis concluded that the business model based on recycled aluminium is resilient to risks (page 125).

Policies related to biodiversity and ecosystems

Reference: page 125.

In 2025 the group adopted a common Environmental Policy that also covers ESRS E4. It includes a general commitment to counteract threats and impacts of operations on biodiversity and ecosystems in sensitive areas, and to carry out an environmental impact assessment before any new activity. The COO supervises implementation (page 125).

The company says the policy is general and does not address the specific items under the E4-2 disclosure requirement. It adds that the group nevertheless has a positive effect on ecosystems through species and habitat projects described under E4-3 (page 125).

Actions and resources related to biodiversity and ecosystems

Reference: page 125.

The group has no formal biodiversity action plans and says it is considering introducing them in the coming years. Resources have nonetheless gone to biodiversity initiatives for several years (page 125).

2025 initiatives: expansion of the apiary at the Kęty plant with queen replacement and honey harvesting; the "Clean Beskids" trail clean-up campaign; replanting of larch and alder in mountain forest with the Bielsko Forest Inspectorate; restoration, through the "Together with the Group" program, of an apiary destroyed by flood; forest clean-ups with the Opole Forest Inspectorate and in the Makowski Beskids; and the workshops and quiz "Biodiversity Around Us" for employees and their families (page 125). No financial amounts are given for these.

Targets related to biodiversity and ecosystems

Reference: page 125.

In 2025 the group had no measurable targets relating to biodiversity and ecosystems (page 125). The Environmental Policy that covers E4 is described as general in nature (page 125). This section sets no target year and says nothing about setting one.

Impact metrics related to biodiversity and ecosystems change

Reference: page 125.

The group did not establish metrics for its identified impacts on biodiversity and ecosystems. It explains that the impacts and risks it identified sit only upstream in the value chain, in primary aluminium production, and that it uses surveys within its supplier due diligence mechanism to assess suppliers' compliance with environmental requirements in this respect (page 125). This section gives no figures for land use, species or habitats.

Policies related to resource use and circular economy

Reference: page 126.

A policy on resource use and circular economy was adopted at group level in 2025; the Code of Ethics and the Code of Conduct for Suppliers also address it (Table 62, page 126). The Climate and Circular Economy Policy commits the group to create conditions for more sustainable, decarbonized and circular production, with recycling development and efficient waste management in all companies. Stated routes: recycling aluminium in the own foundry, supporting sustainable construction and renewable materials in building systems, developing packaging fit for recycling, a life-cycle approach, using as many recycled materials as possible, and supporting research into "sustainable" aluminium products (page 126).

The provisions refer to moving away from primary resources (bauxite, primary aluminium) toward recycled aluminium. The Code of Conduct for Suppliers asks suppliers to source responsibly, cut raw material use and minimize waste (page 126).

Actions and resources related to resource use and circular economy

Reference: page 127.

Each segment has a goal to raise recycled content: Extruded Products, the share of recycled material in billets and profiles; Flexible Packaging, the share of films and laminates fit for recycling; Architectural Systems, the number of certified buildings built with Aluprof systems (page 127). The Extruded Products Segment recycles its own scrap and scrap bought on the market, collects grades selectively and uses no harmful fluxing agents in remelting (page 127).

Aluprof S.A. has been a partner in the CIRCON project of the Polish Green Building Association (circular economy in construction) since 2023. Flexible Packaging is developing paper-based or homogeneous-plastic packaging that is easier to recycle. Upstream, the group works with suppliers of materials with more recycled content; downstream it seeks post-consumer scrap from demolition projects done by Aluprof (page 127). The 2025 actions involved no significant operating or capital expenditure, and no remedies were needed for people harmed (page 127).

Targets related to resource use and circular economy

Reference: page 129; pages 128-130.

Table 63 (page 129), 2025 result against 2029 target: share of aluminium scrap in billets cast in Kęty, 75.9% against 77%; number of certified buildings built with Aluprof systems, 78.0% against a target of +85% (base year 2020); share of packaging materials designed as recyclable, 92.3% against 100%; waste intensity per net income, down 0.3% against a target of down 4% (base year 2024). The targets come from the 2025-2029 Development Strategy, the Climate Policy and the Environmental Policy (page 128).

They are voluntary, were set without scientific evidence and use analyses of aluminium recoverability and scrap availability forecasts. The company says 2025 results confirm all four can be reached by 2029 (page 129). The packaging target counts a material as recyclable by composition, not as recycled at end of life (page 129).

Resource inflows

Reference: page 130; pages 130-131.

Table 64 (page 130): total inputs 320,895 tons in 2025 (329,849 in 2024). Technical materials were 285,729 tons and biological materials 7,082 tons, none from sustainable sources. Reused or recycled input was 7,261 tons, 2.54% of technical materials (2.68% in 2024).

Table 65 (page 131), critical materials: aluminium 148,585 tons, 46.3% of the total, of which recycled 717 tons (0.22%); magnesium 270.5 tons; manganese 19.0 tons; zinc 360.9 tons; copper 175.6 tons. All data come from direct measurement or supplier specification and invoices. To avoid double counting, post-industrial scrap recovered in the Kęty foundry is not treated as a recycled inflow (page 131). The key inputs are aluminium and polypropylene granulate (page 130).

Resource outflows

Reference: page 131; pages 131-133.

Outflows are products and packaging that left the group (page 131). Table 66 (page 133), 2025: products 264,902 tons, of which 221,354 tons (83.6%) recyclable materials; packaging 21,263 tons, of which 21,175 tons (99.6%) recyclable.

Table 67 (page 133) gives durability and recyclability by product. Aluminium profiles and aluminium systems carry an expected durability of 40-50 years or longer under industry documents such as EN 12020; aluminium is described as 100% recyclable (over 90% for systems under the EPD) and glass as usually over 80%. Flexible packaging has no durability figure ("NO DATA") and its recyclability depends on whether the structure is homogeneous or multilayer (pages 132-133). Repairability is stated as replacement or repair of damaged elements. The group assumes 100% homogeneous products are fit for recycling (page 133).

Waste

Reference: page 134; pages 133-135.

Table 68 (pages 134-135), tons, 2025 against 2024: total waste generated 69,808 (65,519). Recycled 68,501, of which hazardous 5,464 and non-hazardous 63,037. Disposed 1,307 (928), of which hazardous 578 and non-hazardous 728. Total unrecycled waste 14,177 tons, 20.3% (20.6%). No radioactive waste. Waste intensity was 12.70 tons per PLN million of net income (12.74).

Significant waste types include waste aluminium and wastewater treatment sludge in Extruded Products, aluminium processing waste, sludge and construction and demolition waste in the architectural segments, and multi-material laminates, paper, plastics and waste paints in Flexible Packaging (page 134). Waste is sorted, stored on sealed areas and passed to licensed companies. Data are calculated per current law and partly estimated or declared by the waste collector or processor (page 135).

Policies related to own workforce

Reference: page 136; pages 136-138.

Policies are developed at the parent company by sector managers, consulted with subsidiary representatives, approved by all Management Board members and published on the OrangeBook platform (page 136). Table 69 (page 137) pairs each material own-workforce impact with its policies: equal pay and the gender pay gap (Remuneration Policy, Human Resources Policy, Diversity Policy), mobbing (Code of Ethics, Dignity at Work Policy, Respect for Human Rights Policy), and safety gaps and work schedules (Occupational Health and Safety Policy, CSR Policy, Respect for Human Rights Policy).

The Respect for Human Rights Policy rests on the European Convention on Human Rights and covers decent and safe working conditions, equal opportunity, diversity, freedom of association and objection to child and forced labor; the group states zero tolerance for discrimination and mobbing (page 137). Policies reach employees through internal platforms, or through superiors where staff have no company account. In 2025 the group had no regulations on particularly vulnerable groups in its own workforce (page 138).

Taking action on material impacts on own workforce

Reference: page 138; pages 138-139.

The group says it provides human, financial and material resources adequate for its actions on own-workforce impacts, but did not run a formal process to identify the actions needed; scope comes from management experience, consultation with the workforce and market practice. It had no data to report current and future financial resources for these actions (pages 138-139).

Table 70 (page 139) lists 2025 actions and 2026 plans: an annual pay review against market benchmarks and job evaluation mapping at several companies, with a remediation plan where needed (equal pay and the pay gap); a new training strategy and a 2026 plan including mobbing prevention; monitoring of OHS procedure compliance; and shift-work measures such as breaks, protective equipment, water, meals and extra pay for adverse shift conditions. Further positive actions include internal promotion paths, incentive funds, a social benefits fund, medical care programs and sport and environmental events (page 139).

Targets related to own workforce

Reference: page 139; pages 139-140.

Targets were set in the 2025-2029 strategy adopted in April 2025, consulted with HR and OHS staff at subsidiaries; staff representatives were not involved (page 139). Results are published annually.

Targets and 2025 results (page 140): TRIR at or below 1, with a rate of 1.42 weighted by headcount (1.39 unweighted, per the ESRS method), above the target; at least 10% internal promotions, 11% in domestic companies; women in at least 30% of key positions by 2029, 33% in domestic companies; at least 60% of new hires retained for 12 months, 78% achieved; equal pay for men and women within the same position and pay grade, reviewed yearly; and 300 projects in the "Together with the Group" program by 2029, with 33 local projects in 2025, 28 of them tied to flood recovery. Table 34 on pages 78-79 gives the formulas and the responsible executive.

Characteristics of the undertaking's employees

Reference: page 140; pages 140-141.

Headcount on employment contracts and appointments was 6,240 at the end of 2025 (6,150 in 2024): 1,937 women and 4,303 men. Average headcount was 6,251 and employee turnover 11.5%; 719 people left in 2025 (pages 140-141). 82% are on contracts for an indefinite period, and women hold 31% of positions (page 140). Table 72 (page 141): 5,122 indefinite and 1,118 definite-term contracts; 6,173 full-time and 67 part-time staff; and 420 persons other than employees (129 women, 291 men).

Beyond employees: 117 people employed through temporary agencies, 262 people working on site under third-party service contracts, and 41 other persons, including Supervisory Board members and people on specific-task or B2B contracts (page 141); together these equal the 420 in Table 72. Table 71 (page 140) gives headcount by gender for all locations and for Poland.

Health and safety metrics

Reference: page 141; pages 141-142.

All 6,240 people on employment contracts and appointments are covered by the OHS management system, 100% (pages 141-142). There were no fatalities from work injuries or work-related ill health.

Table 73 (page 141), 2025 against 2024: 72 accidents at work (44), of which 70 caused absence (44); accident rate (LTIFR) 7.09 (4.71); days lost to injuries and work-related ill health 3,035 (2,610). The text says the 72 accidents include employees and persons other than employees (page 141). LTIFR is a headcount-weighted average calculated per the ESRS formula, injuries per 1,000,000 hours worked (page 142). The TRIR used for the strategy target, 1.42, is reported under S1-5 (page 140).

Compensation metrics (pay gap and total compensation)

Reference: page 142.

Average annual pay was PLN 111,010 for men and PLN 89,000 for women, or PLN 55.76 and PLN 44.68 per hour. The gender pay gap across all employees was 19.9% (22.1% in 2024). The ratio of the top earner's annual total pay to the median employee's was 46.2 (86.9 in 2024) (page 142).

Table 74 (page 142), average annual pay in PLN thousand: managerial positions, women 272.97 and men 424.50; other positions, women 83.81 and men 97.02. Data cover gross salary excluding employer social security, the forecast value of share option plan income granted in 2025, and benefits; the mean is used, and foreign pay is weighted by purchasing power parity and shown in PLN (page 142).

Incidents, complaints and severe human rights impacts

Reference: page 142.

In 2025 one case of harassment and one case of discrimination involving own workforce were reported. The Business Ethics Committee is still investigating the discrimination report. The group recorded no other human rights violations among own workforce or value chain workers, meaning none of non-compliance with the UN Guiding Principles, the ILO Declaration or the OECD Guidelines (page 142).

Six violations of the Code of Ethics were reported through the irregularities reporting channels, and apart from the case above none involved human rights; all were investigated in the period. No fines, penalties or damages related to incidents or complaints were imposed. No complaints came through employee concern channels and none went to OECD National Contact Points (page 142). The channels are described under G1-1.

Policies related to value chain workers

Reference: page 143; pages 143-144, 150.

Policy toward value chain workers rests on the Code of Conduct for the Suppliers of the Capital Group (page 143). It is addressed to key suppliers, together at least 95% of the purchase value tied to manufacturing, and covers child and forced labor, equal treatment, freedom of association and safe working conditions; suppliers must pass the principles to indirect suppliers (page 150). The group checks minimum safeguards once a year, at a high level of generality (page 143).

It identified higher human rights risk, especially child and forced labor, in China, the United Arab Emirates and Kuwait, and in bauxite-producing countries (page 143). Footnotes state that the Code does not refer to third-party standards, has no literal provisions on trafficking, forced or child labor, only a general duty to respect human rights, and that stakeholders were not consulted when it was drafted (pages 143, 149-150).

Taking action on material impacts on value chain workers

Reference: page 144; pages 144-145.

The material risk identified for value chain workers is lack of respect for human rights, including occupational safety, freedom of association, forced labor and child labor (page 144). The group verifies business partners through a supplier assessment questionnaire and audits against the Supplier Code of Conduct (page 144); 12 ESG audits were carried out at selected suppliers in 2025 (page 150).

In 2025 it took no additional measures to create a positive impact on value chain workers and cannot report the financial resources for these actions. In 2026 it will focus on promoting the Supplier Code. It recorded no serious human rights problems or incidents upstream or downstream in 2025 (page 145). The section also says the double materiality analysis showed no material impacts or opportunities for these workers, although Table 40 lists impact S5 for them (pages 91, 145).

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

Reference: page 145.

In 2025 the group had no targets for managing material negative impacts, advancing positive impacts, or managing risks and opportunities related to value chain workers, and did not involve those workers in the process. It plans to adopt measurable targets by the end of 2027 (page 145).

The ESG strategy does include a supplier due diligence target of at least 12 ESG audits a year, tagged to impact S5 and governance impact G3 (Table 34, page 79).

Business conduct policies and corporate culture

Reference: page 146; pages 146-149.

Business conduct rests on the Code of Ethics, the Respect for Human Rights Policy and the Code of Conduct for Suppliers, adopted by the Management Board. The Compliance and Risk Management Director and the Business Ethics Ombudsman supervise ethics, and in 2025 the segment ethics committees were replaced by a single Business Ethics Committee (page 146). The group has been a UN Global Compact signatory since 2014, and Table 75 maps the ten principles to its documents (page 147). The policies predate the CSRD and, the report says, do not take stakeholder interests into account (page 148).

About 71% of employees (85% in 2024) knew the Code of Ethics and 57% the Human Rights Policy (65%) (page 148). About 71% of employees of domestic companies completed the 2025 training on reporting channels (page 149). Reports can go to a supervisor, the Ombudsman or internal reporting channels (mail, e-mail, recorded phone line), anonymously or named, and the group protects whistleblowers by statute (page 149).

Targets related to business conduct

Reference: page 79; pages 79, 149-151.

Two business conduct targets sit in the 2025-2029 ESG strategy (Table 34, page 79). First, due diligence in the supply chain: at least 12 ESG audits a year to verify compliance with the Supplier Code of Conduct, owned by the Internal Audit Director; 12 audits were carried out in 2025 (page 150). Second, at least 60% of employees trained each year on responsible business conduct (Code of Ethics, anti-corruption, mobbing, due diligence, human rights), owned by the Compliance and Risk Management Director. About 71% of employees of domestic companies completed the 2025 reporting-channel training (page 149).

The same table lists a stable dividend payout of 60-100% of consolidated net profit under the governance heading; it is not a conduct target. No separate G1 targets section appears in the statement.

Political influence and lobbying activities

Reference: page 151; pages 151-153.

Lobbying decisions are made by the Management Board. The group does not fund political parties and gave no money in 2025 (as in 2024). No group company is registered as a lobbyist in national or EU transparency registers, and none commissioned a registered lobbyist in 2025. No Management Board or Supervisory Board member currently sits, or sat in the two prior years, on public administration bodies (page 151).

Table 76 (pages 151-153) lists seven memberships: UN Global Compact, Polish Aluminium Association, European Aluminium Association, West Pomeranian Chemical Cluster "Green Chemistry", Polish Green Building Council, Cradle to Cradle Products Innovation Institute and Passivhaus Institute. It gives each body's objectives, the annual contribution (from PLN 7,000 to PLN 78,246.90, plus EUR 25,277.00 for one) and whether the body is a registered lobbyist; three are shown as registered in the EU Transparency Register (pages 151-153).

Payment practices

Reference: page 150.

Payments follow dates set by internal procedures and law. Payment terms are agreed with suppliers but do not exceed 30 days for public entities and 60 days for micro, small and medium-sized companies; for large companies a longer term is allowed only with a clear contractual arrangement (page 150). Payment dates falling on a bank holiday or Saturday move to the next working day under Article 115 of the Civil Code.

86% of payments were made in line with the agreed dates (89% in 2024). The average payment term for group companies in Poland was 29 days (28 in 2024). All companies monitor liabilities to prevent delays, and no court litigation over late payment is pending (page 150).