GVS S.p.A.
Material Topics
Sustainability statement, in full
The complete text of GVS S.p.A.’s FY2025 sustainability statement is held here – 134 pages, captured from the published report. Every disclosure below also links to its own passage.
ESRS 2 – General Disclosures
GOV-1The role of the administrative, management and supervisory bodiesReported
The role of the administrative, management and supervisory bodies
Reference: pages 41-48; index entry page 72.
GVS S.p.A. uses the traditional Italian model: Shareholders' Meeting, Board of Directors and Board of Statutory Auditors (page 41). The Board has nine directors. Five are independent, including the Chair, and eight are non-executive. Four directors (44%) have sustainability expertise, and 44% of directors are women (pages 42-43). The Board has no employee representation, "as this is not required by current legislation applicable to GVS" (page 42).
Two permanent committees, each of three independent directors (page 42): the Control, Risk and Sustainability Committee (CRSC) and the Nominations and Compensation Committee.
Allocation of responsibility (pages 45-48):
- The Board sets sustainability strategy and approves the Consolidated Sustainability Statement and the sustainability targets.
- The CRSC held 15 meetings in 2025, nine with sustainability items. Six of the Board's eight meetings had a sustainability item (page 46).
- A Cross-functional Sustainability Committee (CEO, CFO, COO, VP R&D, Corporate HR Director, General Counsel) gets quarterly KPI reports. The Group Sustainability Director coordinates it (pages 47-48).
- On 28 January 2025 the Board appointed the Sustainability Director as Manager responsible for Sustainability Reporting (page 46).
GOV-2Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodiesReported
Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies
Reference: pages 42, 45-47.
On frequency, the statement says: "The frequency with which the Board is informed about sustainability topics can vary annually according to specific needs or topics of relevance and, therefore, no fixed frequency is defined" (page 45). In 2025 the Sustainability Department, the Legal Department and the Internal Audit & Risk Management Department each reported to the Board (page 45).
Board items in 2025 (page 46): approval of the 2025 Remuneration Policy, which includes an ESG target on health and safety, and of the 2024 Consolidated Sustainability Statement with its double materiality assessment.
CRSC topics in 2025 (page 47): progress on the Multi-Year Sustainability Plan targets; how the statement is prepared; the feasibility study for a Scope 1 + 2 + 3 emissions target and its decarbonization levers; results of the double materiality assessment; the ESG targets in the 2025 Remuneration Policy; the risk catalog with the Head of Internal Audit.
The Board of Statutory Auditors attended all CRSC and Board meetings, in full or through the Chair and at least one member (page 47).
Skills (page 42): an annual Board self-assessment, an external-advisor assessment in the last year of each term, and an induction program that covers sustainability topics.
GOV-2(was GOV-3)Integration of sustainability-related performance in incentive schemesReported
Integration of sustainability-related performance in incentive schemes
Reference: pages 48-51; E1 GOV-3 is covered in the same section (index page 72).
The Chair, non-executive directors and statutory auditors receive fixed fees only, with no variable plan (page 48).
Short-term plan (STI), 2025 (page 49): one of three Group strategic targets is ESG. For 2025 it was the work-related injury rate. The result was 4.83 against a target of 4.6, "higher than the target of 4.6 but still within the threshold value". Some Key Managers also had individual sustainability targets weighted 5%, on pay equity and on a decarbonization feasibility study. Both were "fully met".
Long-term plan (LTI) 2023-25 (page 50): the ESG indicator was non-compliant products per million sold: 23.3 against a target of 28.3.
LTI 2026-28 (page 50): adds an indicator on the reduction of Scope 1 + Scope 2 (market-based) emissions against the 2024 baseline.
The statement is explicit that "In 2025, the targets associated with the short and long-term incentive plans were not linked to a greenhouse gas emissions reduction target" (page 51). It refers readers to the Report on the Remuneration Policy for more.
GOV-3(was GOV-4)Statement on due diligenceReported
Statement on due diligence
Reference: page 56; index entry page 72.
The statement gives a mapping table: "The following is a mapping of the information provided in this Statement on the due diligence process." It lists the five core elements of due diligence and points each to sections of the statement (page 56):
- Build due diligence into governance, strategy and business model: Governance; Double materiality assessment and stakeholder engagement.
- Engage stakeholders: Governance; Stakeholder engagement; the process for identifying and assessing material IROs; the summary of material IROs; Workers in the value chain; Supplier relationship management.
- Identify and assess adverse impacts: the double materiality assessment, plus the E1, E3, E5, E2-E5 supply chain, S1, S2, S4 and both G1 chapters.
- Take action, and track effectiveness and communicate: the Multi-Year Sustainability Plan, Main Group policies, and the same topical chapters.
The datapoint index lists GOV-4 par. 30 against "Statement on due diligence" (page 79).
GOV-4(was GOV-5)Risk management and internal controls over sustainability reportingReported
Risk management and internal controls over sustainability reporting
Reference: pages 52-55.
The internal control and risk management system covers the Board, the CRSC, the CEO (the Appointed Director), Internal Audit, the Board of Statutory Auditors and the Supervisory Body (pages 52-53).
For sustainability reporting (pages 53-55): a dedicated procedure sets the workflow and roles. The Board approves the double materiality assessment and the statement. The CRSC examines the draft. The CEO and the Manager responsible for Sustainability Reporting certify compliance.
Main risks the Group identified (page 54):
- Reporting boundary not complete.
- Inconsistency in data collection and mismatch with internal procedures.
- Inaccuracy and manual errors from aggregating data from different systems.
Mitigations (pages 54-55): a reporting procedure and operating manual, a standard data collection framework with automatic consistency checks, internal training for all Group companies, quarterly monitoring of key metrics, reasonableness analysis, attestations from data owners, and Internal Audit walk-throughs at a selection of significant Group companies.
The statement is also subject to limited assurance by the independent auditors (page 55).
SBM-1Strategy, business model and value chainReported
Strategy, business model and value chain
Reference: pages 35, 37-40, 66-69.
Business (pages 37-39): filtration solutions for critical applications. At 31 December 2025: 18 manufacturing plants (Brazil 1, China 2, Italy 5, Mexico 2, UK 1, Romania 1, USA 6), distribution companies in 19 countries and 3,973 employees. Revenue from contracts with customers by division: Healthcare & Life Sciences 67.1%, Safety 19.5%, Energy & Mobility 13.4%.
Value chain (page 39): tier-1 suppliers provide materials, components and products; further up are the companies that extract and produce raw materials such as fossil fuels and metals. GVS sells mainly business-to-business.
Strategy (pages 66-69): the 2024-2026 Sustainability Plan, "Protecting your tomorrow", has four pillars and covers 15 areas, 5 of them priorities. The Board approved it in July 2024. Only targets that meet all MDR-T requirements are shown as targets; the rest were reclassified as "Planned Actions" (page 67).
Transitional provision (page 35): the Group used the relief for SBM-1 paragraph 40(b)-(c).
SBM-2Interests and views of stakeholdersReported
Interests and views of stakeholders
Reference: pages 57-59, 119-120; S1 SBM-2 also page 119 (index page 72).
GVS identifies 12 stakeholder categories, including shareholders and investors, customers, employees, suppliers, regulators, financial institutions, trade associations, local communities and academia, and uses a mix of formal and informal channels (pages 57-58). Their views are received by the relevant departments and fed into the information used for the Group materiality assessment, and the findings are shared with the CRSC (page 57).
For the 2025 double materiality assessment (page 59): meetings with key managers, workers' representatives and a selection of the main suppliers. The assessment also drew on customer and investor requests, supplier questionnaires and employee climate surveys.
Own workforce (page 120): the Unitary Trade Union Representative of GVS SpA takes part in the assessment, and results are shared back with them.
Limits stated in the report: water and circular economy analyses involved "no direct consultation with local communities" (pages 96, 100), and workers "were not directly involved in the definition of the sustainability targets of the Plan" (page 66).
SBM-3Material impacts, risks and opportunities and their interaction with strategy and business modelReported
Material impacts, risks and opportunities and their interaction with strategy and business model
Reference: pages 35, 62-65, 82-83; index entry page 72.
Pages 62-65 list the material IROs by topic, with type, a description, location in the value chain and time horizon. Impacts and risks are assessed before mitigation. By topic: E1 climate change (negative impacts, a market risk from the automotive transition, and a green hydrogen opportunity); E2 pollution of air and water in the supply chain and microplastics; E3 water; E4 upstream biodiversity impacts; E5 resource inflows, outflows and waste; S1, S2 and S4; and G1.
Change from the prior year (page 65): "all material sustainability topics for 2024 were confirmed, with the addition of a sub-sub-topic on water consumption", linked to the Haemonetics whole blood acquisition. IROs for E1, E5, S1 and G1 were also changed.
Financial effects (pages 35, 65): SBM-3 48(d) is addressed by reference to note 8.18, Provisions for risks and charges, in the consolidated financial statements. "No current financial effects have been identified" beyond those in note 8.18 for S1. The Group used the transitional relief for SBM-3 48(e).
IRO-1Description of the processes to identify and assess material impacts, risks and opportunitiesReported
Description of the processes to identify and assess material impacts, risks and opportunities
Reference: pages 57-62.
GVS updated its double materiality assessment in 2025 in four steps (pages 58-61):
- Context and stakeholder analysis, including the Haemonetics whole blood assets.
- Identification of IROs across all ESRS topics, sub-topics and sub-sub-topics, using benchmarking, ESG standards and ratings, supplier and customer requests, site-level water stress and biodiversity screening, employee surveys, the Group risk catalog and a climate risk analysis of all manufacturing plants.
- Assessment. Impacts are scored on scale, scope, irremediable character and likelihood (potential impacts only), on a scale from 1 to 5. Risks and opportunities use magnitude of financial effect and likelihood.
- Threshold. The materiality threshold was set to "Medium": all IROs rated "High", "Medium-high" and "Medium" are material (page 61).
Sustainability risks sit in the corporate risk catalog, which is updated at least once a year (pages 61-62). "The double materiality assessment process remained unchanged from the prior year (the first year of application)" (page 62). The Board approves the assessment (page 53).
IRO-2Disclosure requirements in ESRS covered by the undertaking's sustainability statementReported
Disclosure requirements in ESRS covered by the undertaking's sustainability statement
Reference: pages 35, 72-81.
This is the company's own ESRS content index. Pages 72-78 list each disclosure requirement with its ESRS topic, number, description and the section of the statement where it appears. The company says the list was "selected on the basis of the results of the double materiality assessment" (page 72).
Topics covered: ESRS 2, E1, E2, E3, E4, E5, S1, S2, S4 and G1. S3 is not listed.
What the index lists, by topic:
- E1: E1-1 to E1-8 (E1-9 is not listed).
- E2: E2-1 to E2-3 only. E2-4, E2-5 and E2-6 are not listed.
- E3: E3-1 to E3-4. E4: E4-1 to E4-4. E5: E5-1 to E5-5.
- S1: S1-1 to S1-10 and S1-13 to S1-17. S1-11 and S1-12 are not listed.
- S2: S2-1 to S2-5. S4: S4-1 to S4-5. G1: G1-1 to G1-4.
Transitional provisions (page 35): SBM-1 40(b)-(c), SBM-3 48(e), E1-9, S1-8 63(a), S1-11 and S1-13 83(a).
Pages 79-81 list datapoints from other EU legislation (SFDR, Pillar 3, Benchmark Regulation, EU Climate Law), each with a section reference, "Not applicable", "Not relevant" or "Not applicable (application of Transitional provisions)".
E1 – Climate Change
E1-1Transition plan for climate change mitigationReported
Transition plan for climate change mitigation
Reference: pages 85-88 (Climate change (E1), Targets and actions); index page 73.
GVS states that it has no transition plan as ESRS defines one: "based on a conservative interpretation of the ESRS, the feasibility study carried out by GVS does not meet all the criteria required by the ESRS to be classified as a transition plan" (page 86). It "may consider supplementing its Plan" with one later.
What it has instead:
- Scope 1 + Scope 2 (market-based): –42% by 2030 against 2024. With the acquired Haemonetics assets added, the baseline is 43,888 tCO2e and the target 25,455 (page 85). On the 2024 reporting scope alone it is 39,273 to 22,778 (page 87).
- Scope 3: a "preliminary target" of 16% for categories 3.1, 3.3 and 3.4 (81,779 to 69,063 tCO2e), equal to an 11% reduction in total Scope 3 against 2024 (pages 86-87).
- No external validation. The Group used SBTi near-term guidance but "has not submitted its target to SBTi to date" (page 87).
- Levers: more renewable energy purchased, self-generation, and process and facility efficiency, listed as options to select from (page 86).
- Resources: planned actions "are already foreseen within the corporate budget" (page 88). No amounts are given.
E1-2(was covered under ESRS 2 IRO-1)Identification of climate-related risks and scenario analysisReported
Identification of climate-related risks and scenario analysis
Back-filled from ESRS 2 IRO-1 and the climate DMA section of Climate change (E1), where this content is disclosed in the FY2025 report (pages 60, 83-84). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.
Reference: pages 60, 83-84.
Physical risk: in 2024 GVS assessed 12 categories of chronic and acute physical risk at its manufacturing sites under three IPCC scenarios: RCP 2.6 (low emissions), RCP 4.5 and RCP 8.5 (high emissions), for 2030, 2035, 2040, 2050 and 2085. In 2025 it added a study of the California plant acquired in January under RCP 2.6, RCP 7.0 and RCP 8.5, to 2085 (page 83). The value chain got a qualitative assessment of the upstream supply chain. The physical risks "were assessed as non-material from a financial point of view" (page 83).
Transition risk: a preliminary qualitative analysis of political and legal, technological, market and reputational risks, supplemented by a qualitative reading of the IEA Net-Zero Emissions by 2050 scenario, which is consistent with 1.5°C (pages 83-84). The significant category is market risk from the automotive shift to lower-emission vehicles (page 84).
The text gives no global average temperature projection per scenario.
E1-3(was covered under ESRS 2 SBM-3)Resilience in relation to climate changeReported
Resilience in relation to climate change
Back-filled from the E1 section of the report (pages 83-84), which draws on ESRS 2 SBM-3. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.
Reference: pages 83-84.
The risk: "an untimely update of the product range for the low-emission vehicle market could entail a risk of market loss if not properly managed in the medium and long term" (page 84).
The response: GVS says it "has for several years taken actions to reduce the impact of this risk and make its business more resilient". These include products for electric cars and plug-in hybrids, and a new plant for an in-house diaphragm for alkaline water electrolysis, aimed at green hydrogen (page 84).
Physical risk: assessed as not financially material. The assessment "is periodically monitored as part of the Group's risk management system" (page 83).
The Environmental Policy commits GVS to "regularly evaluate processes and practices to ensure resilience against climate change risks" (page 84).
The report presents no section labeled as a resilience analysis and gives no statement on uncertainty or capacity to adapt.
E1-4(was E1-2)Policies related to climate change mitigation and adaptationReported
Policies related to climate change mitigation and adaptation
Reference: pages 70, 84; index page 73.
The Group Environmental Policy, last updated in February 2026, covers climate change and commits GVS to "contribute to climate change mitigation by improving energy efficiency and exploring opportunities to increase the use of renewable energy sources" and to "regularly evaluate processes and practices to ensure resilience against climate change risks" (page 84). The policy also covers pollution, materials and waste, water, biodiversity, product use and end of life, and supplier engagement (page 70). It applies to the GVS Group, and the CEO is responsible for implementation (page 70).
Certified management systems (page 84): 10 companies, representing 14 manufacturing sites, hold ISO 14001 environmental certification. One company holds ISO 50001 for energy management. The report says these cover 85% of Group workers.
Suppliers (page 110): the Supplier Code of Conduct requires suppliers to manage energy and GHG emissions, and encourages targets based on climate science.
E1-5(was E1-3)Actions and resources in relation to climate change policiesReported
Actions and resources in relation to climate change policies
Reference: pages 85, 87-88; index page 73.
Actions in 2025 (pages 87-88):
- Renewable electricity: two Group companies bought certified renewable electricity, 7,251 MWh in total.
- Self-generation: a 105 kWp photovoltaic system installed at Bologna in 2024 began generating in 2025, avoiding about 50 metric tons of CO2e (market-based).
- Fleet: company cars are replaced with electric or plug-in hybrid models when bought or leased, mainly at GVS SpA.
- Relocation: GVS Filter Technology UK moved to a new plant, and the Suzhou operations were consolidated into one new plant. A lower energy use is expected.
- Feasibility study on a Scope 1 + 2 + 3 target, completed in 2025.
Planned (page 88): extend the health and safety assessment program to include environmental criteria in 2026.
Savings are not quantified: "Where not specified, data on the quantification of GHG emission reductions resulting from the action itself are not available to date" (page 88). Planned actions "do not depend on the availability and allocation of resources as they are already foreseen within the corporate budget" (page 88). The ISO 14001/50001 certification target stood at 25%, with 1 company newly certified (page 85).
E1-6(was E1-4)Targets related to climate change mitigation and adaptationReported
Targets related to climate change mitigation and adaptation
Reference: pages 85-87; index page 73.
Targets (page 85):
| Target | Base | Target value | Progress |
|---|---|---|---|
| Scope 1 + 2 (market-based) –42%, tCO2e | 43,888 (2024) | 25,455 (2030) | in progress |
| New sites certified: ISO 14001 (3 more companies) and ISO 50001 (1 more) | 0 (2023) | 4 (2026) | 25% |
The 2024 baseline was recalculated to include the Haemonetics whole blood assets, so it differs from the figure published in July 2024 (page 85, note 13).
Scope 3 (page 87): a preliminary 16% reduction for categories 3.1, 3.3 and 3.4 combined, from 81,779 to 69,063 tCO2e. The statement says "The planned reduction trajectory for Scope 3 indirect emissions does not refer to any external standards" and that the Scope 3 trajectory is not currently fully in line with the Paris Agreement (pages 86-87).
The targets "were adopted voluntarily by the Group and do not derive from legal obligations" (page 85). They have "not been validated or certified against external standards" (page 87).
E1-7(was E1-5)Energy consumption and mixReported
Energy consumption and mix
Reference: pages 88-89, 91; index page 73.
Energy use, MWh:
| 2025 | 2024 | 2023 | |
|---|---|---|---|
| Natural gas | 21,835 | 17,177 | 14,696 |
| Crude oil and petroleum products | 5,973 | 6,495 | 6,146 |
| Purchased fossil electricity, heat, steam | 70,593 | 67,596 | 53,677 |
| Fossil total | 98,401 | 91,267 | 74,518 |
| Renewable total | 7,746 | 7,174 | 18,206 |
| Total | 106,147 | 98,441 | 92,724 |
Fossil sources were 93% of the 2025 total; renewables 7% (2023: 20%). Electricity is 74% of use, natural gas 20% and fuels 6% (page 88). The 2025 renewable total is 7,251 MWh of purchased renewable electricity, 310 MWh self-generated and 185 MWh of renewable fuels.
Intensity (page 89): 0.250 MWh per EUR 1,000 of net revenue (2024: 0.230), on revenue of EUR 424,662 thousand. All revenue is from the manufacturing sector, which the report treats as a high climate impact sector.
Use rose about 8%, mainly from the acquired whole blood assets and from two new plants running in parallel with the sites they replace (page 88).
E1-8(was E1-6)Gross Scopes 1, 2, 3 and Total GHG emissionsReported
Gross Scopes 1, 2, 3 and Total GHG emissions
Reference: pages 90-95; index page 73.
Gross emissions, tCO2e (page 90):
| 2025 | 2024 | |
|---|---|---|
| Scope 1 | 6,510 | 5,570 |
| Scope 2 market-based | 30,886 | 33,703 |
| Scope 2 location-based | 25,306 | 28,508 |
| Scope 3 (10 categories) | 110,818 | 110,570 |
| Total market-based | 148,214 | 149,843 |
| Total location-based | 142,633 | 144,648 |
Largest Scope 3 categories in 2025: purchased goods and services 60,923; upstream transport 15,221; fuel and energy-related 10,489; downstream transport 7,866. Intensity is 0.35 tCO2e per EUR 1,000 of revenue, market-based. Scope 1 and 2 are not covered by the EU ETS (page 90).
Restatement (page 94): the Scope 3 method for logistics (categories 4 and 9) changed to account for shipment weight. The difference from the 2024 statement is –33,169 tCO2e for category 4 and –52,821 for category 9.
The report says Scope 3 estimates carry "a high level of uncertainty" because primary data is limited (page 94). Category 3.1 is 58% weight-based; the rest is estimated (page 92). Of 15 categories, 10 are reported (page 91).
E1-9(was E1-7)GHG removals and GHG mitigation projects financed through carbon creditsReported
GHG removals and GHG mitigation projects financed through carbon credits
Reference: pages 90-91; index page 73.
The company's index lists E1-7. The disclosure is a nil return. The statement says: "The Group did not engage in GHG emission removal or storage activities, did not purchase carbon credits and did not finance emission mitigation projects with carbon credits" (page 91).
It adds that the Group "is not covered by the EU Emissions Trading Scheme (EU ETS)" and that the share of Scope 1 emissions under regulated trading schemes is 0% (page 90, note 20).
The datapoint index also lists E1-7 (GHG removals and carbon credits, par. 56) against the Metrics section (page 79).
E1-10(was E1-8)Internal carbon pricingReported
Internal carbon pricing
Reference: page 91; index page 73.
The company's index lists E1-8. The disclosure is a nil return. The statement says: "To date, the Group has not defined an internal price on carbon" (page 91).
The Group is not covered by the EU ETS (page 90).
E2 – Pollution
E2-1Policies related to pollutionReported
Policies related to pollution
Reference: pages 109-110; index page 73. Reported in the chapter "Environmental information in the supply chain (E2, E3, E4, E5)".
The material pollution impacts are upstream. They are potential negative impacts from suppliers' emissions to air and water, and a potential microplastics impact if plastic granules spill in transport (pages 62, 109). For its own operations, the report says "no significant impacts, risks or opportunities related to own activities were identified in connection with the topic of pollution" (page 109).
Policies (page 110):
- The Environmental Policy covers pollution (page 70).
- The Supplier Code of Conduct requires suppliers to "comply with current pollution regulations and regularly monitor, control, reduce and treat pollutant emissions (including microplastics) into the air, water and soil".
- GVS asks suppliers to go beyond legal requirements on pollution and environmental accidents, to restore damage quickly, and to adopt certified environmental management systems.
The Code is communicated to suppliers' own supply chains. Violations can be reported through the Whistleblowing channel (page 111).
E2-2Actions and resources related to pollutionReported
Actions and resources related to pollution
Reference: pages 111-112; index page 73.
The pollution actions are the supplier engagement program, which also covers E3, E4 and E5.
Completed in 2025 (pages 111-112):
- The sustainability questionnaire for suppliers was updated and finalized. It covers suppliers' policies, targets, risks and actions, including environmental topics.
- The supplier engagement program was launched by sending the questionnaire to the main direct suppliers.
Planned for 2026 (page 112): extend the program to more suppliers so the 2026 target is met, and use results to define improvement actions with suppliers.
Result in 2025: "no environmental mitigation or remedial actions by the suppliers were required" (page 112).
No pollution-specific action in own operations is described, which matches its finding that no significant pollution IRO sits in its own activities (page 109).
E2-3Targets related to pollutionReported
Targets related to pollution
Reference: pages 111-112, 167; index page 73.
The target that covers pollution is the supplier engagement target in the Sustainability Plan: engage 50% of the main direct suppliers (by spend) on sustainability topics through a continuous evaluation and improvement program by 2026 (page 111). Base is 0% in 2023, target 50% in 2026, and progress is described as "Engagement program launched" (page 167).
The target "is not linked to legal requirements" (page 111, note 37). The Plan covers E1, E2, E3, E4, E5, S2 and G1 with this one target (page 167).
No quantified target for emissions to air, water or soil, or for microplastics, appears in the statement.
E3 – Water
E3-1Policies related to water and marine resourcesReported
Policies related to water and marine resources
Reference: pages 96-97, 110; index page 74.
The Environmental Policy sets the water commitment: "Manage water resources responsibly, committing to implement actions to reduce water withdrawals and to treat and recycle water used for production, particularly in water-stressed areas" (page 97).
Context (page 96): water comes mainly from the public supply and, to a lesser extent, on-site wells. In most processes (assembly and molding of plastics) water is not part of production. It is part of the process at the two filtration membrane plants (Italy and the US), for steam sterilization in China, at two plants with extrusion, and at the California plant, which prepares Water for Injection and runs sterilization and pasteurization.
Suppliers (page 110): the Supplier Code of Conduct requires suppliers to monitor water withdrawal and consumption, treat wastewater before discharge, and reduce pressure on local water resources, especially in water-stressed areas.
E3-2Actions and resources related to water and marine resourcesReported
Actions and resources related to water and marine resources
Reference: page 97; index page 74.
Water treatment system (page 97): the Sustainability Plan commits GVS to install a water treatment system on its membrane production line in Italy by 2025. The site is the parent company's, which uses water for production and operates in a water-stressed area. The system is expected to cut the effluent from the line and the water withdrawn. Today that water is collected and disposed of as waste.
After initial tests, "the project timeline was extended as it became necessary to carry out further analyses and assessments". The work continues throughout 2026.
Earlier action: an internal recirculation system with active carbon filters at the same plant in 2022 saved "more than 280m3 of water in the year it was installed".
The certification target (ISO 14001 at 3 more companies) also supports water management (page 97).
E3-3Targets related to water and marine resourcesReported
Targets related to water and marine resources
Reference: pages 67-68, 97; index page 74.
The one target the statement links to water is the voluntary target to extend certified environmental management systems (ISO 14001) to 3 additional manufacturing companies, which strengthens the Group's continuous improvement on environmental topics (page 97). Progress stood at 25%, with 1 company certified (page 85).
The water treatment system for the Italian membrane line is described as a commitment under the Multi-Year Sustainability Plan, due by 2025 and now running through 2026 (page 97). It does not appear in the Plan's target table (page 68). The statement says targets that did not clearly meet MDR-T were reclassified as "Planned Actions" (page 67).
No target on water withdrawal or consumption volumes is set.
E3-4Water consumptionReported
Water consumption
Reference: pages 97-99; index page 74.
Water, m3:
| 2025 | 2024 | 2023 | |
|---|---|---|---|
| Total withdrawal | 201,690 | 161,699 | 150,032 |
| of which in water-stressed areas | 155,438 | 118,387 | 104,311 |
| Total consumption | 26,602 | n.a. | n.a. |
77% of 2025 withdrawal was in areas of high water stress, using the WRI Aqueduct classification of "High" and "Extremely High" (page 97). Consumption is water withdrawn and not returned, about 13% of withdrawal. 2025 is the first year it is reported, so there is no comparison (page 98).
Intensity: 0.47 m3 per EUR 1,000 of revenue for withdrawal (2024: 0.38) and 0.06 for consumption (page 98).
Drivers (pages 96-98): withdrawal rose because of the Haemonetics whole blood acquisition and leaks that were later fixed. Consumption concentrates at three sites: the Italian membrane plant, the California plant (evaporation and water in products) and a Chinese sterilization plant.
Quality limits (page 99): there are no meters on wastewater, so the discharge figure is estimated, and consumption "is subject to a high degree of uncertainty".
E4 – Biodiversity and Ecosystems
E4-1Transition plan on biodiversity and ecosystemsReported
Transition plan on biodiversity and ecosystems
Reference: pages 59, 63, 109, 112; index page 74.
GVS reports no biodiversity transition plan and says why. The one material biodiversity IRO is a potential impact upstream: extraction of fossil fuels and metals "could generate impacts on biodiversity and local ecosystems in terms of land or sea use change or through the release of pollutant emissions" (page 63).
It sits with suppliers beyond tier one, with whom GVS has no direct business relationship. The report says this has so far not shown a need to develop a strategy to adapt the business model on biodiversity, and that no significant risks have emerged on the topic (page 109).
For own operations, "no biodiversity-related IROs were assessed as relevant because the analyses conducted did not identify any production processes of the Group that have a significant impact, risk or dependence on biodiversity" (page 109). The assessment included each site's proximity to biodiversity-sensitive areas (page 59).
E4-2Policies related to biodiversity and ecosystemsReported
Policies related to biodiversity and ecosystems
Reference: pages 70, 110-111; index page 74.
The Environmental Policy covers biodiversity (page 70). The policy tool aimed at the upstream impact is the Supplier Code of Conduct, whose biodiversity pillar says: "Suppliers must manage their activities to avoid negative impacts on ecosystems and biodiversity" (page 111). Suppliers are expected to identify, assess and mitigate activities that could cause biodiversity loss or damage natural habitats, wildlife or ecosystem services, and to "pay attention particularly to activities near to biodiversity-sensitive areas".
Responsibility for implementing the Code sits with the CEO or a designated representative. The monitoring process for the updated Code "is being defined" (page 111).
The datapoint index marks the E4-2 policy datapoints on sustainable land or agriculture practices, sustainable oceans and seas, and deforestation "Not relevant" (page 80).
E4-3Actions and resources related to biodiversity and ecosystemsReported
Actions and resources related to biodiversity and ecosystems
Reference: pages 111-112; index page 74.
The biodiversity action is the supplier engagement program, shared with E2, E3 and E5.
Completed in 2025: the supplier sustainability questionnaire was finalized, and the program was launched with the main direct suppliers (pages 111-112).
Planned for 2026: extend the program to more suppliers (page 112).
The report states that GVS has not used biodiversity offsets linked to its supply chain in setting targets and actions, has not applied ecological thresholds, and has not brought local and indigenous knowledge or nature-based solutions into these actions (page 112).
It explains that the impact is linked to suppliers with whom GVS has no direct business relationship, so the actions focus on learning about supplier practices and, "if necessary", defining further prevention and mitigation actions (page 112). No resources are quantified.
E4-4Targets related to biodiversity and ecosystemsReported
Targets related to biodiversity and ecosystems
Reference: pages 111-112, 167; index page 74.
The only target the statement ties to biodiversity is the supplier engagement target in the Sustainability Plan: involve 50% of the top direct suppliers by spend in a continuous evaluation and improvement program on sustainability topics by 2026. The base is 0% in 2023 and the status is "Engagement program launched" (page 167). The Plan lists E1, E2, E3, E4, E5, S2 and G1 against this one target.
The statement says the target "is not linked to legal requirements" (page 111, note 37).
No biodiversity-specific outcome target, such as a land-use or habitat measure, is set. The report says no strategy to adapt the business model has been needed for the upstream impact (page 109).
E5 – Resource Use and Circular Economy
E5-1Policies related to resource use and circular economyReported
Policies related to resource use and circular economy
Reference: pages 70, 100-101; index page 75.
The Environmental Policy sets the circular economy commitments, and most Group companies hold ISO 14001 certification (page 100). The commitments (page 101):
- Prioritize avoiding or minimizing waste, and otherwise follow the waste hierarchy: prevention, preparation for re-use, recycling, other recovery, disposal.
- Monitor scrap materials closely and look for ways to cut them.
- Consider the locality of materials in relation to where they are used.
- Look for ways to reduce virgin materials and increase renewable materials in products and packaging, where feasible.
The report sets out the sector constraint openly. The Healthcare & Life Sciences division (about 67% of revenue) is mainly single-use, and under local rules single-use medical products "generally have to be incinerated as contaminated waste" (page 100).
IROs from purchasing are managed through the supplier policies in the G1 supplier chapter (page 101).
E5-2Actions and resources related to resource use and circular economyReported
Actions and resources related to resource use and circular economy
Reference: pages 101-104; index page 75.
Packaging and materials (page 102): in 2024 GVS launched two product lines, the new Full Face Mask and the Elipse Rev3 filters, in cardboard packaging with no single-use virgin plastic. The Electrostatic Filters for Spirometry, launched in 2024, use 12% less plastic than the model they replace.
Ecodesign (pages 102-103): the sustainability checklist for new product development was built into the project approval process, and the relevant departments assessed the projects in scope. Planned: define ecodesign guidelines by 2026.
Manufacturing efficiency (page 104): an internal target on Overall Equipment Effectiveness (OEE) aims to cut production scrap and use machines more efficiently. The report says this target is "preliminary and for internal use only" (page 101).
Resource inflows: actions are described in the G1 supplier chapter (page 104).
No resource amounts are given for these actions.
E5-3Targets related to resource use and circular economyReported
Targets related to resource use and circular economy
Reference: pages 102-103; index page 75.
Targets from the Sustainability Plan (all voluntary):
| Target | Base | Target | Progress |
|---|---|---|---|
| 3 new product lines with 100% virgin plastic-free single-use packaging (Safety division) | 0 (2023) | 3 (2026) | about 66% (2 launched in 2024) |
| 1 pilot on alternative packaging with lower impact (Group) | 0 | 1 (2026) | under development |
| 3 projects to cut virgin plastic in 3 product families (Group) | 0 | 3 (2026) | about 33% (1 launched in 2024) |
| Assess at least 50% of new product projects with the sustainability checklist | 0% (2024) | 50% (2025) | achieved, 77% |
| Assess 100% of new product projects with the checklist | 0% (2024) | 100% (2026) | in progress |
The statement notes the targets "were adopted voluntarily by the Group and do not derive from legal obligations" (page 102, note 29).
No target is set for waste volumes. The OEE efficiency target is internal and preliminary (page 101).
E5-4Resource inflowsReported
Resource inflows
Reference: pages 35, 104, 107; index page 75.
Resource inflows: about 26,397 metric tons of materials, components and products in 2025, up 8% from 24,337 metric tons in 2024. The report puts the rise down to "a different mix of material types purchased, each with a different specific weight" (page 104).
What is bought: plastic granules are the main raw material, used in molding filters for all three divisions. Secondary raw materials include steel metal inserts, mainly for Energy & Mobility. Process materials are solvents, oil and silicone. The Group also buys components and finished products. The polymers named are PVC, ABS, polyethylene, polypropylene, polystyrene, nylon, TPE, PVDF, PES and PTFE (page 104, note 33).
Recycled content: "The Group did not use secondary components, or reused or recycled secondary intermediate products and materials, in its production processes" (page 104).
Quality: the weight is partly recorded and partly estimated. The report says the metric "is subject to a high degree of uncertainty" (page 107), and lists E5-4 among the metrics with a high level of uncertainty (page 35).
E5-5Resource outflowsReported
Resource outflows
Reference: pages 104-105; index page 75.
Products: most products are filters for medical, personal protection and automotive uses. The report says "Filtration systems must be replaced at the end of their useful life to ensure the health and safety of users, which generally makes reuse or recycling unfeasible" (page 105).
Durability (page 105):
- Healthcare & Life Sciences (67% of revenue): designed for single use.
- Safety (20%): protective masks last 3 to 5 years, reusable respirators about 1 to 2 years, and replacement filters last until exhausted.
- Energy & Mobility (13%): air intake, HVAC and fuel filters are replaced after about 3 to 5 years. ABS, injector and ventilation filters are designed to last the vehicle's life.
Repair: most Safety division masks have replaceable filters, with spare parts and a video platform. The report says repairability does not apply to the other two divisions.
Recyclable content: "it is currently not possible to determine the percentage of recyclable content." Single-use medical products are mostly incinerated as contaminated waste (page 105).
Waste data is under the separate Waste entry.
E5-5(was E5-5-Waste)WasteReported
Waste
Reference: pages 106-108; index page 75 (E5-5 Metrics).
Waste generated, metric tons:
| 2025 | 2024 | 2023 | |
|---|---|---|---|
| Hazardous | 1,177 | 1,502 | 1,161 |
| Non-hazardous | 5,032 | 4,852 | 4,069 |
| Total | 6,209 | 6,355 | 5,230 |
| Directed to disposal | 1,971 (32%) | 1,671 (26%) | 1,829 (35%) |
| Diverted from disposal | 4,239 (68%) | 4,684 (74%) | 3,401 (65%) |
2025 detail (page 107): hazardous waste diverted 841 metric tons (recycling 789, other recovery 52); directed to disposal 337 (incineration 140, other 197). Non-hazardous diverted 3,398 (recycling 2,620, other recovery 777); disposal 1,634 (incineration 99, landfill 1,205, other 330).
Total waste fell 2% in 2025. The largest hazardous stream by weight is rinse water from membrane production in Italy, mostly recycled (page 106). The largest non-hazardous stream is plastic trimmings from molding. The Group "does not generate radioactive waste" (page 106).
Method (pages 107-108): based on waste collection documents, with estimates from container size and collection frequency where none exist.
S1 – Own Workforce
S1-1Policies related to own workforceReported
Policies related to own workforce
Reference: pages 67, 70-71, 121-122, 136-137; index page 76.
The Code of Ethics sets the workplace commitments (pages 121-122): respect for health and safety and fair and decent pay; a ban on violence, harassment and discrimination; inclusion and gender equality; compliance with data protection law; condemnation of "slavery, human trafficking and the exploitation of labour, whether child, forced or under threat of corporal punishment"; and support for the Universal Declaration of Human Rights.
The Whistleblowing Policy dates from 2023. Other policies listed on pages 70-71 include Health and Safety, Remote Working, Parental Leave, Onboarding, Individual Variable Bonus, Succession Planning, Salary Review, Global Talent Acquisition, Internal Mobility, and IT and Privacy. Several are shown as internal procedures rather than public documents.
The Health and Safety Policy commits GVS to eliminate hazards, keep plant and equipment maintained, train and supervise employees and involve suppliers. The CEO or a designated representative is responsible for implementation (pages 136-137).
In 2025 about 1,700 hours of training covered the Code of Ethics and the new business conduct program (page 122).
S1-2(was S1-2 + S1-3)Engagement with own workforce and workers' representatives, existence of channels for own workforce to raise concerns or needs and approaches to remedyReported
Processes for engaging with own workforce and workers' representatives about impacts
Reference: pages 66, 119-120; index page 76.
GVS reviews its human resources work plan every year, partly through external benchmarking, and the HR department sets resources for projects in the annual budget (page 120).
Channels (page 120): regular surveys, dedicated meetings, digital tools and direct feedback. At GVS SpA and all sites with union representation, regular meetings are held with the Joint Trade Union Representatives. In several offices, including the UK and the US, suggestion boxes allow anonymous or named input.
In the materiality assessment: the Unitary Trade Union Representative of GVS SpA takes part, and the Group shares the published results with that representative. The Group Sustainability Department runs these meetings and feeds the input back into the assessment. Employee climate surveys from some Group companies were also considered (page 120).
Limit: "The Group's workers were not directly involved in the definition of the sustainability targets of the Plan" (page 66).
Processes to remediate negative impacts and channels for own workforce to raise concerns
Reference: pages 120-122, 133, 137, 160-162; index page 76.
Remediation (page 121): "In the event of any negative impact on the workforce, the Group assesses on a case-by-case basis the most appropriate ways to implement remediation and/or corrective actions", such as meetings, improvement actions or disciplinary actions.
Channels:
- The Whistleblowing Policy takes reports from workers, former workers, trainees and volunteers, through an IT platform (main channel), a voicemail box and post. Reports can be anonymous (pages 122, 160).
- The platform is encrypted and outside the corporate network. Each report gets a code to track its status. Retaliation is prohibited (page 161).
- The Reports Team acknowledges a report within seven days and aims to close cases within 3 months (page 161).
- Workers can also raise issues with union representatives and the Workers' Safety Representative, and suggestion boxes exist in some offices (pages 120, 137).
2025 use: 22 reports came through the platform, the same as 2024 (page 161). Separately, 3 reports alleged discrimination, and none was confirmed (page 133).
S1-3(was S1-4)Taking action on material impacts on own workforceReported
Taking action on material impacts on own workforce
Reference: pages 122-123, 131-139; index page 76.
Actions completed in 2025 (pages 122-123):
- Global Talent Acquisition Policy, Salary Review Group Policy and Internal Mobility Policy published.
- A Global Standard Roles catalog, with every employee mapped to a role, to test pay for work of equal value.
- Parental support policies in the US and Italy, including longer leave and financial support for new mothers.
Health and safety (pages 137-138): two more companies gained ISO 45001 certification, more than 26,000 hours of health and safety training were delivered, and a safety awareness campaign ran at manufacturing sites.
Planned (page 123): extend the Succession Planning Policy to top management, Group training guidelines, an employee engagement survey, a psychological first aid service and a social worker in Italy, and remote working in Malaysia (all 2026).
Effectiveness: tracked through the targets in S1-5. The injury rate target for 2025 was missed (4.83 against 4.6) (page 139). No resource amounts are stated beyond the HR annual budget process (page 120).
S1-4(was S1-5)Targets related to own workforceReported
Targets related to own workforce
Reference: pages 67, 131, 133, 137, 139, 141; index page 76.
All targets are voluntary and come from the 2024-2026 Sustainability Plan.
| Target | Result or status |
|---|---|
| Work-from-home Policy at 100% of Italian companies (2024) | Completed |
| Parental Leave Policy at 100% of US companies (2025) | Completed |
| Equal pay for equivalent work irrespective of gender, within +/- 5% (2026) | In progress |
| 70% of indirect employees get a structured performance evaluation (yearly) | Achieved, 72.8% |
| ISO 45001 at 7 more manufacturing companies (2026) | 43% (3 companies since 2024) |
| Internal health and safety assessment at 100% of manufacturing companies (2026) | 61.5% |
| Work-related injury rate of 4.6 (2025) | Not achieved: 4.83 |
| Work-related injury rate of 4.6 (2026) | In progress |
The 2025 injury target was "a 6% reduction in the rate of work-related injuries compared to the three-year average" of 4.9 (page 139). The 2026 target is a 10% reduction against a 5.1 average for 2023-2025 (page 139). The report says the 2025 target "was not achieved" (page 139).
S1-5(was S1-6)Characteristics of the undertaking's employeesReported
Characteristics of the undertaking's employees
Reference: pages 124-126; index page 76.
GVS had 3,973 employees at 31 December 2025 (2024: 4,348; 2023: 4,111), counted by headcount.
| Female | Male | Total | |
|---|---|---|---|
| Employees | 2,369 | 1,604 | 3,973 |
| Permanent | 1,996 | 1,380 | 3,376 |
| Temporary | 373 | 224 | 597 |
| Full-time | 2,333 | 1,597 | 3,930 |
| Part-time | 36 | 7 | 43 |
No employees are reported as "Other" or "Not disclosed", and none have non-guaranteed hours.
By region: Italy 859, Europe excluding Italy 629, the Americas 1,968, Asia 517. Countries with at least 50 employees and 10% of the total: China 462, Italy 859, Mexico 1,317, Romania 444 and the US 407 (page 124).
Turnover: 3,039 employees left in 2025, a rate of 76.5% (2024: 37.4%; 2023: 61.1%), and 2,605 were hired. The report puts the fall in headcount down to merging and rationalizing production sites after recent acquisitions (Puerto Rico, Brazil, China) and to process automation in Romania and Mexico (page 124).
S1-6(was S1-7)Characteristics of non-employee workersReported
Characteristics of non-employee workers
Reference: page 127; index page 76.
Non-employee workers are agency workers and interns. The report says agency work is "generally aimed at coping with production peaks".
| Headcount | 2025 | 2024 | 2023 |
|---|---|---|---|
| Agency workers | 268 | 225 | 230 |
| Interns | 26 | 11 | 7 |
| Total | 294 | 236 | 237 |
Commercial agents are not counted. The report says they "do not work exclusively for GVS, as in most cases they are multi-firm agents".
The statement says there is no formal policy specifically on this topic, and that GVS applies local labor rules in each country (page 127).
Injury data for agency workers is given in the health and safety section: 6 injuries in 2025, a rate of 8.25 (page 140). The S2 section notes that the Group "does not make significant use of third-party workers at its sites (e.g. subcontractors)" (page 146, note 71).
S1-7(was S1-8)Collective bargaining coverage and social dialogueReported
Collective bargaining coverage and social dialogue
Reference: pages 35, 128-129; index page 76.
Collective bargaining: 78% of employees are covered by collective bargaining agreements (2024: 77%; 2023: 69%). In the EEA, which for GVS means Italy and Romania, 100% of employees are covered by workers' representatives (page 128).
The report adds that GVS gives better conditions than local law where possible, through company contracts or second-level supplementary agreements. Representation arrangements and coverage differ by site: in some places covering the whole workforce, in others only some categories (page 128).
The coverage tables give bands by region (0-19% to 80-100%) for 2025 and 2024. No European Works Council was active in 2025 (page 128, note 44).
Transitional provision (page 35): GVS used the relief for S1-8 63(a), the overall share of employees covered by workers' representatives in countries outside the EEA.
Social dialogue in practice: the Health and Safety Policy provides for consulting employees and their representatives (page 128).
S1-8(was S1-9)Diversity metricsReported
Diversity metrics
Reference: page 127; index page 76.
Top management is the 45 people who report to the CEO or hold managerial or departmental responsibility, such as heads of corporate departments, regional directors and general managers of Group companies. It is "predominantly male (88.9%)".
| Top management | 2025 | 2024 |
|---|---|---|
| Male | 40 (89%) | 39 (87%) |
| Female | 5 (11%) | 6 (13%) |
| Total | 45 | 45 |
Employees by age, 2025: under 30, 1,063 (27%); 30-50, 2,103 (53%); over 50, 807 (20%). In 2024 the counts were 1,260, 2,236 and 852.
Board: 44% of directors are women, a gender diversity ratio of 0.8 (page 43).
The overall workforce is 59.6% female (page 124). The unadjusted pay gap by employee category is under S1-16.
S1-9(was S1-10)Adequate wagesReported
Adequate wages
Reference: pages 129-130, 145; index page 76.
GVS states that it "ensures compliance with legal obligations regarding remuneration in all countries", so minimum wages are always paid. For some regions the adequate wage is "significantly higher than the legal minimum" because of living costs (page 129). The Group watches inflation, purchasing power and market benchmarks in each country and reviews pay in the annual salary review.
The table on page 130 gives, for 16 countries, the share of employees whose basic wage is below the adequate wage benchmark, for 2025 and 2024. The report explains the main movements:
- Brazil: the living wage standard rose by more than 10%, and union agreements took effect in November 2025.
- United Kingdom: the living-wage level and employer tax burden rose, which increased the share below benchmark despite pay rises.
- Mexico: wage increases cut the share significantly.
- Some countries: the gap applies to people whose pay is deducted for long absences such as sick or maternity leave and then compensated by the state (page 130).
Method (page 145): each company's basic wage and any fixed guaranteed pay is compared with publicly available adequate wage indicators for its region.
S1-12(was S1-13)Training and skills development metricsReported
Training and skills development metrics
Reference: pages 35, 133-136; index page 76.
Training: more than 59,000 hours of training and development in 2025, an average of 15.1 hours per employee (page 134).
| Average training hours | 2025 | 2024 | 2023 |
|---|---|---|---|
| Male | 13.9 | 11.1 | 25.1 |
| Female | 15.9 | 13.6 | 28.3 |
| Total | 15.1 | 12.6 | 27.0 |
Performance reviews (page 136): 32% of all employees received an individual performance evaluation (2024: 33%). For indirect employees the figure is 72.8%, which meets the Plan target of 70%. A digital platform has run since 2017 for indirect employees, with a quarterly self-assessment and manager review (page 135).
Transitional provision (page 35): GVS used the relief for S1-13 83(a), so it gives no gender breakdown of employees in reviews, no number of reviews per employee and no comparison with reviews agreed by management.
Planned: a management development plan for middle management, including diversity, equity and inclusion training, by 2026 (page 134).
S1-13(was S1-14)Health and safety metricsReported
Health and safety metrics
Reference: pages 136-140, 144; index page 76.
Injuries and ill health:
| Employees | Agency workers | Total | |
|---|---|---|---|
| Fatalities, 2025 | 0 | 0 | 0 |
| Work-related injuries, 2025 | 36 | 6 | 42 |
| Injury rate, 2025 | 4.52 | 8.25 | 4.83 |
| Days lost, 2025 | 1,018 | 84 | 1,102 |
| Total injuries, 2024 | 35 | 6 | 41 |
| Injury rate, 2024 | 4.16 | 7.87 | 4.47 |
The rate is injuries per million hours worked. The combined rate rose 8% (2023: 5.74). There was 1 case of work-related ill health among employees (page 140).
Coverage (page 137): 3,030 workers, 71% of the total, are covered by ISO 45001 certified systems (employees alone: 2,866 or 72%).
Method (page 144): counts injuries causing death, days off, work restriction, treatment beyond first aid, loss of consciousness or a significant physician-diagnosed injury. Commuting is excluded. Where hours worked were missing for some employees, workable hours were used.
S1-14(was S1-15)Work-life balance metricsReported
Work-life balance metrics
Reference: pages 131-132; index page 77.
Family-related leave, 2025:
| Men | Women | Total | |
|---|---|---|---|
| Employees entitled | 98% | 100% | 99% |
| Entitled who took leave | 7% | 9% | 8% |
In 2024 the shares were 99% entitled and 8% took leave, in total. In 2025, 113 men and 205 women took family leave (page 131).
Entitlement rests on company rules, agreements or collective bargaining agreements, and in some places is earned after a period of service (page 132, note 49).
GVS sets two Plan targets here: the Work-from-home Policy at 100% of Italian companies and the Parental Leave Policy at 100% of US companies, both completed (page 131). Since 2025 the US policy allows paid leave for maternity, paternity or adoption, with remote or part-time return options. GVS SpA also added a maternity support bonus and an extra flexible working day for mothers (page 131).
S1-15(was S1-16)Compensation metrics (pay gap and total compensation)Reported
Compensation metrics (pay gap and total compensation)
Reference: pages 140-145; index page 77.
Gender pay gap, unadjusted: 49% in 2025 and 49% in 2024 (page 141).
| 2025, by category | Employees | Unadjusted gap |
|---|---|---|
| Blue-collar | 3,185 | 32% |
| White-collar | 657 | 30% |
| Middle management | 86 | 11% |
| Top management | 45 | 25% |
Middle management is a new category in 2025, so there is no earlier comparison (page 142).
Adjusted gap: a new measure for "work of equal value", which "shows a figure within the ±5% range". 71% of the workforce is in comparable roles, but only 15% of standard roles are fully comparable (pages 142-143). The report puts the overall gap down mainly to the distribution of roles.
Pay ratio: highest-paid individual to median pay is 113.7 in 2025 (2024: 143.5) (page 143). The report says the ratio is influenced by the Group's presence in several countries, including emerging markets.
A Plan target aims for equal pay for equivalent work within +/- 5% by 2026 (page 141).
S1-16(was S1-17)Incidents, complaints and severe human rights impactsReported
Incidents, complaints and severe human rights impacts
Reference: pages 132-133; index page 77.
Human rights: the report says "no cases of human rights violations were recorded in 2025". Incidents of human rights violations and confirmed cases were 0 in 2023, 2024 and 2025 (page 133).
Discrimination (page 133): 3 reports of alleged discrimination came through the reporting channel in 2025 (2024: 1). The Reporting Team investigated under the Whistleblowing Policy. None was confirmed. Fines, penalties and compensation for discrimination and human rights incidents were EUR 0 in both years.
Risk context (pages 119, 132): the Group sees higher risk of human and labor rights violations in China, Russia and Turkey, based on the Global Slavery Index 2023 and a WWF labor and human rights indicator. In 2025 it updated its human rights analysis and "did not detect a significant overall risk of human rights violations".
S2 – Workers in the Value Chain
S2-1Policies related to value chain workersReported
Policies related to value chain workers
Reference: pages 147-148; index page 77.
Workers in the value chain are covered by the Code of Ethics (Board-approved) and the Supplier Code of Conduct. The Supplier Code was updated in December 2024, approved by the CEO and published in February 2025. Its structure and elements "are in line with the United Nations Guiding Principles on Business and Human Rights" (page 147).
Minimum requirements for suppliers (page 147): respect local laws and internationally recognized human rights, including the International Bill of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work.
Labor and human rights pillars (page 148): no child labor (ILO Conventions 138 and 182, minimum age 15 or higher), no forced labor or modern slavery, freedom of association and collective bargaining, respect and dignity, written contracts and lawful wages, working hours, non-discrimination, training, no recruitment fees, and health and safety.
Suppliers must pass the same principles to their own subcontractors and suppliers. GVS may audit. For non-conformities it can demand correction, suspend purchases, refuse orders and return goods, up to ending the relationship (page 147).
S2-2(was S2-2 + S2-3)Engagement with workers in the value chain, existence of channels for workers in the value chain to raise concerns or needs and approaches to remedyReported
Processes for engaging with value chain workers about impacts
Reference: pages 146, 149-150; index page 77.
GVS says the value chain analysis covered tier-1 suppliers and beyond, and that the upstream supply chain is where worker conditions are most at risk (page 146).
Engagement is indirect. The report states: "the Group involved its suppliers through a questionnaire and the collection of documentary evidence. No further activities were carried out to interact directly with supply chain workers or their direct representatives" (page 150).
The supplier sustainability questionnaire covers policies, targets, risks and actions on labor management, human rights and health and safety, and was sent to the main direct suppliers in 2025 (page 149).
No process is described for hearing from supply chain workers or their representatives, and no measure of how effective the engagement is.
Processes to remediate negative impacts and channels for value chain workers to raise concerns
Reference: pages 147, 149-150; index page 77.
The remediation channel is the Whistleblowing channel. It takes reports of violations or suspected violations of the Code of Ethics and company policies and procedures, "including the Supplier Code of Conduct" (page 149). The process is set out in the Whistleblowing Policy on GVS.com.
2025 use: "During 2025, the Group received no reports through the Whistleblowing channel of labour rights violations or potential violations occurring within its supply chain" (page 149).
If a supplier does not meet the Code, GVS can demand that violations be corrected, suspend purchases, refuse orders and return goods until the issue is fixed, and ultimately suspend the business relationship (page 147).
The Whistleblowing Policy lets external parties submit reports, including suppliers, contractors and subcontractors and their employees (page 160).
S2-3(was S2-4)Taking action on material impacts on value chain workersReported
Taking action on material impacts on value chain workers
Reference: pages 147, 149-150; index page 77.
Completed in 2025 (page 149):
- The supplier assessment questionnaire on sustainability was updated and finalized.
- The supplier engagement program was launched by sending the questionnaire to the main direct suppliers.
Planned for 2026 (page 149): extend the assessment to more suppliers to reach the 2026 target and define improvement actions with them, including mitigation or remediation if needed.
Results: "no cases of actual impacts on workers were identified in 2025, and no mitigation or remedy actions were requested from suppliers in relation to workers and human rights" (pages 149-150).
Risk basis (page 147): among the main direct suppliers, China, India, Malaysia, Taiwan, Thailand and Turkey are ranked higher risk using two indices. GVS says it "has chosen to take a precautionary approach to its assessments, which will be progressively updated" (page 147).
No resource amounts are given.
S2-4(was S2-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunitiesReported
Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Reference: pages 149, 167; index page 77.
The target is the supplier engagement target: involve 50% of the top direct suppliers, by spend, in a continuous evaluation and improvement program on sustainability topics by 2026 (page 149). Base is 0% in 2023. Status is "Engagement program launched" (page 167).
The statement says the target "is not linked to legal requirements" (page 149, note 77). The Plan lists E1, E2, E3, E4, E5, S2 and G1 against it (page 167).
It is a coverage target for engagement, not a target on outcomes for workers such as incident rates or wages. No target covers suppliers beyond tier 1, although the report says the upstream supply chain, including suppliers of suppliers, presents the greatest challenges for workers (page 146).
S4 – Consumers and End-users
S4-1Policies related to consumers and end-usersReported
Policies related to consumers and end-users
Reference: pages 152-154; index page 77.
The Quality Policy applies to all Group companies, and the CEO or a designated representative is responsible for implementation (page 152, note 79). Every manufacturing site has a certified quality management system: ISO 9001, ISO 13485 for medical devices, and IATF 16949 for automotive (page 152).
Product information (page 153): products carry labels (batch number, product code, expiry date, mandatory symbols such as sterile or latex-free) and instructions for use with warnings. Technical documentation and information on raw materials and regulations such as REACH, RoHS and conflict minerals are available on request.
Customers and end-users: most sales are business-to-business, so GVS deals mainly with corporate customers. The report says "No end-user categories with particular characteristics have been identified as being at increased risk" (page 152, note 78).
The datapoint index lists the S4-1 policy datapoint against the S4 Policies section (page 81).
S4-2(was S4-2 + S4-3)Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedyReported
Processes for engaging with consumers and end-users about impacts
Reference: pages 153-154; index page 77.
Engagement is mainly with corporate customers, because GVS "primarily interacts with customers rather than end-users" (page 153). Channels differ by Group company. In Healthcare & Life Sciences and Energy & Mobility the quality characteristics of the main products are set with the customer, and companies may send periodic customer satisfaction questionnaires.
Products reach end-users with instructions for use that describe risks from improper use (page 153).
Limits stated (page 154, note 83): "The Group's external stakeholders were not directly involved in the definition of the sustainability objectives of the Plan" and "End-users and/or patients are not directly involved in monitoring results and identifying improvement actions".
Quality coordination sits with the Quality function under the parent company's Quality & Regulatory Director (page 154).
Processes to remediate negative impacts and channels for consumers and end-users to raise concerns
Reference: pages 153-154; index page 77.
Channels: customer service contact details are supplied with the product. The Whistleblowing channel can also be used for reports of violations of company rules, laws or regulations (page 154).
Targets for response (page 153): GVS sets itself a target of responding to customer complaints within 48 hours and closing reports within 15 working days.
Process for non-conformities (page 154): depending on severity and product category, GVS agrees with the customer how to isolate affected products, including recall of defective items for reworking or disposal where needed. It then identifies and removes the cause through corrective action, the quality department checks the fix, and effective fixes are extended to similar processes. Preventive actions aim to remove potential causes.
The statement does not report the number of complaints received or the share closed on time.
S4-3(was S4-4)Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actionsReported
Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions
Reference: pages 152-155; index page 77.
Actions: improving product quality and safety is promoted through the quality management systems and a monthly management report, which each Group company produces with its main quality KPIs (page 153). Group companies take continuous improvement actions "whenever areas for improvement are identified" (page 155). Results are monitored centrally through a periodic report to management (page 155).
Outcome in 2025: "no action was necessary to remedy negative impacts on users and/or patients as a result of non-compliance of GVS products" (page 155).
Impacts addressed (page 64): potential negative impacts if information with products is incomplete or incorrect, or if products are significantly non-conforming, a related reputational and operational risk, and a positive impact from products that protect health and safety.
Effectiveness: measured through the product quality and safety target in S4-5, which was exceeded. No resource amounts are given.
S4-4(was S4-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunitiesReported
Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Reference: pages 50, 154-155; index page 77.
Target (page 154): improve the product quality and safety KPI, non-compliant products per million sold, by 9.6% against a 2023 baseline of 31.4, to 28.3 by 2025. The result was 23.3, so the target was met and exceeded (page 155).
The same KPI was the ESG indicator in the 2023-2025 long-term incentive plan: 23.3 against a target of 28.3 (page 50). The target was introduced in 2023 and is also in the 2024-2026 Sustainability Plan (page 154).
Scope: the target covers companies in the consolidated scope at 31 December 2023 and "therefore excludes companies acquired subsequently" (page 154, note 85).
The target is voluntary and "does not derive from legal obligations" (page 154, note 84). End-users and patients were not directly involved in setting it or tracking results (page 154, note 83).
G1 – Business Conduct
G1-1Business conduct policies and corporate cultureReported
Business conduct policies and corporate culture
Reference: pages 156-162; index page 78.
Business conduct rests on the Code of Ethics, the Global Compliance Program, the Organizational and Management Model under Italian Legislative Decree 231/2001 (adopted by GVS SpA and Haemotronic SpA), the Anti-Corruption Policy and the Whistleblowing Policy (pages 158-160). The Code covers human resources, human rights, health and safety, environment, privacy, cybersecurity, quality, conflict of interest, anti-corruption, supplier relations, fair competition, financial integrity and anti-money laundering (page 158).
Oversight: the Board defines the system and rules of governance and reviews and approves the business conduct policies. The CEO, as Appointed Director, is responsible for implementation (pages 157-158, 162). Directors' ethics expertise comes from experience in multinational settings, and "The Company therefore does not provide specific training to directors on ethics and anti-corruption" (page 162).
Whistleblower protection (pages 160-161): reports from employees and external parties, confidential or anonymous, through an encrypted IT platform. Retaliation is prohibited. In 2025, 22 reports were received (2024: 22). Nine were potentially relevant and one was corroborated, with action taken (pages 161-162).
Training: about 1,700 hours in 2025 on responsible conduct policies (page 162).
G1-2(was G1-2 + G1-3)Actions related to business conductReported
Management of relationships with suppliers
Reference: pages 164-167; index page 78.
Process (pages 164-165): GVS SpA follows a formal procedure to qualify, monitor and develop suppliers, and other Group companies use similar ones. Suppliers are classified by whether they directly or indirectly affect final product quality. A questionnaire lets suppliers self-assess their quality, environmental and safety systems. Suppliers need a quality certification such as ISO 9001:2015, IATF 16949 or ISO 13485. ISO 14001, ISO 45001, ISO 50001 and a code of ethics are "elements of added value". The Quality Department checks purchased materials for REACH and RoHS compliance.
Supplier Code of Conduct (page 166): pillars on labor and human rights, the environment, business conduct (including anti-corruption, money laundering, fraud, conflict of interest, trade compliance and responsible sourcing of minerals) and information technology. Suppliers must pass it down their own supply chain.
2025 (pages 165, 167): GVS strengthened management of its top direct suppliers, built a new Group vendor list of strategic raw material suppliers and refined the sustainability questionnaire.
Target (page 167): involve 50% of top direct suppliers, by spend, by 2026. Base 0% in 2023. Status: engagement program launched.
Prevention and detection of corruption and bribery
Reference: pages 158-163; index page 78.
Prevention: the Organizational and Management Model sets rules of conduct and controls for offences under Decree 231/2001, including corruption and bribery. GVS SpA and Haemotronic SpA analyzed "all (100%) of their activities, sites and processes" with a risk assessment and gap analysis, and each has a Supervisory Body (page 159).
The Anti-Corruption Policy applies to all Group companies and to anyone working for GVS. It sets a zero-tolerance approach to corruption and money laundering. It covers dealings with public officials and third parties, donations, sponsorship, entertainment, gifts and hospitality, and requires segregation of roles, traceability of documents and prior assessment of business partners (pages 159-160).
Detection: internal reporting channels including the whistleblowing system, investigations run by Internal Audit and the Reports Team (with the Supervisory Body for Decree 231 matters), and disciplinary measures for breaches (pages 160-161).
Training: a Business Ethics and Conduct program started in September 2025 and covers bribery and corruption. 443 people took part in 2025 (page 163). At GVS SpA, 37 new hires took a 30-minute online module on the Model, 18.5 hours in total (page 162).
G1-3(part of MDR-T/GDR-T disclosures)Targets related to business conductReported
Targets related to business conduct
Back-filled from the business conduct chapter, where targets are addressed under MDR-T. G1-3 became a standalone disclosure requirement only in the 2025/2026 ESRS, and this report was prepared under the 2023 ESRS.
Reference: pages 163, 167.
Ethics and anti-corruption (page 163): deliver Business Conduct training to 100% of executives, managers and indirect employees worldwide by 2026. Base is 0% in 2024. Status is "Training activity launched in 2025". In 2025, 443 people attended, about 443 hours. The focus is on staff with at least six months at the company (note 88). A program to monitor the effectiveness of the training starts in 2026.
Suppliers (page 167): involve 50% of top direct suppliers, by spend, by 2026.
The targets "were adopted voluntarily by the Group and do not derive from legal obligations" (page 163, note 87).
The training target measures coverage. It does not set a target for outcomes such as reports received or incidents.
G1-4Incidents of corruption or briberyReported
Incidents of corruption or bribery
Reference: pages 161-163; index page 78 (G1-4 and MDR-M).
The statement says "no convictions or fines were received for violations of corruption and bribery laws during the reporting period. During 2025, the Group also found no violations of its policies and procedures on corruption and bribery" (page 163).
| 2025 | 2024 | 2023 | |
|---|---|---|---|
| Convictions for violations of anti-bribery and anti-corruption laws | 0 | 0 | 0 |
| Fines for violations of anti-bribery and anti-corruption laws | 0 | 0 | 0 |
Whistleblowing in 2025 (pages 161-162): 22 reports. Nine were potentially relevant and had enough information to investigate, and one more was potentially relevant but lacked detail. Eight investigations found no violation. One report was corroborated and "adequate action was taken". The statement does not say whether that case concerned corruption or bribery.
The datapoint index lists G1-4 par. 24(a) on fines and 24(b) on anti-corruption standards against the Metrics section (page 81).