H+H International A/S

Reference: pages 35-41, 49 (content index, page 48).

H+H's Board of Directors has five members at the end of 2025, two women and three men (40% women), and the report gives a 100% board independence rate (pages 8, 36, 79). The collective competences the Board lists include Sustainability / ESG and Health & safety (page 36). The Board has two committees: an Audit Committee and a Nomination & Remuneration Committee, which was formed by merging two earlier committees (pages 35-36).

The Board oversees compliance with the ESG Policy and is updated monthly on key ESG metrics by Group Management (page 49). The Audit Committee oversees financial and non-financial reporting, external assurance, internal controls and ESG risk management, receives the results of whistleblower investigations, and meets each quarter (page 49). Its 2025 work included monitoring the sustainability reporting process and reviewing the double materiality assessment (page 35).

Group Management defines and runs the ESG initiatives and reviews progress at least quarterly, including long-term projections of CO2 emissions and health and safety (page 49). Operations is responsible for the environment and health and safety, HR for social matters other than safety, and Finance for governance, reporting, ESRS and taxonomy (page 49). The report gives the GOV-1 datapoints on board gender diversity and independence as page 36 (page 58).

Reference: pages 48-49.

The Board is updated monthly on key ESG metrics by Group Management, and at board and committee meetings, including on ESG projects and on how effective actions are against targets (page 49). Group Management reviews progress at least quarterly in business review meetings, or weekly with the regional Managing Directors (page 49). The Audit Committee meets each quarter when financial reports are released, and also at the request of other board members or of the financial or sustainability auditors (page 49).

On the material impacts, risks and opportunities: the double materiality assessment (DMA) was reviewed in the first half of 2024 by Group Management and the regional Managing Directors, with internal and external stakeholders. The result went first to the Audit Committee and was then presented to and approved by the Board. In 2025 the DMA review was updated with no major changes to the outcome (page 48). The long-term strategy, including how to address the material impacts, risks and opportunities, is discussed at the annual strategy seminar (page 48). The material impacts, risks and opportunities are presented with the topical standards E1, S1 and G1 (page 52).

The report says the Board and its committees are updated on due diligence as part of their annual wheel (page 48).

Reference: page 49 (content index, page 48).

The Remuneration Policy for the Board of Directors and Executive Board is approved by the General Meeting of shareholders, together with any later changes (page 49). It sets targets for both the long-term and the short-term incentive programs (page 49).

For 2025 the short-term incentive program had two ESG KPIs, each weighted 15%: one on lost-time incidents (health and safety) and one on reducing scope 1 and 2 CO2 emissions (page 49). The long-term incentive share program has carried an ESG KPI on scope 1 and 2 emissions since 2023. It continued in 2025 with a 15% weighting, and its measurement period runs over several financial years at a time (page 49). Both emission targets are set against the GHG reduction targets in the Environmental section (page 49).

The report also notes a sustainability-linked financing agreement that gives incentives for achieving specific ESG KPIs (page 48). It does not state the percentage of total remuneration that is linked to sustainability, beyond the 15% KPI weightings.

Reference: page 50 (content index, page 48).

GOV-4 is a mapping table. It lists the five core elements of due diligence and shows where each appears in the statement, with a marker for whether each reference relates to people, the environment or both (page 50).

(a) Embedding in governance, strategy and business model: GOV-2 (pages 48-49), GOV-3 (page 49) and SBM-3 (pages 63-64 for climate; 75-76, 77-78 and 82 for own workforce). (b) Engaging with affected stakeholders: GOV-2, SBM-2 (page 51), IRO-1 (pages 53-54), and the policies E1-2 (page 64), S1-1 (pages 76, 78, 82) and S1-2 (page 82). (c) Identifying and assessing adverse impacts: SBM-3 on the same pages as (a). (d) Taking action: E1-1 (page 62), E1-3 (pages 64-65) and S1-4 (pages 76, 78, 82). (e) Tracking effectiveness: metrics in E1-4 (page 65), S1-14 (pages 76-77), S1-9 and S1-16 (page 81), and targets in E1-4 (page 65) and S1-5 (pages 76, 79, 82).

Elsewhere the report says "Due diligence is managed mainly through policies and their related processes" (page 48). The GOV-4 datapoint on the statement on due diligence (paragraph 30) is marked Material, page 50 (page 58).

Reference: pages 55-56 (content index, page 48).

H+H says it has a risk management and internal control system with sustainability embedded in it. It has three parts. Risk identification and assessment runs at Group and regional level, with each region assessing its risks and Group assessing the overall Group sustainability risks. Control activities are performed and reviewed by the regions to check the quality and validity of management reporting and the Annual Report. Monitoring involves the regions and is anchored in the Group, with reporting to the Audit Committee. A controller visit plan approved by the Audit Committee means each region is visited at least once a year to assess the maturity and effectiveness of internal controls (page 55).

The approach follows the COSO ERM and COSO Internal Control guidance, using qualitative and quantitative methods (page 55). The key internal control risks identified for sustainability reporting are measuring of consumption, measuring of conversion factors and measuring of volumes. The controls are reconciling input data in the ESG reporting system to supporting documentation, analytical reviews, and obtaining and comparing conversion factors (page 55). Findings from regional reviews are reported to the regions as issues and tracked against agreed action plans, with statistics reported to the Audit Committee (page 56). The Risk Management section covers climate and health and safety as enterprise risks (pages 46, 55).

Reference: pages 17, 21-22 (content index, page 48).

H+H's core activity is the manufacture and sale of wall-building materials. The main product lines are aircrete (AAC) blocks and calcium silicate (CSU) units, used in the residential new-build segment (page 5). In 2025 revenue was DKK 2,743 million, the group employed 1,338 people, it ran 25 active plants and produced 3.1 million cubic meters of wall-building materials. Two mothballed plants in Germany were closed in 2025 (page 5). Employees by country are in S1-6: Germany 346, Poland 625, United Kingdom 277 and Other 90 (page 79).

The business model describes full wall-solution selling, with sand, water and lime as the key raw materials and cement added for AAC products (page 17). The report says scope 3 emissions are about 75% of the baseline-year footprint, and that approximately 95% of those come upstream from cement and lime manufacturers (page 63). H+H mainly sells through builders' merchants (page 85).

The strategy page "Mission Zero" sets the climate commitments: a 46% cut in absolute scope 1 and 2 emissions and a 22% cut in scope 3 emissions per m3 by 2030 against 2019, and net zero in operations and products by 2050 (page 21). The report states the business model is prepared in accordance with SBM-1 (page 17).

Reference: page 51 (content index, page 48).

H+H names five stakeholder groups and how it engages each. Employees are reached through intranet updates, workers' councils, engagement surveys in selected areas, manager check-ins and global town halls, and can use the online whistleblower system. Customers are engaged through customer support, surveys, training and business partner due diligence; one outcome is product-specific environmental product declarations in most markets. Suppliers are engaged on carbon reduction initiatives, including carbon capture storage and utilization, through supplier due diligence and industry collaborations. Society and local communities are reached through trade organization memberships, local trade fairs and events. Shareholders are reached through Investor Relations, investor roadshows, analyst briefings and the Annual General Meeting (page 51; see also page 43).

The Board and Group Management are regularly informed of stakeholder views. The report says the need to drive down emissions is a key interest of both internal and external stakeholders, and that the main priority for internal stakeholders is safety, which is reflected in the strategy (page 51). H+H adds that it does not have plans to modify the relationship and views of stakeholders (page 51).

Reference: pages 52, 63-64, 75, 77, 82, 85-86 (content index, page 48).

The SBM-3 table lists the material impacts, risks and opportunities by topic, with type, value chain position and time horizon (page 52).

E1 Climate change: emissions from own operations (actual negative, own operations); value chain emissions from raw materials production (actual negative, upstream); use of energy in own production (risk, own operations); recarbonation of products during their lifetime (labeled an opportunity, entire value chain). The climate chapter describes recarbonation as a positive impact in the downstream value chain (pages 52, 63).

S1 Own workforce: five health and safety rows, all potential negative (industrial accidents and ill health from production materials); three equal-treatment rows (gender equality and equal pay, an actual negative; gender diversity and anti-harassment, potential negative); and one working conditions row on social dialogue (potential negative) (page 52).

G1 Business conduct: three potential negative impacts on corporate culture, whistleblower protection and unethical business practices, all in own operations (page 52).

For climate, H+H identifies material financial risks and opportunities. For the other material topics it has "exercised the phase-in option and not quantified the financial effect" (page 52). For S1 SBM-3 paragraphs 14(e) to 14(g) and 15-16 the report says it does not assess any material impact (page 75).

Reference: pages 54, 56-57 (content index, page 48).

All entities and business segments are in scope, and topics were identified and scored across the value chain. H+H engaged internal and external stakeholders, including employees, suppliers, customers, society, investors, analysts and banks, through interviews and desktop research, and assessed financial risks and opportunities in parallel through its enterprise risk management process. The DMA is reassessed annually or when there are significant changes (page 54).

Stated assumptions: the majority (95+%) of supply is virgin material supplied directly by tier 1 suppliers, and tier 2 risk is assumed equal to tier 1; the primary impact is assumed to lie upstream and in production, so downstream analysis rests mainly on internal interviews and desktop research; and transport is covered as part of scope 3 climate emissions and not analyzed separately (page 54).

Scoring follows ESRS 1: scale, scope, irremediability and likelihood for impacts, with severity taking precedence over likelihood for human rights, and financial significance, likelihood and nature of effect for risks and opportunities (page 54). The outcome is that Climate, Own workforce and Business Conduct are material (page 54). The report explains why it scoped out pollution, water withdrawals, biodiversity, and circularity and waste (pages 54-55).

The climate scenario analysis uses NGFS scenarios and a TCFD workshop of the top 50 leaders (pages 56-57).

Reference: pages 48, 53, 58-61 (content index, page 48).

There is no single concordance table for all disclosure requirements. The report prints a "List of disclosure requirements" with page references for ESRS 2 on page 48, and a "List of material disclosure requirements" at the start of each material topical chapter: E1 (page 62), S1 (page 75) and G1 (page 85). Disclosure requirements absent from these lists are treated here as not reported.

The IRO-2 section (page 53) lists the topics and sub-topics under E1 to G1, numbered 1 to 24 where they were assessed, and plots them in a matrix of impact against financial impact. Climate change adaptation, climate change mitigation and energy (1 to 3) are double material. Own workforce working conditions, H&S and equal treatment (14 to 16), and corporate culture, whistleblower protection and corruption and bribery (20, 21, 24), are impact material. Every other numbered topic is non-material, including E2 to E5, S2, talent development, lobbying and payment practices. The financial-material quadrant is empty. Topics marked '0' were "deemed immaterial from the start" (page 53). In 2025 H+H also assessed S1-13 and S1-15 as immaterial (page 48).

Pages 58-61 give the ESRS 2 Appendix B datapoints derived from other EU legislation, each marked Material with a page reference, or Not material. Material ones cover board gender diversity and independence, GOV-4, E1-4 to E1-6, S1-1, S1-3, S1-14, S1-16, S1-17, G1-1 and G1-4.

Reference: pages 62-63 (content index, page 62).

H+H says its strategy and business model are compatible with the transition to a sustainable economy, with science-based targets and a net-zero target for 2050, compatible with the 1.5 degree scenario (page 62). The 2030 targets are a 46% cut in absolute scope 1 and 2 emissions against 2019 and a 22% cut in scope 3 emissions per m3 (page 21). The Science Based Targets initiative has verified them as in line with 1.5°C (page 65). The quantified targets are in E1-4 (page 65).

The plan rests on four levers: a larger share of renewable electricity, investments in plant energy efficiency, an improved energy mix (coal to natural gas, then to fossil-free sources) and supply-chain decarbonization, mainly carbon capture, storage and utilization by cement and lime producers (page 62). Group Management and the Board of Directors have approved the transition plan, and the Group Operations Director is responsible for implementing it (pages 62-63). Up to 15% of the CAPEX budget is allocated each year to emission reduction projects, and GHG reduction measures are built into management incentive schemes (page 63). Progress is reported in the E1-6 section (page 63).

H+H says it does not assess any locked-in GHG emissions, because it believes all emissions can be avoided through proper strategy and execution (page 62). It also states it is not excluded from the EU Paris benchmarks (page 63).

Reference: pages 56-57, 63-64.

Back-filled from ESRS 2 IRO-1 and SBM-3, where this content is disclosed in the FY2025 report (pages 56-57, 63-64). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

H+H ran a climate scenario analysis in 2022 using the TCFD guidelines, refreshed annually; the 2025 refresh found nothing new (pages 56, 63). It used three NGFS scenarios released in 2021: Net Zero 2050 (1.5°C, orderly), Delayed Transition (disorderly) and Current Policies, paired for physical risk with the IPCC RCP 6.0 scenario (pages 56-57). Short, medium and long term are 2030, 2040 and 2050. Page 56 gives 1.8°C for Delayed Transition while the scenario heading on page 57 says 2°C. The report names no higher-emission physical scenario than RCP 6.0.

The scope covered own operations, upstream cement and lime producers and downstream customers, with no part of the value chain excluded (pages 56, 63-64). The original process included a workshop with the top 50 leaders in the Group (page 56).

The analysis identified four transition risks (raw material cost increase from cement and lime, extension of the EU ETS to include H+H, delay in cement and lime decarbonization roadmaps, and substitution by low-carbon building materials) and one opportunity, decarbonization of products. No material physical risks were identified (page 64).

Reference: pages 57, 63-64.

Back-filled from ESRS 2 SBM-3 and the climate scenario analysis, where this content is disclosed in the FY2025 report (pages 57, 63-64). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The statement has no separate resilience analysis. Its resilience conclusions come from the TCFD-based scenario analysis, and the findings are incorporated in H+H's strategy and annual enterprise risk management (pages 56, 64). After mitigations, the analysis found no net-material financial impact in the short, medium and long term (page 64). For the four transition risks it expects no net cost to respond. For the opportunity, decarbonization of products, it gives a moderately positive impact on EBIT of DKK 100-250 million per annum in the medium to long term (page 64).

Scenario readings (page 57): under Net Zero 2050, the main variable for cutting product emissions is how fast cement and lime producers bring in carbon capture, utilization and storage. Under Delayed Transition, slower renewables and hydrogen would slow H+H's operational cuts, but the timing fits the cement industry's roadmap for the technology, so it would not undermine H+H's plans. Under the 3-4°C scenario H+H sees no material physical risk to its assets.

The report does not describe areas of uncertainty in the scenario results or H+H's capacity to adapt over time.

Reference: page 64 (content index, page 62).

H+H's Environmental, Social & Governance Policy (ESG Policy) covers climate change mitigation. It contains the commitment to reduce scope 1, 2 and 3 emissions in line with net zero by 2050, and the short-term targets set to reach it. Because it covers all emission scopes, it applies to emissions from own operations and from the upstream and downstream value chain (page 64).

The policy does not address energy efficiency, climate change adaptation or renewable energy deployment (page 64). It is distributed through the policy management system on the Group intranet, and stakeholders can reach it on the group website. It is used to communicate H+H's ESG ambitions at a high level, and in daily operations it is supported by process descriptions and manuals written with local stakeholders (page 64).

Group Management holds overall responsibility for the ESG policy. The regional Managing Directors implement it in their countries as heads of their legal entities, and Group Management reviews it annually (page 64).

Reference: pages 64-65 (content index, page 62).

H+H has a roadmap to 2030 to reduce emissions. A dedicated amount of the CAPEX budget, up to 15%, is allocated each year to fund emission reduction projects (page 64).

Scope 1 and 2 levers: (1) renewable electricity, bought through RECs or PPAs, and all plants have used 100% renewable electricity since 2024, which H+H plans to continue; (2) energy efficiency, with multiple projects across regions and plants in 2025 and continued focus in 2026; (3) an improved energy mix, converting from coal to natural gas, then to fossil-free sources when reasonably possible, so far one plant in Poland converted from coal to natural gas and two plants able to supplement coal with biomass; (4) supply-chain decarbonization (pages 64-65).

Scope 3 levers: dialogue with lime and cement producers, collaborating on carbon reduction projects with those that have a science-based target or a credible net-zero pathway, relying mainly on carbon capture storage and utilization and lower-carbon ingredients; a lower clinker content in cement used for AAC products, which has already reduced scope 3 emissions; and low-emissions transport, where H+H expects transport suppliers to cut emissions by about 30% by 2030 (pages 64-65). The roadmap chart on page 65 splits the scope 1 and 2 path by lever (page 65).

Reference: page 65 (content index, page 62).

H+H has two climate targets, one for scope 1 and 2 emissions from own operations and one for scope 3. The 2030 targets have been verified by the Science Based Targets initiative as in line with the 1.5°C scenario (page 65).

Scope 1+2 CO2 emissions: baseline 2019 of 212,997 tonnes, 2030 target of 115,018 tonnes, and zero in 2050. Scope 3 CO2 intensity: baseline 2019 of 161.9 kg/m3, 2030 target of 125.8 kg/m3, and zero in 2050. Of the baseline emissions, 28% are scope 2, and none are in the 2030 target. Scope 2 is calculated on the market-based approach (page 65). The E1-6 table adds annual target rates of 4.2% for scope 1+2 and 2.0% for scope 3 (page 67).

The baseline is 2019 because the SBTi submission was prepared in 2021 and 2020 was not representative because of the Covid-19 pandemic (page 65). The most critical assumptions in the roadmap are the development of fossil-free energy in operations and the use of carbon capture storage and utilization by suppliers (page 65).

Page 66 lists three specific ambitions: 100% renewable electricity by 2024 (marked done), converting all coal plants to natural gas or other more sustainable sources by 2030 (in progress), and at least one scope 1+2 neutral plant by 2030 (in progress). Performance against target is in E1-5 and E1-6 (pages 65-67).

Reference: page 66 (content index, page 62).

Total energy consumption was 471,183 MWh in 2025, up 13% from 417,035 MWh in 2024, with net revenue flat at DKK 2,743 million. Consumption per cubic meter was 548 MJ against 549 MJ in 2024 (pages 8, 66). The report ties the higher energy per net revenue (172 MWh per DKK million against 152) to production volume being higher than sales volume (pages 8, 66).

The 2025 mix, in MWh: natural gas 298,311, coal 106,653, oil 1,573, fossil steam and electricity 16,540, and renewable electricity 48,107, which is 100% of purchased electricity (pages 8, 66). The report says there was no significant change in the energy mix during 2025 (page 66).

Energy use is mainly natural gas and coal for steam in the autoclaves, plus electricity for plant equipment. As part of the science-based target H+H is working to lower the coal share and bring in renewable energy such as biogas, hydrogen or biomass to generate steam. All plants are ISO 50001 certified (page 66). H+H states that 100% of its activities are in the high climate impact sector (page 66). The datapoints on energy from fossil sources, energy mix and energy intensity are marked Material, page 66 (page 58).

Reference: page 67 (content index, page 62).

The 2025 gross emissions, in tCO2e (2024 in brackets): scope 1 92,545 (81,884), up 13%; scope 2 location-based 26,304 (25,522); scope 2 market-based 6,192 (6,885), down 10%; scope 3 453,614 (394,435), up 15%. Total market-based emissions were 552,351 (483,205), and location-based 572,463 (501,842). The 2019 base year total is 971,324 (page 67). None of the scope 1 emissions come from regulated emission trading schemes (pages 66-67).

Significant scope 3 categories are 1 purchased goods and services (409,430), 3 fuel and energy-related activities (21,422), 4 upstream transportation and distribution (14,173) and 9 downstream transportation (8,589) (page 67). The other categories were screened and judged not material, with reasons given for each (page 68). Categories 1 and 3 use primary data, and categories 4 and 9 use generic industry factors (page 68).

Scope 3 intensity rose 2% from 2024, which H+H attributes to higher raw material emissions as suppliers reported lower efficiency at low demand. Scope 3 is approximately 80% of total emissions (page 67). Scope 1+2 intensity fell to 31.9 kg per m3, 29% better than the 2019 baseline of 45.3 kg (page 66). Total GHG per net revenue (market-based) was 201 tCO2e per DKK million, against 176 (page 67).

Reference: page 67 (content index, page 62).

E1-9 is in H+H's list of material disclosure requirements for E1, with page 67 (page 62). The disclosure on page 67 is a short qualitative conclusion: H+H states it "has no net-material financial impact in the short, medium, and long term" and refers to the General Information section (page 67). It gives no monetary amount of assets or revenue at risk, and no breakdown by acute and chronic physical risk.

The supporting content is in the SBM-3 and scenario analysis pages. After mitigations, the four identified transition risks carry no net cost, and the one opportunity, decarbonization of products, is put at a moderately positive impact on EBIT of DKK 100-250 million per annum in the medium to long term (page 64). For topics other than climate, H+H has used the phase-in option and not quantified financial effects (page 52).

The E1-9 datapoints on the benchmark portfolio, on physical risk by location and on real estate energy-efficiency classes are marked "Not material" (page 59).

Reference: pages 76, 78, 82 (content index, page 75).

Three groups of policies are described. Health and safety: the Group H&S Policy is the foundation for preventing, mitigating and remediating H&S impacts. The Group Operational Director has overall responsibility, regional Managing Directors implement it, and Group Management and the Group H&S Director review it every year, based on the Maturity Audit process. It covers H+H employees across the entire workforce but not workers in the value chain, and employees must confirm they have read it (page 76).

Equal treatment: the Board adopted the Group Diversity Policy and the CEO is overall responsible. It applies to recruitment, promotion and development, and H+H does not tolerate any form of discrimination (page 78).

Human rights: a dedicated Human Rights Policy rests on the UN Universal Declaration of Human Rights and the ILO. H+H commits to safety and proper working conditions under local law, freedom of association and the right to collective bargaining, equal opportunity, and rejection of human trafficking, child labor and forced labor (page 78). Working conditions follow the Human Rights Policy and regional policies and employee handbooks (page 82).

H+H states that none of its social policies is inconsistent with the UN Guiding Principles on Business and Human Rights (page 75). The report says the materiality assessment found no material human rights impacts, risks or opportunities (page 78).

Reference: pages 76, 78, 82 (content index, page 75).

Health and safety: the ZERO HARM strategy for 2024-2026 was launched at the start of 2024 with a communications campaign and focuses on behavior-based safety and driving safety through the line. All plants are audited internally and externally using the Maturity Audit Model, and each plant has a Safety Improvement Plan that is monitored. H&S KPIs, including absence and incidents, are monitored monthly and reported to Group Management (page 76). Prevention covers regular H&S training, monitoring of exposure levels of substances used in production, access controls, incident management and protective equipment; technical and organizational measures come first, and personal protective equipment is only needed in a few cases (pages 75-76). For 2026 H+H plans to continue the behavior-based focus through training, communication and lessons learned from incidents. Resources allocated are the H&S community (page 76).

Equal treatment: managers are expected to treat employees equally. Recruitment shortlists are balanced by gender where possible, and if two candidates are equally qualified the one from the under-represented gender is chosen. No additional actions are planned for 2026, and resources are the HR community (pages 78-79).

Working conditions: a performance management framework was rolled out after a pilot, and foundations for evaluating its effectiveness were set (page 82).

Reference: pages 76, 79, 82 (content index, page 75).

Health and safety: the target is an LTIF (lost-time incident frequency) rate of 2.1 by 2030. LTIF was also a KPI in the 2025 short-term incentive plan. It is measured every year, and the target rests on projected performance from the initiatives in the business (pages 76-77). The 2025 LTIF was 0.9 (page 77).

Equal treatment: Group Management has decided not to set targets for managing the material negative impacts while it continues to focus on safety. The report states there are currently no formal processes to track the effectiveness of policies and actions, and that the need for targets and processes is regularly assessed (page 79).

Working conditions: Group Management has decided not to set targets, to focus resources on other priorities. There are no processes at the moment to track the effectiveness of policies and actions, and the need for targets and processes is regularly assessed (page 82).

Board diversity: under section 139c of the Danish Companies Act H+H aims at equal gender distribution on the Board of Directors. This was reached at the Annual General Meeting on 31 March 2022 and is still met, with 2 women and 3 men. A new formal gender target will be set if the composition changes (page 79). The parent company has used the legal exemption from a gender diversity policy and targets for management levels below the Board (page 79).

Reference: pages 79-80 (content index, page 75).

H+H had 1,338 employees at year-end 2025 (1,337 in 2024): 1,131 men, 207 women, and none recorded as other or not disclosed. Of these, 1,336 are permanent, 2 are temporary and none are on non-guaranteed hours. Office workers number 303 (155 men, 148 women) and non-office workers 1,035 (976 men, 59 women) (page 80).

By country: Poland 625, Germany 346, United Kingdom 277 and Other 90, against 608, 413, 228 and 88 in 2024 (page 79).

Employee turnover was 284 people, a 21% ratio, against 280 and 22% in 2024. The ratio is lower than 2023 (40%), but H+H calls it high because of organizational streamlining after the downturn in construction. Voluntary turnover was stable at 11%, against 12% (page 79). The report says the gender ratio of the workforce is stable, with an even split among office workers and low diversity among plant and other non-office workers (page 79).

Headcount is defined as all employees, full-time and part-time, active and non-active, as of 31 December 2025. The turnover ratio is total leavers divided by average headcount (page 84).

Reference: page 79 (content index, page 75).

S1-7 is in H+H's list of material disclosure requirements, with page 79 (page 75). The report covers S1-6 and S1-7 together on that page.

The tables on page 80 give the number of non-employees as zero for 2025, in total and in each region (CWE region, HQ, Poland, United Kingdom). For 2024 the table shows 17 non-employees, 16 of them in the CWE region and 1 at headquarters. Non-employees are defined as self-employed people and people provided by third parties (page 84).

Elsewhere the report says temporary staff who are not employees are either employed directly by H+H or through reputable agencies that follow relevant employment legislation (page 78). The own workforce for the material impacts covers both employees and non-employees, unless otherwise described (page 84), and the health and safety impacts affect employees and non-employees, including self-employed people and people provided by third parties (page 75).

Reference: pages 82-83 (content index, page 75).

Whether employees are represented by a local organization such as a workers' council or work environment organization varies by country and local legislation (page 82). H+H says there is currently no agreement with a European Works Council, a Societas Europaea Works Council or a Societas Cooperativa Europaea Works Council, because it has not been met by any demand from employees (pages 82-83).

The majority of employees' working terms and employment conditions are decided directly between the employee and the company and are generally not set by collective bargaining agreements (page 83). A chart on page 83 uses coverage-rate bands from 0-19% to 80-100% and, under workplace representation for EEA countries with more than 50 employees representing more than 10% of total employees, places Poland in the 0-19% band and Germany in the 60-79% band.

Employee representation for social dialogue is defined as representation by a works council, work environment organization or employee committee (page 84). The only working conditions impact identified in the DMA is H+H's impact on social dialogue, a potential negative impact across all sites (pages 52, 82).

Reference: page 81 (content index, page 75).

Top management gender: 0% women, 0 of 5 in 2025 and 0 of 6 in 2024 (page 81). Top management means Group Management and the regional Managing Directors (page 84).

Age distribution of the workforce: below 30, 10% (9% in 2024); 30-50, 52% (51%); above 50, 38% (40%). H+H says this is in line with other industries and society in general and with its expectations (page 81).

Other diversity figures appear in the five-year summary and on page 36: women are 15% of employees and 49% of office workers, and the Board is 40% women (pages 8, 36). The group-wide gender split of employees is 207 women and 1,131 men (page 80). The report describes the gender ratio as an even split in office roles and low diversity in plant roles (page 79).

Board and management-level gender targets under section 139c of the Danish Companies Act are described under S1-5, including the exemption the parent company uses for management levels below the Board (page 79).

Reference: pages 76-77 (content index, page 75).

The 2025 lost-time incident frequency (LTIF) was 0.9 incidents per million hours, level with 2024 and down from 3.4 in 2023. H+H calls it another record result and credits continued focus on safety leadership at all levels of operational management, behavior-based safety and close follow-up of incidents (pages 76-77).

The page 77 table gives, for 2025: no fatalities from work-related injuries or ill health; 10 total recordable incidents (7 in 2024); no recordable contractor incidents; a total recordable incident rate (TRIR) of 4.3 per million hours (3 in 2024); no cases of recordable work-related ill health; and 100% of the own workforce covered by the H&S management system. Days lost to work-related injuries and ill health are given as 0 in 2025 (83 in 2024, 787 in 2023, 313 in 2022); the report does not explain how that fits an LTIF of 0.9. The 2022 and 2023 comparatives are not covered by the auditor's limited assurance report, apart from figures marked with an asterisk (pages 8, 77).

LTIF counts lost-time incidents and fatality incidents per million hours worked, from actual time registrations and estimates, for the own workforce. TRIR counts all work-related injuries and fatality incidents on the same basis (page 84). The datapoints on fatalities and accident rates and on lost days are marked Material, page 77 (page 60).

Reference: page 81 (content index, page 75).

The gender pay gap was -17% in 2025, unchanged from 2024 (-6% in 2023). It is defined as the difference between the average hourly pay of women and men, as a percentage of the average pay of men (pages 8, 81, 84). H+H says it is hard to read the development of the gap because of the mix of job functions and levels. The main driver it names is the workforce makeup: most staff are non-office workers, who are traditionally male and lower paid, and the countries have materially different salary levels (page 81).

The CEO pay ratio, the CEO's compensation as reported in the Remuneration Report divided by the median salary of all other employees, was 33 in 2025 and 34 in 2024. H+H attributes the slight decrease to the variable components of CEO pay (pages 81, 84).

H+H is working on better transparency of salary differences. The first step is a Group job architecture, planned for 2026, in preparation for the EU Pay Transparency Directive (page 81). The datapoints on the unadjusted gender pay gap and the CEO pay ratio are marked Material, page 81 (page 60).

Reference: page 83 (content index, page 75).

In 2025 (0 in 2024) there were no work-related incidents of discrimination reported to HR or through the whistleblower system, on any of the grounds listed (gender, racial or ethnic origin, nationality, religion or belief, disability, age, sexual orientation, or other relevant forms). This includes harassment as a specific form of discrimination (page 83).

No cases of severe human rights incidents, such as forced labor, human trafficking or child labor, were identified in 2025 (0 in 2024) (page 83).

The S1-17 datapoints on incidents of discrimination and on non-respect of the UN Guiding Principles and OECD guidelines are marked Material, page 83 (page 60). On the G1 side, no whistleblower reports were found to be within scope in 2025 (page 87).

Reference: page 86 (content index, page 85).

The Code of Conduct is the foundation of H+H's compliance program. The Board approves it and the Executive Board is responsible for implementing it. A Code of Conduct for Suppliers is given to all major suppliers in each region with a request to confirm compliance, and the Group Operations Director is responsible for it. Their principles cover, for example, environment and climate, health and safety, diversity, non-discrimination, personal data protection, conflicts of interest, fair competition, anti-corruption, responsible tax and data ethics. Every employee must read and follow the Code of Conduct (page 86).

The Board of Directors is ultimately responsible for oversight of corporate culture and business conduct. Regional Managing Directors sign a declaration every quarter that, to the best of their knowledge, all H+H entities in their region comply with applicable H+H policies (page 86).

Whistleblower policy: reports go to a manager, HR or the public online system. The Board approves the policy and the Executive Board implements it. All employees are asked to read and confirm the policy, and part of the employees were trained on the policy and system in 2024 (page 86). The statement also describes a Tax Policy (page 86). A table lists the ESG policies and where they are described (page 87). The G1-1 datapoint on protection of whistleblowers is marked Material, page 86 (page 61).

Reference: pages 79, 86-87.

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS, and H+H's FY2025 statement was prepared under the 2023 ESRS (page 48 refers to ESRS without naming a version).

H+H sets no business conduct target of its own. Under "Metrics and targets" it says that a diverse Board is linked to better governance, that target setting on this is described in the Corporate Governance and Social sections, and that Group Management "has decided not to set any other targets in relation to Governance" (page 87).

The target it points to is equal gender distribution on the Board of Directors, under section 139c of the Danish Companies Act. It was reached at the Annual General Meeting on 31 March 2022 and is still met, with 2 women and 3 men (page 79).

The statement describes no tracking of effectiveness for its anti-corruption and whistleblower policies beyond controls: regional Managing Directors sign a quarterly compliance declaration, and the outcomes of whistleblower investigations are reported to the Audit Committee (page 86).

Reference: page 87 (content index, page 85).

In 2025 (zero in 2024) no whistleblower reports were found to be within scope. H+H received no injunction, ruling, conviction, fine or similar for violation of anti-corruption or anti-bribery laws (page 87). The report therefore gives no number or amount of convictions or fines. The G1-4 datapoints on fines for violation of anti-corruption and anti-bribery laws and on anti-corruption standards are marked Material, page 87 (page 61).

Context from the same chapter: H+H operates only in European countries with low risks of bribery and corruption, ranked between 1 (Denmark) and 52 (Poland) of 182 in the Transparency International Corruption Perceptions Index 2025 (page 85). No anti-corruption and bribery training was provided to any H+H employees in 2025 (page 87).