Harvia Oyj

Reference: pages 62-64.

Harvia's Board of Directors "holds the ultimate responsibility for sustainability" (page 62). It approves the Sustainability Policy, the Code of Conduct, the long- and short-term remuneration schemes and the Sustainability Program with its targets, and it reviews and approves the annual double materiality assessment and IRO assessment, last approved on 5 November 2025 (page 63).

The Board has seven non-executive members: two women (28.6%) and five men (71.4%). All members elected at the 8 April 2025 AGM were assessed as independent, and employees are not represented on the Board (page 63). The Audit Committee is responsible for monitoring and assessing sustainability reporting and its effectiveness (page 63). Mandatory CSRD training, introduced in 2024, covers the Board, Audit Committee, Group Management Team and Sustainability Steering Group (page 64).

Appendix 2 lists GOV-1 as Material (page 121).

Reference: page 64.

"The Sustainability Steering Group convenes quarterly to monitor sustainability matters and reports progress to the Group Management Team." The CEO, on behalf of the Management Team, reports to the Board on the Sustainability Program "on a case-by-case basis" (page 64).

The Audit Committee regularly discusses sustainability-related risks as part of its risk management protocol (page 64). The Steering Group reviewed the double materiality assessment in September 2025 and the Board approved the reviewed assessment and the IRO assessment in November 2025 (page 64). In the same month the Board reviewed and approved the Sustainability Program for 2026-2030, including its targets and key actions (page 64). The group-wide Sustainability Policy, approved in 2024, is reviewed annually and had a minor update in 2025 (page 64).

Appendix 2 lists GOV-2 as Material (page 121).

Reference: page 65.

Sustainability-related performance is part of the long-term incentive program for the CEO, the Management Team and selected key employees. Three programs ran in 2025 (2023-2025, 2024-2026 and 2025-2027). The performance criterion is the reduction of scope 1 and scope 2 GHG emissions, indexed against a baseline and calculated in relation to sales volumes, with minimum, target and maximum levels and linear payout (page 65).

Table on page 65: 2023-2025 program, baseline 2022, target -23.1%, 15% of total remuneration; 2024-2026, baseline 2023, target -10%, 10%; 2025-2027, baseline 2021, target -3,12 g CO2e per EUR (as printed), 10%.

The Board decides participants, criteria, targets and rewards separately for each performance period (page 65). Appendix 2 lists GOV-3 as Material (page 121).

Reference: pages 65, 120.

"Harvia applies a continuous improvement approach to due diligence in operations impacting the environment, people, and governance" (page 65). The process is guided by Harvia's policies and by the OECD Guidelines for Multinational Enterprises and the OECD Guidelines for Good Corporate Governance (page 65).

Harvia works with employees and suppliers to remedy negative impacts. If a supplier does not respond and remediation cannot be reached, it "may terminate the commercial relationship". Whistleblowing channels exist for reporting serious risks or wrongdoing (page 65).

Appendix 1 (page 120) maps the core elements of due diligence to sections of the statement. Appendix 2 lists GOV-4 as Material (page 121) and Appendix 3 maps the GOV-4 datapoint to the Due Diligence section (page 126).

Reference: pages 65-66.

Sustainability reporting aligns with CSRD and with Harvia's group-level principles for statutory reporting, risk management and internal control, "consistent with those for financial reporting" (page 65). Supervision runs at two levels: company-level checks on data quality and validity, then Group-level review and validation with centralized reporting and data management. The Audit Committee oversees the process and receives regular reports on status and findings (page 65).

The key reporting risks named are accuracy and availability of data, particularly for the value chain, completeness of the data and timely reporting. Harvia mitigates them with internal reviews, consultations, internal guidelines and instructions, and regular reporting (annually, quarterly or monthly) (pages 65-66). It says it is still developing "manual and system-built controls" for ESG data accuracy and completeness (page 66).

Appendix 2 lists GOV-5 as Material (page 121).

Reference: pages 66-69.

Harvia designs, manufactures and markets sauna products: electric and wood-burning heaters, control units, sauna rooms, infrared and steam solutions, and accessories. Revenue was EUR 198.9 million in 2025 (EUR 175.2 million in 2024): heating equipment EUR 107.9 million (54%), saunas and Scandinavian hot tubs EUR 47.5 million (24%), steam products EUR 17.2 million (9%), accessories and heater stones EUR 13.1 million (7%), spare parts and services EUR 13.1 million (7%) (page 66).

Production sites are in Finland, the United States, China, Germany, Romania and Italy, and products sell in nearly 100 countries. Personnel were 735 at end-2025 (696 in 2024), led by Finland 260, the United States 158 and Germany 141 (page 66). The value chain runs from steel, wood and stone suppliers, through Harvia's own manufacturing, to B2B customers, consumers and end-users (pages 68-69).

Harvia omitted the SBM-1 breakdown of revenue by significant ESRS sector under the phase-in provisions (page 84).

Reference: pages 69-70.

Harvia says it "actively engages with its stakeholders" to inform strategy, risk management, due diligence and goal-setting (page 69). The table on page 70 lists eight groups, how each is engaged and what they care about: employees (performance reviews, surveys, employee forum, whistleblowing channel), customers (visits, surveys, training), consumers and end-users (customer service, feedback channels), suppliers (visits, audits, surveys), owners and investors, media and influencers, authorities, and universities.

Stakeholder views were built into the double materiality assessment, including an online survey of employees, potentially impacted communities, B2B customers, consumers and end-users, suppliers and investors (pages 69, 80). Affected stakeholders "were not directly involved" in assessing material impacts, risks and opportunities, but their views were taken into account (page 81). Harvia also used stakeholder views when planning the 2026-2030 Sustainability Program (page 69).

Reference: pages 71-78.

The double materiality assessment, reviewed in 2025, gave the same material topics as before at topical-standard level: E1 Climate change, E5 Resource use and circular economy, S1 Own workforce, S2 Workers in the value chain, S4 Consumers and end-users, and G1 Business conduct (page 71). Pollution, water and marine resources, biodiversity and ecosystems, and affected communities were assessed as low materiality or not material (page 72).

The IRO tables (pages 73-77) list 32 material impacts, risks and opportunities, counted by row: E1 10, E5 6, G1 5, S1 4, S2 3, S4 4. Each is typed as impact, risk or opportunity, actual or potential, and placed in upstream, own operations or downstream. For S1, S2 and S4 the tables also carry a short management description, because Harvia applies the phase-in for those standards (pages 72, 76-77). Page 78 lists which IROs changed in materiality against 2024.

Harvia says its strategy and business model are resilient to the identified sustainability impacts and risks (page 72). It omitted the anticipated financial effects of material risks and opportunities (SBM-3) under the phase-in (page 84).

Reference: pages 80-84.

Four steps: identify impacts, risks and opportunities; set prioritizing criteria; assess; manage (page 80). Impact materiality scores scale, scope, irremediability (negative impacts only) and likelihood, with numeric cut-offs of low below 25, medium 25-50 and high above 50. Financial materiality uses annual effect on profit: low below 1%, medium 1-2%, high above 2% (pages 80-81). Qualitative judgment was added where needed (page 81).

Inputs included strategy, third-party databases, the ERM process, EFRAG guidance, a benchmark study and an online stakeholder survey (page 80). The Management Team, Audit Committee and Board approved the results and thresholds (page 81).

Climate: scenarios covering energy availability and price, regulation, market shifts and hazards such as floods, heat stress and storms were used, and regional hazards at Harvia's locations were assessed as not material (page 81). Pages 82-84 give the process per topic and the topics found not material (E2, E3, E4, S3). Appendix 2 lists IRO-1 as Material (page 121).

Reference: page 84; pages 121-125 (Appendix 2); pages 126-128 (Appendix 3).

Appendix 2 lists the ESRS disclosure requirements Harvia followed, with the chapter and section where each sits and a Material or Non-material flag. It names sections, not page numbers. Phase-in flags appear on the S1, S2 and S4 rows, E1-9 and E5-6. Appendix 3 maps datapoints derived from other EU legislation to sections or marks them Non-material, Phase-in or Not applicable.

Page 84 states that Harvia used the phase-in in paragraph 10.3 of ESRS 1 "to omit all disclosure requirements under S1 Own workforce, S2 Workers in the value chain, and S4 Consumers and end-users". It also omits the SBM-1 revenue breakdown by ESRS sector, the SBM-3 anticipated financial effects, E1-6 scope 3 and total GHG emissions, E1-9 and E5-6. E2, E3, E4 and S3 did not exceed the materiality threshold (page 84).

Harvia says it did not use the option to omit information on intellectual property, know-how or impending developments (page 61).

Reference: pages 88-90.

Harvia's Climate Transition Program 2025-2050 "outlines a structured pathway to achieve net zero emissions by 2050". It is built on 1.5°C-aligned IPCC and IEA Net Zero pathways and plans 90-95% reductions across scopes 1, 2 and 3 before any limited offsetting in 2045-2050 (page 88). Two scenarios are modeled: Harvia's own measures only (scope 1 and 2 near zero by 2040, total emissions down 9% by 2050) and own measures plus favorable external decarbonization (total emissions down 90% by 2050) (page 88). Levers: energy efficiency and electrification, renewable or emission-free energy, circular economy, supply-chain decarbonization, product portfolio changes and new technology (pages 88-89).

Harvia says the program "does not fulfill the ESRS standard requirements set for a transition plan for climate change mitigation" because no scope 3 baseline or progress is reported under the phase-in (page 88). The Head of Operations owns it, and the Management Team and Board approved it (page 89). It reports "a limited amount of locked-in emissions" (page 89) and says Harvia is not excluded from EU Paris-aligned Benchmarks (page 89).

Back-filled from ESRS 2 IRO-1 (pages 81-82) and the E1 climate-related resilience analysis (pages 91-92). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 91-92 (also 81-82).

The IRO assessment used scenarios on energy availability, price and type, technology, regulation, market shifts and climate hazards (floods, heat stress, storms), analyzed by location for own operations and the value chain (page 81). A separate resilience analysis was done in 2024, covers the entire value chain, and was approved on 3 December 2024 by the Head of Operations (page 91).

Scenarios named (page 91): IPCC SSP1-1.9 (Paris-aligned, 1.5°C) and IPCC SSP2-4.5 (about 2.7°C by the end of the century). No high-emission scenario such as SSP5-8.5 is named. Harvia says "No updates for the analysis were needed during 2025" (page 91).

Risk classification (page 92): changes in climate-related regulation, changing customer behavior and cost increase from energy dependency are transition risks; supply chain disruption is a physical risk. Harvia assessed hazards at its own locations as not material and says several suppliers for key components mitigate upstream hazards (page 81).

Back-filled from ESRS 2 SBM-3 (page 72) and the E1 climate-related resilience analysis (pages 91-92). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 91-92 (also 72).

Harvia says its "business model, strategy, operations and governance structures support climate resilience well in both scenarios analyzed" and that "no immediate adjustments are necessary in the short term" (page 91). In the 1.5°C scenario the material risks are mostly transitional: a moderate rise in carbon taxes and energy costs over the medium and long term. In the SSP2-4.5 scenario they are mostly physical, more likely over the long term, and Harvia assesses its own operations as "not to be exposed to high-level risks" (page 91).

Stated strengths are the supplier network, long-term partnerships and flexible in-house operations that can back up suppliers (pages 87, 91). Harvia says it "has the capability to adapt its strategy as required" (page 91). Uncertainties named in the transition program include policy and regulation, the pace of grid decarbonization, cost and availability of low-carbon technology, and the scalability of carbon removals (page 89).

Reference: pages 92-93.

Climate policy is set in the Harvia Group Environmental Policy and the Climate Transition Program, with detailed actions in the Sustainability Program (page 92). The overarching target is net zero by 2050 (page 92).

The Environmental Policy sets principles on compliance with legislation, continuous improvement, product innovation and life-cycle management, responsible sourcing and supply chain management, and energy and emissions, including prioritizing renewable and emission-free energy and cleaner combustion (pages 92-93). Harvia links each principle to the matching risk or opportunity, such as regulation, energy efficiency and supply chain disruption (page 92).

The policy covers the entire Group, all markets and the value chain from sourcing to product use, and suppliers are expected to follow it (page 93). The Management Team approves it and the Quality Director is accountable for it. The Climate Transition Program is owned by the Head of Operations, reviewed yearly by the Sustainability Steering Group and approved by the Management Team and Board (page 93). Emissions are calculated under the GHG Protocol (page 93).

Reference: pages 93-94.

Energy efficiency, EOS Germany (page 93): a new hybrid thermal plant to replace oil heating, plus a new painting line. The painting line was renewed in summer 2025 and the thermal plant began in Q4 2025. The full investment is estimated to cut Group scope 1 emissions by about 30% (about 300 tCO2e a year). The painting line alone cut 95 tCO2e in 2025. Capex allocated: EUR 1.79 million.

Renewable or emission-free energy (page 93): a heat pump at Kirami in Sastamala, Finland, in use since end-2024, cut emissions by 56 tCO2e in 2025, with Opex of EUR 13,800. Solar systems in China and the United States are planned for 2026-2027: about 250 tCO2e less in China and about 400 tCO2e in the U.S. (target of roughly 50% of U.S. electricity), with future Capex of EUR 600,000.

Together the key actions target about 1,000 tCO2e less per year, over 40% of 2025 scope 1 and 2 market-based emissions (page 94). Other actions: electric forklifts and charging stations, a solar plant at Muurame, changes to EU road freight routes and a logistics contract with about 60% lower emissions than a standard one (page 94). Harvia has taken no remedial actions for people harmed by climate impacts (page 94).

Reference: pages 94-95.

Two climate targets are set. Net zero by 2050 across scopes 1, 2 and 3 is not reported against in 2025 because of the scope 3 phase-in (page 94). Scope 1 and 2 emissions are to fall 60% by 2030 from a 2021 base year (page 94). Harvia dropped its earlier target of carbon neutrality in its own operations by 2030 after growth in the United States, where emission-free electricity is limited (page 94).

Progress: scope 1 and 2 market-based emissions were down 14% against 2021 in 2025 (down 12% in 2024) (pages 94-95). The 2021 base year is 2,757 tCO2e, the 2025 figure is 2,385 and the 2030 target level is 1,103 tCO2e (page 97). About 98% of the planned reduction comes from renewable or emission-free energy and about 2% from electrifying company assets, with scope 1 about 51% and scope 2 about 49% of the cut (page 94).

Both targets cover market-based scope 2 only and follow IPCC and IEA 1.5°C pathways. They have not been validated by a third-party initiative such as SBTi (page 95). Stakeholders were not directly involved in setting them (page 95).

Reference: page 96.

Total energy consumption was 15.6 thousand MWh in 2025 (15.2 in 2024), up 3%. Fossil sources were 5.8 thousand MWh, a 37% share (40% in 2024), including 3.3 from crude oil and petroleum products (4.1 in 2024, down 20%) and 2.5 from purchased fossil-sourced electricity, heat, steam and cooling (2.0). Nuclear sources were 4.1 (26% share). Renewable sources were 5.7 (37% share, 36% in 2024), of which 1.6 was fuel from renewable sources and 4.0 purchased renewable electricity, heat, steam and cooling.

Energy intensity was 78.4 MWh per EUR million of net revenue (86.8 in 2024, down 10%). Harvia treats all its activities as high climate impact sectors and uses net revenue of EUR 198.9 million (page 96).

The text attributes the oil decline to the EOS painting line moving to electric heating and Kirami switching to a heat pump, and the rise in renewable fuel to more heating at the Domo factory in Romania (page 96). Where market-based data is missing, location-based energy mix data is used (page 96).

Reference: pages 97-99.

Gross scope 1 emissions were 850 tCO2e in 2025 (1,023 in 2024, down 17%). Scope 2 was 1,535 tCO2e market-based (1,404) and 2,642 location-based (2,259). Total scope 1 and 2 was 2,385 tCO2e market-based (2,428, down 2%) and 3,492 location-based (3,282) (page 97). The United States, China and Germany made up about 70% of the total (page 98). None of scope 1 is under an emissions trading scheme (page 98).

Intensity: 12.1 tCO2e per EUR million of net revenue market-based (13.9 in 2024) and 3.5 kgCO2e per piece produced (4.0) (page 99). Biogenic CO2 outside scopes 1 and 2 was 1,323 tCO2e (1,493) (page 99). Contractual instruments cover 58% of scope 2 emissions (45%) (page 99).

Scope 3 and total GHG emissions are not disclosed. Harvia applies the phase-in and says those datapoints "will be reported in line with the regulatory requirements" (pages 84, 99). Calculations follow the GHG Protocol, and the 2021 base year was recalculated, raising scope 1 and 2 by 196 tCO2e (page 98).

Reference: page 101.

Resource use and circularity are governed by the Harvia Group Environmental Policy, with the Sustainability Program as the platform for objectives, KPIs and actions (page 101). Two principles are named. First, design for circularity and longevity: products are "designed to be durable, repairable, and maintainable", with modular construction to ease part replacement, and Harvia guides customers and distributors on correct use. Second, resource efficiency and waste management: recycled stainless steel (about 90% recycled content on average), "deforestation-free wood materials", material-saving techniques, recycling of all excess steel and of excess stone from heater stone manufacturing (page 101).

The Quality Director is responsible for the policy and the Management Team approves it. It covers the whole Group and the value chain from raw material sourcing to end-of-life, and suppliers are expected to follow it and the Supplier Code of Conduct. Harvia buys wood from suppliers with Chain of Custody certification where feasible and complies with WEEE regulations (page 101).

Reference: pages 101-103.

Harvia says the actions are monitored in operations daily and that their implementation "does not require significant financial resources". It also says no comparative baseline or industry average exists to size their impact (pages 101-102). Targets and action plans in the 2026 program are not yet reported (page 102).

Inflows (page 102): stainless steel is about 90% recycled on average. Biological materials are 62% of inflow excluding stones (65% in 2024), and stone is over 67% of total inflow weight (70%). Excess stone goes back to the mining site or to construction and landscaping uses, within about a 20 km radius.

Outflows (page 102): automation and own equipment cut material use and waste, products are designed to be repairable with spare parts and maintenance services, and heating equipment, the largest product group, is 99% recyclable.

Waste (pages 102-103): all excess steel is recycled. Outside the United States and Italy, waste is recycled or incinerated, covering 97% of all waste (98% in 2024). In West Virginia, excess board is sold as sawdust for animal bedding: 936 tons in 2025 (160 in 2024). Harvia has taken no remedying actions for harm from resource use or waste (pages 102-103).

Reference: pages 102-103.

"In the current Sustainability Program for 2022-2025, Harvia has not set measurable targets related to resource use and circular economy" (page 102). Its principles and actions link to qualitative targets: raising recyclable content in material inflow, products designed to last and be repairable and recyclable at end of life, and minimizing non-recyclable waste (page 102).

Harvia tracks effectiveness by monitoring the recyclable content of inflow materials and the quantities and types of waste, and says it "has not set level of ambition to be achieved but strives for continuous positive development" (pages 102-103). Targets for resource use and circular economy were set in the Sustainability Program that starts in 2026, so they are not part of this statement (page 103).

Appendix 2 lists E5-3 as Material against the section "ESRS E5: Targets related to resource use and circular economy" (page 123).

Reference: pages 103-104.

Main inflow materials: stainless steel, cold and hot-rolled steel, other metals, wood, electrical components and electronics, cardboard, glass, plastic and stones (page 103).

All materials (page 103): total weight 78,500 thousand kg in 2025 (67,000 in 2024), up 17%. Biological materials 20% (21%). Secondary reused or recycled materials 4,200 thousand kg (2,500, up 68%), 5% of the total (4%).

Excluding stones (page 103): total weight 25,600 thousand kg (21,100, up 21%). Biological materials 62% (65%). Secondary reused or recycled share 16% (12%).

Stone is over 67% of inflow weight (70% in 2024). Harvia ties the 68% rise in recycled inflow mainly to more steel use as the business grew and to ThermaSol being in the figures for the full year (page 103).

Recycled-content data comes from suppliers, and Harvia says it cannot tell whether that data rests on estimates or direct measurements. Where no data came in, recycled content was counted as zero (page 104).

Reference: pages 104-105.

Heating equipment is 54% of revenue. Harvia gives guidance on recycling in product packages but has no information on how end-users behave (page 104). Packaging materials are 100% recyclable, and exceptions in products are glass windows and doors, insulation materials and heater stones (page 105).

Expected durability (page 104): electric heater 8 years, wood-burning heater 10, control units 10, sauna cabins 20, infrared heaters 8, infrared controllers 10, steam generators 4, hot and cold tubs 10, sauna stones 3-5. These are estimates from experience and testing, and Harvia says no industry average is available (page 104).

Recyclable material in products (page 104): electric heater 99%, sauna cabins 92%, heater stones 0%, hot and cold tubs 100%. Rates are estimated from the waste management setup in Finland (page 105).

Harvia notes that end-of-life disposal of heater stones "remains an area for improvement" and is exploring reuse options with waste partners (page 105). Spare parts and maintenance services extend product life (pages 102, 104).

Reference: pages 105-106.

Total waste generated was 21,708 thousand kg in 2025 (26,430 in 2024), down 18%, mainly because of much less stone waste (pages 105-106).

Diverted from disposal (page 105): hazardous 9 thousand kg (6), all recycled; non-hazardous 20,949 thousand kg (25,795), all recycled.

Directed to disposal (page 105): hazardous 19 thousand kg (39), all incinerated; non-hazardous 730 thousand kg (590), of which landfill 684 (553) and incineration 47 (36).

Non-recycled waste was 750 thousand kg (629), 3% of the total (2%) (page 105). The landfill increase comes from the U.S. facilities (page 106). Stones are 84% of waste, and 97% of all waste is recycled or incinerated. Harvia generates no radioactive waste (page 106).

Waste data comes mainly from waste management companies. Where it does not, quantities are calculated from bin size and emptying frequency, which Harvia says is under 1% of the total (page 106). The margin of error for waste data is estimated at plus or minus 5% (page 62).

Reference: pages 115-116.

Harvia's Sustainability Policy commits it to operate under the UN Charter on Human Rights and core ILO conventions, and to comply with the OECD Guidelines for Multinational Enterprises and for Good Corporate Governance (page 115). The Code of Conduct, approved by the Board, applies to all employees and covers anti-bribery and anti-corruption, competition law, conflicts of interest, sanctions and money laundering, human rights and non-harassment (page 115). Suppliers with annual purchases over EUR 20,000 must commit to the Supplier Code of Conduct (page 115). The CFO manages the business conduct commitment (page 115).

The whistleblowing channel is open to employees and external stakeholders and runs through an external provider. Reports can be anonymous, receipt is confirmed within seven days, and feedback follows within three months of acknowledgment. Data is stored in the EU, and good-faith reporters are protected from sanctions (page 116).

Code of Conduct e-learning completion was 76% of staff with access (70% in 2024), about 59% of all employees (page 118).

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.

Reference: page 119.

Harvia has one business conduct target, set in 2021 under the Sustainability Program 2022-2025: all suppliers with annual purchases of at least EUR 20,000 commit to the Supplier Code of Conduct by 2027 (page 119). The rate was 55% in the 2021 base year, 87% in 2024 and 86% in 2025, up 31 percentage points on the base year (pages 79, 119).

The Code covers ethics, corruption, labor force, health and safety, and environment, and a supplier's own code is accepted where its principles are similar (page 119). Harvia considered the UN Guiding Principles, the OECD Guidelines and ILO standards in setting the target, and says stakeholders were not directly involved (page 119). It states: "The metric is not validated by an external body other than the assurance provider" (page 119).

No separate target for corruption prevention or other G1 sub-topics is stated. Training completion is reported as an action (pages 117-119).

Reference: page 119.

Harvia's payment terms are typically 14 to 60 days: about 14 days for small service providers and entrepreneurs, 30 days for medium-sized companies and longer for the rest. There are no Group-wide standard payment terms (page 119). It estimates the average time to pay an invoice at close to 30 days (30 in 2024) (page 119).

Harvia says collecting this figure accurately across the Group "would be disproportionate", so it is an estimate, and reporting will be developed (page 119). It is not a party to any legal proceedings over late payments (page 119). It has no specific policy to prevent late payments to suppliers (page 117).

Appendix 2 lists G1-6 as Material against the section "ESRS G1: Payment practices" (page 125).