Hexagon Purus ASA

The role of the administrative, management and supervisory bodies

Reference: pages 31-34, 44-45; also pages 24 and 52.

The ESRS index (page 111) points to the Board of Directors' report and the corporate governance report for this disclosure (pages 31-34, 44-45), and the statement itself incorporates the GOV-1 data points by reference to those pages (page 52).

Board composition (page 44): the report states "Number of non-executive board members = 7", "Gender ratio = 42.86%" and "Independent board members = 87.5%", each tagged to a GOV-1 data point. Directors' experience and ESG competence are listed individually on pages 44-45. Executive management (CEO, CFO and the two segment heads for Hydrogen Mobility & Infrastructure and Battery Systems & Vehicle Integration) is presented on page 24.

Role in sustainability: the Board is responsible for managing the Group in line with its objectives, values and ethical guidelines. It has two committees, remuneration and audit. The audit committee "oversees the assessment of impacts, risks and opportunities related to sustainability matters" (page 32). Sustainability tasks the Board listed for 2025: compliance review and the risk management framework, health and safety reporting, and sustainability work including the double materiality assessment, CSRD reporting and KPIs (page 31).

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

Reference: pages 31-34, 47-48.

The ESRS index lists GOV-2 at pages 31-34 (page 111).

An aggregated risk assessment is reviewed by the Board quarterly. Sustainability risks and opportunities follow a separate process led by the sustainability function twice a year, and the results are reviewed by the Board through the audit committee. One of the two assessments each year coincides with the annual double materiality assessment (page 33). The list of material impacts, risks and opportunities addressed by the governing bodies sits in the double materiality assessment section (page 33).

KPIs and progress against them are reported to Executive Management and the Board on a regular basis, "based on nature of the respective KPIs" (page 33). The statement points to page 48 for the most material sustainability KPIs, and page 47 says eight internal sustainability KPIs were set in 2024. Page 48 lists them: GHG emissions, waste from manufacturing, lost time incident frequency rate, product related safety incidents, number of training hours per employee, completion rate of Code of Conduct training, environmental and social due diligence of suppliers and business partners, and gender diversity.

Integration of sustainability-related performance in incentive schemes

Reference: pages 34-35.

The ESRS index lists GOV-3 at pages 34-35 (page 111).

The 2025 short-term incentive program for Executives rested on three criteria: year-end cash balance (40 per cent), EBITDA (35 per cent) and execution milestones (25 per cent). Sustainability-related targets sat inside the execution milestones: the learning management system roll-out and leadership engagement in health and safety (page 34). The report states that climate-related considerations were not factored into the remuneration of members of the administrative, management and supervisory bodies (page 34).

The long-term incentive program is share-based and tied to share price (page 35). In 2025 the Board also approved a targeted retention element under the short-term framework for a limited number of key executives and managers (pages 34-35).

Statement on due diligence

Reference: pages 100-101.

The ESRS index lists the statement on sustainability due diligence at pages 100-101 (page 111), and page 116 maps the GOV-4 data point to the same pages.

The company says it is "in the process of systemizing its human rights due diligence and management procedures" and follows the OECD Due Diligence Guidance for Responsible Business Conduct (page 100). The statement is organized in four steps: embedding responsible business conduct in policies and management systems; identifying and assessing adverse impacts; ceasing, preventing or mitigating them; and tracking implementation (pages 100-101).

Key facts: a Business Partner Risk Management Policy was implemented in December 2025 and a risk management framework was adopted on 18 December 2025 (page 100). The first human rights due diligence process ran in 2024, with a statement under the Norwegian Transparency Act, and flagged batteries and steel as the main supply chain risks (page 101). "No actual adverse impact has been identified or reported in 2025", and formal mechanisms to track effectiveness are "yet to be established" (page 101).

Risk management and internal controls over sustainability reporting

Reference: pages 32-34, 52.

The ESRS index lists GOV-5 at pages 32-34 (page 111).

The sustainability statements are reviewed by the Executive Management team and the Board before the annual report is released, and they are subject to external assurance by the auditor (page 33). The company applies a three lines of defense model (page 32; the three lines are defined in a footnote on page 33).

The report says controls over sustainability reporting were "reviewed and updated with formalized policies and processes at the end of 2025". It adds that operating effectiveness of risks and controls over sustainability reporting "will be assessed from 2026" and that findings from the auditor will be incorporated annually (pages 33-34). An Internal Control Policy is listed as published or updated on 18 December 2025 (page 33).

Page 52 states that where data is incomplete the company uses judgments and estimates, and that Scope 3 emissions (E1-6) and resource inflows (E5-4) carry a "High", "Medium" or "Low" measurement uncertainty tag.

Strategy, business model and value chain

Reference: pages 11-12, 15, 49, 51, 93, 132-134.

The ESRS index splits SBM-1 into three rows: products, markets and customers (pages 11, 49), headcount by country (page 134) and breakdown of revenue (page 132).

Business: Hexagon Purus offers hydrogen systems built on Type 4 cylinder technology and battery systems for zero-emission infrastructure and mobility applications (page 12). Operations run in two segments, Hydrogen Mobility & Infrastructure (HMI) and Battery Systems & Vehicle Integration (BVI), plus China operations, maritime and corporate overhead (page 132). Production sites: Kassel and Weeze (Germany), Kelowna (Canada), Dallas (USA), Ålesund (Norway) and the Shijiazhuang joint venture (China) (page 15).

Revenue: total revenue and income of NOK 1,143,892 thousand in 2025 (page 132), of which HMI NOK 1,028,177 thousand and BVI NOK 101,489 thousand. By region, Europe excluding Norway was NOK 722,514 thousand and North America NOK 359,209 thousand (page 133).

People: 623 employees at 31 December 2025 (page 93); average full-time equivalents of 669, with 461 in Germany (page 134).

Value chain: the statement maps upstream raw materials and components (carbon fiber, steel, aluminum, batteries), own manufacturing, and downstream zero-emission mobility use (page 49). It names four high climate impact sector codes (page 51).

Interests and views of stakeholders

Reference: pages 53-54, 58-59, 113-115.

The ESRS index lists SBM-2 at pages 58-59 (page 111), with topic-level rows for S1, S2 and S4 (pages 113-115).

A two-page table sets out, for five stakeholder groups, why and how the company engages, the key topics and the intended outcome. The groups are employees and potential employees, customers, investors and strategic partners, suppliers, and NGOs, governments and regulators (pages 58-59). Engagement channels include employee surveys and town halls, customer meetings and surveys, the annual report and general meeting for investors, supplier questionnaires and audits, and industry associations and public forums.

For the 2025 double materiality assessment the main stakeholders engaged were employee representatives and a selected customer (page 53). The company states it did not directly consult affected stakeholders beyond its own operations, such as value chain workers, and relied on its own knowledge and the interviewed stakeholders' feedback (page 54). The S2 and S4 index rows repeat that the understanding of groups at greater risk of harm "was generic and based on the knowledge of the stakeholders engaged" (page 115).

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

Reference: pages 61, 71, 80, 87, 97, 102, 108, 111-115.

The ESRS index states SBM-3 is "Covered in the respective ESRS material topic chapters" (page 111).

Each material topic opens with an IRO overview table giving the sub-topic, IRO type, where it sits in the value chain, a description, and medium- and long-term direction. The tables hold 26 rows in total: climate change 8 (page 61), resource use and circular economy 6 (page 80), own workforce 4 (page 87), workers in the value chain 3 (page 97), consumers and end-users 4 (page 102) and business conduct 1 (page 108).

On strategy, the report says its "strategy and business model are directly linked to the opportunities in the energy transition from fossil fuels to renewables" and that it faces equivalent risks if the transition is slower (page 71). The index adds topic-level comments: for climate, the risk assessment does not include a resilience analysis (page 112); for S1, S2 and S4, the assessment did not examine whether people with particular characteristics are at greater risk of harm (pages 113-115).

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

Reference: pages 53-57.

The ESRS index lists IRO-1 at pages 53-57 (page 111).

The double materiality assessment (DMA) was first run in 2024 and updated in 2025 (page 53). It started by mapping value chain activities from upstream through own operations to downstream, by geography as well (pages 53-54). Internal and external stakeholders were interviewed with a fixed question list, followed by internal workshops to review and calibrate the IROs (page 54).

Time horizons: short term 0-1 year, medium term 2-5 years, long term more than 5 years (page 54). Impacts were scored on scale, scope, irremediability (negative impacts) and likelihood; risks and opportunities used the EBITDA effect as the financial magnitude indicator, multiplied by likelihood. Short-term IROs were scored quantitatively and medium- and long-term ones qualitatively. Thresholds were set after the scoring (page 54).

The process has four phases, ending in validation by executive management and the sustainability team (pages 55-56). The company says that when assessing impacts it did not consider "business activity and/or geography specific factors" that may raise the risk of adverse impact (page 56). Outcome: six material topics (pages 56-57). Compared with 2024, three S1 sub-sub-topics and one G1 sub-topic were dropped as not material (page 57).

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

Reference: pages 111-117; also pages 52, 118.

The company's ESRS index is the table on pages 111-115. Its columns are disclosure requirement, omission, comment or reason for omission, and page(s). It has sections for general disclosures, E1, E5, S1, S2, S4 and G1. IRO-2 itself is listed as "This table" (page 111).

Page 52 says that disclosure requirements or data points that are material but fall under ESRS phase-in are flagged "phase-in" in the ESRS index. The index flags phase-in for E1-9, E5-6 and several S2 and S4 data points (pages 112, 114-115). Many rows carry the company's own comment on a gap, for example no transition plan, no climate targets and no stand-alone climate policy (page 112).

A second table, ESRS data points from other EU legislation (pages 116-117), gives a page number, or marks each data point "Omission", "Not material", "Not relevant" or "Phase-in". It marks the E2, E3, E4 and S3 data points "Not material".

The Board and CEO statement is dated 24 March 2026 (page 118).

Transition plan for climate change mitigation

Reference: pages 62-63, 112, 116.

The ESRS index lists E1-1 with an omission note and pages 62-63 (page 112). The company says it has no transition plan: "We do not have a transition plan. We have not yet decided whether and, if so, we will adopt a transition plan."

Page 63 adds: "As such we have not established a transition plan for climate change mitigation, including any referenced GHG emission reduction targets, actions, or decarbonization levers." Wider emission reduction initiatives are "anticipated to be planned after 2026", and the report links this to "the current business challenges we are facing" (pages 62-63). Scope 1 and 2 reduction targets are to be planned after 2026 (page 63).

The data point table marks the E1-1 transition plan to reach climate neutrality by 2050 as "Omission" and the Paris-aligned benchmark exclusion as "Not relevant" (page 116).

Context the company gives instead: "Climate change mitigation is at the core of our business" through its hydrogen and battery products (page 62).

Identification of climate-related risks and scenario analysis

Reference: pages 62, 71-73.

Back-filled from ESRS 2 IRO-1 and the climate sections of E1, where this content is disclosed in the FY2025 report (pages 62, 71-73; ESRS index page 112). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Physical risk (pages 71-73): a physical climate risk assessment was run in 2023 for the production facilities in Germany, Canada and the U.S. Dallas, Shijiazhuang and the Norway sites were not part of it. Scope was the company's own physical assets, and the supply chain was not assessed. Exposure to climate hazards was evaluated for present day (2020), 2030 and 2050 using IPCC Shared Socioeconomic Pathways: SSP1-2.6 (described as Paris-aligned, below 2°C) and SSP3-7.0 (described as a reasonable worst case), with temperature increases of 1.8°C and 3.6°C by 2100. The company notes these horizons differ from the ESRS short, medium and long term. Findings: the Ontario, Weeze and Westminster facilities are the most exposed; at Weeze river flooding, water stress and drought are high and expected to rise. The work is limited to hazard screening, and potential financial effects have not been evaluated (page 73).

Transition risk (page 62): the company states it has not used climate scenario analysis to determine transition risks and opportunities or their magnitude.

The index notes the assessment did not cover all sites (page 112).

Resilience in relation to climate change

Reference: pages 62, 71-73.

Back-filled from ESRS 2 SBM-3 and the climate sections of E1, where this content is disclosed in the FY2025 report (pages 62, 71-73; ESRS index page 112). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The company states it has not done a resilience analysis. The index comment reads: "Our climate risk assessment does not include a resilience analysis of our strategy and business model in relation to climate change." (page 112, against both SBM-3 and IRO-1).

The narrative gives a qualitative view instead. The company says it "can still assess the resilience of our business" because its strategy depends on the energy transition, and it is exposed to short- and long-term transition risks and opportunities (page 62). Its most significant transition risks stem from delayed adoption of zero-emission infrastructure and mobility solutions, driven by higher cost of capital and uncertain regulatory support. Recent large capital investments give "operational flexibility to scale and scope the production" to some extent, which mitigates the delay risk (page 62).

On physical risk, some facilities will be increasingly exposed and will be monitored (page 62). Weeze and Kassel include general climate considerations in emergency preparedness, and the company aims to complete the assessment for all production facilities (page 73).

Policies related to climate change mitigation and adaptation

Reference: pages 62-63, 69, 112.

The ESRS index lists E1-2 with pages 62-63 and the comment "We do not yet have a policy specifically referring to climate change." (page 112).

Page 63 confirms there is no stand-alone global climate policy. The global Environmental, Health and Safety (EHS) Policy sets out the company's principles on environmental responsibility and so contributes to lowering its climate footprint. Guided by that policy, the company promotes renewable energy and energy conservation in its own operations where feasible (page 69).

The EHS Policy is approved and owned by the CEO and applies to all controlled entities (page 81). The policy overview lists it as published or updated on 21 November 2025 (page 33), and the resource use chapter says it has been implemented since November 2025 (page 83).

Actions and resources in relation to climate change policies

Reference: pages 62-63, 69, 112.

The ESRS index lists E1-3 at pages 62-63 with three comments: the company does not present key mitigation actions "by decarbonization levers and/or including nature-based solutions", does not report expected GHG emission reductions, and the actions presented "do not constitute significant monetary amounts of CapEx and OpEx" (page 112).

2025 actions (page 63): a paper baler at the Weeze facility to cut paper waste volume and so waste-transport emissions, and a mill baler at Kelowna for recyclable cardboard. Kassel and Weeze passed ISO 14001 surveillance audits (page 69). Existing efficiency measures include heat pumps at Kassel, LED lighting at Weeze and Kassel, and rooftop solar PV at both sites (page 69).

Planned (pages 63, 69): possibly co-locating battery pack production with vehicle integration in the BVI segment, moving overseas suppliers to North America, and bringing the Weeze solar PV (527 kWp) online in 2026 after a postponement from 2025.

Wider emission reduction initiatives beyond own operations are anticipated to be planned after 2026 (page 63).

Targets related to climate change mitigation and adaptation

Reference: pages 62-64, 69, 112, 116.

The ESRS index lists E1-4 at pages 62-63 with the comment "We do not have any specific targets related to climate change mitigation and adaptation." (page 112).

Page 63: "We have not set quantifiable climate-related targets, including GHG emission reduction targets for 2026 or any future period as of the publication of this report." Scope 1 and 2 reduction targets will be planned after 2026, and Scope 3 targets once the inventory is complete or has lower measurement uncertainty. Page 69 says the same for energy: quantifiable energy-related targets have not been set.

The GHG results table shows the milestone and target-year columns (2025, 2030, 2050) as N/A for every line (page 64). The data point table marks the E1-4 GHG emission reduction targets data point "Omission" (page 116). GHG emissions is one of the eight internal sustainability KPIs (pages 47-48).

Energy consumption and mix

Reference: pages 69-70.

The ESRS index lists E1-5 at pages 69-70 (page 112).

Total fuel and energy consumption was 15,115 MWh in 2025, up from 12,666 MWh in 2024 (page 70). By source in 2025: fossil 9,487 MWh (2024: 7,956), including natural gas 3,990 (3,269) and purchased electricity 5,060 (4,496); nuclear 782 (549); renewable 4,847 (4,162), including self-generated solar energy of 614 MWh (35). Shares of the total: fossil 63% (63%), nuclear 5% (4%), renewable 32% (33%). Energy intensity per net revenue was 0.0000132 MWh per NOK in 2025 against 0.0000068 in 2024, on net revenue of tNOK 1,143,892 against tNOK 1,875,839.

All of the company's activities are in high climate impact sectors, so total energy and revenue figures cover all consolidated entities (page 70). The split between fossil, nuclear and renewable energy for purchased electricity was estimated from each country's grid mix, and natural gas was converted to MWh using IPCC AR5 factors. Measurement uncertainty is rated "Low". The report states the metrics have not been validated by an external body (page 70).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 64-68.

The ESRS index lists E1-6 at pages 64-68 (page 112).

(page 64). Scope 1 mainly comes from natural gas used for heating (page 65). Categories 1 and 2 make up 79% of total location-based emissions; category 5 (waste) rose sharply, driven by scrap cylinders (page 65). Only 5.1% of emissions use primary data from suppliers or value chain partners (page 65). Categories 4, 9, 10, 11 and 12 were not estimated "due to lack of information and represent omissions from ESRS" (page 66).

2024 market-based Scope 2 was restated from 6,184 to 1,922 tCO2e because Guarantees of Origin at Kassel and Weeze had not been applied (page 65). Intensity per net revenue (location-based): 0.036 tCO2e per tNOK in 2025 against 0.034 (page 65). Methodology follows the GHG Protocol, with DEFRA factors for Scope 1 and several Scope 3 categories (pages 66-67).

Policies related to resource use and circular economy

Reference: pages 80-83, 112.

The ESRS index lists E5-1 at pages 81-83 (page 112).

The company has no separate circular economy policy in the pages cited. It relies on its global Environmental, Health and Safety (EHS) Policy, under which it is "committed to minimizing resource use for our products and solutions where feasible in our own operations" and should "design our products and operate our facilities to minimize environmental impact" (page 81). The policy is approved and owned by the CEO, applies to all controlled entities and is on the website and intranet (page 81). It has been implemented since November 2025 (page 83).

The company says it is "still at the early stage of integrating circular design in our product development" (page 81). For Type 4 cylinders the company is working with higher-specification materials and higher material utilization. For battery packs it is looking at removing parts and investigating remanufacturing with a third party. None of its materials come from secondary sources (pages 81-82).

The screening of assets and activities used internal experts and stakeholder interviews; direct consultation with affected communities was not conducted (page 81).

Actions and resources related to resource use and circular economy

Reference: pages 48, 81-83, 112.

The ESRS index lists E5-2 at pages 81-83 (page 112).

2025 actions (page 83): the global EHS policy was developed and implemented from November 2025; polymer liner material was tested and evaluated for recycling through regrind and reuse, to cut liner manufacturing waste; carbon fiber waste fell through better fiber handling and spool exchange, so spools run until nearly empty. Page 48 also lists improved tracking of resource inflows.

Planned (page 83): reuse of recycled carbon fiber in secondary parts in the company's own products, a long-term focus with stepwise improvement "to at least 2030 and beyond".

End of life (pages 82-83): cylinders used within specification can be re-qualified for lower pressures and reused in new applications. Scrap cylinders go to a recycler in Europe, and in North America a specialized company recycles scrapped composites. Battery packs and electric powertrain components can be recycled, and second-life uses will be studied.

The pages cited give no monetary amount for these actions.

Targets related to resource use and circular economy

Reference: pages 48, 83, 112.

The ESRS index lists E5-3 at pages 81-83 with the comment "We do not have any specific targets related to resource use and circular economy." (page 112).

Page 83 explains why: 2025 is the first year the company reports resource inflows (E5-4) using estimates and assumptions. "No targets have therefore been adopted at this stage", because baseline data on material inflows and waste outflows must first be established before targets can be credible and actionable. Completing the material inflow and waste inventory is described as a key focus for 2025 and onwards.

Waste from manufacturing is one of the eight internal sustainability KPIs (page 48), which the company will monitor going forward (page 83).

Resource inflows

Reference: pages 52, 84.

The ESRS index lists E5-4 at pages 81-84 (page 112). Page 52 flags it as one of the estimated metrics.

(page 84). The company states "Currently none of our key materials are from secondary (recycled) sources" and that no biological materials are used.

Method (page 84): purchase data from each site's ERP system, intercompany transactions excluded, and the top 10 production materials by spend per facility, consolidated at Group level. Ålesund and Shijiazhuang are excluded because of low production. The company assumes the top 10 materials capture most of the inflow and acknowledges "potential underestimation". Unit weights are estimated where not available, and for multi-material parts the main material is assumed representative. Measurement uncertainty: "High".

Resource outflows

Reference: pages 81-83, 85.

The ESRS index lists E5-5 at pages 81-83 and 85 (page 112); the data point table maps the non-recycled and hazardous waste data points to page 85 (page 117). Waste quantities are covered under the Waste entry.

Products (page 82): the company says its products do not generate waste in the use stage, but end-of-life handling is technically challenging because of the materials. Type 4 cylinders have a typical lifetime of at least 15 years, and cylinders can be re-qualified for lower pressure levels repeatedly, "potentially giving a cylinder multiple decades of extended life". Carbon fiber recovered from cylinders after repurposing is expected to be reusable in secondary structural parts once recycling technologies pass required tests.

End of life (page 83): scrap composites go to specialized recyclers in North America, and scrap cylinders to a recycler in Europe. Battery packs and powertrain components can be recycled, with second-life applications to be studied.

The pages cited give no percentage of recyclable or recycled content for products or packaging.

Waste

Reference: page 85 (E5-5 resource outflows table and accounting policies); also pages 64-65, 82.

(page 85). In 2025, 1,000 tonnes of non-hazardous waste were diverted from disposal (964 recycling, 30 preparation for reuse) and 6 tonnes of hazardous waste were recycled. Non-hazardous waste sent to disposal was 316 tonnes (124 incineration, 143 landfill) and hazardous waste 37 tonnes (33 incineration, 4 other disposal). No radioactive waste is reported.

Non-hazardous waste is mainly general metal, liners, plastic and wood; hazardous waste is mainly abrasives, resin and solvents (page 85). All waste is segregated, and hazardous waste goes to licensed contractors (page 82).

Method (page 85): waste data comes from waste companies at each facility. Where weights are missing, operations management estimates them, which applies to non-hazardous waste in Ontario, Kelowna, Dallas, Ålesund and Shijiazhuang. The company takes a conservative approach and assumes landfill unless the waste company says otherwise. Measurement uncertainty: "Low". Scope 3 category 5 emissions rose from 265 to 1,122 tCO2e, driven by scrap cylinders (pages 64-65).

Policies related to own workforce

Reference: pages 88-92, 113.

The ESRS index lists S1-1 at pages 88-92 (page 113).

The commitments sit in the Human Rights and Working Conditions Policy (updated in 2025), a global EHS Policy established in 2025, the Code of Conduct and a Diversity, Equity and Inclusion Policy (pages 90-91). The human rights policy rests on the OECD Guidelines, the UN Guiding Principles, the ILO Declaration on Fundamental Principles and Rights at Work and the International Bill of Human Rights. It prohibits trafficking in human beings, forced or compulsory labor and child labor, and it also covers suppliers, business partners and affected communities (pages 89-90). The company says no significant risks of forced, compulsory or child labor have been found (page 90).

The EHS Policy applies to everyone working for or representing the company, and the CEO has overall responsibility (page 88). The DEI Policy applies to all personnel or workers whose work is controlled by the company, and employment and promotion decisions are based on merit (page 91). Policies are on the intranet and in the learning management system (page 90).

Taking action on material impacts on own workforce

Reference: pages 88-92, 113.

The ESRS index lists S1-4 at pages 88-92 (page 113).

2025 actions (pages 90, 92):

• updated the Human Rights and Working Conditions Policy and set up a global EHS Policy
• Weeze and Kassel passed ISO 14001 and ISO 45001 surveillance audits and were re-certified to ISO 9001
• senior leadership and joint committee safety walks, internal EHS representatives certified, and structured review of near misses and unsafe conditions
• new company agreements at Weeze with the works council
• learning management system rolled out to all locations, with Health and Safety and Code of Conduct modules; bullying and harassment training relaunched in Canada and legally required harassment training completed in the U.S.

Planned (pages 90, 92): first aid training, an internal Health and Safety Day, more safety walks with shopfloor employees, and a move from two salary systems to one in Germany.

The market downturn in 2025 forced a headcount reduction, handled with internal communication and outplacement services (page 88). The company says the downsizing had unintended consequences for diversity, including a lower proportion of senior female leaders (page 92).

Targets related to own workforce

Reference: pages 48, 88-92, 113.

The ESRS index lists S1-5 at pages 88-92 (page 113).

The company has set no specific targets. For working conditions: "We have not set any specific targets for 2026." (page 90). For training: "We have therefore not set specific targets for 2026", because the learning management system will only allow tracking of training hours per employee from 2026, which will be used as a baseline for 2027 (page 92). The company "deliberately" avoids targets for incidents and near misses, though reduction is a long-term goal (page 88). On gender, it says it does not currently have the targeted gender balance in its workforce, without stating a figure (page 92).

Three of the eight internal sustainability KPIs relate to the workforce: lost time incident frequency rate, number of training hours per employee and gender diversity (page 48).

Characteristics of the undertaking's employees

Reference: pages 93, 134.

The ESRS index lists S1-6 at pages 93-96 (page 113). Figures are headcount at 31 December from payroll systems (page 93).

(page 93). 232 permanent employees left in 2025, a turnover rate of 33% (2024: 100, 13%). The company has no non-guaranteed hours employees, and most temporary employees are trainees in structured training programs (page 93). Geographic breakdown is given in full-time equivalents in Note 5 (page 134), which shows 598 FTEs at year-end and 461 average FTEs in Germany.

Characteristics of non-employee workers

Reference: pages 93-94.

The ESRS index lists S1-7 at pages 93-96 (page 113).

Non-employees numbered 48 at year-end 2025 (42 male, 6 female), against 20 (all male) in 2024 (page 94). Most are agency workers brought in for extra capacity in peak periods and paid by their agencies. The 2025 figure was elevated by an arrangement in Dallas, where Hexagon Purus subleases space to Hino and sources temporary workers for Hino's operation there. From January through July 2025 there were no non-employees in Dallas, against 44 in December (page 94).

Diversity metrics

Reference: pages 48, 92, 94-95.

The ESRS index lists S1-9 at pages 93-96 (page 113).

Gender split at senior levels, 2025 against 2024 (page 94): Executive Management 5 people in both years (4 male, 1 female, so 80% and 20%); "Directors (M5) and above" 33 in 2025 (25 male, 8 female) against 52 in 2024 (38 male, 14 female); other staff 585 in 2025 against 791. The table also splits each level by age band (under 30, 30-50, over 50).

Across the workforce, 105 of 623 employees are women (page 95). The company acknowledges that the 2025 downsizing reduced the proportion of senior female leaders (page 92), and says it does not yet have its targeted gender balance (page 92). Gender diversity is one of the eight internal sustainability KPIs (page 48).

Health and safety metrics

Reference: pages 88, 95.

The ESRS index lists S1-14 at pages 93-96 (page 113), and the data point table maps the fatalities, accidents and days-lost data points to page 95 (page 117).

Employees (page 95): 623 covered by the health and safety management system (100%); 1,108,737 hours worked in 2025 against 1,216,462 in 2024; no fatalities in either year; 21 recordable work-related injuries in 2025 against 29; a rate of 19 against 24 (per 1,000,000 hours); 127 lost days against 479. Non-employees are reported separately: 48 people and 38,429 hours worked in 2025, with no recordable injuries (2024: one injury and 3 lost days).

Method: the injury rate is cases divided by hours worked and multiplied by 1,000,000. Only incidents arising directly from operating company machinery, equipment or other assets are counted, so commuting and business travel incidents are excluded (page 95). Ownership: the CEO has overall responsibility for adequate EHS standards, and EHS data is regularly reviewed with the Board (page 88). Kassel and Weeze have been ISO 45001 certified since 2024 (page 88).

Work-life balance metrics

Reference: pages 93-96.

The ESRS index lists S1-15 at pages 93-96 (page 113).

Family-related leave (page 95): all 623 employees are entitled (517 male, 105 female, 1 unspecified), 100%. 37 took leave in 2025 (25 male, 12 female), which is 5% of entitled men and 11% of entitled women. In 2024, 848 were entitled and 30 took leave (19 male, 11 female), 3% of men and 8% of women.

Incidents, complaints and severe human rights impacts

Reference: pages 88-96, 117.

The ESRS index lists S1-17 at pages 88-96 (page 113), and the data point table maps the discrimination and non-respect of UNGP and OECD guidelines data points to page 96 (page 117).

The company reports handling "one matter that we classify as a reported concern", related to working environment, and says "There have not been any concerns reported through the external channel on our website" (page 96). The table shows one reported working environment complaint, including discrimination and harassment, in 2025 against 7 in 2024. It shows no severe human rights incidents and no cases of non-respect of UNGP, OECD or ILO guidelines in either year.

People & Culture departments at all sites handle employee relations matters such as conflicts, which the company calls a natural part of any organization (page 96).

Policies related to value chain workers

Reference: pages 98-99, 114.

The ESRS index lists S2-1 at pages 98-99 and flags paragraph 17(b)-(c) as phase-in (page 114).

The Supplier and Business Partner Code of Conduct sets requirements on business ethics, human rights and working conditions, occupational health and safety, environment, product safety and management systems, and it describes the right to audit and the approach to non-compliance. It is always included in the supplier self-assessment questionnaire during qualification and/or in the purchase agreement (page 98).

The Code is backed by the Human Rights and Working Conditions Policy, which refers to the Norwegian Transparency Act, the OECD Guidelines, the UN Guiding Principles, the eight fundamental ILO conventions and the Universal Declaration of Human Rights, and addresses trafficking in human beings, forced labor and child labor (page 98). In 2025 the company developed a Business Partner Risk Management Policy setting requirements to assess integrity risks across suppliers and business partners (page 99).

Taking action on material impacts on value chain workers

Reference: pages 99-101, 114.

The ESRS index lists S2-4 at pages 98-101 and flags paragraph 35 as phase-in (page 114).

2025 actions (page 99): the Business Partner Risk Management Policy was developed and launched, and the Supplier and Business Partner Code of Conduct was updated to support EU Taxonomy minimum safeguards and human rights commitments. Supplier audits currently focus on quality. Planned for 2026: improved local supplier management procedures aligned with the new policy.

Due diligence findings (page 101): the contextual assessment points to batteries and steel as the main supply chain risks. The main battery cell supplier is a member of the Responsible Minerals Initiative, but Hexagon Purus is a small customer with "limited visibility and influence" over sub-supplier risks. "No actual adverse impact has been identified or reported in 2025."

The company describes its approach as based on "the generic nature of manufacturing industries" and says it is still working to understand the characteristics of value chain workers (page 99).

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

Reference: pages 48, 98-99, 114.

The ESRS index lists S2-5 at pages 98-99 and flags paragraphs 41 and 42(b)-(c) as phase-in (page 114).

"Quantifiable targets for engagement with workers in the value chain have not yet been set in 2025." From 2026 the company will monitor risks found through environmental and social due diligence on suppliers and business partners, and plans environmental and social audits of selected suppliers; these results will inform later targets (page 99). Environmental and social due diligence of suppliers and business partners is one of the eight internal sustainability KPIs (page 48).

Policies related to consumers and end-users

Reference: pages 33, 103-106, 115.

The ESRS index lists S4-1 at pages 103-106 and flags paragraphs 16-17 as phase-in (page 115).

The Product Safety Policy is currently adopted from Hexagon Composites. It covers regulatory compliance, testing and validation, and training and continuous improvement, applies to all Hexagon Purus employees and is available on Hexagon Composites' website (page 103). The policy overview dates it July 2025 (page 33). The Executive Vice Presidents of the HMI and BVI segments are accountable for implementing it (page 104). The company sells business-to-business, and its end-users are vehicle and vessel operators and, where relevant, passengers (page 103). The Supplier and Business Partner Code of Conduct requires suppliers to cooperate in product-safety investigations (page 106).

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 103-106, 115.

The ESRS index lists S4-4 at pages 103-106 and flags paragraph 31(d) as phase-in (page 115).

Approach (pages 103, 105): all products are tested to internal, national, industrial and international standards before shipment. Safety is part of product development, with design reviews, Advanced Product Quality Planning and Design Failure Modes and Effects Analysis. In BVI, tests include vehicle crash, rollover and durability testing.

2025 actions (pages 104, 106): safety training for customers and users in hydrogen mobility and infrastructure was further developed, including a practical session with Solaris on a hydrogen fuel storage system; quality audits were run on BVI suppliers with a focus on product quality and safety.

Planned (pages 104, 106): ISO 9001 certification for Ålesund, postponed from 2025 to 2026; completion of UN ECE R100 testing for the third-generation battery system; compliance in 2026 with FMVSS 305a ahead of the mandated date of September 1, 2029.

Outcome: "In 2025, there were no reports about injuries or specific material negative impacts affecting the personal safety of our consumers and end-users" (page 106).

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

Reference: pages 48, 104, 106, 115.

The ESRS index lists S4-5 at pages 104 and 106 and flags paragraphs 38 and 40-41 as phase-in (page 115).

No quantitative targets are set. On information-related impacts: "Setting quantitative targets related to information-related impacts for consumers and/or end-users is still an on-going process" because global metrics for different products are still being established (page 104). On personal safety: no quantifiable target has been set, but the company keeps "a zero-vision for safety incidents involving our products and solutions" (page 106). Product related safety incidents is one of the eight internal sustainability KPIs (page 48).

Business conduct policies and corporate culture

Reference: pages 108-110, 115, 117.

The ESRS index lists G1-1 at pages 108-110 (page 115), and the data point table maps the UN Convention against Corruption data point (paragraph 10(b)) to the same pages (page 117).

The Code of Conduct is the overarching governance document. It covers human and labor rights, anti-corruption and bribery, sanctions and export controls and data privacy, among others, and the core values are Integrity and Drive (page 109). The Board has ultimate responsibility for ethical business conduct and the risk management and internal control framework, and the CEO leads day-to-day implementation (page 109). Anyone can report concerns, including employees, temporary workers, contractors, supply chain workers, business partners and members of affected communities, through the channels in the Whistleblowing Policy, including an external channel (page 110).

2025 actions (page 110): updated and new policies adopted to build a risk, impact and opportunity management and internal control framework aligned with EU Taxonomy minimum safeguards; learning management system rolled out at all locations; Code of Conduct training rolled out to employees and the Board in local languages. Planned for 2026: more training, review of local processes and a new external whistleblowing channel.

The one G1 IRO is a potential negative impact on corporate culture (page 108).

Targets related to business conduct

Reference: pages 48, 89, 110.

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; this statement was prepared under the 2023 ESRS.

No quantitative target is set. The report states: "We do not have a quantitative target concerning corporate culture." The stated objective is to ensure employees "understand and act on the guiding principles set out in our Code of Conduct" (page 110).

Effectiveness is tracked in other ways. Code of Conduct training is part of the standard employee curriculum and becomes part of mandatory onboarding from 2026 (page 110). Completion is tracked in the learning management system (page 89), and completion rate of Code of Conduct training is one of the eight internal sustainability KPIs (page 48). Stakeholder feedback and reported concerns are "taken seriously and handled appropriately" and used to improve governance and corporate culture (page 110).