Holmen Ab

The role of the administrative, management and supervisory bodies

Reference: page 99; incorporated by reference to the corporate governance report, pages 44-48.

The sustainability report does not restate GOV-1 in full. It says the Board and Group management reformulated the business concept and strategy in recent years, and that sustainability matters "have been integrated into the operations and governance of Holmen", so that governance and monitoring of these issues "follow the same structure as other operations within Holmen" (page 99).

For the detail it points to the corporate governance report: Board meetings (page 44), Nomination committee (page 45), Composition of the Board (pages 45-46), The Board’s activities (page 46), Audit committee (page 46), Group management (pages 46-47), Internal management processes (pages 47-48) and Internal control of reporting (page 48). The content index also lists the Board gender diversity and Board independence datapoints (ESRS 2 paragraph 21 (d) and (e)) at page 99.

From the corporate governance report: eight of the nine Board members elected by the AGM (89 per cent) are deemed independent of the company, the CEO is the only Board member with an operational position, and the local labor organizations appoint three members and three deputy members in addition (page 46). The audit committee, which monitors sustainability reporting alongside financial reporting and internal control, met six times (page 46).

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

Reference: page 99; incorporated by reference to the corporate governance report, pages 44-48; stakeholder reporting to the Board on page 102.

Holmen reports GOV-1 and GOV-2 together under one heading (page 99). Governance of the operations, sustainability work included, runs through Group policies, guidelines and Group instructions. The sustainability reporting guidelines set the framework for reporting, the environmental and energy policy sets the framework for environmental and energy work, and the Code of Conduct and Supplier Code of Conduct set principles on business conduct, anti-corruption, human rights and the environment (page 99).

The Board’s work follows a plan intended to "ensure that the Board receives all the information it requires" on strategically important issues (page 99). The heads of the business areas report to Group management and the Board on the business situation, "including stakeholder perspectives on a wide range of issues, such as climate and other ESG factors" (page 102). The double materiality assessment "has been presented to Group management, the audit committee and the Board" (page 103).

Integration of sustainability-related performance in incentive schemes

Reference: page 99; Note 4 on pages 73-74 (incorporated by reference); E1-4 on page 112.

Holmen states that its short and long-term incentive programs for Group management are "linked to sustainability-related matters" (page 99).

• Short-term program for key individuals: "10 per cent is based on whether the accident rate at Holmen’s workplaces has decreased compared to the previous year".
• Long-term program for Group management: "performance conditions linked to increased climate benefit compared with the reference period". The report adds that climate benefit includes greenhouse gas emissions, where a reduction in GHG emissions can produce a greater climate benefit.

The report refers readers to Note 4 on page 73 for the remuneration detail and to E1-4 on page 112 for the climate benefit target. The content index lists ESRS E1 GOV-3 at page 99 and Note 4 (pages 73-74) in its incorporation by reference table (page 109).

Statement on due diligence

Reference: page 99.

Holmen says its due diligence process, "which involves systematically identifying, analysing and managing negative impacts on human rights, the environment and anti-corruption, is described in Holmen’s steering documents" (page 99). The Code of Conduct and Supplier Code of Conduct are supported by the HR policy, health and safety policy, purchasing policy, business ethics policy and a whistleblower function. Risk assessments are run in own operations and in the supply chain, and supplier assessments flag sustainability risks.

Outcomes stated for 2025: "Holmen has no convictions for human rights violations in 2025", and no final convictions for breaches of competition law or corruption offenses (page 99).

A table maps the core elements of due diligence to the places they are covered: embedding in governance and strategy (GOV-2, GOV-3, SBM-3, pages 99 and 102), stakeholder engagement (GOV-2, SBM-2, IRO-1, pages 99, 101, 103), identifying and assessing impacts (IRO-1, SBM-3, page 103), actions (MDR-A in E1 page 111, E2 page 119, E4 page 122, E5 page 124, S1 page 127, S2 page 129, S3 page 130) and tracking effectiveness (MDR-M and MDR-T in E1 page 112, E2 page 119, E4 page 123, E5 page 124, S1 page 127, S2 page 129, S3 page 130, G1 page 132).

Risk management and internal controls over sustainability reporting

Reference: pages 99-100; corporate governance report, Internal control of reporting, page 48 (incorporated by reference).

Holmen has prepared sustainability reports under the GRI standards for many years and says it has built "an organisation with defined roles and responsibilities, as well as processes and internal controls" for preparing the report (page 99). Risk assessment of sustainability reporting and monitoring and evaluation are part of its internal control work for financial reporting.

The main sustainability reporting risks are described as relating to definitions and to dependence on individuals for data generation. During the year, activities were carried out in these areas to reduce the risk of errors, "including a review of reporting instructions and procedure descriptions" (page 100). Readers are directed to the corporate governance report, pages 44-48, for the Group's internal control and risk management (page 100).

Strategy, business model and value chain

Reference: pages 100-101.

Holmen’s strategy "revolves around its land holdings" (page 100). The business concept is to own and add value to the forest, refining the growing trees into wood products, paperboard and paper while generating hydro and wind power on its land.

The Group has four business areas (Forest, Wood Products, Board and Paper, Renewable Energy) and 3,851 employees, 3,295 of them in Sweden and about 412 in the UK. Forest covers over a million hectares of productive forest land plus partnerships with about 15,000 private forest owners; Wood Products runs five sawmills; Board and Paper runs four production facilities in Sweden and the UK; Renewable Energy has 21 wholly or partly owned hydro power plants and three wholly owned wind power plants (page 100).

Income per sector, SEK million, 2025 (2024): Forestry 3,188 (2,991); power generation and energy 430 (634); paper and wood products 18,438 (19,132) (page 100).

Value chain: about half of the wood comes from Holmen’s own forests and the rest is bought in, mainly from private forest owners in Sweden, with only a small proportion imported; downstream activity is outbound transport to customers, and electricity is sold on the Nordic market (pages 100-101). The index marks the SBM-1 datapoints on fossil fuel, chemical, controversial weapons and tobacco activities "Not material" (page 106).

Interests and views of stakeholders

Reference: pages 101-102.

Holmen identifies stakeholders from the operations carried out, how they affect the world around them and who affects Holmen. A table (page 101) sets out priority topics and the forum for each group: investors, customers, suppliers, employees, workers in the value chain, affected communities, politics and society, civil society organizations and nature. Forums include investor meetings and ESG rankings, customer visits and surveys, supplier audits and follow-up meetings, employee surveys and appraisal talks, consultation with local representatives, and expert panels and roundtables.

Two points are specific to Holmen: "Thanks to good union relations, the views of employees are effectively heard" and the "silent stakeholder, nature, is taken into account in the permit process and by research projects" (page 102).

Holmen states that "No material changes in strategy or business model have been made as a direct consequence of this stakeholder dialogue" (page 102).

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

Reference: pages 102-103.

A table on page 102 lists the material sustainability matters, their sub-topics and the chapter page: carbon dioxide capture and storage in standing timber and products, value chain greenhouse gas emissions, renewable energy production and electricity-intensive paper production (all E1, page 110); pollution to water and air (E2, page 119); forestry impacts on the local environment and water, and hydro power impacts on landscape and aquatic environments (E4, page 121); production of renewable products and industrial production generating waste (E5, page 124); risk of accidents and need for skilled workers (S1, page 126); dependence on contractors in forestry (S2, page 128); operations impact on local residents and local businesses (S3, page 130); exposure to business conduct risks (G1, page 131). The detailed impact, risk and opportunity tables sit at the head of each chapter.

Holmen ties these to five areas: climate benefit grows with the business; forestry fosters biodiversity; the business develops within environmental permits and certifications; employees develop and thrive; and long-term relationships rest on responsible business conduct (page 103). The report judges the strategy resilient to sustainability-related impacts, risks and opportunities in the long term and well placed for the transition to a low-carbon economy (page 103).

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

Reference: pages 103-105.

Holmen ran the double materiality assessment under the CSRD with a central project team (environment, sustainability, finance, legal, communication) reporting to a steering group of Group management representatives; the outcome was presented to Group management, the audit committee and the Board (page 103). The process surveyed own operations and the value chain, inventoried actual and potential impacts, risks and opportunities by value chain location and time horizon, then assessed each one.

Negative impacts were rated on scale, scope and irremediable character, plus likelihood for potential impacts; positive impacts on scale, scope and likelihood. Each was rated low, medium or high, and for human rights impacts "precedence" was given to scale. Financial risks and opportunities were rated on likelihood and financial impact. "Sustainability matters with a final rating of high or medium in terms of their impact perspective and/or financial perspective have been judged to be material sustainability matters for Holmen" (page 103).

Topic notes (pages 103-105): for climate, "Holmen has not used any specific climate scenario analysis" for transition events and relies on business-area climate adaptation plans for physical risk; E3 was not identified as material; S4 was judged not relevant because products are not sold directly to end consumers.

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

Reference: page 105; content index, pages 106-109.

Holmen says "The Content index table on pages 106-109 provides an index of the disclosure requirements contained in the sustainability report, including datapoints derived from other EU legislation" (page 105). After identifying the material topical standards, the materiality of each disclosure requirement and datapoint was assessed under ESRS 1 section 3.2 and EFRAG guidance (page 105).

What the index shows (pages 106-109): ESRS 2, E1, E2, E4, E5, S1, S2, S3 and G1 carry page references. E3 is marked "Not material" as a whole standard, and S4 appears without page references. Within covered standards, these are marked "Not material": E1-8, E2-5, S1-7, S1-8, S1-10, S1-11, S1-12, S1-15, S1-16, S1-17 and G1-6, together with some datapoints. "Phasing in" is marked against E1-9 (and its datapoints), E2-6, E4-5 paragraph 38, E4-6 and E5-6. An incorporation by reference table (page 109) points to the corporate governance report (pages 44-48) and Note 4 (pages 73-74).

Transition plan for climate change mitigation

Reference: page 111 (also pages 110, 112-113).

Holmen states that "Holmen’s transition plan is thus an integral part of the Group’s strategy, as established by Group management with a view to increasing climate benefit throughout the value chain" (page 111). The plan rests on a positive climate impact from forest growth, renewable products and renewable energy, plus fossil emission cuts.

Progress cited: a 2005 target to cut fossil fuel use at material sites by 90 per cent by 2020, and fossil emissions from production down 85 per cent since 2005 (page 111). Going forward, "Holmen has set targets for Scopes 1-3 in line with the Science Based Targets initiative (SBTi), based on the ambition level “below 2°C”", detailed under E1-4. Scope 3 holds 88 per cent of total fossil emissions, mainly purchased goods and upstream and downstream transport (page 111).

Funding: "No significant resources have been allocated to maintain low emission levels. This is done within the regular budget process of the material site" (page 111). For purchased goods Holmen follows up suppliers' climate targets and encourages science-based targets. Holmen’s operations are not covered by Article 12 of Commission Delegated Regulation (EU) 2020/1818 and so are not excluded from EU Paris-aligned benchmarks (page 111). No net-zero year of Holmen's own appears in the E1 chapter; the targets run to 2030.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 (the E1 climate section, pages 103-104), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against (its E1-2 is Policies).

Reference: pages 103-104; page 110.

Transition risk. "In identifying transition events, Holmen has not used any specific climate scenario analysis, but has instead chosen to use the climate targets and policy frameworks set by the EU and Sweden", including LULUCF, the EU Deforestation Regulation and climate neutrality by 2050 (page 103). No 1.5°C-aligned transition scenario is named.

Physical risk. The basis is the climate adaptation plan of each business area, which "are based on scenario analyses" (page 103). Forestry: IPCC projection of 2.7°C by 2050, an average of SMHI scenarios as per RCP 6 and a 100-year rotation as reference. Industry: SMHI RCP 8.5, reference period 1971-2000. Wind and hydro power: the 2.7°C projection with SMHI RCP 2.6, 4.5 and 8.5, same reference period. Analysis is at installation level, with each risk’s financial impact estimated in SEK million per year (pages 103-104).

Gap stated: "Potential climate adaptation needs in the value chain, which are beyond Holmen’s direct control, have not yet been analysed" (page 103). No date is given for the scenario work; plans are "reviewed regularly" (page 104).

Resilience in relation to climate change

Back-filled from the E1 section of ESRS 2 SBM-3 (page 110), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: page 110; pages 103-104, 112.

Holmen states it has not run an ESRS-defined resilience analysis: "Holmen has not conducted a resilience analysis in the specific sense provided by ESRS. Instead, the assessment of the company’s resilience to climate change is conducted in the context of the climate adaptation plans" (page 110).

What the plans show: climate change could affect the business but physical risk impacts "are not judged to be material". Forestry has the greatest exposure: a warmer climate could raise growth, but pests such as fungi and insects, drought and fire risk could cut timber volume and limit forest management. Mills and sawmills may need capacity to handle sudden large volumes of water, and in drought a unit might have to limit production; "the investments or impacts on production are not judged to be material" (page 110).

The report also judges the strategy resilient to physical and transition risk in the long term (page 110). On capacity to adapt, the report says its ability to implement climate measures "is partly dependent on the availability of financial and operational resources" and that actions are funded through the regular investment process (page 112).

Policies related to climate change mitigation and adaptation

Reference: page 111.

The environmental and energy policy (E1-2 / MDR-P) sets the climate position. Forestry is to aim for high-volume, sustainable production of raw material "so that the growing forest and products make a positive contribution to the climate", while safeguarding long-term soil productivity and protecting aquatic environments. Sawmills, paperboard and paper mills must comply with applicable standards and be certified. Energy is to be recovered and used internally and externally, and purchased electricity is to come from fossil-free generation. Due diligence is to ensure raw materials and products are deforestation-free and all timber is traceable to origin (page 111).

Holmen is also to contribute to the transition of the energy system by increasing renewable energy production, and hydro installations are to be adapted in line with the national plan for modern environmental conditions for hydro power. "All material sites and forest operations must prepare a climate adaptation plan" describing climate risks, their effects and the actions that can be taken (page 111).

The President and CEO has overarching responsibility, delegated in writing. The policy applies to the whole Group, and each business area makes sure the rules are reflected in its internal regulations (page 111).

Actions and resources in relation to climate change policies

Reference: pages 111-112.

Each material site is responsible for its certified energy and environmental management systems; actions are "seen as part of day-to-day operations, with no end date" and financed in the regular investment process, with results of major investments reported to the Board (pages 111-112). Capacity to act depends partly on financial and operational resources.

Actions reported for 2025 (page 112):

• Wind power: about 30 projects in development; the Blisterliden Wind Farm, a SEK 1.5 billion investment decided in 2024, was fully commissioned at the end of 2025 and lifts annual deliveries of renewable energy from water and wind by around 20 per cent to 2.2 TWh.
• Fossil emissions: transport is the largest source, around 40 per cent of total emissions. The first electric truck for wood chip transport was commissioned (est. about 50 tonnes CO2e a year saved against a diesel truck). A biogas boiler at Workington is estimated to save around 1,000 tonnes CO2e a year, at a cost of approximately SEK 3.7 million.
• Energy efficiency: new wash presses in the bleaching works, a more efficient sootblowing system and water temperature changes, expected to save 136 GWh a year, from investments of around SEK 32 million.

Reaching the E1-4 targets is expected to cut fossil emissions by about 72,500 tonnes CO2e. Most of the year’s investments are not included in taxonomy-aligned activities (page 112).

Targets related to climate change mitigation and adaptation

Reference: pages 112-113.

Holmen’s overarching target is that climate benefit is to increase by growing the business; "This target is relative, not quantitative". Climate benefit is calculated under ISO 13391. Five key activities include more forest growth and harvest, more wood products for building, more wind power, energy efficiency and lower value chain emissions.

SBTi-endorsed targets at the "below 2°C" ambition level, base year 2019, target year 2030:

• Scope 1 and market-based Scope 2: 15 per cent lower CO2e per tonne of pulp and paper.
• Scope 3 transport: 22 per cent lower CO2e per tonne kilometer.
• Scope 3 forest machinery: 22 per cent lower CO2e per tonne of wood raw material.
• Suppliers accounting for 35 per cent of purchased goods and services emissions to have science-based targets by 2025.

Outcomes: the supplier target was met (42 per cent). Emissions per tonne of pulp and paper had stayed below the 2030 level since 2022, but in 2025 a December 2024 fire at Braviken forced an oil-fired boiler into use, lifting Scope 1 CO2 by 42 per cent against a normal year. Holmen adds that "emissions from transport and forest machinery have not reduced compared to the base year". The base year was recalculated in 2025. Holmen states it "has not assumed a low-emissions scenario when identifying drivers". In the climate benefit table, storage in Holmen’s forests is -1.86 (2024: -2.13) million tonnes CO2e.

Energy consumption and mix

Reference: page 113 (energy sold, page 114).

Total energy consumption was 7,325,777 MWh in 2025 (7,637,531 in 2024): fossil 330,892 MWh, renewable 4,946,427 MWh and nuclear 2,048,458 MWh. The mix was 5 per cent fossil, 68 per cent renewable and 28 per cent nuclear (2024: 3, 72 and 26). "Only 5 per cent is fossil based, mainly from use of oil and diesel", and Holmen does not use coal or coal products as fuel (page 113). Fuel from crude oil and petroleum products was 277,989 MWh against 160,180 MWh in 2024 (page 113).

Purchased or acquired electricity was 3,160 GWh. Holmen buys just under 200 GWh a year from a wind farm on its land at a price fixed until 2032. Paperboard production generates most of the energy its own mills need, while thermomechanical pulp at the two paper mills is electricity intensive (page 113).

Energy intensity is 307 MWh per SEK million of IFRS 15 income (308 in 2024). All operations are classed as high climate impact sectors (forestry A02, sawmills C16, paperboard and paper mills C17, wind and hydro power D35) (page 113). Energy sold in 2025: hydro and wind 1,634,113 MWh, solid biofuels 2,225 GWh, tall oil 148 GWh, district heating 27 GWh, and 116 GWh of surplus electricity from Workington (pages 113-114).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: page 114 (accounting policies, page 115).

Scope 1 rose from 61 to 87 thousand tonnes CO2e in 2025. The report gives the oil boiler at Braviken as the main reason, used as a temporary solution while the solid fuel boiler was renovated. Location-based Scope 2 was 23 thousand tonnes and market-based Scope 2 under 1 thousand tonnes (0.48). Scope 3 was 635 thousand tonnes (2024: 594), with purchased goods and services at 262 and capital goods at 44. Total gross emissions were 745 thousand tonnes location-based and 722 market-based (2024: 675 and 655), or 31.3 and 30.3 tonnes CO2e per SEK million of IFRS 15 income (2024: 27.3 and 26.5). Scope 3 is 88 per cent of fossil emissions (page 111).

Method (page 115): GHG Protocol, with IPCC AR6 global warming potentials; Scope 3 screening used a 1 per cent materiality cut-off, with waste and end-of-life treatment judged not material and upstream and downstream leased assets, franchises and investments not applicable. Scope 3 biogenic emissions are not calculated because data is lacking and estimates are uncertain. The 2025 method for purchased goods and services was updated without recalculating earlier years, and capital goods moved to an average-spend method with the base year and 2024 recalculated (pages 98, 114-115). "Other than the statutory audit carried out by the company’s auditor, there has been no external review of the reported metrics" (page 115).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 114.

"Holmen does not finance any external carbon capture or storage projects and does not use any carbon credits." All uptake and storage happens in Holmen’s own operations as a result of forest growth and storage in wood and fibre products, not a designed removal project (page 114).

In 2025 net uptake in Holmen’s forests was 1.86 (2.1) million tonnes of CO2, with an additional 0.4 (0.4) million tonnes stored in products. Calculations follow ISO 13391 and IPCC methodology, including half-lives for wood and fibre products (page 114). Uptake and storage are classified as a nature-based solution. "No part of the uptake or storage has been transferred or sold to an external party." Holmen judges the risk of shortcomings in the duration of its carbon uptake and storage to be low, based on regular forest inventories, and reports that no reversal or leakage events were identified during the year (page 114).

Policies related to pollution

Reference: page 119.

Holmen contributes to the EU Zero Pollution Action Plan "by not exceeding the permitted emission levels according to the material site’s environmental permit and the BAT conclusions" (page 119). The environmental and energy policy requires each material site to follow its permits and standards and be certified, to work in line with the precautionary principle, and to put the environment first when processes are disrupted: "In the event of process disruptions, the environment takes precedence over production". Environmental impact in ongoing and discontinued operations "must be acceptable to humans and the environment". The policy also calls for resource-efficient use of water, chemicals and input goods, minimal fossil fuel use, and recycling of chemicals, fibres and water.

All material sites have certified environmental management systems, with internal audits and regular external audits. Sites that use environmentally hazardous process chemicals fall under the Seveso legislation, and their permits carry conditions on managing those chemicals, with regular exercises (page 119). The President and CEO holds overarching responsibility, delegated in writing, and the policy covers the whole Group.

Limit stated in the report: "The policy does not specifically address the use of substances of very high concern" (page 119).

Actions and resources related to pollution

Reference: page 119.

Each material site sets environmental targets from its register of key environmental aspects, and actions follow from those targets. In 2025 water treatment actions continued at the Workington mill, and dust treatment at Linghem Sawmill was completed, with measurements showing the conditions are met (page 119).

Legacy sites: under Swedish legislation Holmen has obligations for discontinued sites whose operations caused pollution. In consultation with the County Administrative Board or municipality it investigates former industrial sites, and "funds are earmarked for the costs judged to be incurred". In 2025, studies were in progress at the former sawmill in Stocka, the sulphite mills at Strömsbruk, Domsjö, Loddby and Mariannelund, the paper mill at Silverdalen and the groundwood mill at Bureå. Work to cover the former industrial landfill at Strömsbruk is proceeding to plan, and remediation of the former sawmill area at Lännaholm was completed and the case closed (page 119).

Noise: conditional limits were exceeded at two material sites; actions include noise barriers, wall insulation, hoods on exhausts, speed restrictions and re-routing of truck routes (page 119).

Targets related to pollution

Reference: page 119.

The common environmental objective for Holmen’s material sites is "to prevent and limit air pollution and emissions to water to levels set in environmental permit conditions and in line with Best Available Techniques (BAT)". Holmen’s overarching objective is for operations to run within the permits awarded. The target covers material sites under the Swedish Industrial Emissions Ordinance and is monitored through each site's self-inspection program, as described under E2-4 (page 119).

The report is explicit on the target's form: "No base year is noted, as the target of operating within the environmental permits granted is constant. There is no statutory requirement to set targets" (page 119). Each site also sets targets for prioritized environmental matters from its own aspects analysis. No quantified pollutant reduction target is given.

Pollution of air, water and soil

Reference: pages 119-120.

Holmen’s operations fall under the European pollutant release register reporting obligation. The report tabulates emissions from the sites required to report, "based on consumption" (page 120).

Emissions to air, tonnes, 2025 (2024): nitrogen oxides 740 (816); nitrous oxide 23 (24); volatile organic compounds except methane 3,819 (3,692); nickel 0.22 (0.24); zinc 0.24 (0.25); dioxins and furans 0.01 (none reported).

Emissions to water, 2025 (2024), tonnes unless stated: chlorinated organic matter 29 (34); nitrogen 63 (132); phosphorus 15 (10); organic matter 15 (17) thousand tonnes; arsenic 0.01 (0.01); cadmium 0.01 (0.01); copper 0.26 (0.24); nickel 0.20 (0.19); lead 0.20 (0.02); zinc 3.45 (4.31).

Compliance: the permit limit values for nitrogen, phosphorus and organic matter in water were exceeded, linked to the water treatment plant at Workington (UK), which Holmen is rebuilding. In total 21 exceedances of permit conditions or BAT-AELs were found: two noise events, one nitrogen oxides event to air and 18 emissions to water, all the water events at Workington. Corrective actions followed each event, and the exceedances "are not considered to have caused a significant negative impact" (page 120). Of the six air pollutants reported, only nitrogen oxides are measured directly; default values from SSVL are used for the other five (page 120).

Anticipated financial effects from pollution-related impacts, risks and opportunities

Reference: page 120 (index entry for paragraph 40 (b)).

The content index marks E2-6 "Phasing in" and lists the paragraph 40 (b) datapoint, operating and capital expenditure for major incidents and deposits, with a page reference (pages 107, 120). The report therefore gives the incident datapoint but no anticipated financial effects of the pollution risks and opportunities.

What is disclosed: "In 2025, 42 (46) environment-related incidents were reported to the supervisory authorities." All were addressed by corrective actions within the environmental management systems, and "There were no incidents that led to long-term consequences for the environment, production or human health". The incidents are "minor in nature and did not involve significant operational and capital expenditure" (page 120).

The E2 impact, risk and opportunity table (page 119) names two risks, changes in future emission conditions that may require investments and potential obligations at discontinued sites, without a financial estimate.

Transition plan on biodiversity and ecosystems

Reference: pages 121-122.

Forestry plan (page 121): Holmen owns 1.3 million hectares of land in Sweden, almost 1.2 million of it forest, and about half the wood its industry needs comes from its own forests. The objective is to keep the conditions in place for natural species to survive in the forest landscape, delivered through a nature conservation strategy that works from ecological landscape planning down to individual stands and trees. (page 122).

Resilience: "Holmen’s business model is judged to be resilient to risks related to biodiversity and ecosystems" (page 122). The analysis covers forestry, uses landscape plans, nature conservation assessments and risk assessments of wood purchasing, and applies the IPCC 2.7°C projection with the SMHI RCP 6 average and a 100-year rotation reference (page 122).

Sourcing: due diligence is to keep raw materials deforestation-free, in line with the EU Deforestation Regulation. Holmen does not buy wood from key habitats, protected areas, primary forests, High Conservation Value Forests, illegal harvests, genetically modified trees or areas where human rights are actively impeded (pages 122-123).

Hydro power: "Holmen has not assessed its resilience in this respect for this reporting period, as it is currently unclear what the outcome of the decisions will be" (page 122).

Policies related to biodiversity and ecosystems

Reference: page 122.

The environmental and energy policy states that forests must be managed responsibly in a way that ensures "the long-term survival of native plants and animals in the forest landscape", and that the impact of hydro power on biodiversity is to be taken into account. The President and CEO has overarching responsibility, delegated in writing. The policy covers the entire Group and is publicly available on Holmen’s website. It addresses societal impacts at an overarching level, and societal impacts linked to biodiversity are also addressed through legislation, permits and certifications (page 122).

Forest operations hold forestry and chain-of-custody certification, and all production facilities that use wood raw material hold chain-of-custody certification. Hydro power is governed by water-rights court rulings that set limits for water levels and rivers. Holmen also has internal guidelines and instructions on environmental considerations in managed forests, voluntary set-asides and management conservation, describing how biodiversity management, monitoring and reporting are carried out (page 122).

The content index lists the deforestation policy datapoint (paragraph 24 (d)) at page 122 and marks the sustainable land practices (24 (b)) and sustainable oceans and seas (24 (c)) datapoints "Not material" (page 107).

Actions and resources related to biodiversity and ecosystems

Reference: pages 122-123.

Holmen applies the mitigation hierarchy: avoid negative impacts, then minimize them, not least by creating or improving habitats. "Holmen does not currently apply biodiversity compensatory actions." It spends approximately SEK 200 million a year on forest management, booked in the income statement line Raw materials and consumables, and "No forward-looking key actions with associated major costs have therefore been identified" (page 122).

Four elements make up the conservation work (pages 122-123):

• Environmental considerations in managed forests: high stumps and dead wood left for wood-living insects and fungi, buffer zones along watercourses, biotopes and large trees left in place during harvesting.
• Management conservation: conservation burning, removal of invasive spruce to benefit broadleaves, wetland restoration; about 400 hectares a year.
• Voluntary set-asides: more than 9,000 areas identified as not to be harvested because of high conservation value, some left to develop freely and some managed.
• Hydro power: aquatic ecosystems protected by adapting water flows and protecting fish migration routes under water-rights court permits, with environmental impact assessments and inspection programs.

Targets related to biodiversity and ecosystems

Reference: page 123.

Forestry target: "Holmen’s target is for the Group’s forestry to foster biodiversity", meaning forestry run so that naturally occurring species can survive in the forest landscape in the long term. It covers all forest holdings. Progress is tracked with the five metrics reported under E4-5, drawn from the National Forest Inventory (page 123).

The report is open about the form of the target: "no target level or time horizons have been set", and no thresholds were set to evaluate the metrics. The targets follow the mitigation hierarchy, aiming first to avoid and minimize impacts through conservation measures in forestry, with rehabilitation and restoration where impacts are unavoidable. Holmen links the target to the EU Biodiversity Strategy and Forest Strategy, the UN Convention on Biological Diversity and SDG 15 (page 123).

Hydro power target: to increase generation of renewable energy on Holmen’s own land "with no negative impact on biodiversity", with the limits of acceptable impact set by each environmental permit (page 123).

Impact metrics related to biodiversity and ecosystems change

Reference: page 123 (paragraph 38 datapoint marked "Phasing in", page 107).

Holmen monitors five habitat metrics on its productive forest land, using National Forest Inventory data from SLU: area of old forest; area of old forest with specific indications of nature conservation value (SIN); dead wood volume per hectare; broadleaf volume per hectare; and large broadleaf volume per hectare. Values are five-year rolling averages, with 2022 the latest available average; 1996 is the first year with an available average (2005 for SIN) (page 123).

Starting point, current situation and change (page 123):

• Old forest, share of productive forest land: 4.6% to 6.4% (+39%).
• Old forest with SIN: 2.1% to 3.6% (+71%).
• Dead wood: 5.6 to 10.5 m3 growing stock, solid over bark per hectare (+87%).
• Broadleaves: 14.6 to 16.5 m3 per hectare (+14%).
• Large broadleaves (over 35 cm): 0.8 to 1.3 m3 per hectare (+74%).

Holmen concludes that "All the metrics have developed positively over the past thirty years". Old forest is defined as forest over 140 years old in northern Sweden and over 120 in southern Sweden. The metrics cover Holmen's forestry; no land-use change metrics under paragraph 38 are given, and that datapoint is flagged "Phasing in".

Policies related to resource use and circular economy

Reference: page 124.

Holmen’s environmental and energy policy covers resource use, chemicals, by-products and waste. It states that the Group's forests, processes and products are part of a natural ecocycle, and that "raw materials must be used efficiently, waste must be minimised, by-products must be dealt with and used for different purposes and that constant improvements must be sought" (page 124). Forestry is to produce high-volume, sustainable wood raw material, the origin of all wood must be traceable, and energy recovery is to be applied.

The report explains a scope limit: operations are based on fresh fibre from sustainably managed forests, so secondary resources are not material to the main raw material supply and "therefore not included in the Group’s environmental and energy policy" (page 124).

Actions and resources in relation to resource use and circular economy

Reference: page 124.

Holmen works with suppliers, customers and industry organizations on more resource-efficient material flows and products that promote recovery. Environmental management systems and improved production processes cut waste and downgrading of upstream materials; downstream, products with high recyclability and new uses for residual materials reduce waste through the value chain (page 124).

Completed in 2025: timber sorting and the planing mill at Iggesund Sawmill are running and raised productivity; key actions at Braviken Paper Mill produced a new packaging product. Sawing and drying at the sawmills are tuned to limit waste. Holmen works to the waste hierarchy to prevent waste and steer residual materials to reuse, recycling or energy recovery (page 124).

Looking ahead: Holmen "plans to continue investing in technical solutions and process improvements" but "has not initiated any specific new actions"; each material site works on resource efficiency within its environmental certification, and timeframes are set within annual business planning (page 124).

Targets related to resource use and circular economy

Reference: page 124 (the content index gives page 124).

Holmen states plainly: "Holmen has no specific measurable targets for resource use and circular economy, and instead manages this work based on the Group’s environmental and energy policy." The reason given is an integrated approach in which resource efficiency, waste minimization and circular principles are built into daily processes rather than set as stand-alone objectives. Permit requirements, internal KPIs and continuous environmental monitoring are said to give enough guidance (page 124).

Directional aims are stated: the wood products business is to grow through products for sustainable building, and the paperboard and paper business is to offer recyclable renewable products, with climate benefit reported under E1. Outcomes are measured continuously for each material site's waste, resource use and other environmental key figures, to spot trends, nonconformities and negative changes (page 124).

Resource inflows

Reference: pages 124-125.

Wood from sustainably managed forests is the largest material resource; harvesting from Holmen’s own forests covers about half the timber requirement, the rest is bought mainly from private forest owners in Sweden, and only a small proportion is imported. At the Workington mill in the UK about a quarter of the wood comes from state-owned forests. All wood purchasing is subject to chain-of-custody requirements, using FSC and PEFC. Chemicals are recycled and reused several times. 95 per cent of the energy inflow to production facilities is fossil-free (pages 124-125).

Metrics related to resource inflows, 2025 (2024): wood 5.8 (6.1) million m3sub; purchased pulp 73 (84) thousand tonnes; externally purchased seedlings 7 (20); chemicals 135 (131); filler and pigment 181 (199); packaging 31 (15). Total weight of material 5,666 (5,910) thousand tonnes, of which biological 5,319 (5,564) and technical 348 (346). Biological materials of sustainable origin: 5,238 (5,460) thousand tonnes. Secondary reused or recycled materials: 718 thousand tonnes, 13 per cent (798, 14 per cent). Water purchased or acquired: 67 (69) million m3, with total water consumption 1.7 million m3 (page 125).

Double counting is avoided by not reporting internal wood consumption (roundwood and chips from sawmills). Data is collected quarterly and annually from invoiced amounts and volumes (page 125).

Resource outflows

Reference: page 125.

Products: all of Holmen’s wood, paperboard and paper products can be reused or recycled, or used as bioenergy at end of life. Paperboard and paper made from fresh fibre support a recycled paper system that "must constantly receive injections of fresh fibre to function" (page 125). Deliveries in 2025 (2024): own forests 2,694 (2,643) thousand m3sub; wood products 1,295 (1,348) thousand m3; paperboard and paper 1,391 (1,424) thousand tonnes; hydro and wind power 1,634 (1,728) GWh (page 125).

Packaging: "88 per cent of the total packaging material purchased is judged to be recyclable", calculated from cost data as the sum of bio-based materials and plastics against total packaging purchased (page 125).

Energy outflows: Holmen has 21 wholly or partly owned hydro power plants and three wind farms of its own, with Blisterliden in full operation since the end of 2025 (page 125). Waste outflows are covered under the waste disclosure (E5-5 paragraphs 37 (d) and 39, page 125). Other than the statutory audit by the auditor, there has been no external review of the reported metrics (page 125).

Waste

Reference: pages 124-125 (waste table and datapoints at page 125; content index lists paragraphs 37 (d) non-recycled waste and 39 hazardous waste at page 125).

Waste streams: solid waste is mainly process waste, packaging, scrap metal and electronic waste, with process waste the largest volume: green liquor sludge, chemical sludge, lime mud and fly ash. A significant share is recycled as raw material in other industrial processes, such as construction material, or recovered as energy (page 125). By-products and waste that cannot be handled in Holmen’s own processes are sold to external partners; sediment fibre goes back into paperboard production and dewatered sludge from the mechanical pulp mills becomes fibre mulch used as a soil conditioner (page 105).

Hazardous waste is only a small proportion of the total: oil, paint, grease, solvents and electronics, handled by authorized recycling companies. "Holmen has no radioactive waste." Of the total material flow, "only 1 per cent becomes waste sent to landfill or destroyed, while 99 per cent goes for energy and material recovery" (page 125). A table splits waste by hazardous and non-hazardous type and by recovery and disposal route (page 125).

Method: data comes from production-unit waste reporting under Swedish Environmental Protection Agency regulations, measured at weighed weight and largely supplied by the waste contractor (page 125).

Policies related to own workforce

Reference: page 126.

Holmen’s stated ambition is "to have zero workplace accidents". The work environment policy sets out how injuries and illness are to be prevented, with employees and their representatives, a focus on risks and safe behaviors, safety equipment, procedures for all health and safety activities, reporting and analysis of accidents and incidents, and certified management systems at production sites (page 126).

The HR policy follows the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work and the OECD Guidelines. It states that all employees should have the same rights, obligations and opportunities irrespective of protected grounds for discrimination, and that Holmen is to work for a good relationship with trade unions. Each business area prepares an annual long-term talent management plan, and recruitment and promotion procedures must minimize the risk of discrimination (page 126).

Stated limit: "Holmen does not have any specific policy commitments relating to people from groups at particular risk of vulnerability in its own workforce." The CEO adopts policies; operational responsibility sits with the responsible owner in Group management (page 126).

The index lists the human rights policy commitment (paragraph 20), ILO conventions (21) and workplace accident prevention (23) datapoints at page 126 and marks trafficking (22) "Not material" (page 108).

Taking action on material impacts on own workforce

Reference: page 127.

Health and safety: all material sites and forest operations hold ISO 45001 certification. Committees and groups carry out preventive work, with processes for sick leave, rehabilitation and adjustment on return to work. A safety culture initiative, steered by the Work Environment Network and focused on the mills and sawmills, includes manager training at the sawmills in 2025 and an internal campaign at the mills; it has increased cooperation and information sharing between sites. Success is measured mainly in accident statistics, with health and safety questions to be added to the recurring employee surveys (page 127). "No action has been taken to enable remediation."

Talent: managed in each business area, with action plans based on each site's needs. No Group-wide key actions have been identified or taken. Holmen works on its employer brand with a consistent picture of the company and company ambassadors, and with other organizations in the sector. Success is measured in brand surveys, rankings and interest at events (page 127).

Diversity: the industry is mostly male and Holmen aims for a more even gender distribution, seeking candidates from the underrepresented sex and aiming for equal distribution in summer jobs, with action plans and annual pay surveys. "No specific time horizons have been set for the above actions" (page 127).

Targets related to own workforce

Reference: page 127.

The target is for Holmen’s employees "to develop and thrive". It is "measurable but not time-bound as it is a continuous endeavour" and was not formulated in consultation with stakeholders. Indicators: accident statistics (ambition of zero accidents), sickness absence, employee turnover, employee Net Promoter Score (eNPS), and diversity measured by staff numbers and age distribution (page 127).

Sickness absence (hours of absence as a share of scheduled hours): total 4.2% in 2025 (4.7% in 2024); long-term (over 15 days) 2.0% (2.4%).

Engagement: average eNPS was 13 in the reporting period (26 before) against a global benchmark of 15. Holmen links the fall to a survey sent during an ongoing reorganization involving many employees. "At this stage, no lessons have been identified regarding the drop in the eNPS score for the target. As of the end of the reporting period, action plans are still in development" (page 127).

Characteristics of the undertaking's employees

Reference: pages 127-128; Note 4 on page 73 for personnel costs.

Holmen had 3,851 employees in 2025, 24.2 per cent of them women; the report prints 3,868 as the earlier figure in its text and 3,874 in its tables. Tables use the average number of employees in the period (page 127).

By gender (2025, 2024): female 933 (930), male 2,918 (2,944). By country: Sweden 3,295 (3,341), UK 412 (386), Netherlands 63 (67), other countries 81 (80). Permanent employees were 3,592 and temporary 259 in 2025, with the split by gender and by full-time and part-time work in the table on page 128.

Turnover: 7.9 per cent in 2025 (6.9 per cent in 2024), with 282 employees leaving (249), calculated on the average number of permanent employees (page 128).

Personnel costs and FTE-based employee numbers are in Note 4 of the financial statements (page 73), which the report incorporates by reference (page 109).

Diversity metrics

Reference: page 128; Note 4 on page 74 for gender distribution at top management level.

Gender: 933 women and 2,918 men among 3,851 employees; women are 24.2 per cent (24.0 per cent in 2024) (page 127). "Information on the gender distribution at top management level is shown in Note 4 on page 74" (page 128), which the report incorporates by reference (page 109).

Age distribution of employees (average permanent employees), 2025 (2024): under 30, 433 (463); 30-50, 1,817 (1,812); over 50, 1,342 (1,351) (page 128).

Diversity is also a tracked indicator under the S1-5 target, measured through staff numbers and age distribution (page 127), and the S1 table records that the industry is "overwhelmingly male" and that diversity is important for running a profitable business (page 126).

Training and skills development metrics

Reference: page 128.

Employee development happens at all levels to meet current and future skills needs. Many employees complete regular compulsory training to maintain skills in specific areas, and training in business conduct follows the Code of Conduct. Holmen offers Group-wide leadership programs and programs for new and experienced managers and specialists, and "Each manager must hold annual appraisal talks with their employees" (page 128).

Health and safety training: new employees at material sites are trained in health and safety, employees complete regular online training based on site risks, and contractors are trained before access is granted (page 128).

Average training hours recorded in the period: 8.7 (6.8 before) for women and 11.4 (15.2) for men (page 128).

Health and safety metrics

Reference: page 128 (fatalities, accident and days-lost datapoints, paragraph 88, also at page 128).

All Holmen employees are covered by statutory health and safety requirements, and 71 (73) per cent are covered by a health and safety management system audited and certified by an external party (page 128).

Work-related accidents recorded in 2025 (2024): 34 (38), of which 20 (20) were severe. Of the total, 27 (31) involved employees in Holmen’s own workforce. Accident frequency for the own workforce was 4.7 (5.3) accidents per million hours worked. Days lost to work-related injuries totaled 260 (1,217). Fatalities: 0 (0). The most common accidents were slips, trips and crush injuries. Holmen counts an accident causing more than seven days of sickness absence as severe (page 128).

Holmen includes an accident-rate measure in its short-term incentive program for key individuals (10 per cent of the criteria, page 99). The report names overhead cranes and vehicles with people in movement as the main areas of risk (page 126).

Policies related to value chain workers

Reference: page 129 (S2 SBM-3 on page 128).

Holmen’s policy base is the Supplier Code of Conduct, "based on the UN’s Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work and the OECD Guidelines". It covers business conduct, human rights and labor conditions, environment and climate, and due diligence in suppliers' own operations; it bans child labor, forced labor and human trafficking and requires working conditions and pay in line with legislation or agreements. Compliance is a contractual condition, with a right to terminate, and the Code is included in new supplier contracts and in forestry contractor agreements (page 129).

The forest operations management system has a procurement process for forestry services. Forestry contractors must comply with Swedish law, apply collective agreements and be certified for sustainable forestry. Social checks by on-site visits on a sample basis: for contractors with foreign or temporary resident labor, at first hire and at least every three years for recurring contracts; for others, when abuse is suspected. Where a negative human rights impact is found, a remedial action plan is drawn up with the contractor. The head of the business area is ultimately responsible. "The policies were not formulated in consultation with stakeholders" (page 129).

Taking action on material impacts on value chain workers

Reference: page 129.

The report is direct about scope: "Holmen has not formulated any Group-wide actions." Local actions are in place in forestry operations through the management systems, mainly regular site visits. In 2024 Holmen reviewed its procurement process to make sure its own business practices do not cause negative impacts on value chain workers; see G1-2 on page 131. "No other resources beyond day-to-day management have been added" (page 129).

Context from SBM-3 (pages 128-129): the material impact concerns forestry suppliers. Forestry relies on contracted harvesting and silviculture, with a high proportion of migrant and seasonal labor, and silviculture employs around 1,000 seasonal workers each year. The index lists the datapoint on human rights issues and incidents in the upstream and downstream value chain (paragraph 36) at page 129. The S2-5 section reports no suspected breaches of the Supplier Code of Conduct at site visits and no reports of disregard for the UN Guiding Principles (page 129).

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

Reference: page 129.

Holmen’s target is to build long-term relationships based on responsible business conduct, and to ensure suppliers provide a safe, healthy work environment and good working conditions. The report states that "Holmen’s target for value chain workers is neither time-bound nor measurable" and that it was not formulated in consultation with stakeholders (page 129).

Monitoring runs through the management system for forestry operations, with social controls, including site visits during ongoing contracts and surveys of workers on site. Results for the period: no suspected breaches of the Supplier Code of Conduct were noted during site visits; no contractual employees reported irregularities through Holmen’s channels; no lessons led to process changes; and no reports came in of disregard for the UN Guiding Principles, the ILO Declaration or the OECD Guidelines covering value chain workers (page 129).

Policies related to affected communities

Reference: page 130 (S3 SBM-3 on page 130).

The Code of Conduct sets out how Holmen should promote responsible business conduct and long-term relationships with forest owners, local residents and local businesses. The environmental and energy policy requires operations in line with the precautionary principle, environmental impact acceptable to people and nature, and the environment taking precedence over production during disruptions. Holmen takes reindeer husbandry into account through dialogue with Sami reindeer herding associations as laid down by law, and has steering documents on consultation meetings and communication with them. Joint planning of silviculture must be conducted in good faith, with reindeer grazing and cultural sites such as carved trees taken into account (page 130).

Holmen says it must support and respect internationally recognized human rights, including the UN Convention on the Rights of the Child. The policy covers the whole operation and the communities where Holmen operates, and the CEO adopts policies. "The policies were not formulated in consultation with stakeholders" (page 130).

Taking action on material impacts on affected communities

Reference: page 130.

"No Group-wide actions have been taken", and impacts on local residents are largely linked to operations that need permits. Nonconformities in those operations are handled through each site's self-inspection program. The work is continuous, so there is no time horizon for completion (page 130).

Reindeer husbandry: in 2024 Holmen reviewed and developed its joint planning processes and found the necessary steps were included. In 2025 it deepened work on coexistence on forest land, appointing liaison officers and expanding the web-based information system for joint planning, with effectiveness to be evaluated through contact with the association concerned. For wind power, fences and feeding stations are built for the reindeer, and in some cases turbines may have to be shut down temporarily (page 130).

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

Reference: page 130.

Holmen’s target, based on responsible business conduct, is to build long-term relationships and to develop operations within the framework of environmental permits and certifications. The target "was not formulated in consultation with stakeholders" (page 130).

Holmen explains why there is no measurable, time-bound metric: it is difficult to measure the effectiveness of the activities linked to contact with affected communities. Instead, the effectiveness of the policy is judged by compliance with the permit limits for noise and for pollutants to air, water and soil, and "Improvements are always made if authorised limits are exceeded" (page 130).

Business conduct policies and corporate culture

Reference: page 131.

The Code of Conduct and the business ethics policy lay the foundation for responsible business conduct, both based on the ten principles of the UN Global Compact, the ILO core conventions and the OECD Guidelines. The Code covers business conduct, information management, human rights, workers' rights and the environment. The purchasing policy sets standards for objective, competitive purchasing and for managing risks of negative impact and corruption in the supply chain (page 131).

Training: recurring Code of Conduct training for all employees, mandatory for new employees at induction, plus themed training for roles with greater corruption and bribery risk. In 2025 thematic sessions on corruption and conflict of interest ran for risk-exposed departments, with managers trained to run dilemma workshops (page 131). Corporate culture is described in "The Holmen Way", built on the values of courage, commitment and responsibility.

Whistleblowing: a function under the Swedish Whistleblowing Act, open through the intranet and the external website to employees and other stakeholders, anonymously or openly, run by an external service for case management and data protection. No one may prevent or attempt to prevent reporting, the investigator must not disclose the reporter's identity without authority, and Holmen may not retaliate. Cases go to an independent reviewing function (page 131).

Targets related to business conduct

Back-filled from the business conduct chapter, where the target is presented inside the G1-4 section as an MDR-T disclosure ("G1-4 / MDR-T", page 132). G1-3 became a standalone DR only in the 2025/2026 ESRS; this report was prepared under the earlier numbering, where G1-3 is Prevention and detection of corruption and bribery.

Reference: page 132.

Holmen states a target: "Holmen’s target is to build long-term relationships based on responsible business conduct." It is measured by the annual number of incidents of corruption and bribery. Holmen explains that no time-bound or outcome-oriented level can be set because the ambition is that no cases occur, and that responsible conduct in decision-making and operations "requires continuous work". Through EcoVadis, preventive work is done with suppliers to secure compliance with the purchasing policy and Code of Conduct. "The target was not formulated in consultation with stakeholders" (page 132).

Result: "No cases of corruption or bribery were identified during the reporting period" (page 132).

Incidents of corruption or bribery

Reference: page 132 (datapoints on fines, paragraph 24 (a), and anti-corruption standards, 24 (b), also at page 132).

"No cases of corruption or bribery were identified during the reporting period. Holmen has not been convicted of or fined for breaking the law regarding corruption or bribery" (page 132). The GOV-4 statement adds that Holmen has not been subject to any final convictions for breaches of competition law or corruption offenses in 2025 (page 99).

The annual report's risk section adds that no corruption-related adverse judgments were delivered against Holmen or its employees, none are pending in court, and seven cases were reported through the whistleblowing service in 2025, none of them identified as corruption or bribery (page 51). Preventive work with suppliers runs through EcoVadis (page 132). The incidents metric also serves as the measure for the business conduct target (see G1-3-Targets).

Political influence and lobbying activities

Reference: page 132.

Holmen takes part in dialogue, consultation responses, preparedness work and lobbying, on its own and with industry organizations, and is a member of national and international industry bodies including the Confederation of European Paper Industries (Cepi), the Swedish Forest Industries Federation, the Confederation of Swedish Enterprise, the Swedish Association of Industrial Employers and SKGS (page 132). "Holmen does not engage in party politics and does not support political parties, candidates or their representatives financially." During the period no new Board or management member who had held a senior position with a public agency in the past two years was appointed (page 132).

The Senior Vice President Sustainability and Communications bears overarching responsibility for lobbying work. Holmen has been listed on the EU Transparency Register since 2025 (page 132).

Topics lobbied on in 2025: the climate benefits of the forest industry and biodiversity; LULUCF, the EU Deforestation Regulation, the EU Nature Restoration Regulation and the Swedish Species Protection Ordinance; permit processes for wind and hydro power; and the EU Emissions Trading System (page 132).