Huhtamaki Oyj

The role of the administrative, management and supervisory bodies

Reference: pages 44-46.

The Board of Directors is "the governance body with the highest decision-making authority in the entire Group" and has three committees: the Audit Committee, the Human Resources Committee and the Investment Committee (page 44). The Board "oversees sustainability-related activities in the Group", approves the sustainability targets and guiding policies, and approves the Sustainability Statement as part of the Directors' Report (pages 44-45).

Composition (pages 44-45): nine members of seven nationalities were elected at the 2025 AGM; five are female (56%) and four male (44%). All are non-executive and considered independent, and employees are not represented on the Board.

Management (page 45): the Global Executive Team (GET) supervises that material Group policies are followed. The Interim SVP, Sustainability, Corporate Affairs and Legal reports to the CEO, leads the Group Sustainability Center of Expertise and chairs the Sustainability Leadership Team. The Board, Audit Committee and GET receive sustainability reports quarterly.

Business conduct (page 46): an ethics and compliance review goes to the Audit Committee at least twice a year.

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

Reference: pages 45-46.

"Regular updates on the progress of Huhtamaki's sustainability ambitions are given to the Board throughout the year" (page 46). With each quarterly result update the Board receives a sustainability dashboard tracking six topics: use of renewable, recycled or certified materials, use of renewable electricity, greenhouse gas emissions, waste treatment, health and safety, and solvent consumption. The company says the dashboard "will be developed to align with the renewed sustainability ambition developed over the course of 2025".

The Human Resources Committee validates the Global Sustainability and Safety Index (GSSI) targets each year (page 45) and receives quarterly updates on safety performance and attrition (page 46). A summary report on risks and opportunities goes to the Audit Committee and the Board once a year (page 46). The Audit Committee monitors sustainability target progress and the assurance of the statutory sustainability reporting (page 45).

Integration of sustainability-related performance in incentive schemes

Reference: page 47.

"There are no incentive schemes in place for the Board." The incentive model for the President and CEO includes the Global Sustainability and Safety Index (GSSI). For 2025 it had eight metrics: renewable or recycled material use, certified or recycled fiber use, renewable electricity consumption, non-hazardous waste recycled, waste to landfill, water intensity, solvent consumption, and total recordable injury frequency rate.

"The sustainability-related performance formed 10% of the overall variable remuneration criteria for the President and CEO during 2025." The Human Resources Committee deliberated the GSSI model and targets and the Board approved them.

On climate: "Climate targets and greenhouse gas (GHG) emission reductions were not directly considered in the GSSI for 2025 but were partially captured through the target of renewable electricity consumption." A new ESG criterion for the CEO, Huhtamaki leadership and broader personnel, with a specific GHG emissions target, applies from 2026.

Statement on due diligence

Reference: page 47.

Huhtamaki gives a mapping table (Table 1) of where the Sustainability Statement covers the five core elements of due diligence:

• Embedding due diligence in governance, strategy and business model: General information, and Environmental, Social and Governance information
• Engaging with affected stakeholders in all key steps: General information
• Identifying and assessing adverse impacts on people and the environment: General information
• Taking action to address adverse impacts: Environmental and Social information
• Tracking the effectiveness of these efforts: Environmental and Social information

The table points to sections of the statement by name and gives no page numbers.

Risk management and internal controls over sustainability reporting

Reference: page 48.

The Group's risk management "follows the principles of the Enterprise Risk Management (ERM) framework of the Treadway Commission (COSO), and ISO 31000 Risk Management Standard", tailored by Huhtamaki. The Group Sustainability Center of Expertise prepares the reporting and maintains a non-financial reporting handbook with definitions, procedures and frequency.

The reporting risks identified are "inaccurate, incomplete, or misleading reporting". A control catalogue defines how sustainability information is collected, processed and reported, with segregation of duties and required approvals, and "Regular control testing is conducted as part of the governance framework". The Audit Committee "monitors and assesses the effectiveness and efficiency of the Company's internal control" and the statement is subject to external assurance.

Strategy, business model and value chain

Reference: pages 48-50.

Huhtamaki's strategic ambition is "to be the first choice in sustainable packaging solutions" (page 48). Its product groups are paperboard conversion packaging for food and drink, molded fiber packaging, flexible packaging (including mono-material blueloop solutions, labels, tube laminates and cylinders) and plastic-forming packaging (page 49). Customers include food, beverage and petfood companies, quick service restaurants, foodservice operators and retailers, plus home and personal care, industrial, FMCG and healthcare customers.

The Group operates in 35 countries with 71 sites in 106 locations and employs 17,390 people: Europe 6,267, Asia-Pacific 4,671, Americas 4,743, Middle East and Africa 1,709 (page 49). Its four segments are Foodservice Packaging, Fiber Packaging, Flexible Packaging and North America (page 42).

Value chain: "operations are dependent on natural resources as raw material", sourced from a large number of suppliers; Figure 1 on page 50 shows the value chain. The content index records SBM-1 40(b) and 40(c) as omitted because ESRS sectors are not defined by the European Commission (page 105).

Interests and views of stakeholders

Reference: pages 51-53.

Huhtamaki sees "customers, employees, suppliers, and policy makers" as its key stakeholders and also engages shareholders and investors, consumers, industry associations and trade unions, non-governmental organizations and communities near its manufacturing units (pages 51-53). A table (pages 52-53) sets out each group's main interests and form of dialogue. Examples: the Voice of Customer satisfaction survey and customer sustainability questionnaires; for employees, the Connect engagement survey, townhall meetings, the Speak Up whistleblowing channel, the European Works Council and Health and Safety Committees; for suppliers, an ESG due diligence tool and supplier screenings.

The company says "the views of stakeholders are a key input to the strategic planning process" and that engagement results "have been reported to the Board as part of these discussions" (page 51). Its own workforce "is a key group of affected stakeholders", and workforce findings and the commitment to align human rights due diligence with the UN Guiding Principles inform people priorities and targets (page 51).

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

Reference: pages 53-56.

The 2025 double materiality assessment update leaves material IROs in four topical standards (pages 54-55):

• E1 Climate change: negative impacts from Scope 1 and 2 emissions and from Scope 3 emissions in sourcing and end-of-life; a negative impact from energy use; a risk from carbon pricing (EU and UK ETS, sustainability-linked bonds)
• E5 Resource use and circular economy: negative impacts from raw material use and waste generation; a regulatory risk (for example extended producer responsibility costs); positive impacts from waste reduction and food waste reduction; an opportunity in circular business models
• S1 Own workforce: a health and safety impact and risk; a risk from a shortage of skilled workforce
• G1 Business conduct: positive impacts from ethical business conduct and corporate culture, and from whistle-blower protection

"No current financial effects arising from the risks and opportunities were identified during the reporting period" (page 56). The content index marks SBM-3 48(e) as omitted due to phased-in optionality (page 105). E3, E4, S2 and S4 were reassessed as not material in 2025 (page 43).

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

Reference: pages 56-60.

In 2025 Huhtamaki "completed an update of the double materiality assessment (DMA)" (page 56). The steps were: describe and validate the value chain for the four segments; collect stakeholder input (an internal survey sent to a representative from every manufacturing site, plus interviews with selected customers from all segments, one supplier and three NGOs representing "silent stakeholders"); then two workshops, one on impact materiality and one on financial materiality, with Global Risk Management advising on financial materiality (pages 56-57). The GET approved the final list and the Audit Committee then reviewed the results (pages 57, 60).

Scoring (page 60): impact weighted by likelihood; "the most severe and significant impacts on a scale of 1–5 start at a value of 4 (80% or higher), while material risks and opportunities start at a value of 3 (60% or higher)". Horizons: short-term within the fiscal year, medium-term 2-5 years, long-term beyond five years.

Climate scenario analysis is described on pages 57-58. Pollution, water and biodiversity IROs were assessed without consulting affected communities, while for E5 communities were consulted by proxy through NGO interviews (pages 58-59).

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

Reference: pages 105-107 (content index); pages 108-113 (datapoints from other EU legislation).

The appendix "Disclosure requirements in ESRS covered by Huhtamaki's sustainability statement" (page 105) is a content index with page numbers for ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2) and the topical standards E1, E5, S1 and G1. Requirements not covered carry a marker instead of a page: E1-9, E5-6, S1-7, S1-11, S1-13 and S1-15 are "Phased-in requirement"; E1-7 is "Not applicable"; S1-8 to S1-10, S1-12, S1-16, S1-17 and G1-2 to G1-6 are "Not material" (pages 105-107).

The index adds that SBM-1 40(b) and 40(c) are "omitted due to ESRS sectors not defined by the European Commission" and SBM-3 48(e) is "omitted due to phased-in optionality" (page 105). A second table (pages 108-113) lists datapoints derived from other EU legislation, each with a page number or a "Not material" or "Phased-in" marker. E2, E3, E4, S2, S3 and S4 do not appear in the index. Page 43 names E3, E4, S2 and S4 as topics reassessed as not material in 2025.

Transition plan for climate change mitigation

Reference: pages 67-68.

Huhtamaki "has a transition plan to mitigate climate change, which is integrated into its overall business strategy and financial planning" (page 67); GSSI indicators on renewable electricity and renewable or recycled materials link it to the CEO incentive plan.

Targets (page 67): absolute Scope 1 and 2 emissions down 50.44% by 2030 from a 2022 base year, compatible with 1.5°C, and absolute Scope 3 emissions from six categories down 25.0%; both approved by SBTi in 2025. Long-term net-zero targets are still to be set, and a "comprehensive transition plan" for them is in development.

Levers (pages 67-68): Scope 1 and 2 are energy efficiency, fuel switching, electrification, renewable electricity and clean technology; Scope 3 are supplier engagement, more renewable and recycled content, and recycling systems.

Funding (page 67): "Huhtamaki does not currently have significant operational or capital expenditures allocated for the implementation of the defined climate-related actions or transition plan"; resources are reserved in annual budgets and three-year plans.

Approval and locked-in emissions (page 68): the Board and GET approved the plan in 2025. Scope 1 includes assets "primarily using natural gas", and these locked-in emissions "do not jeopardize Huhtamaki's near-term emission reduction targets".

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 climate resilience section, where this content is disclosed in the FY2025 report (pages 57-58, 69-70). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 57-58, 69-70.

Huhtamaki identified climate hazards (floods, storms, heat, drought) and transition risks and opportunities over short-, medium- and long-term horizons, and screened whether its assets and activities are exposed (page 57).

Scenarios used (pages 57-58):

• Physical risk: IPCC SSP1-2.6 (limiting warming to 1.5°C) and SSP5-8.5 (warming up to 4°C, the high-emission case)
• Transition risk: IEA Net Zero Emissions by 2050, with the IEA Stated Policies Scenario (STEPS) added in 2025

The company says "final results from the new scenario analysis were not yet available during the DMA update" (page 57). Page 57 says the 2025 update used site-specific physical risk evaluations with geospatial data, while page 58 says geospatial coordinates for Huhtamaki's locations "have not been considered". Outcome: physical risks are "not considered as material"; carbon pricing is a material transition risk (page 70).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 / IRO-1 and the E1 climate resilience analysis, where this content is disclosed in the FY2025 report (pages 69-70). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 69-70.

Huhtamaki "has assessed the resilience of its strategy and business model through a climate resilience analysis carried out alongside the climate scenario analysis" (page 69), covering own operations and the upstream and downstream value chain and all material physical and transition risks.

Findings (page 70): physical risks "are expected to remain moderate" given global diversification, and transition risks "are expected to gradually increase in the short, medium and long term". Physical impacts are assumed to evolve over a longer horizon, "providing sufficient opportunity to adapt and, if necessary, redeploy, repurpose, or decommission existing assets".

Uncertainty (page 70): pace of technological development, market and regulatory change, and evolving consumer preferences; constraints include limited resources for large-scale renewable energy, high upfront capital and retrofit challenges.

Capacity: "The Group has sufficient access to funding to ensure adequate financial resources under all foreseeable circumstances" (page 70).

Policies related to climate change mitigation and adaptation

Reference: page 71.

The Group Environmental Policy addresses the management of Huhtamaki's material climate IROs across operations and the value chain. It commits the Group to cut GHG emissions in line with science-based targets, improve energy efficiency and raise the share of renewable energy, and it "encompasses climate change adaptation, requiring ongoing assessment of short-, medium-, and long-term physical climate risks and transition risks". The GET approves it; it applies to all Huhtamaki entities globally and to external workforce under Huhtamaki's direction on its premises, and it is published on the company website.

The Code of Conduct for Huhtamaki Suppliers sets climate expectations for suppliers: comply with environmental laws, make efforts to reduce environmental impacts including energy use and GHG emissions, and not source materials that contribute to deforestation of high conservation value areas.

Actions and resources in relation to climate change policies

Reference: pages 71-72.

2025, own operations (Scope 1 and 2):

• Renewable electricity: a larger share across sites, with an estimated reduction of 3,000 tCO2e against the previous year
• Energy efficiency: outdated chillers replaced with high-efficiency models at two locations and heat recovery upgraded at another
• Fuel switching and electrification: assessed and explored, but "still in the evaluation phase" and "still in the exploratory phase", with no measurable reductions yet

Scope 3: with customers, mechanically recycled plastics rose by over 2,000 tonnes and chemically recycled materials by 500 tonnes; collaboration on recycling and composting systems continued (page 71).

Planned (page 72): a group captive special purpose vehicle (SPV) project for a site in India, with generation expected to begin in the first half of 2026, plus continued work on fuel switching, electrification, recycled content and supplier engagement. The Scope 3 lever contributions "have not yet been assessed".

Resources (page 72): "Huhtamaki does not currently have significant operational or capital expenditures allocated"; smaller financial resources and dedicated personnel at Group, segment and site level support delivery.

Targets related to climate change mitigation and adaptation

Reference: pages 73-74.

Two science-based near-term targets, approved by SBTi in 2025, from a 2022 base year (page 73):

The 2030 target values are 335,375 tCO2eq (Scope 1 and 2) and 1,738,189 tCO2eq (Scope 3). The Scope 1 and 2 target covers 99% and the Scope 3 target 68% of base-year emissions; the Scope 3 boundary is categories 1, 3, 4, 5, 6 and 7. The GET reviewed the targets and the Board approved them; "External stakeholder groups were not involved in the target setting process". Huhtamaki "does not have separate targets related to climate change adaptation". A comprehensive transition plan for the Scope 3 target is scheduled for 2026 (page 74).

Energy consumption and mix

Reference: pages 74-76.

Total energy consumption was 2,288,225 MWh in 2025 (2024 restated: 2,245,775). Fossil sources were 69.1% (1,580,494 MWh) and renewable sources 30.9% (707,731 MWh). Fossil: natural gas 1,032,432 MWh; crude oil and petroleum products 92,371 MWh; purchased fossil-based electricity, heat, steam and cooling 455,691 MWh; coal and nuclear zero. Renewable: purchased renewable electricity, heat, steam and cooling 699,429 MWh; fuel from renewable sources including biomass 8,208 MWh; self-generated renewable electricity 93 MWh.

Energy intensity was 577.2 MWh per EUR million of net revenue (2024 restated: 541.8), using revenue of EUR 3,964.5 million for NACE C17 and C22 (page 76).

The scope is all manufacturing units. Separate collection of nuclear and self-generated electricity data began in July 2024 (page 75). The company states "The measurement of the metrics presented in the E1 section is not validated by an external body" (page 75).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 76-82.

Gross emissions in tCO2eq (pages 76-77):

Total location-based emissions were 3,857,782 tCO2eq. Scope 1 emissions from sites in emissions trading schemes were 30.1% of the total (EU ETS and UK ETS, page 80). Intensity: 918.6 tCO2eq per EUR million market-based and 973.1 location-based (page 81). Biogenic CO2 outside Scope 1 was 2,873 tCO2eq (page 81).

Method (pages 77-80): GHG Protocol; of 15 Scope 3 categories, 11 are significant. "Zero percent of emissions are calculated using primary GHG emission data obtained from suppliers or other value chain partners", and in 2025 38% of Scope 3 emissions used estimated activity data (pages 78, 80). Zellwin Farms was added retrospectively.

Internal carbon pricing

Reference: page 82.

"Huhtamaki does not apply internal carbon pricing schemes." (page 82). The content index lists E1-8 with a reference to page 82 (page 106), so this is a nil return, not an omission.

Carbon pricing still features in the climate IROs: Huhtamaki's GHG emissions "impact finances via increased carbon pricing, such as the EU and UK Emissions Trading Systems (ETS)", and increased carbon pricing "is considered a material climate-related transition risk" (page 69). In 2025, 30.1% of Scope 1 emissions came from sites covered by emissions trading schemes (page 76).

Policies related to resource use and circular economy

Reference: pages 83-84.

Huhtamaki manages its material resource use and circular economy IROs through the Group Environmental Policy, the Code of Conduct for Huhtamaki Suppliers and the "Design principles for circularity in our products" guideline (page 83). Commitments include designing for circularity, minimizing waste in own production, maximizing recycling of production waste, and working with customers and stakeholders on waste management solutions that raise actual recycling and composting rates. The supplier code requires suppliers to reduce environmental impacts and safeguard natural resources, with a focus on raw materials and waste management.

The design principles follow RecyClass guidelines for plastic packaging and 4evergreen guidelines for fiber-based packaging, and are approved by the GET (page 84). Huhtamaki applies the waste hierarchy, "with the primary focus being on waste prevention as the first option", and is "committed to zero deforestation and conversion in its virgin fiber supply chain", sourcing fiber that is FSC, PEFC or SFI certified or recycled (page 84).

Actions and resources related to resource use and circular economy

Reference: pages 84-85.

Product design and sourcing (pages 84-85): renewable or recycled material use reached 67.9% (2024: 65.4%); new mono-material recyclable flexible packaging, including for sensitive formats such as hair color, pet food and instant food; recyclable paper cups and lids with less than 10% plastic content; certified virgin fiber (FSC, PEFC, SFI) and ASI-certified aluminum.

Own operations (page 85): a World Class Operations program across all sites with annual waste reduction targets per site, and local partnerships with waste operators. "Forty sites have achieved zero waste to landfill".

End-of-life (page 85): collaboration on recycling and composting, including The Cup Collective, the Sporting Kansas City partnership (59% of food and packaging waste diverted from landfill in the 2025 season) and a closed-loop cup recycling system at Slush; continued compliance with Extended Producer Responsibility rules.

Resources: "Huhtamaki does not currently have significant operational or capital expenditures allocated"; financial resources are reserved in annual budgets and three-year plans. Huhtamaki "has not yet identified the specific individuals or groups who are actually harmed by its material impacts", so it reports no remedy actions (page 85).

Targets related to resource use and circular economy

Reference: pages 86-87.

Four voluntary targets, all due in 2030 from a 2020 base year (page 86):

The recyclable-design share fell because of "the adverse change in sales mix" (page 87). The targets are "not based on legislation but are voluntarily set by Huhtamaki", and "it cannot be concluded whether these are based on scientific evidence" (page 86). The Board approved them; external stakeholders were not involved. The company intends to "refresh and update" its resource use and circular economy metrics and targets during 2026 (page 87).

Resource inflows

Reference: page 88.

Table 8, built from purchase data in site ERP systems that "reflect actual invoiced figures":

The total covers "production and maintenance chemicals, fiber materials, plastics, metals, and packaging materials". Sustainably sourced means virgin fiber from managed forests certified by FSC, PEFC, SFI or comparable schemes; recycled fiber includes post-consumer and post-industrial paper. For packaging materials only the PEFC-certified share is counted, to avoid double counting. The company says "The measurement of the metrics is not validated by an external body".

Resource outflows

Reference: pages 86-89.

Resource outflows are reported mainly through waste (Table 9, page 89). In 2025 Huhtamaki generated 214,210 tonnes of waste, of which 35,338 tonnes (16.5%) was non-recycled, down from 39,700 tonnes (19.2%) in 2024; hazardous waste generated was 16,693 tonnes. Waste covers process waste (paperboard, plastic, aluminum, wood, cardboard) and maintenance waste (chemicals, used oil, machine parts, e-waste). The full breakdown is under the Waste entry.

Products: 70.1% of revenue in 2025 came from products designed to be recyclable, compostable or reusable (2024: 72.0%), against a 100% target for 2030; the share is calculated on revenue (pages 86-87). "The expected durability of products is not reported, as this data is not material for Huhtamaki's packaging solutions" (page 89).

Limitation: new waste streams from raw materials such as bio-based plastics "are not consistently reported as part of the total waste volumes at some operational sites" (page 89).

Waste

Reference: page 89 (Table 9 and reporting principles).

Waste in tonnes:

Diverted waste went to recycling (hazardous 11,790 t; non-hazardous 164,614 t) and preparation for reuse (21 t; 2,447 t). Waste directed to disposal went to incineration (hazardous 4,659 t; non-hazardous 20,635 t) and landfill (223 t; 9,820 t). The share of non-recycled waste was 16.5% (2024: 19.2%).

Volumes are based on actual measurements from invoices, weighbridge slips and the waste management system. The company states "The measurement of the metrics is not validated by an external body".

Policies related to own workforce

Reference: pages 91-92.

A table (page 91) lists the Group documents that manage own-workforce impacts, with scope and accountable body (the GET for most): the Group Human Rights Policy, Code of Conduct, Huhtamaki Working Conditions Requirements, Code of Conduct for Huhtamaki Suppliers, Group Speak Up and Investigations Policy, Global Employment Guidelines, Group Occupational Health and Safety (OHS) Policy Statement, Global Health and Safety Working Conditions Overview, Recruitment Policy and Guidelines and Group Diversity, Equity and Inclusion Guiding Principles.

Human rights (pages 91-92): the Human Rights Policy supports the International Bill of Human Rights and the ILO Declaration, commits to improving due diligence in line with the UN Guiding Principles and the OECD Guidelines, and prohibits discrimination and trafficked, forced and child labor.

Safety (page 92): the health and safety management systems cover all activities, the own workforce, contractors and visitors, and are "constructed based on ISO 45001 standards". Every employee takes mandatory annual Code of Conduct training (page 91).

Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions

Reference: pages 94-95.

Safety (pages 94-95): site and job-specific health and safety training at induction; contractor inductions; the multi-year Safety Pillar program of seven steps, where by the end of 2025 "all Huhtamaki locations have been trained on Step 1 and Step 2" and most manufacturing sites on Step 3; monthly risk reviews; occupational health risk assessments for all activities; hazardous material standards and control processes for chemical safety; locally contracted occupational health services.

Skilled workforce (page 95): retention drivers identified locally, an exit questionnaire, voluntary turnover set as a Group target, the Strategic Leadership Program, Global Week(s) of Learning, a global Employer Brand and Career Hub tool, a 360 feedback pilot and a new onboarding process. Training effectiveness is followed through employee feedback and performance reviews.

Resources (page 94): "Huhtamaki does not currently have significant operational or capital expenditures allocated for the implementation of the defined own workforce related actions".

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

Reference: pages 95-96.

Annual targets for own employees globally (Table 10, page 95):

The 2024 injury rates were restated for one lost time injury that occurred in 2024 and was reported in 2025 (page 96). The HR leadership team kept the same targets as the previous year. "Huhtamaki's own employees or their representatives are not directly involved in the Group level target setting process" (page 96). The indices are benchmarked against Willis Towers Watson data and turnover against Mercer's Annual Movement data.

Characteristics of the undertaking's employees

Reference: pages 97-99; employee numbers by area on page 49.

Huhtamaki employs 17,390 employees: Europe 6,267, Asia-Pacific 4,671, Americas 4,743, Middle East and Africa 1,709 (page 49). Tables 11 to 14 (pages 97-98) break headcount down by gender, by country for "countries with at least 50 employees representing at least 10% of its total number of employees", and by contract type by gender and by region; see the report for those table values.

Turnover (page 99): 2,719 employees left in 2025 (2024: 2,886), a turnover rate of 16.0% (2024: 17.1%).

Method (page 99): headcount comes from the HRIS at 31 December 2025 and includes inactive employees on long-term leave; temporary employees include fixed-term employees, apprentices and interns; the turnover rate divides all termination events by the average number of own employees. Limitation (page 100): "fluctuations in headcount numbers during the reporting period are not reflected in the reported numbers".

Health and safety metrics

Reference: pages 99-100.

Coverage counts people at sites certified to a recognized standard: "ISO 45001 certified systems for all reporting sites except for one site in Germany where management system is OHRIS certified" (page 100). Rates are per million hours worked, and contractor hours are excluded "Due to limitations in tracking contractor working hours". The index records non-employee datapoints, recordable ill health cases and days lost to ill health as omitted due to phased-in optionality (page 106).

Business conduct policies and corporate culture

Reference: pages 101-104; role of the Board on page 46.

The Code of Conduct, approved by the Board and built on the values "Care, Dare, Deliver", applies to all employees, management and directors and is available in 24 languages (pages 101-102). Related documents include the Code of Conduct for Huhtamaki Suppliers and the Group Anti-corruption Policy ("consistent with the United Nations Convention against Corruption"), plus competition, data privacy, human rights, insider, speak-up and trade sanctions policies (page 102).

Training (page 102): every employee, including part-time, temporary and fixed-term staff, completes annual Code of Conduct training; 98.5% did in 2025 and all Board members did. Anti-corruption e-learning is mandatory each year for employees in functions at risk (finance, legal, sales, sourcing, general managers, senior operations managers, the GET and their reports).

Concerns (page 103): channels include managers, HR, legal, Global Ethics and Compliance and the Speak Up platform (anonymous, run by an external provider, upgraded in 2025 with mobile app and phone reporting). The Investigations Council decides on investigations and updates the Board through the Audit Committee. Whistle-blowers (page 104): a "strict non-retaliation rule" applies, in line with Directive (EU) 2019/1937.

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

Reference: page 101.

Huhtamaki "has established a measurable, outcome-oriented, and timebound target for ethical business conduct and corporate culture" (page 101). The target is that all Huhtamaki employees complete the annual Code of Conduct training by the end of the year, with an annual target of 100%. Completion was 97.9% in 2024 and 98.5% in 2025. The target serves the policy objective "Fostering ethical business conduct and corporate culture", and is monitored annually with related actions recurring each year.