Humana Ab

Governance roles

Reference: pages 75-76. The Board has seven members: four women (57 percent) and three men (43 percent). All are independent of the company and its management, and there are no employee representatives on the Board (page 75).

The Board has overall responsibility for sustainability. It sets the sustainability strategy and targets, approves the double materiality assessment results and the overarching policies, and oversees progress on the material impacts, risks and opportunities (page 76). An Audit Committee and a Remuneration Committee support it (page 75). The Audit Committee supports the Board on sustainability reporting and reviews the procedures for internal auditing of sustainability work (page 76).

The Board states that it "continues to collectively possess, or have access to, the skills and expertise required to address these material issues" (page 76). Group Executive Management has operational responsibility. The Head of Sustainability coordinates the work and reports to the Board annually (page 76).

Information provided to the Board

Reference: pages 75-76. The CEO briefs the Board on sustainability progress every quarter. The Head of Sustainability joins the CEO for a discussion of the material sustainability matters at least once a year. The Board also gets in-depth presentations during the year on each material area, such as HR, IT, quality and climate (page 76).

In 2025 the Board considered and decided on the Group's climate targets, the application to join the Science Based Targets initiative (SBTi), the annual review of the double materiality assessment and updated sustainability policies. It also received briefings on GDPR, NIS2 and information security, and discussed the KPI work, the IT roadmap, the AI strategy and risk analysis (page 76).

Sustainability reporting and adaptation to ESRS were a standing item on the Audit Committee's agenda (page 76).

Sustainability in incentive schemes

Reference: pages 76-77, 88; Note C5, pages 142-143 (incorporated by reference, page 74). Humana points to Note C5 for how sustainability matters link to incentive schemes (page 76). The remuneration guidelines there say variable remuneration targets "should be linked to outcomes of financial targets for the Group and business areas, as well as clearly defined individual targets such as measurable quality and sustainability, customer satisfaction, employee satisfaction and important projects and activities" (page 143).

The three long-term incentive programs described in Note C5 (2023-2025, 2024-2026 and 2025-2027) use earnings per share as the financial performance target, adjusted earnings per share in the two later programs (page 142).

On climate, the statement says "Humana has not linked executive pay to the Group's climate targets" (page 88).

Statement on due diligence

Reference: page 77. Humana describes sustainability due diligence as "a process to identify, prevent, mitigate and account for how the company addresses actual and potential negative impacts on people and the environment in its own operations or in the value chain".

A table maps five core elements of due diligence to sections of the statement: integrating due diligence into governance, strategy and business model; collaborating with affected stakeholders; identifying and assessing negative impacts; taking action to mitigate them; and tracking the effectiveness of actions. Its page references run from 75 to 123 and point to GOV-1 to GOV-3, SBM-2, SBM-3, IRO-1, MDR-P, MDR-A and the S1 and S4 chapters.

In Norway there is also a formal duty under the Norwegian Transparency Act to carry out due diligence and report on it each year. Further information is on Humana Norway's website (page 77). Note 1 points the "Statement on due diligence" datapoint (paragraph 30) to page 77 (page 124).

Risk management and internal controls over sustainability reporting

Reference: page 77. The Head of Sustainability leads the work on the statement together with Group Finance. Humana names the main risk of error as "the human factor in manual processes: data being reported incorrectly or incompletely, or not being consolidated correctly, and analysis and conclusions being incorrect when based on incomplete or incorrect data".

The controls are still being built: Humana "intends to establish internal controls for sustainability data that function with the internal control environment used for financial reporting". In 2025 it began implementing system support for data collection, drew up Group-wide procedures and definitions, trained reporting units on data validation, source control, calculation methods and documentation of assumptions, and introduced an annual evaluation of definitions, processes and structures.

The Audit Committee monitored the work and could give its views on the DMA and the statement before the Board approved them. The auditors were engaged for a limited review.

Strategy, business model and value chain

Reference: pages 78-79; Board of Directors' report, page 66 (incorporated by reference, page 74). Humana provides health and social care in Sweden, Norway and Finland under contracts with municipalities, regions and governments: individual and family care, support under the Swedish LSS Disability Act, and elderly care. It also provides personal assistance, mainly bought by individuals with care needs. Around 8,000 people receive its care services (page 78). Net revenue for 2025 was SEK 10,011 million (page 94).

The workforce is about 22,000 people. Purchases of goods are around 6 percent of revenue, from more than 7,500 registered suppliers, mainly in the Nordic region. Around 50 of them account for half of all goods and services purchased (page 78). The value chain figure on page 79 sets out upstream, own operations and downstream impacts and Humana's actions.

Note 1 marks involvement in fossil fuel, chemical production, controversial weapons and tobacco activities "Not applicable" (page 124).

Stakeholder interests and views

Reference: page 80. A table covers six stakeholder groups: customers and clients; commissioners in municipal, regional and national government; employees and employee representatives; authorities; shareholders, investors and lenders; and suppliers. For each it lists the type of dialogue (for example annual customer and client surveys, procurement and contract management, the annual employee survey, inspections and audits, the AGM), the views raised, and how those views are addressed.

Examples of how views feed into strategy are investing in the Humana Academy for skills and career development, and a focus on evidence-based methods and performance measurement to show social benefits.

Stakeholders, channels and views were reviewed and confirmed in 2025. Humana "decided to merge shareholders and lenders into a single stakeholder group, as the channels and views were the same, and to remove politicians and researchers as primary stakeholders". The Head of Sustainability or topic leads report stakeholder views to management and the Board.

Material impacts, risks and opportunities

Reference: pages 81, 84, 86-87, 100-102, 112-114, 120. The DMA found impacts, risks and opportunities material in four areas: E1 Climate change, S1 Own workforce, S4 Consumers and end-users, and G1 Business conduct (page 81). Page 84 maps each material matter to the value chain: climate change mitigation (upstream and own operations); for S1, terms of employment, health and safety, diversity and skills development, and privacy; for S4, high-quality health and social care, personal safety, access to products and services and non-discrimination, and privacy; for G1, corporate culture including whistleblower protection, and corruption and bribery.

On financial effects Humana says it "has not yet carried out a full analysis of how the company's material sustainability risks and opportunities could affect its financial position, financial performance or cash flows" (page 81). It also states it "has not carried out any formal analysis of resilience" (page 81).

Climate impacts are expected to increase in severity over time; the other areas are expected to stay relatively unchanged in the short, medium and long term (page 81).

Process to identify and assess material IROs

Reference: pages 82-84. Humana carried out its DMA in 2023-2024, and the Board decided the outcome in spring 2024 (pages 82-83). The Head of Sustainability managed the project, with the CFO and the Head of Group Finance as steering group. Country and Business Area Managers described the value chains, Group Executive Management decided the outcome and the Board determined the material matters (page 82).

The steps were: identify stakeholders and their views, describe the value chain, build a longlist (using ESRS 2 AR 16, the risk assessment, subject-matter experts, ESG rating agencies, SASB and benchmarking), score each matter, then validate. Humana concluded that "a single overarching value chain for the entire Group" is reasonable (page 83). Purchases were screened with the Swedish National Agency for Public Procurement's list of high-risk products (pages 82-83).

Impact materiality is severity (scale, scope and remediability) multiplied by probability, graded 1-5, and high-impact matters are material. Financial materiality is the scope of the financial effect multiplied by its probability over the short, medium and long term, using the thresholds from the enterprise risk management process (pages 83-84). A 2025 review changed nothing (page 84).

Disclosure requirements in ESRS covered by the statement

Reference: pages 72-73, 85, 99, 119; Note 1, pages 124-126. Humana says it placed "a content index (IRO-2) at the beginning of each main section referring to the relevant page" (page 72). Four tables list what is covered: ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1 and Note 1) on page 73; E1 (E1-1, E1-3, E1-4, E1-5, E1-6 and the Taxonomy disclosures) on page 85; S1 (S1-1 to S1-11 and S1-14 to S1-17) and S4 (S4-1 to S4-5) on page 99; and G1 (GOV-1, SBM-3, G1-1, G1-3, G1-4) on page 119.

The E1 table does not list E1-2, although a section headed "E1-2 Policies related to climate change mitigation and adaptation" appears on page 88. S1-12 and S1-13, and G1-2, G1-5 and G1-6, are not in the tables either.

Note 1 lists datapoints derived from other EU legislation, each with a page or a marker: "Not applicable", "Not material" or "Complete data not available" (pages 124-126). The report says disclosure requirements with no related material impacts, risks or opportunities "have been omitted from the sustainability statement" (page 84).

Transition plan for climate change mitigation

Reference: page 89 (index, page 85). Humana's transition plan builds on its environmental policy, its sustainability strategy and its science-based targets, which the SBTi approved in September 2025. They cover short-term targets to 2030 and net zero by 2050. The plan was drawn up with the Paris Agreement's 1.5°C ambition and the EU's net zero by 2050 target "as the sole scenario", and "No alternative scenarios have been considered". The Board and Group Executive Management approved it in the fourth quarter of 2025.

It covers Scopes 1, 2 and 3. Humana plans to invest mainly in renewable energy, energy efficiency and fossil-free transport over 2025-2030, with no reliance on new technology. A key assumption for Scope 3 is that high-emitting suppliers also cut emissions in line with science. The reduction chart takes emissions from 49,735 tCO2e in base year 2024 to 34,692 tCO2e in 2030 (-30 percent).

Planned OpEx and CapEx are not yet quantified ("Work on quantifying the planned investments is under way"). Humana reports 0 percent of 2025 CapEx as environmentally sustainable under the EU Taxonomy. It "has not identified any material risks of locked-in emissions".

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 SBM-3 and IRO-1 as they apply to E1 (pages 86-87), and from the transition plan (page 89), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Physical risks (page 87): heatwaves; extreme precipitation and flooding; interruption of power, water and data from extreme weather. Exposure to acute physical risk is "low to moderate in the short term" and to more lasting physical risk "somewhat higher in the longer term". Humana mostly leases its premises and so has "limited direct control over buildings' technical performance".

Transition events (page 87): higher energy prices and environmental taxes; stricter EU and national climate requirements; suppliers' transition costs. Transition risks are low to moderate in the short term and expected to rise in the medium to long term.

Scenarios (page 89): the only scenario mentioned is the plan's own 1.5°C and EU net zero 2050 ambition, described as "the sole scenario". The report names no physical-risk scenario, gives no temperature projection and describes no method for exposure and sensitivity beyond the general DMA process (pages 82-84).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the E1 SBM-3 section, where this content is disclosed in the FY2025 report (pages 81, 87, 90). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Humana states it "has not carried out any formal analysis of resilience", and expects sustainability risks and opportunities not to change how the business is run or its finances in the short, medium or long term (page 81). It has not identified major investment or disposal plans, or changes to funding, tied to these matters.

Its qualitative view (page 87): the business model is "relatively resilient to climate change and transition risks", demand for care will not be directly affected, and Humana sees no need for major adjustments to its business model and strategy in the short to medium term. It adds that an extreme weather event near an operational unit could disrupt care for a period, and that it needs ongoing action such as comfort cooling in elderly care homes.

On the action side, the Individual & Family business area carried out risk and vulnerability analyses that led to a joint emergency and contingency plan (page 90).

Policies related to climate change mitigation and adaptation

Reference: page 88. The E1 content index on page 85 does not list E1-2, but the report prints a section with this heading.

Humana's environmental policy applies to all parts of the company and all employees. It requires Humana to minimize its climate impact and cut greenhouse gas emissions in line with the Paris Agreement, for example through energy efficiency and a move to renewable fuels, built on three strategies: responsible purchasing, minimized consumption and minimized waste. Climate adaptation was not a material matter in the DMA, yet the policy still requires contingency planning to mitigate climate risks.

Country and business area policy documents supplement the Group policy. Effects are assessed through annual follow-up of Scope 1, 2 and 3 emissions and progress on the transition plan. The Board approves the policy each year; some operations hold ISO 14001 or equivalent certification. "Humana has not linked executive pay to the Group's climate targets".

Actions and resources in relation to climate change policies

Reference: page 90 (index, page 90). Actions follow the three strategies in the environmental policy: responsible purchasing, minimized consumption and minimized waste. Humana says that "In most cases, they have not been allocated any specific time horizons or deadlines but are ongoing, often over a period of years."

Transition plan actions for the 2030 targets: renewable electricity through certificates of origin in all electricity contracts; building improvements such as insulation, smart heating controls, energy-efficient lighting, heat pumps and district heating where possible; a gradual switch to electric and hybrid vehicles and fossil-free fuels, with charging infrastructure; climate criteria in purchasing; and dialogue with suppliers on emissions data and targets.

Progress in 2025: SBTi validation with 2024 as base year, emissions mapped by country and category, work started on renewable electricity and vehicle emissions, and preparations for a net zero roadmap to 2050 and tracking of climate investments.

On resources, the transition plan expects higher OpEx and CapEx and quantification is under way (page 89).

Targets related to climate change mitigation and adaptation

Reference: page 91 (index, page 91); emissions table, page 93. The SBTi approved the targets in 2025. Base year is 2024. They are gross targets, set with the market-based method for Scope 2 and excluding biogenic CO2 in Scopes 1 and 2.

• Scopes 1 and 2: -42 percent by 2030 and -90 percent by 2050.
• Scope 3: -30.8 percent for fuel- and energy-related activities, business travel and employee commuting by 2030, and -90 percent by 2050. The table on page 93 also shows -28 percent for total Scope 3 in 2030.
• Supplier engagement: 67 percent of suppliers, by emissions in purchased goods and services, with science-based targets by 2030.
• Net zero across the value chain by 2050.

Outcome 2025: Scope 1 and 2 emissions fell 35 percent against the base year, helped by renewable electricity certificates in Norway and less fuel oil in Finland and Sweden. Scope 3 fell 14 percent, and 17 percent in the categories covered by the targets. At least 30 percent of suppliers (by emissions) had science-based targets in February 2026.

Energy consumption and mix

Reference: page 92 (index, page 92). Total energy consumption in 2025 was 53,410 MWh, down 19 percent from 65,949 MWh in 2024.

Renewable consumption in 2025 was 33,951 MWh of purchased or acquired electricity, heat, steam or cooling, 563 MWh of renewable fuel including biomass, and 217 MWh of self-generated renewable energy (none in 2024). The calculation uses actual consumption and estimates from distances driven and standard consumption per floor area, with the residual mix for electricity. Humana attributes the shift to certificates of origin on purchased electricity, solar panels on new properties where appropriate, and vehicles on renewable fuels.

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 93-94 (index, page 93). Base year 2024 is restated against the prior report because of the Finland elderly care sale, the Team Olivia acquisition, a more thorough inventory and SBTi guidance (page 93).

Scope 3 is 88 percent of the total. Purchased goods and services (18,914) and employee commuting (11,154) are the largest categories. Intensity is 4.04 tCO2e per SEK million of net revenue location-based and 4.10 market-based (2024: 4.56 and 4.83). Biogenic emissions outside the scopes are 161 (Scope 1), 150 (Scope 2) and 663 (Scope 3) tCO2e. Nine Scope 3 categories are counted, and 43 percent of emissions rest on primary data from suppliers or other value chain partners (page 94).

Policies related to own workforce

Reference: pages 102-103 (index, page 102). Humana lists four policies: a code of conduct, an occupational health and safety policy, a diversity, equity and inclusion policy, and an information security policy.

The code of conduct applies to all employees, requires collective bargaining agreements across the operations, and is "consistent with the UN Guiding Principles on Business and Human Rights, OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, and the ILO Declaration on Fundamental Principles and Rights at Work". The health and safety policy covers all employees and external parties whose agreement with Humana covers health and safety responsibility. The diversity policy targets discrimination and harassment on grounds including gender, ethnic origin, religion, functional impairment, sexual orientation and age, and promotes equal pay for equal performance.

The Board approves the policies each year and assesses compliance. Country Managers implement them with the Director of Human Resources, and the CIO owns information security (page 103). Note 1 marks trafficking prevention (paragraph 22) "Not material" (page 125).

Taking action on material impacts on own workforce

Reference: pages 104-107 (index, page 104). No major strategic change was made in HR in 2025; the focus was on digitization and AI capability. Actions are mostly ongoing, without specific deadlines (page 104).

• Terms of employment: annual pay surveys to prevent unfair pay gaps between women and men; preparation for the Pay Transparency Directive, with a new analysis system in Sweden and Finland and a new shift planning manual in Finland (pages 104-105).
• Health and safety: training for managers and safety representatives on risk assessment, threats and violence and alcohol problems; an annual health and safety week in Sweden; annual safety inspections; wellness contributions; a values program (page 105).
• Diversity and skills: basic diversity training for all employees; skills maps and a learning portal. 75 percent of employees had a development review in 2025 (77 percent in 2024); an anonymous recruitment model was developed in Finland (pages 105-106).
• Privacy: data protection officers and a Privacy Office; GDPR training moved to short microlearning in December 2025; compulsory IT security training from April 2025; NIS2 gap analyses (pages 106-107).

Targets related to own workforce

Reference: page 107 (index, page 107). Humana sets two targets for its own workforce, covering all employees in Sweden, Norway and Finland.

The eNPS target runs from a 2025 base of +14 to +20 by the end of 2028 and is tracked in the annual employee survey. Humana says the aim is "to create more stable employee groups and reduce the need for expensive recruitment and staffing solutions".

Top management means Group Executive Management and the management teams at country and business area level. At 64 percent, the share of women is above the 40-60 percent interval, so Humana will work on succession planning to restore the balance. Results go to the Board. Employees take part in the eNPS target through the annual survey.

Characteristics of the undertaking's employees

Reference: page 108 (index, page 108). Humana had 21,948 employees on 31 December 2025 (23,550 in 2024): 14,842 women and 7,106 men. By country: Sweden 13,421, Norway 6,273 and Finland 2,254 (2024: 14,186, 6,028 and 3,336). The sale of all elderly care in Finland at the start of 2025 cut the Finnish workforce by around 1,000.

2,914 permanent employees left during the year (2,536), a turnover rate of 21.9 percent (21.6). Humana says temporary, part-time and non-guaranteed-hours work reflects round-the-clock care and the needs of individual care recipients, and that for some employees it means a lack of employment security. Figures are headcount at year end.

Characteristics of non-employee workers

Reference: page 108 (index, page 108). Humana's own workforce was 22,563 individuals on 31 December 2025 (24,650). Employees were 97 percent of the total (96). The other 615 workers (1,100), 3 percent (4), were brought in from staffing agencies or work as independent consultants.

Agency workers are common in the care sector, for example as doctors, nurses, auxiliary nurses and treatment instructors, hired full-time or part-time for short or long periods. Consultants fill some specialist roles, often only while recruitment to a permanent position is under way. Unless otherwise stated, the S1 disclosures cover employees only (page 108). Page 78 describes agency workers as 1 percent of workers, which differs from the 3 percent given here and on page 101.

Page 101 gives the same 615 agency workers and notes they are found among nurses, doctors and occupational therapists in Sweden, nurses and auxiliary nurses in Finland, and treatment instructors and assistants in Norway.

Collective bargaining coverage and social dialogue

Reference: page 109 (index, page 109). "All employees at Humana other than the Group CEO are covered by collective bargaining agreements." The coverage ratio is 100 percent of employees in the EEA, and Humana's operations are all in the EEA (Sweden, Norway and Finland). For social dialogue, employee representatives exist in Sweden, Norway and Finland.

Humana takes a positive view of collective bargaining and supports the right of all employees to form and join trade unions. It is not permitted in the Nordic countries to keep records of union membership, so Humana cannot say how many employees are actually represented by a union, or the share of union members among non-employee workers. For social dialogue through trade unions and committees, the report refers to S1-2 (page 109).

Diversity metrics

Reference: page 109 (index, page 109). Top management means Group Executive Management and the management team in each country and business area.

Age distribution of employees, as printed (2025 / 2024): under 30 years 34% / 24%; 30-50 years 36% / 48%; over 50 years 29% / 28%. Figures are contracts as at 31 December.

Humana sets a target interval of 40-60 percent for each gender in top management, so the 64 percent share of women is above it (page 107). Women are 14,842 of 21,948 employees (page 108).

Adequate wages

Reference: page 109 (index, page 109). All Humana employees are in Sweden, Norway and Finland, "countries with well-developed systems and practices for ensuring adequate wages". All employees are covered by collective bargaining agreements, so they are guaranteed wages in line with applicable benchmarks. Humana also runs an annual pay survey to identify, address and prevent unwarranted pay gaps, for example between women and men.

The report gives no list of countries or locations where wages fall below an adequate wage benchmark, and states no percentage of employees paid below one. It bases the adequate-wage position on the collective bargaining coverage in S1-8.

Social protection

Reference: page 109 (index, page 109). All of Humana's employees in Sweden, Norway and Finland are covered by social protection under the national guidelines and social security systems of each market. It gives "protection against loss of income due to major life events such as illness, unemployment, retirement, parental leave and employment injury/acquired disability".

Page 104 adds that employees are covered by the terms and insurance in the collective bargaining agreements, including benefits from the Swedish Social Insurance Agency and insurance companies for occupational injuries and from Trygghetsrådet TRS in the event of redundancies. The report gives no breakdown by country or employee category.

Health and safety metrics

Reference: page 110 (index, page 110). All employees are covered by Humana's occupational health and safety system (100 percent); there are no data for non-employee workers.

• Injuries: 1,087 work-related injuries were reported in 2025 (750 in 2024), an accident frequency of 49.5 (32.7) per million hours worked. Humana attributes the rise mainly to a new incident management system that made reporting easier.
• Fatalities: none in 2025 from work-related injuries or ill health (the table shows one employee fatality in 2024).
• Sickness absence: 7.1 percent (6.9), of which 4.0 percent (4.1) short-term and 3.2 percent (2.8) long-term.
• Working Conditions Index: 67 out of 100 in the employee survey.

"For 2025, Humana lacks the system support required to report either the number of documented cases of work-related ill health or the number of days lost due to work-related injuries and ill health." Note 1 marks the days-lost datapoint "Complete data not available" (page 126).

Work-life balance metrics

Reference: page 111 (index, page 111). Humana reports that 100 percent of employees are entitled to family-related leave, a right "assured through social policy and collective bargaining agreements".

It does not report the share of entitled employees who took family-related leave, by gender: "For this first year of ESRS reporting, Humana has opted to apply the phase-in relief for disclosures under S1-15 on the share of employees taking family-related leave by gender."

The entitlement figure is the only quantified work-life balance metric in the chapter. Humana's shift planning work in Finland, a new shift planning manual with mentors for managers, is described under S1-4 (page 105).

Remuneration metrics (pay gap and total remuneration)

Reference: page 111 (index, page 111). Humana expresses its gender pay gap as the average earnings of female employees relative to male employees: 100.2 percent in 2025, so women's average hourly pay is slightly above men's. The 2025 figure includes basic salary, bonuses and fixed supplements; on basic salary alone it is 100.9 percent. Earlier years include basic salary only: 100.7 (2024), 100.6 (2023) and 100.5 (2022).

The ratio of the highest-paid individual's annual total compensation to the median for all other employees is 14.1 times (14.8 in 2024). Annual total remuneration is basic salary, bonuses and fixed supplements. Hourly pay is the average gross hourly level, with all currencies converted to SEK, assessed once a year. Figures are as at 31 December.

Note 1 points both datapoints (unadjusted gender pay gap, paragraph 97(a), and the CEO pay ratio, 97(b)) to page 111 (page 126).

Incidents, complaints and severe human rights impacts

Reference: page 111 (index, page 111). Humana reports that "No serious human rights-related complaints or incidents were reported through the whistleblower system" and that no cases were identified as serious human rights incidents during the reporting period. No fines, penalties or damages were issued.

Humana cannot tell whether reports through the whistleblower system came from an employee or an outside party, because reports can be made anonymously. It points to G1-1 on page 122 for the whistleblower system, which received 17 reports in 2025 that were considered to come under the Whistleblower Protection Act (page 122).

Note 1 marks the incidents of discrimination datapoint (paragraph 103(a)) "Complete data not available", and points non-respect of the UN Guiding Principles and OECD Guidelines (paragraph 104(a)) to page 102 (page 126).

Policies related to consumers and end-users

Reference: page 115 (index, page 115). Humana's policies for customers and clients are a quality policy, the code of conduct and the information security policy.

The quality policy covers all of Humana and sets four strategies: continuous improvement, evidence-based practice, "quality measurement and transparent quality reporting", and employee skills development and wellbeing. It requires a process-driven quality management system and systems for reporting and managing deviations, and it includes identifying and mitigating risks that could harm customers and clients. Procedures supplement it across the whole care process, from preparation for placement to conclusion of placement.

The code of conduct and the information security policy are the tools for the right to privacy, which Humana names as a material human right in its business (page 115; details on pages 102-103). The Board approves the policies each year and checks compliance, and the Country Managers and the Director of Quality and Compliance run quality management. Note 1 points the S4-1 policies datapoint to page 115 and the UN Guiding Principles datapoint to pages 102 and 115 (page 126).

Taking action on material impacts on consumers and end-users

Reference: pages 116-117 (index, page 116). Most operations need permits and are tightly regulated, and each country and business area has a quality and compliance function, supported by a central one. Humana's quality management system covers deviation management: deviations are compiled and reported monthly to management, and the CEO keeps the Board informed. Critical deviations reported to authorities (Lex Sarah and Lex Maria in Sweden and their equivalents in Norway and Finland) follow a specific procedure.

In 2025 internal controls covered areas such as documentation, IVO permits, rehabilitation, protection measures and use of restraints, and Lex Sarah reporting. Staff working with children and youth must provide a criminal record check, and employees have training through the Humana Academy (page 117).

Individual & Family holds ISO 9000 and ISO 14001 certification; some Swedish operations hold SS 41000:2018; Norwegian personal assistance holds ISO 9001 and ISO 45001. There were "no serious human rights matters or incidents related to customers or clients in 2025" (page 117). Privacy actions are under S1-4 (page 106).

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

Reference: page 118 (index, page 118). The target is to raise the Customer Satisfaction Index (CSI) from a baseline of 85 in the base year 2025 to 86 by the end of 2028. It covers all of Humana's operations in Sweden, Norway and Finland.

The index comes from surveys on five areas: treatment, safety, participation, self-determination and overall satisfaction. All customers and clients can take part. Surveys run at least annually in Sweden and Norway and at least three times a year in Finland as the law requires; in Swedish elderly care the National Board of Health and Welfare carries it out. Results are followed up by the country and business area management teams, Group Executive Management and the Board, and shared with contractors and purchasers. Customers and clients take part in tracking through the surveys, and results feed local operational plans and central business plans.

Business conduct policies and corporate culture

Reference: pages 121-122 (index, page 121). Policies: a code of conduct (zero tolerance of corruption; explains how Humana is to operate in line with the UN Convention against Corruption; approved by the Board), a code of conduct for suppliers (based on the UN Global Compact's ten principles; approved by the Group CFO), an anti-corruption policy (Board approved) and a whistleblowing procedure (approved by the Group CEO). At the end of 2025 the procedure gained a dedicated investigator for cases under Norwegian jurisdiction.

Culture: the core values are Joy, Engagement and Responsibility. Whether employees feel the values guide Humana is measured each year; the 2025 result was 4.0 (4.0) on a scale of 1-5. All new employees confirm they will follow the code of conduct, and onboarding includes digital learning on values and the code.

Whistleblowing: a function open around the clock, with intake and first assessment by an independent external service, and an internal investigation unit. Reporters can stay anonymous. 17 reports in 2025 were considered to come under the Whistleblower Protection Act (page 122). Note 1 points the UN Convention datapoint to page 121 and whistleblower protection to pages 111 and 121 (page 126).

Targets related to business conduct

Back-filled from the business conduct chapter. G1-3 became a standalone DR only in the 2025/2026 ESRS; the report was prepared under the 2023 ESRS, where targets fall under MDR-T.

The G1 chapter has no target table and no numeric business conduct target. It states goals and tracks how the work is going (pages 121-122):

• "Humana's goal is for there to be no corruption at Humana" or in its relations with contractors, customers, clients, employees, authorities and other stakeholders (page 121).
• "Humana's goal is for all employees to undergo at least one session of anti-corruption training during their employment with Humana" (page 122). Compulsory modules for high-risk roles are planned for 2026, and Humana will assess whether participation can be tracked.
• Corporate culture is measured and reviewed annually; the 2025 score was 4.0 (4.0) on a scale of 1-5 (page 121).
• Confirmed corruption or bribery cases are counted under G1-4; there were none in 2025 (page 123).

Incidents of corruption or bribery

Reference: page 123 (index, page 123). "No incidents of corruption or bribery were identified at Humana in 2025, and so no fines were issued."

The accounting policy counts "cases received through the whistleblower channel or other channels, which have been confirmed as bribery or corruption following investigation by Humana". Whistleblower intake is a wider measure: 17 reports in 2025 were considered to come under the Whistleblower Protection Act, and they were dealt with under internal procedures (page 122). The report does not say how many of them concerned corruption or bribery.

Note 1 points the datapoint on fines for violations of anti-corruption and anti-bribery laws (paragraph 24(a)) to page 123, and the datapoint on anti-corruption and anti-bribery standards (24(b)) to page 121 (page 126).