Humble Group Ab

Sweden|Processed Foods|FY2025|Auditor: BDO Mälardalen AB|View original report →

Sustainability statement, in full

The complete text of Humble Group Ab’s FY2025 sustainability statement is held here – 80 pages, captured from the published report. Every disclosure below also links to its own passage.

ESRS 2 – General Disclosures

GOV-1The role of the administrative, management and supervisory bodies
Reported

The role of the administrative, management and supervisory bodies

Reference: page 36 (profiles on page 25).

Supervisory bodies: the General Meeting, Nomination Committee, Board of Directors, Board Audit Committee and Board Remuneration Committee. The executive team is the CEO, CFO and COO (page 36).

Board in Q1 to Q3 2025: 6 members, 4 men (66%) and 2 women (33%); 5 independent of the Group and management; 3 independent of major shareholders. Board in Q4: 5 members, 3 men (60%) and 2 women (40%); all 5 independent of the Group and management; 3 independent of major shareholders. No employee representatives in either period. Noel Abdayem left the Board on 1 October 2025 to become interim CEO (page 36).

The Group Sustainability Team sets the strategic direction, oversees all sustainability policies, sets targets and trains subsidiaries for reporting. Policy changes it proposes are approved by the Executive Team and the Board (page 37). Each subsidiary now has its own board, which meets quarterly and reviews sustainability performance (page 37).

GOV-2Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies
Reported

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

Reference: page 37.

Humble Group AB has set an annual activity plan for sustainability matters (page 37). It covers:

  • the annual Sustainability Statement review and audit
  • the double materiality assessment
  • a bi-annual review of Group-wide progress toward sustainability targets
  • inclusion in the annual business plan and budget
  • the annual internal controls review and improvement plans

The Board and Executive Team approve the double materiality assessment, which is run every year. The Board and CEO own all Group policies, including sustainability policies, and review them annually. The Board Audit Committee is the working committee for sustainability reporting and its internal controls. The Board reviews target progress twice a year, during quarterly Board meetings. The CEO and Executive Team oversee how policies, action plans and targets are carried out.

Each governing body must "balance the views and interests of all stakeholders" (page 37).

GOV-2(was GOV-3)Integration of sustainability-related performance in incentive schemes
Reported

Integration of sustainability-related performance in incentive schemes

Reference: pages 37, 55.

The 2024 Annual General Meeting set remuneration guidelines for the CEO and the rest of the Executive Team. A 5% portion of their variable cash remuneration is tied to one sustainability target. For 2024 and 2025 that target was being "CSRD ready". In 2025, despite the Group being CSRD ready, 0% of the discretionary variable cash remuneration was paid to the Executive Team "as a result of wider business considerations and cost-cutting measures" (page 37).

Subsidiaries had no sustainability-related incentives in 2025. Humble Group AB encourages them to build the Group's targets into business planning, but no formal link between targets and pay exists yet (page 37).

On climate, the report says "climate-related incentives were not part of any remuneration guidelines" in 2025 (page 55).

GOV-3(was GOV-4)Statement on due diligence
Reported

Statement on due diligence

Reference: page 38.

The statement on due diligence is a table that points to where each element is covered (page 38):

  • ESRS 2 general disclosures: SBM-1 (page 39), SBM-2 (page 41), SBM-3 (page 41), IRO-1 (page 44) and GOV-5 (page 38)
  • Taking action on material impacts and overseeing business conduct: S1-4 (page 67), S2-4 (page 73) and G1-1 (page 75)

Page 38 gives the table and no narrative on the process itself. Supply chain due diligence is described elsewhere as work still under way. The S2 chapter says the Group "is actively working to improve its supply chain due diligence over the coming years" (page 72), and the S2-4 section says action plans, remediation plans and effectiveness tracking are areas it plans to develop (page 73).

GOV-4(was GOV-5)Risk management and internal controls over sustainability reporting
Reported

Risk management and internal controls over sustainability reporting

Reference: page 38.

Humble Group has used Position Green as its digital sustainability reporting platform since 2023, and since July 2024 the data collection follows the CSRD format. In 2025 it included sustainability reporting in the Group's internal controls process for the first time. That process runs every year: risks are identified, controls are set, and portfolio companies self-assess. Results go to the Audit Committee, the Board and the auditors.

The main risk is the complexity of gathering the quantitative data internally. In 2025, 40 operational entities reported quarterly or half-yearly. Many are small, without dedicated sustainability staff, in different locations and on different business models. Collection and Group-level consolidation are both manual.

Mitigation: live training before each reporting window, documentation of the data points each business must prepare, and continuing support from the Group Sustainability Team.

SBM-1Strategy, business model and value chain
Reported

Strategy, business model and value chain

Reference: pages 39-40 (also pages 5, 13, 19, 34).

Humble Group operates in fast-moving consumer goods (FMCG) through 40 entrepreneur-led companies of three types: brands, production facilities and distributors (page 39). Net sales were 8,097 MSEK in 2025 (page 19). By segment: Nordic Distribution 38%, Sustainable Care 29%, Quality Nutrition 19% and Future Snacking 14% (page 13).

The ambition is "healthy people on a healthy planet", built on three pillars: protecting the planet, committing to people, and delivering results with integrity. Five Group-wide 2030 targets, announced in 2024, cover ISO 14001 certification, renewable energy, recyclable packaging, zero recordable workplace accidents and a 60:40 gender split in management (page 39).

Headcount at year end was 1,282 employees across 17 countries, 739 of them in Sweden (page 39).

Value chain (page 40): upstream is raw materials, packaging and finished goods bought from suppliers; own operations are the subsidiaries (located in 9 countries, mostly Nordic) and the Stockholm head office; downstream is outbound transport and distribution to wholesalers and retailers, then consumers. The report says most impacts, risks and opportunities arise upstream (page 34).

SBM-2Interests and views of stakeholders
Reported

Interests and views of stakeholders

Reference: page 41.

Stakeholder groups: investors, employees, customers and suppliers (with value chain workers), end consumers, local communities and public authorities. Some dialogue happens at Group level and some in subsidiaries, especially for a company's own suppliers.

The DMA takes stakeholder perspectives into account, but the report says "direct input/dialogue has not always been possible". The Group plans to formalize the process.

  • Investors: interested in the climate strategy and reporting expectations, which shape priorities and resources.
  • Suppliers and customers: supply chain risk, ingredient sourcing and traceability, human rights and emissions. Worldfavor is used to map the supply chain and engage suppliers.
  • Employees: an annual Employee Engagement Survey and a Speak Up tool. Health and safety and gender balance in management shape strategy.
  • End consumers: handled by each brand.
  • Local communities: no process for direct engagement yet.
  • Public authorities: handled at Group and subsidiary level.
SBM-3Material impacts, risks and opportunities and their interaction with strategy and business model
Reported

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

Reference: pages 41-43 (also pages 40, 55).

The 2025 DMA confirmed 6 of 10 ESRS topics as material: E1, E3, E5, S1, S2 and G1. They cover 13 sub-topics (page 41). The tables on pages 42-43 hold 19 individual IRO rows by our count:

  • E1 climate change mitigation and energy: an actual negative impact and a financial risk each (4 rows). The risks are higher costs from new regulation, taxes and low-carbon investment, and from energy prices.
  • E3 water withdrawals and water consumption: an actual negative impact each (2 rows).
  • E5 resource inflows and outflows: an actual negative impact and a financial risk each; waste: an actual negative impact (5 rows).
  • S1 working conditions, and equal treatment and opportunities: an actual negative impact each (2 rows).
  • S2 working conditions and other work-related rights, such as child or forced labor: potential negative impacts (2 rows).
  • G1: actual positive impacts for corporate culture and whistleblower protection; a potential negative impact and a financial risk for corruption and bribery (4 rows).

"A large proportion of Humble Group's value chain and impact falls upstream" (page 40). The E1 section states the DMA identified no climate-related financial opportunities (page 55).

IRO-1Description of the processes to identify and assess material impacts, risks and opportunities
Reported

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

Reference: pages 44-46.

Humble Group began mapping impacts, risks and opportunities in 2024 and ran a full DMA built for CSRD and external assurance in 2025. It is done at Group level every year, with all steps documented. The 2025 method did not change from the prior year (page 44).

Four steps: understand the value chain and stakeholders, identify IROs, assess them, determine materiality. Time horizons: short term under 1 year, medium term 1 to 3 years, long term over 3 years. Impacts are scored on scale, scope and irremediability, weighted equally. For potential human rights impacts, severity takes priority over likelihood. Financial risks and opportunities are scored on size of financial effect and likelihood (pages 44-45). A materiality threshold is set in step 4; the report gives no value for it (page 45).

The Group Sustainability Team runs the process. The Executive Team approves, the Audit Committee reviews, and the Board gives final approval (page 44).

Climate (page 45): a high-level analysis by facility location and supply chain; no facility-level climate risk assessment yet. E2 and E4 were judged non-material (pages 45-46). Water: Aqueduct Water Risk Atlas used; 3 of 17 production facilities are in water-stressed areas (page 45).

IRO-2Disclosure requirements in ESRS covered by the undertaking's sustainability statement
Reported

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

Reference: pages 47-48 (phase-ins on page 34).

The index lists each disclosure requirement with a page number, split into material and non-material topics.

Covered: all ESRS 2 disclosure requirements (BP-1 to IRO-2); E1-1 to E1-6 and E1-8; E3-1 to E3-4; E5-1 to E5-5; S1-1 to S1-10 and S1-14 to S1-17; S2-1 to S2-5; and G1-1, G1-3 and G1-4.

Listed as non-material topics: E2 Pollution, E4 Biodiversity and ecosystems, S3 Affected communities and S4 Consumers and end-users (page 48).

Under BP-1 the report says it applied the phase-in and "quick fix" rules to E1-9, E3-5, E5-6, S1-8 (details beyond total coverage), S1-11, S1-12 and S1-13 (page 34). S1-8 still appears in the index (page 69).

Not in the index and not in the phase-in list: E1-7, G1-2, G1-5 and G1-6.

E1 – Climate Change

E1-1Transition plan for climate change mitigation
Reported

Transition plan for climate change mitigation

Reference: pages 55-56 (also page 45).

Humble Group states that it has not set Paris Agreement-compatible targets, so no transition plan is in place and it has not set a date for having one. It has therefore not identified any locked-in emissions (page 55).

The missing plan is recorded as a risk. Financial stakeholders expect targets and a transition plan, and future regulation brings a risk of non-compliance fines (page 55). The E1 risk text refers to the "growing requirements of EU companies to set climate targets and transition plans which Humble Group has not yet established" (page 45).

The only forward statement is an ambition to set science-based targets with the Science Based Targets initiative (SBTi) in the future. The Group keeps monitoring Scope 1, 2 and 3 emissions (page 56).

E1-2(was covered under ESRS 2 IRO-1)Identification of climate-related risks and scenario analysis
Reported

Identification of climate-related risks and scenario analysis

Reference: pages 45, 55 (also page 42).

Back-filled from ESRS 2 IRO-1 (E1 IRO-1), where this content is disclosed in the FY2025 report (page 45), with the climate risks in SBM-3 (pages 42, 55). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

To identify material climate-related risks and opportunities, the Group ran "a high-level climate analysis based on the geographic location of Group facilities and the Group's supply chain" (page 45). It adds that it "has yet to conduct a climate-related risk assessment at facility or asset level" and that the analysis needs "to be further extended to fully meet the requirements of the ESRS" (page 45).

Climate risks named (pages 42, 55): higher energy and transportation costs, particularly for EU facilities in the medium term; costs and low-carbon investment needs from new regulation and taxes; and the financial risk of having no climate targets or transition plan. The report does not label these as physical or transition risks.

No climate scenario, such as an IPCC pathway or an IEA scenario, is named, and no temperature projection is given.

E1-3(was covered under ESRS 2 SBM-3)Resilience in relation to climate change
Reported

Resilience in relation to climate change

Reference: pages 55, 45.

Back-filled from ESRS 2 SBM-3, where this content is disclosed in the FY2025 report (page 55). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The report states plainly: "A complete climate resilience analysis according to the ESRS requirements has not been performed yet for the group" (page 55).

Related statements: the climate risk analysis done so far is high-level and not extended to facility or asset level (page 45), and there is no Group-wide decarbonization action plan because Group-wide climate targets are not yet set (page 55). The E1 chapter gives no assessment of the Group's capacity to adapt its strategy or business model.

E1-4(was E1-2)Policies related to climate change mitigation and adaptation
Reported

Policies related to climate change mitigation and adaptation

Reference: page 55.

Climate commitments sit in Humble Group's Environmental Policy. It says the Group will:

  • aim to achieve carbon-positive production and supply chains
  • support the transition to renewable energy and fossil-free transportation
  • promote a circular economy and reduce greenhouse gas emissions by eliminating waste and using more recycled and recyclable materials

The Supplier Code of Conduct sets similar expectations for upstream and downstream suppliers and subcontractors: work to reduce greenhouse gas emissions through energy-efficient processes and renewable energy, and use design methods that conserve natural resources, minimize resource use or contribute to a circular economy (page 55).

The text covers mitigation. It does not describe an adaptation policy.

E1-5(was E1-3)Actions and resources in relation to climate change policies
Reported

Actions and resources in relation to climate change policies

Reference: pages 55-56 (also page 57).

Humble Group has no Group-wide decarbonization action plan, because Group-wide climate targets are not yet set. Subsidiaries act on their own (page 55). Actions named for 2025:

  • LED lighting and motion-sensor technology in production facilities and offices
  • one subsidiary (Jalofoods, page 56) keeps producing energy at an on-site biogas plant
  • two subsidiaries keep producing power from rooftop solar panels installed earlier, and a third installed solar panels during 2025
  • a framework agreement with Fortum for 100% certified renewable electricity, open to Swedish entities; six subsidiaries had joined, covering 7% of the Group's purchased electricity (page 57)

The section gives no CapEx or OpEx amounts or other resources for these actions.

E1-6(was E1-4)Targets related to climate change mitigation and adaptation
Reported

Targets related to climate change mitigation and adaptation

Reference: page 56 (also page 12).

Two targets were set in 2024, both for 2030 (page 56):

  • 100% renewable electricity and heating in all Group-owned facilities. Status in 2025: 83%. The report says many Nordic subsidiaries already buy 100% renewable electricity.
  • 100% ISO 14001 certified production sites. Status in 2025: 12% (2 of 17 production facilities). The report notes ISO 14001 is not a climate standard specifically.

Both are energy and management-system targets. The Group has set no GHG reduction target for Scope 1, 2 or 3. It has an ambition to set science-based targets with SBTi in the future (page 56).

The Group targets overview on page 12 gives the renewable energy status as 89%, against 83% here.

E1-7(was E1-5)Energy consumption and mix
Reported

Energy consumption and mix

Reference: page 56 (estimates on page 34).

Total energy consumption was 25,852 MWh in 2025 (25,373 MWh in 2024). Producing subsidiaries accounted for 83% of it. Renewable sources were 73% (18,780 MWh, against 76% in 2024), fossil sources 22% (5,715 MWh) and nuclear 5% (1,357 MWh).

Fossil use: 3,542 MWh from crude oil and petroleum products, 257 MWh from natural gas, none from coal, and 1,916 MWh of purchased electricity, heat, steam and cooling from fossil sources. Renewable use: 16,546 MWh purchased, 556 MWh of fuel and 1,678 MWh of self-generated non-fuel renewable energy. On-site renewable production was 1,735 MWh.

Energy intensity for the 17 production facilities, which the report classes as high climate-impact sectors (NACE sector C), was 87 MWh per MEUR of net revenue (169 in 2024). National energy mix averages were used to estimate the mix where purchased energy is not 100% renewable (page 34).

E1-8(was E1-6)Gross Scopes 1, 2, 3 and Total GHG emissions
Reported

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 57-58 (estimates on page 34).

Scope 1: 1,000 tCO2e in 2025 (1,125 in 2024, down 11%), from mobile combustion (192) and stationary combustion (808). The report says fewer leased cars drove the fall.

Scope 2, market-based: 1,222 tCO2e (up 6%); location-based 859. Total Scope 1 and 2: 2,222 tCO2e market-based (down 2%) and 1,860 location-based.

Scope 3, upstream categories only: 200,304 tCO2e (down 12%). Purchased goods and services is 188,322 of that, upstream transport 9,954, business travel 1,062, fuel and energy 776 and waste 191.

Total Scope 1, 2 and 3: 202,527 tCO2e market-based (230,835 in 2024). Intensity: 25.0 tCO2e per MSEK of net revenue, down 16%.

Scope 3 is mostly spend-based, with conservative food estimates the report says likely overstate emissions. For 2H 2025, 91% of Scope 3 spend data was actual and the rest estimated (page 34). Categories 3.2 and 3.7 to 3.15 are not reported because the spend data does not capture them. No biogenic emissions were identified (page 58).

E1-9(was E1-7)GHG removals and GHG mitigation projects financed through carbon credits
Not Material
E1-10(was E1-8)Internal carbon pricing
Reported

Internal carbon pricing

Reference: page 58.

Humble Group states it "does not apply any internal carbon pricing schemes" (page 58).

E1-8 is listed in the IRO-2 index at page 58 (page 47), so this nil answer is the company's own disclosure under the requirement. It follows the GHG emissions intensity and biogenic emissions notes on the same page.

E1-11(was E1-9)Anticipated financial effects from material physical and transition risks and potential climate-related opportunities
Omitted

E3 – Water

E3-1Policies related to water and marine resources
Reported

Policies related to water and marine resources

Reference: page 59.

Water policy sits inside the Group's Environmental Policy. It sets an ambition to combine responsible growth with a continuous cut in environmental footprint, and names water among the natural resources to safeguard. It outlines preventive measures for Group companies to reduce pollution, including water pollution, but "does not yet outline specific actions for tackling areas at water risk" (page 59).

Environmental stewardship covers efforts to reduce water withdrawals and protect water quality. The Supplier Code of Conduct sets matching expectations for responsible environmental practices across the value chain (page 59).

E3-2Actions and resources related to water and marine resources
Reported

Actions and resources related to water and marine resources

Reference: page 59.

Humble Group "monitors and follows up on water withdrawals across all subsidiaries" (page 59). Reduction targets and a detailed action plan are still plans. The Group "intends to establish measurable water reduction targets in the future" and, over time, a more detailed plan to reduce water consumption, starting with the areas of highest water risk. In the supply chain it seeks preventive measures against sources of pollution, including water contamination. No resources or amounts are given.

E3-3Targets related to water and marine resources
Reported

Targets related to water and marine resources

Reference: page 59 (also page 56).

Humble Group "has not yet defined specific quantitative targets for water management" (page 59). The related commitment is the 2024 Board target for all Group-owned production facilities to reach ISO 14001 certification by 2030. The report says certification supports systematic monitoring of water consumption, compliance with water legislation and pollution prevention (page 59). Status in 2025 is 12%, 2 of 17 facilities (page 56). The Group says it aims to set clearer water targets in the future (page 59).

E3-4Water consumption
Reported

Water consumption

Reference: page 60 (estimates on page 34; restatement on page 35).

Water withdrawals were 92,629 m3 in 2025 (77,872 m3 in 2024). Of that, 22,589 m3 (24%) came from areas of high water stress and 70,040 m3 from low-stress areas. Water intensity was 126.6 m3 per MEUR of net revenue (115.5 in 2024).

Water consumption data is not available for 2025. The 2024 figure was first published as consumption but was withdrawals, and has been restated (page 35). No water is recycled, reused or stored at any Group facility.

Three production facilities sit in water-stressed or high-risk areas, mapped with the Aqueduct Water Risk Atlas (page 60). Where a subsidiary had no data, withdrawals were estimated from the average of other subsidiaries (page 60).

E3-5Anticipated financial effects from water and marine resources-related impacts, risks and opportunities
Omitted

E5 – Resource Use and Circular Economy

E5-1Policies related to resource use and circular economy
Reported

Policies related to resource use and circular economy

Reference: page 61.

The Environmental Policy covers resource use and circular economy principles. The report says the Group has "not yet set specific criteria for specific components". It describes three areas (page 61):

  • Product development: integrate circular economy principles into product and packaging design, using less material and more recycled, renewable and recyclable inputs.
  • Waste reduction across operations: structured measures to track waste flows, prevent waste, promote reuse and strengthen recycling, to minimize landfill.
  • End-of-life guidance: clear labeling and information so consumers can choose responsibly.

The Supplier Code of Conduct sets matching standards for suppliers (page 61).

E5-2Actions and resources related to resource use and circular economy
Reported

Actions and resources related to resource use and circular economy

Reference: page 61.

Humble Group has no central action plan. Each subsidiary sets its own plan to fit its business (page 61). Actions taken in 2025 by several subsidiaries:

  • Waste reduction and recovery: surplus production sometimes goes to animal feed; good-quality products with short shelf life are increasingly donated to charities; waste is source-separated; one subsidiary turns factory biowaste into biogas.
  • Packaging and materials: packaging sizes were adjusted to cut material use and waste, refill solutions were introduced to lower plastic use, and the share of certified, sustainably sourced paper, cardboard and plastic rose.
  • Recyclability: recycling instructions were added to some packaging.

No resources or amounts are given.

E5-3Targets related to resource use and circular economy
Reported

Targets related to resource use and circular economy

Reference: page 61.

In 2024 Humble Group adopted a Group-wide target of 100% recyclable packaging by 2030 for its own brands, in line with the EU Packaging Waste Regulation (EU 2025/40). The report says the target remains in place and ties it to its climate ambitions under E1.

Status in 2025: 100% (page 61). The E5-5 table gives a 96% recyclability rate for total product packaging (page 63). The report does not reconcile the two figures.

E5-4Resource inflows
Reported

Resource inflows

Reference: page 62 (restatement on page 35).

Inflows are raw materials and finished goods, packaging and other inputs. Raw materials and finished goods are tracked by spend, not weight; the Group intends to move to weight and material type. Packaging is tracked by weight, spend and material (page 62).

Purchased packaging was 8,801 tonnes in 2025 (23,890 in 2024):

  • plastic 2,786 t, of which 28% recycled or bio-based (12,775 t, 8%)
  • paper and cardboard 3,465 t, 85% recycled or certified (8,931 t, 65%)
  • wood 1,837 t, metal 470 t, glass 241 t, other 2 t
  • renewable packaging 61% (44%); recycled packaging 25% (25%)

Certified inputs named: "IP Livsmedel", RSPO-certified palm oil, Rainforest Alliance-certified cocoa butter and EU Organic soybeans; certifications do not cover all raw materials. The 2024 figure for one subsidiary was corrected after a units error (page 35).

E5-5Resource outflows
Reported

Resource outflows

Reference: page 63.

Humble Group's products are consumables meant for single use, which the report says limits circularity at product level. Packaging and production waste are the material outflows. Outflows are monitored half-yearly across all subsidiaries and consolidated centrally (page 63).

Product packaging totaled 10,672 tonnes in 2025 (8,529 in 2024). Recyclability rates:

  • plastic: 2,702 t, 87% (55% in 2024)
  • paper: 4,398 t, 99% (96%)
  • metal: 3,572 t, 100% (100%)
  • total: 96% (79%)

The report says it keeps working on packaging weight, volume and material mix, and on recyclability with suppliers and recycling partners (page 63).

E5-6Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities
Omitted
E5-5(was E5-5-Waste)Waste
Reported

Waste

Reference: page 64.

The Group generated 1,968 tonnes of waste in 2025 (1,568 in 2024). 58% was recovered or recycled rather than disposed of; 22% went to reuse, often animal feed or biogas from food residues (page 64).

Non-hazardous waste: 1,908 t (97%). Diverted from disposal 1,132 t (reuse 437, recycling 683, other recovery 12); directed to disposal 776 t (incineration 465, landfill 279, other 32).

Hazardous waste: 60 t (about 3%), mainly electronic equipment, batteries, chemicals, lamps, paint and oil. Diverted 9 t; directed to disposal 51 t, of which 50 t by other disposal operations.

Recycled waste was 1,141 t (58%) and non-recycled 828 t (42%).

S1 – Own Workforce

S1-1Policies related to own workforce
Reported

Policies related to own workforce

Reference: page 66.

Humble Group lists four policies for working conditions and labor rights (page 66):

  • Code of Ethics ("The Humble Way"): values and expected behavior, with standards for compliance and safe working conditions.
  • Human Rights Policy, based on the UN Guiding Principles on Business and Human Rights: equal opportunity, zero tolerance for discrimination and harassment, and a ban on forced labor, child labor and human trafficking.
  • Human Resource (HR) Policy: a safe and fair working environment, diversity and inclusion, and competitive pay and benefits.
  • Speak Up (Whistleblowing) Policy: how to file a report, handled under the EU Whistleblowing Directive (2019/1937).

The report says its policies "do not include specific commitments related to the inclusion of or positive action for vulnerable groups of people". It identifies no employees at significant risk of forced or child labor (page 66).

S1-2(was S1-2 + S1-3)Engagement with own workforce and workers' representatives, existence of channels for own workforce to raise concerns or needs and approaches to remedy
Reported
2023 ESRS S1-2Processes for engaging with own workforce and workers' representatives about impacts
Reported

Processes for engaging with own workforce and workers' representatives about impacts

Reference: page 66.

Since 2024 an annual employee engagement survey has collected anonymous feedback on motivation, training and development, remuneration and inclusivity. The Executive Team reviews the results and summarizes them for the Board.

The Group engages external employee representatives or legal counsel when needed for specific cases or grievances. It "does not have ongoing dialogue with workforce representatives outside of handling specific cases". The Speak Up channel gives any stakeholder a secure, anonymous route to the management team at any time (page 66).

2023 ESRS S1-3Processes to remediate negative impacts and channels for own workforce to raise concerns
Reported

Processes to remediate negative impacts and channels for own workforce to raise concerns

Reference: pages 66-67.

Humble Group says it complies with the EU Whistleblowing Directive (2019/1937). The Speak Up platform is run by a third party, reached through the intranet and website, and open to current and former employees and to external parties such as suppliers, contractors and customers. Cases go to the Executive Team and/or the Board depending on the case, and can be raised verbally and then filed on the platform. All cases are tracked with audit and activity logs (page 66).

Gaps the report states: awareness and trust of the platform are not measured, and platform users are not involved in assessing its effectiveness (page 66). The Group has "yet to define a standardized process for providing remedy". Each subsidiary handles cases one by one, and the effectiveness of remedial actions has not been evaluated (page 67).

S1-3(was S1-4)Taking action on material impacts on own workforce
Reported

Taking action on material impacts on own workforce

Reference: page 67.

Subsidiaries manage workforce impacts locally and allocate their own resources. The Group does not plan to centralize either. Actions a subsidiary may take: onboarding, continuous training, issuing safety gear and hygiene protection, emergency drills, first aid training for nominated representatives, continuous improvement of safety protocols, best practice sharing, and reassigning an employee or rescoping a role to mitigate repeated impacts. Departures from standard protocol must be documented and justified. Humble Group AB is responsible for making sure correct safety measures are in place, through governance and reporting, and supports subsidiaries where needed.

Positive-impact initiatives vary by subsidiary: wellness allowances, private health or dental insurance, and flexible or remote work. Under "Humble Gives Back" every employee may take one working day a year for community projects or charity.

The report says the effectiveness of these actions is not measured (page 67).

S1-4(was S1-5)Targets related to own workforce
Reported

Targets related to own workforce

Reference: page 67.

In 2024 the Group set two Group-wide targets for workforce impacts (page 67):

  • 60:40 male/female ratio in management positions by 2030. Status in 2025: 66:34.
  • Zero recordable workplace accidents by 2030. Status in 2025: 32 accidents.

Recordable accidents are those causing medical treatment beyond first aid, one or more days of absence, restricted work or reassignment, a serious injury or illness, loss of consciousness or death. Employees and their representatives were not engaged in setting the targets. HR, production line and warehouse managers contribute to progress against them.

S1-5(was S1-6)Characteristics of the undertaking's employees
Reported

Characteristics of the undertaking's employees

Reference: pages 67-68.

The Group had 1,282 employees at 31 December 2025 (1,262 in 2024), as headcount: 596 women (46%) and 686 men (54%), none other or undisclosed (page 68).

By contract: full-time 1,125 (88%) and part-time 157 (12%); permanent 1,193 (93%), temporary 55 (4%) and non-guaranteed hours 34 (3%). By country: Sweden 739 (58%), United Kingdom 133 (10%) and other countries 410 (32%) (page 68).

228 employees left in 2025, a turnover of 18%. The figure includes contracts ended in restructures and seasonal staff hired and released within the year (page 67).

S1-6(was S1-7)Characteristics of non-employee workers
Reported

Characteristics of non-employee workers

Reference: pages 66, 69.

Humble Group had 41 non-employees in 2025 (57 in 2024): 16 self-employed (39%) and 25 contractors (61%). In 2024 there were 38 self-employed (67%) and 19 contractors (33%) (page 69).

The report calls them a minor part of the workforce, typically in specialist roles for projects or operational needs such as finance, legal or technical work (page 69). They are "used strategically where external support is needed" (page 66).

S1-7(was S1-8)Collective bargaining coverage and social dialogue
Reported

Collective bargaining coverage and social dialogue

Reference: pages 69, 34.

53% of employees were covered by collective bargaining agreements in 2025. That includes 517 employees in Sweden, 70% of employees there (page 69).

BP-1 says Humble Group applied the phase-in rules to S1-8 for "details beyond total coverage" (page 34). The report gives only the two figures above, with no breakdown by country beyond Sweden and no social dialogue detail.

S1-8(was S1-9)Diversity metrics
Reported

Diversity metrics

Reference: page 69.

Top management (senior or executive-level roles): 47 women (34%) and 93 men (66%), 140 people in all, against 55 women (36%) and 98 men (64%) in 2024. The report says one subsidiary changed its management team to match the Group definition of management positions, which put all the women previously reported on that team outside the definition although they remain employed.

Age of employees: under 30, 319 (25%); 30 to 50, 691 (54%); over 50, 272 (21%).

The 2030 target is a 60:40 male/female ratio in management positions. Status in 2025: 66:34 (page 69).

S1-9(was S1-10)Adequate wages
Reported

Adequate wages

Reference: page 69.

The report states that all Humble Group employees were paid an adequate wage in 2025, measured against applicable wage benchmarks and national legislation (page 69). It gives no breakdown by country, no list of the benchmarks used and no count of employees below one. S1-10 is listed in the IRO-2 index at page 69 (page 48).

S1-10(was S1-11)Social protection
Omitted
S1-11(was S1-12)Persons with disabilities
Omitted
S1-12(was S1-13)Training and skills development metrics
Omitted
S1-13(was S1-14)Health and safety metrics
Reported

Health and safety metrics

Reference: page 70.

The HR Policy commits the Group to comply with health and safety law, to identify and minimize hazards, and to give adequate training and safety gear. The CEO of each subsidiary must ensure the commitments are met. A Board target adopted in 2024 sets zero recordable workplace accidents by 2030 (page 70).

Employees in 2025: 71% covered by a health and safety management system (65% in 2024); 0 fatalities; 32 recordable work-related accidents (27 in 2024). The table also gives a rate of recordable accidents of 9, 15 cases of recordable work-related ill health and 905 days lost to accidents and ill health (2024: rate 18, 2 cases, 457 days). Non-employees: 63% covered (88% in 2024), with no recorded cases in 2025.

Examples of accidents: hands caught in machinery, burns from hot water or dough, injuries from lifting and unpacking boxes, and falling items (page 70).

S1-14(was S1-15)Work-life balance metrics
Reported

Work-life balance metrics

Reference: page 70.

All employees are entitled to parental leave under applicable national legislation (100% entitled). In 2025, 10% of employees took family-related leave (12% in 2024): 73 women and 54 men, shown in the table as 6% female and 4% male (page 70).

The S1 impact on working conditions notes that working hours may be long or unfavorable for production shift and freight transport workers (page 66).

S1-15(was S1-16)Compensation metrics (pay gap and total compensation)
Reported

Compensation metrics (pay gap and total compensation)

Reference: page 71 (also page 43).

Gender pay gap: 10% in 2025 (11% in 2024). The report defines it as the average difference between the median base salaries for men and women across the subsidiaries. Annual total remuneration ratio: 29 (27 in 2024). It is calculated as the ratio between the total compensation of each subsidiary's highest-paid employee and the CEO of Humble Group AB, and the average median compensation of all other employees across the reporting entities (page 71).

The SBM-3 table links the pay gap to the material impact on equal treatment: an underrepresentation of women in management positions contributes to a noticeable gender pay gap (page 43).

S1-16(was S1-17)Incidents, complaints and severe human rights impacts
Reported

Incidents, complaints and severe human rights impacts

Reference: page 71.

No cases of discrimination, including harassment, were reported in 2025, directly or through the Speak Up platform (one incident in 2024). Complaints through channels for the workforce to raise concerns: 0 (1 in 2024). Complaints to OECD National Contact Points: 0. Severe human rights incidents connected to the own workforce: 0.

The report says no material fines or penalties were paid in 2025 for violations of human rights factors connected to the own workforce (page 71).

S2 – Workers in the Value Chain

S2-1Policies related to value chain workers
Reported

Policies related to value chain workers

Reference: page 72.

Policies (page 72):

  • UN Global Compact signatory since 2022, committed to its ten principles, including human and labor rights.
  • Human Rights Policy: safe, healthy and productive workplaces, and a ban on forced labor, child labor and modern slavery. It officially governs Humble Group employees only; suppliers and partners are encouraged to adopt the same.
  • Supplier Code of Conduct: human rights and labor standards that suppliers and subcontractors are urged to uphold.

Subsidiary CEOs are responsible for implementing the standards. The Code is sent each year for signature on Worldfavor, and over 100 suppliers signed in 2025. No violations of international standards (UN Guiding Principles, ILO Declaration, OECD Guidelines) were reported in 2025. The Group has yet to define its process for remedy of violations against value chain workers.

S2-2(was S2-2 + S2-3)Engagement with workers in the value chain, existence of channels for workers in the value chain to raise concerns or needs and approaches to remedy
Reported
2023 ESRS S2-2Processes for engaging with value chain workers about impacts
Reported

Processes for engaging with value chain workers about impacts

Reference: pages 72-73.

As of 2025 Humble Group had not set up a process to engage directly with value chain workers to inform decisions or actions on its potential negative impacts (page 72). Engagement is with suppliers: the Supplier Code of Conduct is distributed once a year for signature on the Worldfavor platform. Direct engagement with workers or their representatives is something the Group hopes to introduce in the coming years, as part of its supply chain due diligence work (pages 72-73).

2023 ESRS S2-3Processes to remediate negative impacts and channels for value chain workers to raise concerns
Reported

Processes to remediate negative impacts and channels for value chain workers to raise concerns

Reference: pages 72-73.

The Group has not yet defined a process to remediate negative impacts on value chain workers. As of 2025 no cases had been raised, and a Group-wide escalation and remedy process is still to be defined (page 72).

The channel is the Speak Up (Whistleblowing) platform, which is external, reached through the intranet and website, and open to current and former employees, value chain workers, suppliers and customers. Reports can be named or anonymous and go to the subsidiary, the Executive Team or the Board depending on the case. Cases are tracked in audit and activity logs, but users are not involved in assessing effectiveness, and the Group does not assess whether value chain workers know the platform exists (page 72). The policy protects whistleblowers from retaliation, with disciplinary action for anyone who retaliates (page 73).

S2-3(was S2-4)Taking action on material impacts on value chain workers
Reported

Taking action on material impacts on value chain workers

Reference: page 73.

Humble Group says it has material impacts and risks for value chain workers, upstream and downstream, and has taken "initial steps" (page 73):

  • It has started mapping its supply chain in Worldfavor and uses the platform to engage some suppliers. The Supplier Code of Conduct is sent every year with digital opt-in signatures. The platform is to be rolled out to more suppliers over time.
  • Subsidiary CEOs work under CEO Instructions that record their responsibility to uphold the Group's values and policies.

The effectiveness of these actions has not been tracked. Action plans, remediation plans and effectiveness tracking are areas the Group plans to develop. Resources are limited to the Sustainability Team's time on supply chain due diligence and the annual budget for the Worldfavor agreement (page 73).

S2-4(was S2-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Reported

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

Reference: page 73.

Humble Group "has not yet set targets to reduce its potential negative impacts on value chain workers". Discussions of potential targets have taken place internally. Any targets set will follow relevant regulatory requirements, with the Corporate Sustainability Due Diligence Directive given as an example (page 73).

G1 – Business Conduct

G1-1Business conduct policies and corporate culture
Reported

Business conduct policies and corporate culture

Reference: page 75 (also page 43).

Policies listed (page 75):

  • Code of Ethics ("The Humble Way"), for all employees
  • Supplier Code of Conduct, setting the business conduct expected of suppliers and subcontractors
  • HR Policy, a safe, fair and positive work environment
  • Anti-Bribery and Corruption Prevention Policy, the behavior expected to avoid situations where bribery or corruption may arise
  • Environmental Policy; animal welfare is "not expressly mentioned", though biodiversity and the protection of natural habitats are included
  • Speak Up (Whistleblowing) Policy, with a commitment to no retaliation, compliant with the EU Whistleblowing Directive (2019/1937)

Four values sit at the core of the culture: innovation, entrepreneurship, passion and integrity. They are communicated at onboarding and expected in every employee's conduct (page 75). The SBM-3 table links the Supplier Code of Conduct to the UN Global Compact (page 43).

G1-2(was G1-2 + G1-3)Actions related to business conduct
Partly reported
2023 ESRS G1-2Management of relationships with suppliers
Not Material
2023 ESRS G1-3Prevention and detection of corruption and bribery
Reported

Prevention and detection of corruption and bribery

Reference: page 75.

The Speak Up (Whistleblowing) platform is the main process for reporting and investigating bribery and corruption, or suspected cases. Cases go to the relevant case manager and are overseen by the Executive Team and the Board (page 75).

Distributing the policies and giving training on responsible business conduct and bribery mitigation is the job of each subsidiary CEO. Subsidiaries are expected to give training and resources to teams at particular risk. The Group gives no formal training on the topic to its own administrative or supervisory bodies.

No function is identified as at material risk of corruption or bribery. The report adds that, if it occurred, purchasing or sales managers who negotiate contracts with suppliers or B2B customers might be affected (page 75).

G1-3(part of MDR-T/GDR-T disclosures)Targets related to business conduct
New in 2026 standards
G1-4Incidents of corruption or bribery
Reported

Incidents of corruption or bribery

Reference: pages 75, 50.

"In 2025, Humble Group had no known incidents of bribery or corruption occurring" (page 75). The G1 text repeats that no cases of bribery or corruption have been raised, and says the extensive supply chain makes governance far upstream or downstream difficult (page 75).

No convictions or fines are reported. The EU Taxonomy minimum safeguards section adds that no cases of violation or suspected violation of competition law were raised in 2025 and that there were no material tax disputes (page 50).

G1-5Political influence and lobbying activities
Not Material
G1-6Payment practices
Not Material