Husqvarna AB

Governance roles

Reference: page 46.

The Board has 10 members, all non-executive: 40 percent female and 60 percent male, with 50 percent independent. The report states that "The Board consists of 2 employee representatives" (page 46). The Board is supported by the Audit Committee and the People Committee.

Who owns what (page 46):

• The Board "holds overall responsibility for the Group's sustainability agenda". The Audit Committee oversees broader sustainability ambitions, skills, target-setting, progress monitoring and sustainability-related disclosures.
• Sourcing matters sit with the Sourcing Board, a sub-committee of Group Management. Ethics and integrity issues go to the Audit Committee quarterly. Product safety is overseen by the Committee on Product Safety.
• Day-to-day responsibility is delegated to the Group CEO and Group Management. A Sustainability Committee reviews performance against the material IROs, and a cross-divisional Sustainability Network carries out the initiatives.

For business conduct, the Board approves the Group Code of Conduct (page 46).

Information to the Board and management

Reference: page 46.

Material IROs reach the Board through the double materiality assessment: "the identified material IROs are reviewed and approved by the Group Management and Board of Directors". The DMA runs "on a periodic basis, with additional yearly interim reviews" (page 46).

Each material ESRS topic has a designated Topic-owner, who leads a cross-divisional Topic team. The team turns policies into metrics and targets where applicable and plans the actions. Progress goes into recurring reports to all levels of sustainability management.

In 2025 (page 46):

• Performance on material IROs was discussed quarterly with Group Management in the Sustainability Committee.
• The Board held several sessions on the 2030 strategy, covering decarbonization levers, trade-offs between emissions and growth, and circular offerings.
• Risks from putting the strategy into practice went into the annual ERM reviews.

Incentive schemes

Reference: pages 47, 91-92. The company incorporates this disclosure by reference to Note 4 to the Financial Statements (page 47).

Climate sits inside the long-term incentive programs: "The LTI 2023, 2024 and 2025 programs have a weight of 90% on value creation and 10% on Carbon dioxide (CO2) emission reduction" (page 92). The programs vest over three years as performance share awards.

LTI 2023 result (page 92): the CO2 reduction target levels were -33% (entry), -35.0% (target) and -37% (stretch), and the result was -55.6%. Value creation came in at SEK -2,238m against an entry level of SEK 4,000m. The total result was 10.0% of the maximum number of shares, which equals the 10% weight of the CO2 measure.

Other members of Group Management receive variable salary "based on annual targets", up to 80 percent of fixed salary (page 92).

Statement on due diligence

Reference: page 47.

The statement is a mapping table, not a narrative: "Information about Husqvarna Group's due diligence is found in the below sections."

The table names no G1 section.

Risk management and internal controls over sustainability reporting

Reference: pages 46, 79. Page 47 lists GOV-5 points 36(a) to 36(e) as incorporated by reference to "Internal Control over Financial and Sustainability Reporting" (page 79).

The approach follows the COSO framework. The Board is ultimately responsible for the internal control system. "In 2025, internal controls over sustainability reporting for the most material sustainability matters were deployed" (page 79).

• Risk assessment: "Risks relating to financial and sustainability reporting are evaluated and monitored by the Board through the Audit Committee" (page 79).
• Controls: a Sustainability Reporting Manual sets the reporting rules, and internal control requirements exist for material sustainability matters. A dedicated Internal Control function maintains the framework.
• Monitoring: Group Finance follows up on reporting quality, Country Officers are appointed in each country with at least one active subsidiary, and Group Internal Audit reports directly to the Audit Committee.

Strategy, business model and value chain

Reference: pages 39-40.

Husqvarna Group sells through three divisions, Husqvarna Forest & Garden, Gardena and Husqvarna Construction, mainly under the Husqvarna and Gardena brands. Products reach users "in more than 100 countries" through direct sales, dealers and retailers (page 39). Net sales were SEK 46,613m (page 52). The division revenue breakdown is on pages 27-28 (page 40). The Group also supplies alkylate fuel, with revenue of SEK 1,022m at December 31, 2025 (page 40).

The 2025 strategy rests on three priority areas, Carbon, Circular and People, with 2030 Carbon and Circular targets (page 40).

Value chain model (page 39), material topics by stage:

• Upstream (suppliers, material extraction, components, business services): E1, E5, S2, G1.
• Own operations (research and development, finished goods production): E1, E5, S1, G1.
• Downstream (sales partners, customers): E1, E5, S2, S4, G1.

Employee information is in S1-6 (page 40).

Interests and views of stakeholders

Reference: page 43.

The company engages five stakeholder groups (page 43):

• Employees: performance dialogues, townhalls, unions, worker representatives, employee-elected Board members and surveys.
• Customers: divisional customer dialogue and surveys, and partnerships with corporate customers.
• Suppliers and supply chain employees: supplier due diligence, on-site assessments and industry collaborations.
• Investors: Investor Relations activities, periodic updates and capital markets days.
• Sales partners: workshops, advisory boards, surveys and digital platforms.

Group Management "receives regular updates on stakeholder perspectives" and the Board is briefed at varying intervals. "In 2025, no material changes were made to the strategy or business model based on stakeholders' interests" (page 43).

Material impacts, risks and opportunities

Reference: pages 40-43.

The DMA was run in 2024, and no change to strategy or business model followed in 2025 (page 40). The tables on pages 40-41 list 22 IROs, against a stated total of 23 (page 44):

• E1 (6): weather-driven demand risk, a smart irrigation opportunity, carbon emissions (negative impact), limited customer acceptance of robotic and battery products (risk), a growing market for them (opportunity) and energy consumption (negative impact).
• E5 (5): virgin resource use, material availability, circular design trade-offs, new business models and aftermarket.
• S1 (4), S2 (4), S4 (1), G1 (2).

"All impacts identified in E1 and E5 are generated through our own operations and business relationships" (page 40). "By the end of 2025, the Group had not conducted a resilience analysis of its business model in relation to these material IROs" (page 40). A climate resilience analysis was conducted in 2025 (page 42). The S1, S2 and S4 narratives (pages 42-43) each say no positive impacts or material risks were identified for that topic.

Process to identify and assess IROs

Reference: pages 44-45.

The DMA followed EFRAG guidance "complemented by our own interpretation of the standards" and is reviewed every year (page 44). Internal subject matter experts from all three Divisions, Group functions and Enterprise Risk Management took part. "Although no external stakeholders were directly consulted during the DMA process, their perspectives were indirectly reflected through insights gathered by internal teams" (page 44).

Scoring (page 44): impacts are scored 1 to 5 on scale, scope and irremediable character, plus likelihood for potential impacts. Risks and opportunities are scored 1 to 5 on the size of the effect on EBIT and on likelihood. An IRO is material when its overall score is high or very high.

"The outcome of the DMA was approved by the Board of Directors in December 2024." 23 IROs were material across 12 sustainability matters. E2, E3, E4 and S3 were not assessed as material (page 44).

Topic sections follow for E1 (three time horizons, RCP scenarios), E5 (internal specialists, no external consultancy) and G1 (location, activity and sector as criteria) on page 45.

Disclosure requirements covered

Reference: pages 46, 70-72.

The statement's own rule: "IROs with a result of high or very high were deemed material", and "IROs below the threshold were not included in the Sustainability Statement" (page 46).

ESRS index (pages 70-71) lists ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2), E1, E5, S1, S2, S4 and G1. Each DR carries a page reference or a dash. Seven DRs carry a dash: E1-9, E5-6, S1-7, S2-2, S2-3, S4-2 and S4-3, with phase-in notes beside them. GOV-3 (pages 91-92) and GOV-5 (page 79) point to other parts of the report.

The S1 block lists S1-1 to S1-7, S1-9 and S1-14. The G1 block lists G1-1 to G1-4. Nothing is listed for E2, E3, E4 or S3.

Page 72 adds a table of datapoints derived from other EU legislation, with page numbers or marks such as "Not material" and "Phase-in".

Transition plan for climate change mitigation

Reference: pages 50-51.

Target: "By 2030, Husqvarna Group aims to reduce absolute CO2 emissions across the value chain by 60 percent compared to the 2015 baseline" (page 50), which is 44 percent against 2022. Net zero is the ambition for 2050 (page 45). The plan chart takes total emissions from 4,195 thousand tCO2 in 2025 to 3,555 in 2030: upstream -90, own operations -10, product use -540 (page 50).

Locked-in emissions (page 50): upstream, supplier production on fossil-based energy; own operations, heating, machinery and fleet that depend on natural gas and other fossil fuels; downstream, "the largest contributor to locked-in emissions" is the use of sold products.

Status: the plan "is subject to approval in accordance with the Group's governance processes", and "As implementation has not yet commenced, progress will be reported in the next reporting year" (pages 50-51).

Funding (page 51): CapEx goes to EU Taxonomy activities CCM 3.6 and CE 5.5, and two Green Bond series total SEK 2,750m. No significant CapEx went to coal, oil and gas activities.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and SBM-3, where this content is disclosed in the FY2025 report (pages 42, 44-45). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Horizons (page 45): 1-3 years, 2030 and 2050, across upstream, own operations and downstream.

Scenarios (page 45):

• Physical risk: RCP 2.6, RCP 4.5 and RCP 8.5, applied with site coordinates. RCP 4.5 was used specifically for own operations. RCP 8.5 is the high-emission case.
• Transition risk: RCP 2.6 (net-zero, "consistent with limiting warming to 1.5°C") and RCP 8.5 (business-as-usual).

Risks found (page 42): one acute physical risk (heatwaves, downstream), chronic physical risks (heat stress, shifting precipitation, drought) and one transition risk, customer acceptance of the shift from petrol to battery products.

Method (page 45): a quantitative physical assessment of own locations, a simplified qualitative one for the wider value chain, and an internal assessment of selected key suppliers. The report gives radiative forcing per scenario, not global temperature projections. It does not say when the scenario analysis itself was done; the resilience analysis that used these scenarios was conducted in 2025 (page 42).

Resilience in relation to climate change

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

"In 2025, the Group conducted a climate resilience analysis to assess potential risks and opportunities across the value chain" over short term (1-3 years), medium term (up to 2030) and long term (up to 2050) (page 42).

Method: qualitative, "focusing on identifying exposures and potential vulnerabilities", carried out by internal subject matter experts including risk management, using the scenarios in IRO-1. Upstream scope covers major supplier regions, with emphasis on Asia, Europe and the U.S. Own operations covers all key production and operational facilities. Downstream covers end-users in Europe and the U.S.

Uncertainty: the analysis recognizes uncertainties linked to regulation, technology, market dynamics and weather variability.

Conclusion: "Husqvarna Group concludes that its business model is resilient to material climate-related risks." "The Group has not re-assessed the financial impacts of material risks and opportunities within this analysis" (page 42).

Policies related to climate change mitigation and adaptation

Reference: page 51.

Three policies are described, each with a named owner (page 51):

• 2025 Sustainovate strategy: sets the direction for the low-carbon transition through electrification, smart solutions and energy efficiency, backed by science-based targets validated by the SBTi. Owner: the Group CFO.
• Supplier Code of Business Ethics: expects suppliers to reduce greenhouse gas emissions, improve energy efficiency and limit environmental impact, with a specific focus on decarbonization. Owner: the General Counsel, Executive Vice President Legal Affairs.
• Enterprise Risk Management Policy: covers climate-related risks alongside other business risks and sets roles for identification, evaluation, mitigation and escalation. It applies to all employees globally. Owner: the Vice President, Risk Management, within Group Legal Affairs.

Actions and resources in relation to climate change policies

Reference: pages 51-52; EU Taxonomy pages 66-69.

Use of sold products is "approximately 68 percent" of the CO2 footprint, so the main lever is the move from petrol to electric products (page 51).

• Electrification (page 51): three new robotic mowers (Automower 560 EPOS, 580 EPOS and 580L EPOS), the 550iXP battery chainsaw, the Z245i zero-turn mower and the Rider R200iX AWD.
• Own operations (page 51): HVAC upgrades and LED lighting. At Gardena's Niederstotzingen site a 634 kWp solar installation produces about 650 MWh a year, nearly 20 percent of site demand. A Power Purchase Agreement from July 2025 covers around 40 percent of electricity use in Germany.
• Construction (page 51): equipment for a fully electrified job site at the Siemens campus in Erlangen.
• Smart watering (pages 51-52): Gardena AquaPrecise and AquaBloom Solar Set.

Resources (page 52): the E1-3 text states no budget for these actions; Taxonomy-aligned CapEx of SEK 278m (10 percent of SEK 2,716m) is on page 68. The Net-Zero Transition Plan "will require additional resources and investments", with feasibility studies in the annual financial cycle.

Targets related to climate change mitigation and adaptation

Reference: page 52 (progress: pages 49, 53).

"Husqvarna Group has set a combined Scope 1, 2, and 3 emissions reduction target aligned with a 1.5°C decarbonization pathway" (page 52): 60 percent lower absolute emissions across the value chain by 2030 against 2015, or 44 percent against 2022. 2015 is the baseline year and 2022 the reference year for CSRD reporting.

• Scope 3 is 99.1 percent of emissions, Scope 1 is 0.5 percent and Scope 2 market-based 0.4 percent.
• "GHG removals, carbon credits, or avoided emissions are not included in achieving this target."
• Emissions fell 53 percent between 2015 and 2025 (page 52), ahead of the 2025 target of 35 percent (page 53). Page 49 gives 56 percent for the same period.
• Progress is tracked monthly and reported quarterly. The Board approved the targets as strategic objectives.

The pathway is cross-sectoral and needs a 42 percent cut between 2020 and 2030, because "our industry does not yet have a defined sector-specific trajectory" (page 50). Transport emissions are excluded from the 2030 target as not material.

Energy consumption and mix

Reference: page 52.

Total energy consumption was 258,280 MWh in 2025.

Energy intensity is 5.54 MWh per SEKm of net revenue (SEK 46,613m); all three divisions count as high climate-impact sectors. Non-manufacturing sites are estimated from floor area, and group vehicles from fuel records for markets with 88 percent of net sales. Uncertainty is rated low. The 2025 boundary change "limits comparability with 2024 results" (page 47).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: page 53 (method: pages 47, 53).

Total location-based is 4,236,454 tCO2eq. Intensity is 91 (location-based) and 90 (market-based) tCO2eq per SEKm. Only Scope 3 categories 1 and 11 are reported, as the two judged material. Uncertainty is rated high upstream, low for own operations and medium downstream. Category 1 moved to an LCA method in 2025, which limits comparability with 2024 (page 47).

Policies related to resource use and circular economy

Reference: page 54.

Two policy documents are described (page 54):

• 2025 Sustainovate strategy: aims to cut dependence on scarce and virgin materials, limit environmental impact and move to a circular business model through the 5Rs: reduce, reuse, repair, refurbish and recycle. It covers all divisions, geographies and value chain stages, and addresses resource scarcity, supply dependency and circular design, new business models and recycled materials. Owner: the Group CFO.
• Supplier Code of Business Ethics: requires natural resources to be managed responsibly. The report is candid about its limits: "At present, however, the document does not outline specific actions or set requirements for how suppliers should progress toward more sustainable practices." Owner: the General Counsel, Executive Vice President Legal Affairs.

Actions and resources related to resource use and circular economy

Reference: pages 54-55; EU Taxonomy pages 66-69.

• PVC hose recycling (Gardena): 128 hoses made with about 60 percent recycled content, saving around 190 kg of virgin material. The report calls the scale "modest".
• Diamond wire plastic (Husqvarna Construction, Portugal): process changes allow reuse of a substantial share of discarded plastic.
• Less material: replacing the physical reference station with EPOS via cloud avoided 70 tons of electronic equipment in 2025. Gardena AquaPrecise may cut installed materials by as much as 70 percent for representative lawns.
• Leasing and service: Forest & Garden service contract value rose 25 percent in 2025, with operational leasing in nine European markets and the U.S. (page 55).
• Aftersales: the "PandA" (Parts and Accessories) program covers sales training, repair processes, IT for spare parts pricing and a digital supply chain platform (page 55).

Resources (page 55): no amount is stated. Circular initiatives need "additional resources and investments", and Taxonomy activities CE 5.2 and CE 5.5 are cited.

Targets related to resource use and circular economy

Reference: page 55.

The Group set a target to launch 50 circular innovations between 2021 and 2025. By year-end, 49 had been launched under Group criteria (page 55).

What the target measures: the number of initiatives, across suppliers (recycled material sourcing), own operations (circular design and manufacturing), product use (aftersales and business models) and end-of-life, "rather than directly quantifying environmental impact". "The target is not focused on waste handling."

Governance: divisions generate ideas and projects, and a project needs "proof of concept through at least one paying customer". Projects are reviewed and approved quarterly, tracked quarterly and reported in quarterly reports. The target was set voluntarily by internal experts with support from researchers at KTH Royal Institute of Technology. As no accepted method existed, the Group wrote its own criteria for a Circular Innovation.

New 2030 targets are mentioned, with progress "disclosed in the next report".

Resource inflows

Reference: page 55.

The Group buys steel, aluminum, magnesium, plastics and electronic parts (circuit boards, cables, battery cells), minerals including tin, tungsten, tantalum, gold, cobalt, mica, nickel, lithium, copper and graphite, and packaging such as cardboard, plastics and wooden pallets. Water and property, plant and equipment are treated as non-material.

• Total weight of products and materials used in 2025: ca. 262 thousand tons.
• Top five by weight (adjusted by sales): steel, polypropylene, polyvinyl chloride, cardboard and aluminum.
• Verified sustainably sourced biological materials: 0 percent, as there is no systemic process to confirm it.
• Secondary recycled materials: ca. 32 thousand tons, 12 percent of total material use, mostly steel and aluminum.

Method: a simplified LCA on representative products by group, built from bill of materials data and extrapolated across the portfolio. Recycled content for metals uses global averages. The Group rates uncertainty as high.

Resource outflows

Reference: page 56.

The Group applies a 5R framework (reduce, repair, reuse, refurbish, recycle) to design for durability and reparability, backed by spare parts, aftersales, operational leasing and refurbishment. It also states that "industry averages for product lifetimes or standardized product testing procedures have not been established for the relevant product groups", which prevents benchmarking.

• Reparability: the French Reparability Index score was 8.8 on a 1-10 scale in 2025, for robotic, electric and battery lawn mowers and high-pressure washers. Uncertainty is low.
• Recyclability: about 50 percent of the material content of products and packaging is estimated to be recyclable. Plastics and certain other materials are assumed to be 0 percent recyclable, which the report calls conservative. Uncertainty is high.

The report does not give waste figures; see E5-5-Waste.

Policies related to own workforce

Reference: page 58.

Four policies are described, with named owners (page 58):

• Diversity and Inclusion Strategy (launched 2021, seven Principles of Inclusion): covers workforce diversity, inclusive culture, inclusive leadership and external validation. Owner: the Executive Vice President, People & Organization.
• Code of Conduct: global commitment to fair employment, inclusion and integrity. It "prohibits forced and child labor, human trafficking, and harassment", in line with the UN Global Compact, the ILO Declaration and the OECD Guidelines. Owner: the General Counsel, Executive Vice President Legal Affairs.
• Anti-harassment Policy: covers discrimination and bullying, sets reporting procedures and bars retaliation. Owner: the Executive Vice President, People & Organization.
• Occupational Health and Safety Policy: aims to prevent work-related injuries and illness, and applies globally. Owner: the Executive Vice President, People & Organization.

"The Group does not have a dedicated policy for workforce planning."

Taking action on material impacts on own workforce

Reference: pages 59-60.

• Health and safety: dedicated safety professionals at major manufacturing sites, and Occupational Health and Safety and Environmental Networks that review incidents monthly (page 59).
• Workload and wellbeing: manager training, structured health dialogues, confidential 24/7 support where short-term absences point to wellbeing issues, and individual return-to-work programs.
• Diversity: in 2025 the Group Management Team reached 50/50 gender balance for the first time. Women are 30 percent of people managers, and 41 percent of newly hired people managers were women, up from 31 percent in 2024.
• Restructuring: accelerated cost-saving, "selected job redundancies", and the divestment of the Orangeburg plant to Flex Ltd. Affected people received severance packages, job search help and career counselling. The Battery Competence Centre builds electrification and robotics skills.

Resources (page 60): "Dedicated personnel within the People & Organization function manage workforce-related activities, supported by defined budget allocations for planned initiatives."

Targets related to own workforce

Reference: page 60.

The statement says: "The Group has not established a target in this area but monitors the effectiveness of its policies and actions as outlined in the previous sections" (page 60).

What is monitored, per the S1-4 text (page 59): health and safety through monthly reviews in the OHS governance networks, central tracking of incidents, closure rates and recurrence; wellbeing through absence patterns, use of support services and employee feedback; diversity through analytics, leadership representation, promotion and hiring data; workforce transition through redeployment rates, attrition trends and employee consultations.

Group Management reached 50/50 gender parity in 2025 (pages 58-59), but this is presented as an outcome, not a target.

Characteristics of the undertaking's employees

Reference: page 60.

Headcount is a 12-month average from the Group HR system: 12,275 employees. Leavers are counted at December 31, 2025.

Turnover: 2,397 leavers, a rate of 20 percent (female 20, male 19, other 21).

The employee count in Note 4 (page 91) is in full-time equivalents and "is therefore not fully comparable to headcount figures presented elsewhere in the sustainability statement" (page 60). Countries above 10 percent of employees are shown separately.

Diversity metrics

Reference: page 60.

Figures are 12-month averages from the Group HR system. Gender and age follow the classifications and date-of-birth data in the system. Positions sit in 12 job levels under the Group's career architecture.

Group Management itself reached 50/50 gender parity in 2025 (page 58). The report says the representation of women in top management and the overall workforce "remains below the Group's ambitions" (page 41).

Health and safety metrics

Reference: page 60.

The Group "applies the simplification option under the ESRS S1 standard" and covers its own employees only, "except for the number of fatalities, which includes all individuals working at the Group's premises". Hours worked come from clocking systems or standard hours under national law, less leave. The report notes possible over-estimation where other absences are not deducted, and rates uncertainty as low. Ill-health data are subject to legal restrictions on collection.

Policies related to value chain workers

Reference: page 61. The index flags this DR "Phase-in option used, disclosed in line with ESRS 2, paragraph 17" (page 71).

Two policies are described, both owned by the General Counsel, Executive Vice President Legal Affairs (page 61):

• Supplier Code of Business Ethics, built on the Group Code of Conduct. It sets expectations on ethical practices, legal compliance, human rights and environmental responsibility. Suppliers must follow rules against bribery, corruption, forced labor and child labor, and meet standards on fair employment, conflict minerals and workplace health and safety. Screening tools assess and monitor suppliers and other third parties.
• Whistleblower policies, Group-wide and EU-specific. Employees and stakeholders, including value chain workers, can report concerns confidentially or anonymously, with protection from retaliation. Channels include a third-party-hosted platform with multi-language support.

Taking action on material impacts on value chain workers

Reference: page 61. The index flags this DR "Phase-in option used, disclosed in line with ESRS 2, paragraph 17" (page 71).

The company took a risk-based approach, focused on direct material suppliers, and tracks "the number of suppliers completing assessments" as its key metric (page 61).

• EcoVadis: 96 high-risk suppliers completed the assessment in 2025, against 116 in 2024. Low scores or negative on-site audit findings lead to corrective action plans and reassessment. These plans "are not yet mapped against the material IROs", and the Group is reviewing its approach.
• IT sourcing: scope grew to IT hardware, software and service providers. 112 IT suppliers were asked to complete the Technology Sustainability Index in a first-year pilot.
• Conflict minerals: all four material negative impacts relate to minerals in electronics and battery products. Due diligence goes beyond direct suppliers, uses the Responsible Minerals Initiative template and covers tin, tungsten, tantalum, gold, cobalt, mica, nickel, lithium, copper and graphite.

"In 2025, no significant operational or capital expenditures were incurred in this area."

Targets related to value chain workers

Reference: page 61. The index flags this DR "Phase-in option used, disclosed in line with ESRS 2, paragraph 17" (page 71).

The statement says: "The Group has not established a target in this area but monitors the effectiveness of its policies and actions as outlined in the previous sections" (page 61).

What it tracks, per the S2 actions text (page 61): the number of high-risk suppliers completing the EcoVadis assessment (96 in 2025, 116 in 2024), the 112 IT suppliers asked to complete the Technology Sustainability Index, and corrective action plans for suppliers with low scores or negative on-site audit findings. The Group says those plans "are not yet mapped against the material IROs" for this topic.

Policies related to consumers and end-users

Reference: page 62. The index flags this DR "Phase-in option used, disclosed in line with ESRS 2, paragraph 17" (page 71).

Two policies are described (page 62):

• Product Compliance Policy: sets expectations for complying with laws, directives, regulations and standards on product design, operation, content, chemical composition and safety. It defines roles and sets governance, monitoring and escalation. It applies to all employees globally and to all products manufactured, sourced or supplied by the Group. Owners: the Divisional Presidents in their divisions.
• Product Safety Policy (Group Product Safety and Committee on Product Safety Reporting Policy): requires continuous monitoring of potential safety issues, prompt investigation, and remedial action including recalls or other market interventions. It applies across all divisions and product lines. Owners: the General Counsel, Executive Vice President Legal Affairs, and the Divisional Presidents.

Taking action on material impacts on consumers and end-users

Reference: page 62. The index flags this DR "Phase-in option used, disclosed in line with ESRS 2, paragraph 17" (page 71).

The Group uses a "threefold approach to product safety" (page 62):

1. Innovating and designing features that assist operators.
2. Raising safety awareness for users and bystanders through product literature and other media.
3. Taking part in developing standards, such as those from the IEC and ANSI.

2025 activity (page 62): 10 meetings of the Committee on Product Safety (COPS), the Group-level advisory body on potential safety issues; ongoing awareness training on the Product Compliance and Product Safety policies; and 3 audits under the product compliance audit program, which checks selected sites against Group policy. Where action is needed the Group follows each country's rules, which "may include suspending sales or initiating a product recall".

"In 2025, no significant operational or capital expenditures were incurred in this area."

Targets related to consumers and end-users

Reference: page 62. The index flags this DR "Phase-in option used, disclosed in line with ESRS 2, paragraph 17" (page 71).

The statement says: "The Group has not established a target in this area but monitors the effectiveness of its policies and actions as outlined in the previous sections" (page 62).

The monitoring described in the S4 section covers the work of the Committee on Product Safety (10 meetings in 2025), the product compliance audit program (3 audits in 2025) and awareness training on the Product Compliance and Product Safety policies. No figures on recalls, safety incidents or complaints are given in the S4 section.

Business conduct policies and corporate culture

Reference: page 64.

The ethical framework rests on the Group Code of Conduct (described under S1, page 58), the Supplier Code of Business Ethics and the Whistleblower policies (described under S2, page 61).

Reporting channels: employees, officers, directors and business partners can report through managers, HR, a dedicated compliance email or the third-party AlertLine, which supports multilingual and, where permitted, anonymous reporting. The Group General Counsel and Chief Compliance Officer handle reports confidentially, and local channels exist under the EU Whistleblower Directive. Good-faith reporters are protected from retaliation. The Audit Committee gets regular updates on cases and outcomes.

Training: eLearning and live sessions on the Code of Conduct, compliance policies and function-specific topics, including anti-bribery. White-collar employees complete mandatory, risk-based training annually, and blue-collar employees attend tailored sessions at least every three years. Completion rates and engagement metrics are tracked.

Targets related to business conduct

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

Husqvarna Group sets no business conduct target. The statement says: "The Group has not established a target in this area but monitors the effectiveness of its policies and actions as outlined in this section" (page 65).

Consistent with MDR-T, effectiveness is tracked in the absence of a target:

• "Completion rates and engagement metrics are tracked to measure effectiveness and reach" for business conduct training (page 64).
• 43 percent of at-risk functions were covered by anti-bribery and anti-corruption training in 2025 (page 65).
• All compliance concerns are logged in AlertLine, and Board and Group Management members get regular updates on ongoing and closed investigations, including lessons learned (pages 64-65).
• The Audit Committee gets regular updates on reported cases and outcomes (page 64).

Incidents of corruption or bribery

Reference: page 65.

"During the reporting period, no convictions or fines were issued against Husqvarna Group for violations of anti-corruption or anti-bribery laws" (page 65).

On breaches of anti-corruption and anti-bribery procedures, the Group "strengthens controls, provides additional training, adjusts systems to prevent similar cases in the future, and, where necessary, enforces disciplinary actions, including dismissal".

The section gives no count of confirmed incidents, reports received or cases closed, and no table. The only quantified item is the statement that no convictions or fines occurred.