ICA Gruppen

Reference: page 74.

The Board of Directors adopts ICA Gruppen's Sustainability Policy and "is also responsible for the structure of ICA Gruppen's sustainability reporting and for monitoring sustainability work." The Board has established a Sustainability Committee that "validates the results of ICA Gruppen's double materiality assessment and decides the Group's climate transition plan."

The Board has 11 non-executive members (9 elected by the AGM, 2 employee representatives); 55% are independent and the gender split is 36% women / 64% men. Day-to-day sustainability work is delegated to the Chief Corporate Responsibility Officer (CCRO), who since 1 January 2026 is no longer a member of the ICA Management Team (IMT) but still attends IMT meetings. The IMT itself has 6 members with a 50/50 gender split, and is supported by CR Group Management, comprising each Group company's sustainability manager.

Reference: page 74.

"The IMT receives an annual review of ICA Gruppen's material impacts, risks and opportunities based on ICA Gruppen's double materiality assessment," and is kept updated on progress toward shared sustainability goals. "Once yearly, the Board receives a corresponding review of ICA Gruppen's double materiality assessment," including how impacts, risks and opportunities are managed in policies, strategies and goals; the CCRO is responsible for briefing both bodies.

Beyond overseeing the DMA, due diligence, the climate transition plan and the sustainability statement in 2025, the Board's Sustainability Committee specifically addressed: reduced climate impact from food sold, the definition of and ambitions for a sustainable customer offering within ICA Sweden, and employee training in the Committee's areas of responsibility.

Reference: page 74.

ICA Gruppen states plainly that "ICA Gruppen's long-term bonus programmes include performance requirements linked to the Group's climate targets" (cross-referenced again under E1, page 89). The disclosure is brief and does not quantify the weighting of climate performance within the incentive structure or specify which management levels are covered beyond the general reference to the long-term bonus programmes. No separate social or governance KPIs are described as incentive-linked in this section; the climate link is the sole integration point stated.

Reference: page 75.

"ICA Gruppen's sustainability due diligence process was decided in 2025," aimed at ensuring negative impacts on human rights, climate and the environment in the value chain "are identified and managed proactively" using "a risk-based approach ... in line with applicable legislation and international standards." The process is published on ICA Gruppen's website.

The disclosure sets out six core elements with page cross-references: (1) positions on due diligence in the Sustainability Policy/Guideline; (2) the impact-materiality analysis within the DMA identifying negative impacts (pages 79-81); (3) actions to cease, prevent and mitigate impacts, covering supplier requirements, industry collaboration, direct dialogue/audits, and strategies/targets/KPIs; (4) continuous follow-up through own KPIs and dialogue forums; (5) annual reporting in the sustainability statement; and (6) an ambition to "clarify procedures and contact channels" for remediation "in the coming years."

Reference: pages 74-75.

Internal control requirements for sustainability reporting "are set out in Appendix 1 of the Sustainability Reporting Manual," coordinated by ICA Gruppen's Internal Control function, which "identifies risks of error in material reporting processes ... and implements key mitigating controls." Controls are evaluated annually through business self-evaluation "complemented by selective control testing," and action plans are prepared for identified gaps.

Outcomes are reported to CR Group Management, the Executive Management Team and the Audit and Sustainability Committee in the first tertial, with a status update in the third. Scope "is limited to the most material reporting processes, but is evaluated every year"; the stated 2025 focus was climate reporting, food waste reporting and reporting on ICA's own workforce.

Reference: pages 76-78.

ICA Gruppen's core business is grocery retail, supported by pharmacy operations (Apotek Hjärtat), non-food, banking and insurance (ICA Bank/ICA Insurance) and property (ICA Real Estate). At year-end the Group had 16,194 employees in Sweden plus a 72-person purchasing office in Asia (ICA Global Sourcing); Rimi Baltic, operating in Estonia, Latvia and Lithuania, was divested during the year and excluded from the sustainability statement.

Under "the ICA Idea," ICA Sweden owns the store location and brand while independent retailers own and operate individual stores. Each business unit runs its own sustainability strategy: ICA Sweden's "making sustainable choices easier," Apotek Hjärtat's four focus areas built around public health, ICA Real Estate's local/resilient-places ambition, and a joint ICA Bank/ICA Insurance strategy.

Reference: page 79.

Stakeholder dialogue is described as "at the core of due diligence to create deeper insight into stakeholder expectations as well as ICA Gruppen's impacts on people and the environment," feeding into actions, effectiveness follow-up and remediation approaches. Both Group-level and OpCo-level dialogues run continuously, supplemented by dedicated dialogues tied to each company's materiality assessment.

A table lists the key stakeholder groups and dialogue formats: consumers (customer service, social media, surveys), employees (employee surveys, trade union dialogue), owners (Board representation), independent ICA retailers (council structures and reference groups), suppliers (direct dialogue, forums, amfori BSCI) and public authorities, each mapped to its prioritised sustainability matters. Where relevant, stakeholder input feeds into information provided to management and the Board (see GOV-2).

Reference: pages 79-80, with topic cross-references at pages 83-84, 98-99, 103-104, 106-107, 110-111, 118-119, 126-127, 130, 133-134 and 138-139.

The double materiality assessment shows "ICA Gruppen's own operations have relatively limited impact, whereas material impacts in most areas exist upstream in ICA Gruppen's value chain, primarily linked to the products and services that ICA Gruppen purchases," with downstream impact tied to retailer-owned ICA stores and to consumption of the goods and services sold. A Group-wide resilience analysis carried out in 2024 is referenced as informing this assessment (see E1-3-Resilience).

The page-80 materiality outcome table maps every sub-topic across E1-E5, S1-S4 and G1 against impact materiality (actual/potential) and financial materiality (actual/potential), the basis for the material_topics list and the IRO count in this file.

Reference: page 81.

The materiality assessment instruction "is subject to annual review, and was adjusted in 2025 to clarify each company's responsibility for the assessment of financial materiality." Each ICA Gruppen company applies shared principles to map its own impacts, risks and opportunities; Group-level material IROs are then determined from the company-specific assessments, using the ESRS list of sustainability matters plus prior years' statements and peer reports.

Impact materiality scoring uses scale, scope, irremediable character and likelihood, drawing on tools such as amfori BSCI's high-risk country list, the SAFAD database and ICA Sweden's HRDD mapping. Thresholds are explicit: negative impacts are material at severity ≥21 (scale 3-27) or, for potential impacts, ≥21 with likelihood ≥7 (scale 1-9); human-rights potential impacts are material at severity ≥21 regardless of likelihood. Positive impacts are material at scale-plus-scope ≥14 (scale 2-18). Financial materiality uses ICA Gruppen's general risk framework combined with the ESRS assessment criteria. Time horizons are short (<3 years), medium (<10 years, redefined from the report's general definition since 2030 was judged too close to short-term to add analytical value) and long-term (<2050).

Reference: pages 145-146 (content index), with the underlying materiality outcome table at page 80.

ICA Gruppen's List of Disclosure Requirements sets out, DR by DR, the page reference where each is addressed, or a note that a topic uses ESRS 2 §17 phase-in provisions. The index confirms E1, E2, E3, E5, S1 and G1 are disclosed against individually numbered DRs with specific page references, while E4, S2, S3 and S4 are covered only through the ESRS 2 §17 general-information phase-in, meaning the company reports general impact/risk/opportunity information for these topics without structuring it against the individual numbered sub-requirements. Separately, the "Datapoints derived from other EU legislation" table (pages 146-148) cross-references SFDR, Pillar 3, Benchmark Regulation and EU Climate Law datapoints against the same DR structure, flagging several (e.g., climate benchmark exclusion datapoints, EU Taxonomy-linked E1-9 items) as "Not material." This file's status for every disclosure requirement below follows that same index.

Reference: pages 86-89.

ICA Gruppen's "long-term ambition is to reduce the climate footprint of the entire value chain in line with what is needed to reach the Paris Agreement's 1.5°C goal and to achieve net zero climate emissions by 2050," with 2030/2050 targets approved by the Science Based Targets initiative (SBTi) and covering Scope 1, 2 and 3. The plan, approved by Management Team and Board, "does not include the purchase of carbon credits to reach the short-term greenhouse gas reduction targets" and is revised annually; 2025 revisions reflected the Rimi Baltic divestment, an updated energy strategy and a new IT sustainability strategy.

Seven named action levers (reduced climate impact from food, non-food, fossil-free goods transport, reduced packaging footprint, lower-impact refrigerants, energy efficiency, other) are each mapped to strategy/targets, key activities and financing, most funded through normal sourcing/product-development budgets rather than dedicated capital. The company states it "does not have any significant investments in products or assets with locked-in GHG emissions" and has not been excluded from any EU benchmarks.

Back-filled from ESRS 2 IRO-1, where this content is disclosed in the FY2025 report (page 85). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Since 2023, ICA Gruppen has run three complementary climate analyses: a climate risk analysis for ICA Sweden's value chain, climate risk/vulnerability analyses of ICA Real Estate's portfolio (screened across all sites, with in-depth analysis of 15 properties in 2024 and 25 in 2025), and a Group-wide resilience analysis (2024). Physical risks are both actual and potential; transition risks stem from measures like "increased protectionism, stricter regulations and changed customer behaviour patterns."

Scenarios named: ICA Sweden's assortment/sourcing and logistics analyses use IPCC RCP 2.6 and RCP 8.5 to 2030 and 2050; the property vulnerability analyses use IPCC RCP 4.5 and RCP 8.5. No 1.5°C-aligned transition scenario or explicit global-average-temperature projection is named for either analysis - an omission consistent with CLAUDE.md's flagged gap pattern. Scope covers ICA Sweden's assortment/sourcing/logistics functions and ICA Real Estate's property portfolio; key assumptions are not itemised beyond the risk categories described.

Back-filled from ESRS 2 IRO-1, where this content is disclosed in the FY2025 report (page 85), cross-referring to the 2024 Group-wide resilience analysis described at page 78. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"The company is deemed to have a solid foundation for resilience, but identified measures such as increased electricity redundancy in logistics warehouses, alternative payment solutions, backup systems for pharmacy prescriptions, climate adaptation of properties and strategic activities in the supply chain are required to meet future challenges." The 2024 Group-wide resilience analysis "encompassed all of the Swedish companies in ICA Gruppen" and "revealed that these companies already have robust protection against many of the risks identified," while identifying both short- and long-term strengthening measures.

For financial-effect estimation: ICA Sweden's climate risk analysis used qualitative scenario analysis and risk matrices, while the Group-wide resilience analysis and ICA Real Estate's property analyses produced cost estimates for mitigating measures based on investment, opex and headcount costs - a mixed qualitative/quantitative approach, with no aggregate resilience investment figure disclosed.

Reference: page 89.

The Sustainability Policy and Sustainability Guideline "provide the overarching framework and direction for the Group's work to mitigate climate change (climate adaptation not included)," applying to all employees, suppliers and business partners and covering the value chain, not just own operations. The Guideline requires climate aspects "be taken into account in investment decisions" and covers transportation, energy consumption (including renewable energy promotion) and refrigerants.

Sector-specific store/pharmacy guidelines prioritise local sourcing and seasonality, restrict air transport to legal necessity with prior approval, and commit ICA Gruppen "to ensure that suppliers adopt science-based climate targets that are in line with the Paris Agreement" - a requirement written into every sourcing agreement's sustainability appendix. Notably, the policy framework explicitly excludes climate adaptation, leaving adaptation content concentrated in the IRO-1/resilience disclosures rather than in a dedicated policy statement.

Reference: page 89.

Investment is channelled partly through the green financing framework established in 2023, covering green buildings, renewable energy, fossil-free transport and sustainability-labelled private-label products. The 2024 green-bond impact report (published on a lag) shows a total green project portfolio of SEK 9,860 million and 2024-allocated volume of SEK 5,500 million, an estimated 31,688 tonnes CO2e/year avoided, i.e. roughly 5.8 tonnes CO2e avoided per million SEK invested. Allocation split: 41.3% green buildings, 37.7% environmentally labelled products, 20.5% fossil-free transport, 0.5% renewable energy.

Assortment-side investment is not separately quantified, since "this is taking place within the framework of ICA Gruppen's regular assortment development, and therefore does not burden the Group in the form of monetary investments." Additional actions include electrification of ICA Sweden's own logistics fleet, a first own fast-charging site at the Kungälv warehouse (partly grant-funded by the Swedish Energy Agency), and continued conversion of refrigerants.

Reference: pages 90-91.

SBTi-approved targets (2022 base year): by 2030, reduce absolute Scope 1+2 GHG emissions 42% (Non-FLAG) and Scope 3 42% (Non-FLAG); reduce Scope 3 FLAG emissions 30.3%; eliminate deforestation across primary deforestation-linked commodities by December 2025. By 2050: reduce Scope 1+2 and Scope 3 (Non-FLAG) 90%; reduce Scope 3 FLAG 72%; reach net zero across the value chain.

2025 progress against these targets is reported as a percentage of the base-year gap closed (e.g. -5% of the Scope 1+2 base-year target achieved), rather than as an absolute percentage reduction. Supporting operational targets include: cutting the climate impact of customers' food purchases 30% by 2030 (2025 outcome: 1.80 kg CO2e/kg sold food, down 3.2% from the 2022 baseline of 1.86); 70% of suppliers by upstream climate impact adopting science-based targets by 2025; fossil-free goods transport in Sweden by 2030 (major cities by 2025); and a 20% energy-consumption reduction by 2030.

Reference: page 92.

2025 total energy consumption: 725,595 MWh, of which 706,678 MWh (97.4%) from renewable sources and 11,522 MWh from fossil sources (down from 27,110 MWh in 2023), plus 7,395 MWh from nuclear power. No fuel consumption is reported from coal, crude oil/petroleum, or natural gas; the fossil total comes entirely from purchased electricity, heat, steam and cooling. Energy intensity in high-climate-impact sectors (grocery, pharmacy, real estate) was 5,183 MWh per SEK m of net sales from those sectors, down from 6,585 in 2023.

Fossil-free goods transport reached 88% of own-operations transport (between warehouses and stores/pharmacies) in 2025, up from 58% in 2023, driven by electrification, HVO/RME diesel substitution and expanded biogas use; interim 2025 targets for the three largest cities were achieved from 1 January.

Reference: page 93.

2025 totals (market-based): Scope 1 - 2,735 tCO2e; Scope 2 - 2,239 tCO2e; Scope 3 - 6,218,877 tCO2e; Total - 6,221,613 tCO2e, essentially flat versus the 2022 base year (+3%) but down 2% year-on-year. Scope 3 accounts for over 99% of total emissions. Category 1 (Purchased goods and services) is by far the largest at 5,991,725 tCO2e; Category 4 (upstream transport/distribution) is next at 112,624 tCO2e, followed by Category 11 (use of sold products) at 53,181 tCO2e.

Location-based Scope 2 was materially higher, at 63,355 tCO2e, versus the 2,239 tCO2e market-based figure, reflecting the impact of renewable-electricity contracts. The table also carries 2030/2050 milestone trajectories per line item, each requiring a 20% cut from the 2025 figure (Scope 1/2) to stay on the SBTi path, alongside base-year (2022) and prior-year (2024) comparatives for every category.

Reference: page 94.

Since 2020, ICA Gruppen has offset the climate impact of its own operations (stores, pharmacies, warehouses, offices and inter-warehouse/store transport); in 2025 this equalled 38,269 tonnes of CO2e, sourced from three projects (Brazil-nut forest protection in Peru, landfill-gas-to-energy in China, and wastewater biogas in China) totalling 38,810 tonnes CO2e, all VCS- or VCS/Redd+-certified and cancelled. Selection criteria are additionality, confidence in expected benefit, and local-community co-benefit, via partners South Pole and Climate Partner.

Apotek Hjärtat separately donates its former plastic-bag-tax surplus (over SEK 6 million in 2025) to WWF's One Planet City Challenge. Looking ahead, "carbon offsets will gradually be replaced by permanent carbon dioxide removals in line with the SBTi's Corporate Net-Zero Standard" as the Group approaches its 2050 net-zero target.

Reference: page 94.

"ICA Gruppen does not apply an internal carbon pricing system." The company states it "is exploring how an internal price on carbon could be used to support decisions, investments and proactively move the business towards lower climate emissions," citing pilot shadow-price projects in ICA Sweden's logistics operations as an early step. No price level, scope or implementation timeline is disclosed - the entry is a stated intent rather than an operating system.

Reference: page 100.

ICA Gruppen's sustainability guidelines for grocery retail and pharmacy operations state "ICA Gruppen is to restrict the use of hazardous chemicals in the products that are sold and in their production," and that products/packaging "must not contain substances of very high concern under the REACH criteria or PVC." Guidelines also target antibiotic resistance: ICA Sweden "requires all its suppliers not to use antibiotics to treat animals preventively, but rather only if prescribed by a vet," and all PFAS are prohibited in Apotek Hjärtat's assortment, with all PFAS-containing cosmetics already removed.

Product-specific requirements apply across "essentially all product categories," covering process chemicals in textiles/leather/footwear, pesticides in food production and antibiotics in animal husbandry; ICA Real Estate maintains its own restricted-chemicals list, and suppliers must maintain chemical-use lists under the sourcing sustainability appendix. Relevant standards cited include ISO 14001, the PFAS Movement, the Swedish Food Retailers Federation's pesticide phase-out list and REACH.

Reference: page 101.

Continued phase-out of synthetic refrigerants: by 2024, 52% of ICA stores (695 stores) had converted to natural refrigerants; ICA Real Estate "does not refill units with synthetic refrigerants in the event of leakage" and is compliant with the F-gas Regulation. Product/supplier chemical compliance is monitored through pre-production testing plus risk-based "spot checks" on finished goods; 26 pesticide-residue analyses were conducted for ICA Sweden in 2025, alongside cosmetic-ingredient self-declarations against the Restricted Cosmetic Ingredients list.

Industry collaboration includes the Sustainable Food Chain initiative's 2030 goal for pesticide-free-by-criteria cultivation and ICA Sweden's use of the Swedish Food Retailers Federation's pesticide phase-out list; the text notes "significant problems" maintaining production quality while phasing out pesticides in certain crops (e.g. bananas).

Reference: page 102.

"ICA Gruppen has not set any specific quantitative targets in this area since governance and actions related to ICA Gruppen's impacts, risks and opportunities primarily pertain to setting and following up product and supplier requirements, and collaborating with the industry and suppliers." The company instead points to two adjacent targets that contribute to pollution reduction: its overall climate targets (since transport and refrigerant emissions are covered there, see E1-4) and ICA Real Estate's goal to phase out synthetic refrigerants in its properties by 2030. Conversion to natural refrigerants more broadly follows the EU F-gas Regulation's phase-down schedule rather than an ICA-specific target.

Reference: page 102.

ICA Gruppen states its guidelines "state that substances of very high concern should not be present in products or packaging and, as such, reporting volumes of these substances is not material." For the broader category of substances of concern, "the ICA Gruppen companies currently have no reliable method of measuring or obtaining data on total volumes of any undesirable substances." Reporting to registers such as the Swedish Product Register and the EU SCIP database "pertains to only a few substances and products, such as fragrance oils and electronics, and is therefore not representative."

Medicines and medical devices present particular limits on data availability "due to product category regulations, confidentiality and patent protection," with no current system support at product or supplier level. The company expects data availability to improve as suppliers become subject to reporting obligations under the Ecodesign for Sustainable Products Regulation (ESPR).

Reference: page 104.

The sustainability appendix for products "states that suppliers of goods with significant water consumption, or who operate in areas of water scarcity, must manage water sustainably, for example, through the Alliance for Water Stewardship." ICA-handlarnas Förbund's Store Policy directs stores to "follow the applicable WWF Seafood Guide," and product-specific requirements state seafood suppliers "must ensure that the fish and shellfish delivered to ICA Gruppen's companies are MSC-, ASC- and/or KRAV-certified, or listed green or yellow in the WWF Seafood Guide," with full traceability to stock, fishing zone/farming location and fishing method. Fish and shellfish from endangered stocks may not be sold regardless of store ownership. ICA Sweden also helped develop the Swedish Food Retailers Federation's (SvDH) 2025 roadmap for water, based on "a shared risk-based approach ... based both on origin and on raw material."

Reference: page 105.

ICA Sweden began implementing the jointly-developed SvDH roadmap for water in 2025, starting with "putting ICA Gruppen's supplier requirements regarding water into a tangible form, and developing possibilities for data-driven identification of water stressed areas." On seafood, the company works "in close collaboration with suppliers to reduce dependence on species and stocks that are not fished at sustainable levels today," using the WWF Seafood Guide, though it acknowledges "major challenges" because "demand for certified ingredients exceeds the supply." This work sits within ICA Sweden's regular sustainability, assortment and purchasing functions rather than a dedicated water programme with separate resourcing.

Reference: page 105.

Two 2025 targets, both voluntary: 100% sustainability-certified seafood in ICA Gruppen's corporate-brand products (MSC, ASC or KRAV, for products with ≥50% seafood content) - 84% achieved in 2025, up from 71% in 2024; and 100% certified cotton in corporate-brand products - 27% achieved (up from prior year), a shortfall attributed to "poor availability of organic cotton volumes," though a large share of uncertified volume is "more sustainable cotton" via Better Cotton or organic/recycled/Fairtrade certification. A related ICA Sweden target - 90% of own-brand textile cotton to be "more sustainable cotton," irrespective of content share - reached 97% in 2025.

Reference: page 111.

The Sustainability Guideline "states that ICA Gruppen shall increase circularity and resource efficiency in its own operations and value chain," and grocery/pharmacy guidelines direct the company "to work preventively to minimise the amount of waste (mainly food, plastic and paper) ... and turn unavoidable waste into a resource," following the waste hierarchy "with prevention as the first option, and landfill as a last resort." Guidelines also require packaging to be "recyclable, resource and transportation efficient, and preferably made from renewable or recycled material," and require suppliers to be affiliated with a producer-responsibility/recycling scheme. Suppliers are separately directed to reduce environmental impact across a product's full life cycle.

Reference: page 112.

Food-waste prevention runs on the "food waste pyramid," with forecasting, purchasing, registering, monitoring and root-cause analysis in warehouses and stores, AI-based tools for forecasts and price reductions, and long-term donation partnerships (e.g. Stadsmissionen's Matmissionen). A new food-waste target for ICA Sweden was set in 2025: a further 35% cut in own-operations waste by 2030 versus 2025.

On packaging, ICA Sweden's packaging strategy targets material minimisation, mono-materials and recyclability; concrete 2025 actions include extending flowpack packaging to hamburgers (plastic savings), switching ICA's own olive oil from glass to plastic bottles ("more than halving the climate footprint of the packaging material"), and piloting plant-based edible film on cucumbers in place of plastic wrap.

Reference: page 113.

Targets are "voluntary and in line with the ambition in the Sustainability Guideline." Food waste: halve warehouse/store food waste by 2025 versus a 2016 base year - 2025 outcome: -37% (vs -28% in 2024), short of the 50% goal; a new ICA Sweden target adds a further 35% cut by 2030 versus 2025. Plastic packaging: all corporate-brand plastic consumer packaging recyclable by 2025 and made from recycled/renewable material by 2030 (industry roadmap, reinforced by the incoming EU PPWR); Apotek Hjärtat set 2025 targets of 100% recyclable primary plastic packaging, 30% average recycled content and a 10% reduction by 2030. Real estate: all commercial buildings (incl. warehouses) environmentally certified by 2030; construction waste reduced through supplier collaboration.

Reference: page 114.

Upstream resource inflows "consist mainly of food and groceries purchased for resale, but also of resources used in stores, offices, warehouses and construction," plus indirect use of virgin/non-virgin materials in electronics, disposables, textiles, batteries, household goods and building materials. Reported KPIs: 86 environmentally certified properties in 2025 (43% of the portfolio), up from 52 (28%) in 2024 and 28 (15%) in 2023; and 235 environmentally certified ICA stores (19% of stores), essentially flat on 2024's 242 (19%), with a continuing shift from Nordic Swan Ecolabel certification toward ICA Sweden's internal Miljösmart Butik standard (226 stores in 2025 vs 215 in 2023).

Coverage is explicitly partial: reporting "currently includes IT equipment and furniture for the entire ICA Gruppen, ICA Sweden's purchases of goods for sale, and machinery and vehicles for warehouses as well as packaging materials for Apotek Hjärtat's e-commerce deliveries and ICA Sweden's logistics operations."

Reference: page 114.

2025 resource outflows: 2,415,635 tonnes total aggregate weight of products and technical/biological material, of which 99.9% biological material. Of packaging specifically, 45% was reused/recycled secondary intermediate material (1,419 tonnes) and 22% carried FSC sustainability certification. The share of recyclable products generally "is not reported, since recyclability is not deemed material for the consumables (food, near-food products, pharmaceuticals and pharmacy products) that account for the majority of ICA Gruppen's sales."

Scope is again partial - covering IT equipment/furniture Group-wide, ICA Sweden's sold assortment, warehouse machinery/vehicles and specific e-commerce/logistics packaging - with ICA Sweden's dedicated resourcing to improve packaging data quality expected to expand coverage in 2026-2027.

Reference: page 115.

2025 total waste: 11,833 tonnes, of which 95% was diverted from disposal (recycled). By disposal route: 11,193 tonnes non-hazardous waste diverted (5,140 t material recycling, 6,050 t other recycling, 3 t reuse-prep) and 570 tonnes hazardous waste diverted; waste sent to disposal totalled 569 tonnes non-hazardous (mostly incineration, 556 t) and 71 tonnes hazardous. By composition, "35% of the waste comprised packaging waste, 33% food waste and 14% combustible waste." A further 56 tonnes generated in 2025 were reported after period-end and excluded from the table.

Coverage is limited to "waste from the warehouses of ICA Sweden and Apotek Hjärtat"; retailer-owned ICA stores and most pharmacy waste streams are excluded because "data collection is challenging as waste streams in most cases are not separate from other activities in the same building." Pharmaceutical waste collected by Apotek Hjärtat from customers is instead reported under E2 (pollution). As reporting principles changed in 2025, no historical (2023/2024) comparatives are shown.

Reference: page 119.

Employee relations are governed by a suite of policies aligned to the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, the UN Children's Rights and Business Principles and the OECD Guidelines. Each CEO is responsible for implementation within their business; ICA Management Team members oversee compliance within their areas, and breaches "may be subject to measures under labour law," reportable to the CHRO.

The Work Environment Policy aims "to promote health and to prevent work-related injuries and ill health," offering "safe and secure workplaces that enable a sustainable work life." The Reward Policy requires remuneration decisions to be "gender-neutral and non-discriminatory" and based on objective grounds. A separate alcohol and drugs policy prohibits being under the influence at work and provides for testing, run in negotiation with trade unions.

Reference: page 120.

ICA Gruppen "strives for a straightforward, open and continuous dialogue between employees, and between employees and managers," supported by the Worknet intranet as a key information channel. The primary structured mechanism is the SpICAp employee survey, run "two to four times a year" for most employees, used "to better understand how employees perceive their working conditions, and to identify areas for improvement and action." The disclosure does not separately detail formal workers'-representative/union consultation forums beyond the collective-agreement relationships described under S1-1 and SBM-1.

Reference: pages 120-121.

"All employees in ICA Gruppen are encouraged and urged to report irregularities and breaches of internal or external regulations," via their immediate supervisor, safety officer or the HR department, or anonymously to the head of Internal Audit or ICA Gruppen's third-party-operated online whistleblower service. The 2025 metrics (see S1-17) show 69 complaints raised within the own workforce (up from 36 in 2024) and 6 assessed as genuine whistleblowing cases under law (up from 1), an increase the company attributes to "major Group changes, increased world unrest and heightened awareness of the whistleblower channel among employees."

Reference: pages 121-123.

Remuneration actions: pay for unionised staff follows collective agreements; salaried pay is set on "the role's level of responsibility, market salary level and individual performance," with annual salary surveys against the Swedish Equality Ombudsman's regulations to check gender pay gaps. 4 FTEs are dedicated to payroll/benefits and 3 FTEs to labour law.

Health and safety: 2 FTEs work on health and safety, incidents are logged via the HIA system, and mandatory training runs on a two-year cycle - "Safety in warehouses and offices" and "Business Ethics at ICA" - plus targeted safety training for Apotek Hjärtat managers addressing threats and racist harassment in pharmacies, with new threat/violence procedures developed in 2025 for rollout in 2026. Regulatory adaptation covers the EU Pay Transparency Directive (new salary-mapping system, started 2025) and the EU Critical Entities Resilience Directive (pending Swedish implementing legislation).

Reference: page 123.

Gender balance in critical positions: target of women holding 50% (+/-10%) of business-critical positions; 2025 outcome: 47%, monitored continuously by HR with corrective action "when necessary." This is the only own-workforce target with an explicit numeric goal disclosed in the report; other workforce metrics (turnover, sickness absence, pay gap) are tracked and reported but without a stated target level.

Reference: page 123.

Total headcount at year-end 2025: 16,339 (16,266 in Sweden, 73 in Asia), of whom "35% worked in stores and pharmacies, 35% in warehouses and 30% in other operations." By employment type: 13,807 permanent, 673 temporary, 1,786 non-guaranteed-hours employees; 10,579 FTEs, with 5,687 part-time employees concentrated in stores and pharmacies, which also have a higher share of women. Employee turnover was 13% (rolling 12-month), down from 14% in 2024; 1,755 employees left during the period, down from 1,862. Rimi Baltic is excluded from 2025 figures following its divestment, with prior-year comparatives restated accordingly.

Reference: page 124.

Gender headcount 2025: 8,675 women, 7,591 men (53%/47%); no employees are recorded under "Other" or "Not disclosed" gender categories, since "no third legal gender exists in Sweden or in the Asian countries where ICA Gruppen operates." Management gender splits: all management levels 44% women/56% men; business-critical positions 53%/47%; Board and IMT 60%/40% (all little-changed on 2024). Age distribution across all employees: 24% under 30, 52% aged 30-50, 23% over 50; the Board/IMT skews older (0% under 30, 35% aged 30-50, 65% over 50).

Reference: page 124.

Coverage by health and safety management system: 80% of ICA Gruppen (excluding ICA Global Sourcing). Fatalities: 1 in own workforce in 2025 (0 among other employees) - the company discloses that "during the year, a tragic incident occurred in which an employee passed away as a result of unprovoked violence in an ICA store." Number of workplace accidents: 1,491, down slightly from 1,503 in 2024 (26%/29% women/men split roughly matching a 45%/55% skew depending on category). Sickness-related absence: 5.5%, down from 5.8% in 2024 and 6.0% in 2023. Note: the same "S1-14 Health and safety" datapoint also appears on the Appendix C phase-in list (page 73), indicating specific sub-datapoints beyond the metrics shown remain phased in even though the core metrics above are reported.

Reference: page 124.

Gender pay gap 2025: not disclosed as a single headline figure; instead, the report gives a pay-band distribution - employees earning within 30% of the median pay 24% (down from 26% in 2023), within 30-50% of median 52%, and over 50% above median 23%. Annual total remuneration ratio: 40% (highest-paid employee's total remuneration versus the median annual total remuneration of Swedish employees on monthly/hourly wages). No CEO pay ratio expressed as a multiple, nor a single unadjusted gender-pay-gap percentage, is presented in this section; the pay-gap methodology (based on one month of 2025 data, per ESRS S1-AR 98) is described in the reporting principles (page 124-125).

Reference: page 124.

53 incidents of discrimination reported (including harassment) in 2025. 122 total complaints within the own workforce (up sharply from 69 in 2024), 6 of which were assessed as genuine whistleblowing cases under law (up from 1). The company attributes the rise to "major Group changes, increased world unrest and heightened awareness of the whistleblower channel among employees." Figures "include the number of incidents for currently Group-owned stores within ICA Gruppen but exclude incidents at retailer-owned stores reported to the channel," so the true own-workforce total is understated relative to the full ICA system. No severe human-rights incidents (e.g. forced or child labour) within the own workforce are reported.

Reference: pages 139-140.

ICA Gruppen "applies zero tolerance for bribery and works actively and preventively with business ethics," under a governance model in place "since 2015" comprising the Code of Conduct, the Policy and Guideline for Business Ethics, the whistleblower service, risk analysis, training, communication and reporting. External frameworks include the UN Global Compact, UN Guiding Principles, ILO core conventions, OECD Guidelines and the Swedish Anti-Corruption Institute's Code of Business Conduct.

Corporate culture rests on three values - simplicity, commitment and entrepreneurship. The Board endorses the Code of Conduct and Business Ethics Policy; the CEO approves the Business Ethics Guideline; the ICA Accountability Committee (joint with ICA-handlarnas Förbund) can issue reminders/warnings to, or expel, ICA retailers. The online whistleblower service, run by an external party, is available to employees, other covered persons and external stakeholders across Sweden and Asia.

Reference: page 140.

ICA Gruppen "works systematically to prevent corruption and maintain high ethical standards," via mandatory online Business Ethics training for all salaried employees (including management, but not the Board, which sets the policy itself), refreshed every two years and covering "anti-corruption, benefits, conflicts of interest, and fair competition." Completion rates are "monitored and reported internally to the Board's Sustainability Committee." Higher-exposure groups (e.g. purchasing staff) additionally receive classroom-based training; ICA Sweden's entire purchasing function is covered, though completion numbers for that classroom training are "not reported," pending evaluation "ahead of next year's reporting."

Reference: page 141.

"ICA Gruppen reports cases of corruption or bribery only for its operations in Asia, within ICA Global Sourcing (IGS)." In 2025, IGS reported no cases of attempted bribery by a supplier. The company explicitly flags a coverage gap: "the conditions for monitoring cases of corruption or bribery in the rest of the operations are currently being evaluated ahead of next year's reporting" - i.e. no Group-wide corruption/bribery incident count exists yet outside the Asia sourcing operation.

Reference: page 141.

"While ICA Gruppen has no specific policy regarding payment times," the Group is bound by the Swedish Interest Act (claims fall due 30 days after demand unless otherwise agreed), the Act on Prohibition of Unfair Trading Practices for agricultural/food purchases (payment within 30 days, no late order cancellations or unilateral term changes) and the Code of Conduct for Swedish SME companies (payment terms capped at 30 days for SMEs).

Reported payment-time data (July 2024-June 2025, covering ICA Sweden, ICA Maxi Special, ICA Bank and Apotek Hjärtat) shows default payment periods of 36 days for micro enterprises, 35 days for small enterprises and 39 days for medium-sized enterprises. "ICA Gruppen currently has no outstanding legal proceedings related to late payments." Share-of-payments-made-within-terms figures are presented in the report's payment-terms table but not fully captured in the extracted text available for this summary.