Ignitis Grupe AB

The role of the administrative, management and supervisory bodies

Reference: pages 161, 93-122.

The Supervisory Board sets strategic direction and approves the strategic sustainability goals (page 161). Below it, the Sustainability Committee oversees environmental and social sustainability, sustainability governance and the sustainability statement. The Audit and Risk Committee oversees sustainability reporting and assurance, risk management and internal controls. The Management Board approves the governance and management structure, approves the statement and agrees the double materiality results. A Group Sustainability function coordinates the work across the Group.

Composition: the Supervisory Board has 9 members, 6 independent and 3 civil servants. Since 27 October 2025 it runs three committees, the Sustainability Committee among them, chaired by an independent member (pages 94, 110). Women hold 53% of seats on the parent company's management and supervisory bodies (page 97). The competency matrix covers environment and climate, HR and diversity, health and safety, and ESG regulation such as CSRD and the EU Taxonomy (page 103).

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

Reference: pages 161, 108, 111, 120, 122.

Page 161 treats GOV-1 and GOV-2 together and points to section 4 Governance.

What reached the boards in 2025:

• Supervisory Board: 25 meetings. Agenda items included the 2024 sustainability statement and the assurance conclusion, sustainability issues such as occupational health and safety, the double materiality results, and the Strategic Plan 2025-2028 (page 108).
• Risk Management and Sustainability Committee (to 25 October 2025): 6 meetings on occupational health and safety, the double materiality assessment, the anti-corruption system and sustainability and ESG information (page 120).
• Audit and Risk Committee (from 31 October 2025): reviewed the plan and preliminary findings of the limited assurance engagement on the sustainability statement (page 111).
• Management Board: considers and approves the Group's long-term and annual sustainability plans (page 122).

After year end, five Supervisory Board meetings (1 January to 24 February 2026) covered the 2025 statement and the assurance provider's conclusion (page 108).

Integration of sustainability-related performance in incentive schemes

Reference: pages 161, 185, 146-148 (section 5 Remuneration).

Page 161 sends GOV-3 to section 5, and page 185 says the pay of top executives is directly linked to pre-set sustainability targets.

• 2025 short-term incentive (Management Board): ESG targets focused on safety at work. They cover zero work-related fatal accidents among employees and contractors, the injury rate (TRIR) for employees, the TRIR for contractors, and an inclusive recruitment program (at least 33% of the underrepresented gender on shortlists for top management hires). The short-term incentive is capped at 20% of annual fixed base salary (page 146).
• 2026 short-term incentive: sustainability targets carry 15% of the weighting, made up of safety at work (10%) and inclusive recruitment (5%) (page 147).
• Long-term incentive 2022-2025: one objective is targeting net zero emissions, measured as GHG emissions reduction against a 2020 base of 5.37 million t CO2-eq (page 148).

The 2025-2028 long-term objectives are published on the company website (page 148).

Statement on due diligence

Reference: page 162.

The Group says due diligence is managed by senior leadership and supported by several functions. The statement maps the five core elements of due diligence to pages of the report:

• Embedding in governance, strategy and business model: pages 90, 148, 180, 274 and the topical chapters.
• Engaging affected stakeholders: pages 90, 165, 168, 275-277 and topical sections.
• Identifying and assessing adverse impacts: the double materiality assessment covers own operations and the value chain, supported by risk screenings and assessments of compliance with the Supplier Code of Ethics.
• Taking action: pages 274, 278-279 (business conduct), 237, 242, 246, 251 (people), 185, 190, 220, 222, 231 (environment).
• Tracking effectiveness and communicating: strategic KPIs reported regularly, plus work to improve supply chain traceability (pages 195, 197-198, 225, 227, 232-233, 238, 240, 243-244, 247-249, 252-254, 258, 280-281).

The human rights due diligence guidelines are not publicly available (page 236).

Risk management and internal controls over sustainability reporting

Reference: page 162; also pages 111, 161, 168.

The Group Sustainability function leads the Group sustainability reports and works with Finance, People and Culture and Health, Safety and Environment on the double materiality assessment, climate risk and data collection (page 162).

Named risks in preparing the statement are human errors and data misalignment across companies. The controls described: one Group-wide data framework, a systematic risk prioritization method, and standard definitions and emission factors under the GHG Protocol. After the first reporting cycle in 2024 the Group added process walk-throughs, extra controls, more internal expertise and digital tools. A Sustainability DataHub is being built, and a separate Sustainability Reporting division was set up in 2025. The Head of Group Sustainability briefs the CEO and CFO on progress.

The Audit and Risk Committee oversees the sustainability reporting process, assurance, risk management and internal controls (page 111). Sustainability risks are tied into the overall Group risk management process (page 168).

Strategy, business model and value chain

Reference: pages 163-165.

The stated purpose is a 100% green and secure energy ecosystem. Strategic Plan 2025-2028 sets five sustainability priorities with ESG targets: decarbonization, safety, employee experience, diversity and sustainable value creation (page 163).

Four segments make up the business: Green Capacities, Networks, Customers & Solutions and Reserve Capacities. They generate energy from renewable and non-renewable sources, distribute electricity and gas across Lithuania, and sell energy products and EV charging (page 163).

The value chain map on page 164 places 9 positive impacts, 7 negative impacts and 8 risks and opportunities across upstream inputs (wind, solar, batteries, fuel), own operations and downstream customers and end-of-life solutions.

The Group does not operate in the coal or oil sectors, and reported no Taxonomy-aligned revenue from fossil gas in 2025 or 2024. The revenue breakdown by ESRS sector (SBM-1 paragraphs 40(b) and 40(c)) is under the phase-in (page 165).

Interests and views of stakeholders

Reference: pages 165-167.

The Group lists nine stakeholder groups: employees, local communities, investors and shareholders, government and municipal institutions, private customers, business customers, suppliers and contractors, media, and partners. For each it records the expectations raised in the double materiality dialogue, how the Group engages, and what happened in 2025 (pages 166-167).

Examples from the table:

• Employees: intranet and newsletters, regular wellbeing surveys and a quarterly eNPS survey, and works councils and trade union dialogue.
• Local communities: financial support for community projects near wind and solar farms, Kaunas CHP and Elektrėnai Complex, and a community gathering in 2025.
• Suppliers and contractors: cooperation on safety under the Supplier Code of Ethics, basic GHG training launched for suppliers, and improvement plans after Code assessments.
• Investors: earnings calls, general meetings and ESG data platforms.

Views feed the materiality assessment and due diligence; the Group says it will keep these engagement practices (page 165).

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

Reference: pages 178-182.

Results of the double materiality assessment (page 178): E1, E4, S1, S2, S3 and S4 are material from both impact and financial views. E5 and G1 are material from the impact view only. E2 Pollution and E3 Water were again found not material.

Material items by topic (pages 180-182): E1 has 6 (GHG emissions, green portfolio growth, electrification, lack of policy support, renewable market opportunity, physical climate events). E4 has 2 (ecosystem impacts, non-compliance with environmental requirements). E5 has 2 (waste to energy, waste and decommissioning). S1 has 6, S2 has 2, S3 has 3, S4 has 2 (access to energy, cybersecurity). G1 has 2, plus a company-specific positive impact on energy security.

Changes from 2024 (page 179): a new E4 risk, a new S1 impact on demanding work environments, a new S3 impact from construction disturbance, and a new E5 sub-topic on waste.

The Group says none of the identified risks and opportunities had a material financial effect in 2025, and it applies the phase-in for anticipated financial effects (page 179).

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

Reference: pages 168-170.

The Group ran its first double materiality assessment in 2024 and repeated it in 2025. It follows EFRAG guidance and Annex I of Delegated Regulation 2023/2772 (page 168). The process runs annually in six phases: engage stakeholders, map value chains, list and group impacts, assess, validate, and set the final list (pages 169-170).

Scoring: impact materiality is severity (average of scale, scope and irremediable character) multiplied by likelihood. Financial materiality is likelihood multiplied by financial effect, using adjusted EBITDA and net profit as the quantitative anchor and expert judgment where effects cannot be measured. The threshold is the one in the Group Risk Management Framework (pages 168-169).

Time horizons: short term up to 1 year (2025), medium term 2 to 4 years (2026-2028), long term 5 years and more (page 169).

Value chain coverage focuses on first-tier suppliers. Internal experts did the scoring; stakeholders validated the impact list; the Management Board agreed the final list after the Supervisory Board saw it (page 170).

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

Reference: pages 171-177 (content index and EU datapoint list).

The Group prints a content index of ESRS disclosure requirements with a page for each (pages 171-174). It lists ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2) and every disclosure requirement of E1, E4, S1, S2, S3, S4 and G1. For E5 it lists E5-1, E5-2, E5-3, E5-5 and E5-6, and leaves out E5-4. E2 and E3 do not appear.

The EU datapoint list (pages 175-177) gives a page for each datapoint from SFDR, Pillar 3, the Benchmark Regulation and the Climate Law, or marks it NR (not relevant), NM (not material) or PH (phase-in). Examples: E1-9 datapoints are PH; E2-4 and the E3 datapoints are NM; the forced and child labor datapoints are NR.

The statement says the E, S and G sections cover disclosures assessed as material or mandatory under the ESRS (page 160). Page 178 explains why E2 and E3 were left out.

Transition plan for climate change mitigation

Reference: pages 185-186.

The Group says its climate transition runs through a set of processes that together act as the plan: SBTi-validated targets, GHG accounting and forecasting, annual and multi-year decarbonization planning, climate criteria in investment decisions, and progress monitoring. It is still working on a standalone transition plan document (page 185).

Targets: net zero emissions by 2040-2050 and 4-5 GW of installed green capacity by 2030, with Scope 1, 2 and 3 targets validated by SBTi on a 1.5°C pathway (page 186). Three priorities: lower the carbon intensity of Scope 1 and 2, grow green electricity supplied, and grow biomethane supplied.

Locked-in emissions come mainly from gas-fired generation, waste incineration and the gas sold to customers. A more detailed analysis is planned (page 186).

The plan sits inside Strategic Plan 2025-2028, approved by the Supervisory Board. The plan directs at least 85-90% of investments to EU Taxonomy-aligned activities. The Group is not excluded from the EU Paris-aligned Benchmarks (page 186).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and SBM-3 in the E1 chapter, where this content is disclosed in the FY2025 report (pages 185, 188-189). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

A climate scenario analysis done in 2023 fed the 2025 double materiality assessment (pages 185, 188). It used two pathways to 2030 and 2050:

• Physical risk: a high-emission 4°C pathway (IPCC SSP5-8.5), covering almost 300 sites including Kaunas HPP, Kruonis PSHP, Elektrėnai Complex and the CHPs.
• Transition risk: a net-zero (below 1.5°C) pathway, using the IEA net zero scenario where available, covering all four segments and all GHG scopes.

It found three physical risks, one physical opportunity, two transition risks and two transition opportunities. The 2025 assessment kept one physical risk, one transition risk and one transition opportunity as financially material (page 189).

In 2025 the Group added an asset-level climate risk tool that screens Taxonomy assets against SSP1-2.6, SSP2-4.5 and SSP5-8.5 for baseline, 2030 and 2050 (page 189). The 2023 results themselves sit in the 2024 annual report (page 189).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 in the E1 chapter ('Business resilience in relation to climate change', pages 188-189). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The Group says it periodically tests the resilience of its strategy and business model against climate impacts, risks and opportunities, using the 2023 scenario analysis, the 2025 materiality assessment and its risk processes (page 188).

Resilience is attributed to the corporate strategy (growth in green generation and flexibility capacity), risk management and emission reductions. Climate risks go through Group Risk Management like other business risks. Extreme weather risk is handled through measures against energy infrastructure failure, including replacing overhead 10 kV lines with underground cable (pages 189, 192).

On capacity to adapt, the Group says it keeps a high degree of flexibility to adjust strategy and business model and keeps access to affordable financing by following the EU Taxonomy criteria (page 189).

No quantified result of the resilience test is given on these pages.

Policies related to climate change mitigation and adaptation

Reference: pages 189-190.

Three documents govern the Group's climate work, each applying to all Group companies:

• Group Environmental Policy (public): reduces environmental impacts, improves energy efficiency, strengthens network resilience and promotes low-carbon solutions.
• Climate Management Guidelines (not public): commit the Group to limit warming to 1.5°C, including net zero by 2040-2050, phasing out fossil-fuel activities and engaging the value chain. They are an annex to the Environmental Policy.
• Group Sustainability Policy (public): commits to net zero in line with the European Green Deal and the Paris Agreement, and encourages efficient energy use and Lithuania's energy savings goals.

The Group requires every company to follow these principles and monitors them periodically. Each company reviews its decarbonization measures once a year and reports progress to the Group. Implementation decisions come out of annual and four-year strategic planning cycles (page 190).

Actions and resources in relation to climate change policies

Reference: pages 190-194.

Each segment has its own approach. Green Capacities builds green generation and flexibility (2.6-3.0 GW by 2028, 4-5 GW by 2030). Networks cuts grid losses. Customers & Solutions sells green electricity, biomethane and EV charging. Reserve Capacities keeps existing plants running for energy security (page 190). Seven levers are named, from green technology to fuel switching and avoided emissions. No carbon removal is planned for now.

2025 results from the action table (pages 191-194):

• Green share of generation 70.2% (81.5% in 2024).
• Gas network losses 1.4% (1.5%); electricity network losses 4.8% (5.0%).
• SF6 leakage 0 g (100 g in 2024).
• 47% of the vehicle fleet is electric; 1.3 million smart meters installed; 1,799 EV charging points.
• 0.11 TWh of biomethane sold.

Resources: EUR 285.9 million invested in Green Capacities expansion and EUR 82.8 million in network maintenance. OPEX was EUR 43.5 million (Networks) and EUR 35.6 million (Green Capacities, estimated). Planned 2025-2028 investment in these actions is EUR 2,300-3,000 million (page 194).

Targets related to climate change mitigation and adaptation

Reference: pages 195-196.

SBTi validated the Group's targets in 2021 and revalidated them in 2025 against a 2023 base year. The overall goal is net zero across the value chain by 2040 (page 195).

Near-term 2030 targets: cut Scope 1 intensity of power and heat generation by 86.6% per kWh; cut Scope 1 and 3 intensity of electricity sold by 79.9% per kWh; cut remaining absolute Scope 1 and 2 by 42%; cut Scope 3 from use of sold gas by 42%; cut Scope 3 from purchased goods and fuel- and energy-related activities by 42%. The 2040 cuts are 91.5%, 94.5%, 90%, 90% and 90%. The table on page 196 shows 86.3% and 79.6% for the first two 2030 figures.

No carbon credits are used, and the Group has no approach yet for residual emissions (page 195).

Progress (page 196): Scope 1 and 2 outside power generation 181 thousand t CO2-eq (260 in 2023); use of sold products 1,703 (1,802). Strategic target: Scope 1 and 2 intensity of 190 g CO2-eq/kWh by 2028; it rose to 248 in 2025 (199 in 2024).

Energy consumption and mix

Reference: page 197.

Total energy consumption was 5,997,242 MWh, up 32.0% from the restated 4,541,878 MWh in 2024.

• Non-renewable: 3,243,926 MWh, 54.1% of the total (43.1% in 2024). Natural gas fuel is the largest item at 2,603,618 MWh, up 123.8%. Non-biologic waste fuel was 584,705 MWh.
• Renewable: 2,753,316 MWh, 45.9% (56.9%). Biomass 1,452,952 MWh, biologic-origin waste 637,062 MWh, purchased renewable electricity and heat 659,548 MWh, self-generated non-fuel renewable 3,754 MWh.

Energy intensity was 2,425.0 MWh per EUR million of net revenue (1,978.5 in 2024, restated). All business segments are classed as high climate impact sectors.

Generation totaled 6,185,516 MWh, of which 60.1% was renewable (63.3%).

The 2024 totals were restated; the report points to section 7.3 for the notes. Data comes from the Group's internal collection system, with each plant entering monthly operating data. The higher gas use is linked to extra services at Elektrėnai Complex (page 198).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 198-200.

Emissions in thousand t CO2e (2025, change on 2024):

• Scope 1: 736, up 54.7%; 83.4% falls under emission trading schemes (73.8% in 2024).
• Scope 2: 50 location-based (down 37.1%) and 113 market-based (down 4.0%).
• Scope 3: 3,638, up 4.4%. Largest categories: use of sold products 1,703 (natural gas sold), fuel- and energy-related activities 1,250, capital goods 327, purchased goods and services 294.
• Total: 4,487 market-based (up 10.1%) and 4,424 location-based (up 9.5%).

Intensity: 1,796.6 t CO2e per EUR million of net revenue, market-based (1,767.4). Biogenic emissions of 115 are reported outside the scopes.

The Group attributes the Scope 1 rise to extra services at Elektrėnai Complex that raised gas use (page 198).

Method: GHG Protocol, operational control, the inventory covers the 15 Scope 3 categories, with categories 9, 10, 12, 14 and 15 judged not relevant. No methodology changes in 2025. The Group says the share of Scope 3 calculated from primary data is hard to determine at this stage and does not report it (page 199).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 200.

The Group gives a nil return. It did not carry out carbon removal or storage in 2025 and did not finance any GHG mitigation project through carbon credits (page 200).

Related statements elsewhere in the E1 chapter:

• The targets validated by SBTi are gross, and the Group says it does not use carbon credits and does not plan to rely on them to reach those targets (page 195).
• It has not yet developed an approach for residual emissions or neutralization in its net zero scenario (pages 195, 200).
• It has no carbon removal initiatives, nature-based solutions included, though it may consider them later (page 190).

The content index lists E1-7 on page 200 (page 171).

Internal carbon pricing

Reference: page 200.

The Group has no internal carbon pricing scheme at present. It is exploring options by assessing the life-cycle emissions of new investment projects (page 200).

Carbon prices do show up in the E1 chapter as an external risk driver. Citing IPCC data, the Group says carbon prices are expected to rise about 1.7 times by 2030 and 3 times by 2050 under the 1.5°C scenario, which could raise energy and heat generation costs at Elektrėnai Complex, Kaunas CHP and Vilnius CHP (page 188).

For context, 83.4% of Scope 1 emissions fall under regulated emission trading schemes (page 198).

The content index lists E1-8 on page 200 (page 171).

Transition plan on biodiversity and ecosystems

Reference: pages 220-221.

The Group has no finished biodiversity transition plan. It says it is working on one, to guide its approach through 2030, with KPIs for nature and for the business. The plan is to be built with biodiversity experts and approved by management (page 220).

Groundwork done in 2025: a GIS-based assessment of the biodiversity footprint, not published, which maps own sites in or near sensitive areas (page 220). The Group also used the TNFD LEAP approach, including identification of sensitive areas and of impacts and dependencies on ecosystem services (page 221).

Material items (page 220): a negative impact from changes to the land and to aquatic environments, driven by land acquisition and site preparation, water use at Kaunas HPP and Kruonis PSHP, and tree cutting along power lines. One risk of breaching environmental permits, including bird protection rules affecting wind production. Both sit in own operations.

The Group says it integrates biodiversity into planning and operations, engages stakeholders early and refines its practice from monitoring data (page 220).

Policies related to biodiversity and ecosystems

Reference: pages 221-222.

The policy set (page 221):

• Group Environmental Policy (public): mitigation hierarchy, protecting areas and species of high ecological value, preventing deforestation, restoration after activities, and an informed consent principle toward communities.
• Guidelines for Biodiversity and Ecosystem Management (not public): regular impact assessments and the steps of avoidance, minimization, restoration and compensation in infrastructure projects.
• Kaunas HPP pollution permit: requires monitoring so water level changes do not harm protected species and habitats.
• Tree and Shrub Management Process (not public) for hazardous trees near power lines, ISO 14001 systems at ESO, Ignitis Gamyba and Ignitis, and Environmental Protection Standards (not public) for the same three companies.

Ignitis Renewables is piloting supplier screening with a questionnaire that asks about biodiversity and deforestation, and plans to roll it out Group-wide (pages 221-222).

The Group has no dedicated policy for tracing all sourced products and materials that affect biodiversity, but gathers data on key materials such as paper, cardboard and wood and prefers certified sources (page 222).

Actions and resources related to biodiversity and ecosystems

Reference: pages 222-225.

• Power lines: ESO plans to replace 2,000 km of overhead lines in forested regions with underground cable in 2025-2028, with 365 km done in 2025. This would release 3,950 hectares of protection zones for forest (page 222).
• Birds: 474 white stork nests relocated or managed from 2021 to 2025. After eagle-owl deaths at poles in Šiauliai in summer 2025, protective measures were installed and a bird protection study contracted for 2026 (page 223). The Kelmė wind farm uses a bird collision detection system that stops turbines; bird and bat monitoring runs at several wind farms (page 223).
• Invasive plants: control of Sosnowsky's hogweed at four substations and a management plan for goldenrod at the Tauragė solar site (pages 223-224).
• Kaunas Lagoon: annual fish and water bird monitoring. For 2025-2026 the permitted daily level fluctuation was raised to 0.4 meters, with an added study program; the earlier limit returns from 2027 (page 224).
• Offshore wind: the environmental impact report for Curonian Nord went to public and cross-border consultation in October 2025 (page 225).

The Group does not use biodiversity offsets and has not compiled offset cost data (page 225).

Targets related to biodiversity and ecosystems

Reference: page 225.

The Group states that it has no specific targets related to biodiversity and ecosystems at present. It is building its understanding of the topic, analyzing regulatory requirements and market practice, and says it is working toward comprehensive targets in the near future (page 225).

The company links this to the risk of non-compliance with species protection rules: construction of wind farms and operation of power grids can harm species and threaten protected birds (page 225).

It adds that no biodiversity offsets are part of its actions, because no compensation targets or KPIs exist and cost data was not compiled, so it treats offsets as not significant to its activities (page 225).

The biodiversity transition plan, under development, is to carry KPIs (page 220). The content index lists E4-4 on page 225 (page 172).

Impact metrics related to biodiversity and ecosystems change

Reference: pages 226-228.

The Group maps its sites against protected areas using GIS data (page 226).

• Green Capacities: counts of objects in or near protected areas of 1/12 for wind, 0/4 solar and 0/3 battery storage. Distances to the nearest protected area are listed per site, from 0.1 km to 7.0 km (page 226).
• Hydro, waste and thermal: 1/2 hydro, 0/2 waste-to-energy and 0/2 thermal. Area occupied by technology is listed at 587.1, 7.7 and 247.8 ha for the three groups, unchanged from 2024 (page 227).
• Networks: the electricity network occupies 1,051.5 ha and the gas network 7.3 ha inside Natura 2000 areas, with no 2024 comparison. Underground electricity cable in forested areas reached 7,187.4 km, up 8.7% (page 227).
• Birds: counts of Red Book listed species seen in monitoring at Kelmė and Mažeikiai wind farms and the Kaunas HPP reservoir, with activity impact rated minimal and protection by preserving natural habitats (page 228).
• Invasive species: 38,500 m2 cleared of Sosnowsky's hogweed by chemical control (page 228).

Policies related to resource use and circular economy

Reference: pages 229-230.

Two material items sit under the Waste sub-topic: a positive impact from converting waste to energy, and a negative impact from waste generation and limited end-of-life options for equipment and materials (page 229).

Policies (page 230):

• Group Sustainability Policy and Group Environmental Policy: support the circular economy and ask for efficient, careful use of energy, fuel, commodities, waste and by-products, with lifecycle thinking in design.
• Resource Use and Circularity Management Guidelines (not public): sustainable resource management and waste reduction, built on nine circular economy principles from refuse to recycle.
• Pollution prevention permits for Vilnius CHP and Kaunas CHP: allow burning only post-sorting, non-recyclable, non-hazardous municipal waste for energy recovery.
• Waste Management Guidelines (not public): waste accounting and removal instructions, handling of hazardous waste, and contractor duties.
• Supplier Code of Ethics: asks suppliers to conserve resources, reduce waste and reuse and recycle.

Actions and resources related to resource use and circular economy

Reference: pages 231-232.

• Waste to energy: the Vilnius and Kaunas units burn only municipal waste that cannot be sorted or recycled, with annual waste composition analyses and daily visual checks (page 231).
• Resource optimization: membranes are washed and reused, and process condensate is cleaned and reused at the CHPs (page 231).
• Fly and bottom ash: hazardous fly ash is shipped to Langøya in Norway, where the site is nearing capacity, so the Group is studying alternatives such as recovering salts and metals. Bottom ash and slag go to construction products for foundations and roads (page 231).
• Waste prevention: ESO piloted circular economy procurement criteria; training courses on waste reduction and sorting (page 231).
• Reuse and repair: ESO repurposes electrical equipment and reuses gas measurement devices; decommissioned EV chargers are reinstalled, used for parts or sold; some equipment was sent to Ukraine (pages 231-232).
• End of life: Ignitis Renewables studied wind farm decommissioning practice and takes part in a WindEurope expert group (page 232).

The waste-to-energy activity is treated as a daily service, so it is not counted as an action with significant investment or OPEX (page 231).

Targets related to resource use and circular economy

Reference: page 232.

The Group says it has not set formal Group-wide targets for resource use and the circular economy. It commits to reduce negative impacts through policies and actions, and says it is analyzing regulatory requirements while building its understanding, with the aim of defining targets later. Future targets are meant to address the most significant impacts and match the circular economy policies (page 232).

In the meantime it checks whether actions match its waste policies by comparing waste treatment data over time, using the quantitative waste data in E5-5 (page 232).

The content index lists E5-3 on page 232 (page 172). The Group's waste figures show 99.9% of waste diverted from disposal in 2025 (page 233), but the Group sets no target for that rate (page 232).

Resource outflows

Reference: page 233.

The E5-5 section covers waste only. The Group reports waste diverted from disposal and waste directed to disposal for all waste types from its operations and projects (page 233).

Key figures: waste reclamation was the most common treatment. The largest reclaimed streams were 105,824.2 tonnes of bottom ash and slag and 17,562.3 tonnes of fly ash, up 9.9% and 9.3% on 2024, which the Group ties to burning more non-recyclable waste. Of total waste, 145,379.3 tonnes (99.9%) was diverted from disposal and nearly all of it kept out of landfill (page 233).

Total waste was 145,547.5 tonnes in 2025 (132,411.4 in 2024, restated; the 2024 report showed 198.0 thousand tonnes). Hazardous waste was 17,866.6 tonnes.

The page gives no figures on products and materials leaving the Group, such as durability or recyclable content. The Group does not use radioactive components and generates no radioactive waste (page 233).

Anticipated financial effects from material resource use and circular economy-related risks and opportunities

Reference: page 234.

The Group gives a nil return. It says that no material resource use and circular economy-related risks and opportunities were identified in the double materiality assessment, so it discloses no anticipated financial effects (page 234).

This matches the materiality results: E5 is material from the impact view only, through the two Waste impacts, and the risk of shortage of materials and components reported under E5 last year was found not material this year (pages 178-179).

The content index lists E5-6 on page 234 (page 172). This is a statement that no financial effects arise, and not a use of the phase-in, which the Group applies to E1-9 and E4-6 (pages 200, 228).

Waste

Reference: page 233 (waste table and accounting policy).

Waste diverted from disposal, tonnes (2025, 2024):

• Non-hazardous: reclamation 120,459.6 (109,607.5), recycling 7,065.1 (6,206.1), other recovery 0.0 (34.6).
• Hazardous: reclamation 17,562.3 (16,062.0), recycling 43.9 (62.7), other recovery 248.4 (300.8).

Waste directed to disposal, tonnes:

• Non-hazardous: incineration 41.8 (70.7), landfill 111.8 (54.2), other disposal 2.5 (1.6).
• Hazardous: incineration 9.8 (11.1), landfill 2.2 (0).

Totals: non-hazardous 127,680.9 (115,974.7 in 2024), hazardous 17,866.6 (16,436.6), all waste 145,547.5 (132,411.4, restated). Diverted 145,379.3 (99.9%); sent to disposal 168.2 (0.1%). Radioactive waste: none.

The table splits waste by treatment route and has no separate line labeled non-recycled waste, although the EU datapoint list points to this page for it (pages 176-177).

Accounting policy: data comes from national systems, contractors and waste facilities. The Group follows the European Waste Catalogue and Annex I and II of the Waste Framework Directive (page 233).

Policies related to own workforce

Reference: pages 235-236, 241, 245.

• Health and safety (page 236): Group Occupational Health and Safety Policy; a standard for investigating and recording incidents; a Stop Work Authority Policy that obliges staff to halt work they think is dangerous; ISO 45001 (companies employing 93% of staff are certified); Human Rights Due Diligence Guidelines; a TRIR reporting standard; guidelines on protective equipment and work at heights. The Group says it follows the OECD Guidelines and the UN Guiding Principles.
• Working conditions (page 241): Remuneration Policy; Code of Ethics (equal pay for equal work, ILO Conventions 100, 111 and 155); Directive (EU) 2022/2041 on adequate minimum wages.
• Equal treatment (page 245): Equal Opportunities and Diversity Policy with zero tolerance for discrimination; Abuse and Harassment Prevention Policy (updated August 2025); People and Culture Policy; Strategic Plan for Diversity, Inclusion and Wellbeing 2022-2025.

The Group has no separate policy on human trafficking, forced labor or child labor, and says national laws already govern them (page 235).

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

Reference: pages 237-238, 242, 246-247, 250-252.

• Safety (pages 237-238): mandatory training and certification, contractor training, workplace risk assessments, sharing of incident findings, ISO 45001, the '10 Lifesaving Rules' and Stop Work Authority. Planned: root-cause investigation of incidents, more reporting of unsafe situations, stronger HSE risk assessment.
• Pay and benefits (page 242): health and accident insurance, extra days off, social allowances, vaccinations and pension fund payments.
• Equality and wellbeing (pages 246-247): mandatory training on abuse and harassment, a women's referral challenge, anonymized CV screening, LGBT awareness activities, burnout prevention guidelines, and quarterly tracking of team burnout risk and resilience.
• Skills (pages 251-252): training on safety, career planning, ethics, resilience, leadership and AI and digital skills; a New Skills and Competencies Development program in renewable operations; scholarships.

The Group tracked the effect of some actions, such as the referral challenge, and says it judges training by follow-up assessments and feedback (pages 247, 252).

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

Reference: pages 238, 243, 247-248, 252.

• Safety (Strategic Plan 2025-2028, approved by the Supervisory Board): zero fatal accidents, employee TRIR at or below 1.0 and contractor TRIR at or below 1.7. In 2025 there were no fatalities and TRIR was 0.72 for both groups (page 238).
• Wellbeing: keep the eNPS at 50 or more. 2025 result 65.6 (65.2 in 2024) (page 243).
• Gender balance: at least 33% women in top management by 2028. The 2025 share was 29.4% (page 248). A 2026-2029 plan under development raises this to 35% or more and adds a target to raise the share of resilient teams (page 247).
• Skills: all employees complete the first level of four strategic competencies within six months. The Group says this was reached (page 252).

Employee involvement: staff took part indirectly in the safety target through a maturity assessment of the safety system. For the gender target, the workforce was not engaged directly and is informed through quarterly reports (pages 238, 247).

Characteristics of the undertaking's employees

Reference: page 239.

Year-end headcount was 4,851, up from 4,688 in 2024. Women are 1,555 (32.1%) and men 3,296 (67.9%).

By country: Lithuania 4,629, Latvia 114, Poland 75, Estonia 31, Finland 2.

Turnover: 602 employees left in 2025 (264 women, 338 men), a rate of 12.4%, up from 11.4% (536 leavers). The rate is leavers divided by year-end headcount.

The table also splits employees by permanent and temporary contract, full-time and part-time, with a gender split for each. No employees work on non-guaranteed hours. The category 'other' for gender is not applicable, because registration of it is not legally recognized in the countries concerned.

Method: data comes from personnel registration systems at year end. The count excludes people on maternity, paternity or parental leave, in military service, and trainees not on the payroll (page 239).

Collective bargaining coverage and social dialogue

Reference: pages 242-243.

Page 243 gives the collective bargaining and social dialogue table for Lithuania only. Lithuania is the one country with more than 50 employees representing more than 10% of the Group's workforce, since 95% of all employees work there. Latvia, Estonia, Poland and Finland fall below that test. The table shows coverage in percentage bands (80-100%, 60-79% and so on), so this summary gives no single figure.

Employee representation: trade unions at Ignitis Gamyba and ESO, and works councils in the other companies. Representatives have the right to be informed and consulted on company decisions, restructuring and health and safety programs. Collective agreements are reached through collective bargaining, and unions and councils meet management quarterly on wages, working hours and benefits (page 242).

The Group did not meet the criteria for a European Works Council in the reporting period (page 243).

Diversity metrics

Reference: page 248.

Top management (2025, with 2024 in brackets): 35 women (29.4%) and 84 men (70.6%) against 33 women (27.7%) and 86 men.

All employees by age (women and men in 2025):

• Under 30: 168 women (35.6%), 304 men.
• 30-50: 1,091 women (38.8%), 1,718 men.
• Over 50: 296 women (18.9%), 1,274 men.

Top management covers the collegial bodies, the CEOs of Group companies, the first management level below the CEOs, heads of functions and the head of the Group service center. Special purpose vehicles are out of scope. For companies registered outside Lithuania it covers only collegial bodies and CEOs. A manager holding positions in different companies is counted once per company.

Data comes from personnel registration systems at year end, excluding people on maternity, paternity or parental leave, in military service, and unpaid trainees (page 248).

Adequate wages

Reference: pages 241, 243.

The Group states that all employees are paid an adequate wage, in compliance with Directive (EU) 2022/2041 on adequate minimum wages (page 243). The statement is one sentence. It gives no pay levels and no benchmark by country.

Supporting text on page 241: the Group follows the directive by ensuring all employees receive wages higher than the minimum. Its Remuneration Policy sets principles of internal fairness, external competitiveness, clarity, transparency, equal opportunities and non-discrimination, and the Code of Ethics provides for fair pay based on functions performed.

The content index lists S1-10 on page 243 (page 172).

Social protection

Reference: page 244.

The table covers five life events in each of the five countries where the Group has employees (Lithuania, Latvia, Estonia, Poland, Finland). For retirement, unemployment and parental leave, all employees of Group companies are covered according to national laws. For sickness, all employees are covered, with health insurance and further sickness benefits and wellness days added by the Group. For employment injury and acquired disability, all employees are covered and receive extra accident insurance that pays out on death, disability, injury or critical illness.

Additional Group benefits come from the Standard of Additional Benefits. They include support payments for serious illness, accident or natural disaster, and allowances for birth or adoption and for families with many children, disabled dependents or single parents. In Lithuania, employees may choose voluntary contributions to a pension fund. Unemployment cover starts from when the person works for the company, except where the contract ends at the employee's initiative or through breaches of work rules (page 244).

Persons with disabilities

Reference: page 249.

The table reports the percentage of employees with disabilities, by gender, for 2025 and 2024. The share is below 1% for both women and men in both years. Disability status is recorded at year end and comes from personnel registration systems.

The Equal Opportunities and Diversity Policy commits the Group to creating an inclusive environment for people with disabilities (page 245). The Group has also made its customer self-service portals and websites compliant with the EU Accessibility Directive (page 268).

The content index lists S1-12 on page 249 (page 172).

Training and skills development metrics

Reference: page 253.

All employees (1,555 women and 3,296 men) took part in regular performance and career development reviews (100%). The format of the review varies by company but covers everyone.

Total training hours were 91,382 in 2025 (99,653 in 2024), an average of 18.8 hours per employee against 21.3. Women averaged 20.4 hours (24.4 in 2024) and men 18.1 (19.8).

Method: average hours equal total recorded training hours divided by year-end headcount. Mandatory briefings such as fire safety and work procedures are not counted as training, and online courses are not included in these indicators (page 253).

The table splits the figures by gender only, with no breakdown by employee category.

Health and safety metrics

Reference: page 240.

• Share of own workforce covered by the health and safety management system (ISO 45001): 91.8% (87.2% in 2024). The policy table on page 236 gives 93% of employees working in certified companies.
• Fatalities: 0 among employees and 0 among contractors, same as 2024.
• Recordable incidents among employees: 6 (9 in 2024); TRIR 0.72 (1.12).
• Lost time injuries: 6 (5); LTIR 0.72 (0.62).
• Contractors: 7 recordable incidents (9); TRIR 0.72 (0.84).

TRIR and LTIR are counted per million hours worked. LTIR counts injuries that cause at least one calendar day of lost work after the day of the incident. TRIR adds incidents where the person could work the next day and cases needing medical treatment. Contractor hours come from contractor data.

The EU datapoint list marks the days-lost datapoint as phase-in (page 176). No count of days lost appears on page 240.

Work-life balance metrics

Reference: page 249.

All employees are entitled to family-related leave. In every country where the Group operates, the entitlement follows national law and covers all employees (100%).

Take-up in 2025: 37.1% of entitled employees took family-related leave, against 37.9% in 2024. Among women it was 47.8% (49.4%) and among men 32.1% (32.5%).

The figure counts employees who took maternity, paternity, parental and carers' leave during the financial year. The 2024 comparatives were restated: the report previously showed 1.73% overall, with 4.4% of women and 0.5% of men (page 249).

Data comes from the personnel registration systems.

Compensation metrics (pay gap and total compensation)

Reference: pages 244, 157.

Page 244 sends S1-16 to section 5 Remuneration. On page 157 the Group reports:

• Gender pay gap: the average gap in fixed and total pay between women and men for 2025 and 2024, split into managers, experts and specialists, and blue-collar employees. It calls the overall gap insignificant in 2025 and says the largest gaps are at senior executive and worker levels. Figures by category are in the table on page 157. The gap is calculated on average gross monthly pay.
• Pay ratio: the total remuneration of the highest-paid employee (the table labels it the parent company CEO) against the median total cash remuneration of Group employees was 10.3 in 2025 and 11.0 in 2024. The Group says this level is typical for small organizations.

Fringe benefits such as accident and health insurance are excluded from total remuneration because all employees receive them equally (page 157).

Incidents, complaints and severe human rights impacts

Reference: page 254.

• Complaints filed through channels for own workforce: 14 in 2025 (16 in 2024).
• Of these, incidents of discrimination including harassment: 11 (6 in 2024, restated from 3). Confirmed incidents: 0 (3 in 2024).
• Complaints to OECD National Contact Points: 0.
• Fines, penalties and compensation for these incidents and complaints: EUR 0.
• Severe human rights issues connected to own workforce: 0, including cases of non-respect of the UN Guiding Principles, ILO Declaration or OECD Guidelines. Fines for these: EUR 0.

Reports come in through the Trust Line, are logged in an internal register, can be anonymous and are sorted by topic. The Group Internal Investigation Commission handles investigation. The count covers complaints about potential violence and harassment, violations of the code of ethics and violations of equal opportunities, and may not reflect every complaint employees raised (page 254).

Policies related to value chain workers

Reference: pages 255-256.

Material items: a negative impact from work-related injuries and fatalities among contractors, and a risk from occupational health and safety in the value chain (page 255). The Group says it cannot yet cover the full scope of value chain workers because it cannot access the necessary data, and focuses on first-tier suppliers and contractors. It considered child and forced labor and found no material item (page 255).

Policies (page 256):

• Occupational Health and Safety Policy: extends the same standards to value chain workers. Contractors must run risk assessments, give training, report incidents and follow procedures, and companies check this through prequalification, onboarding and monitoring.
• Supplier Code of Ethics: covers all suppliers and business partners, requires safe and healthy workplaces, and addresses labor practices under the UDHR, ILO fundamental conventions and UN Global Compact.
• Company internal standards and instructions (not public) at Ignitis Renewables, Ignitis Gamyba, Vilnius and Kaunas CHPs and ESO, covering high-risk tasks.

Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actions

Reference: pages 257-258.

• Pre-partnership checks: suppliers confirm the absence of exclusion grounds and compliance with social and labor law. Procurement contracts require safe working conditions and ISO 45001. Ignitis Renewables runs supplier due diligence and is piloting an AI tool to pre-assess ESG risk (page 257).
• Annual supplier assessments of tier 1 suppliers on human rights and labor law. The Group says nearly all suppliers support legal norms for safe working conditions (page 257).
• Engagement: training, permits to work, quarterly meetings, contractor safety days and professional skills competitions at ESO (page 257).
• Inspections: annual plans, with reports sent to contractors. Contractors must report accidents within 24 hours or the next working day (page 258).

Results: contractor TRIR was 0.72, down 14.3%, with no fatalities. Seven incidents involved contractor employees, one major and six minor (page 258).

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

Reference: page 258.

The Strategic Plan 2025-2028 sets two safety targets for value chain workers: zero contractor fatalities and a contractor TRIR below 1.7. In 2025 the Group reports it met them, with a TRIR of 0.72 (page 258).

The targets were informed by Group company representatives who deal directly with contractors and know their working conditions. The targets, results and lessons learned are published in the annual report (page 258).

Ignitis Renewables also keeps an internal register of objectives and targets and an OHS strategy that covers its supply chain. Each construction project has its own OHS objectives and targets in its execution plan, and the company aims to give main contractors a generic risk register before a project starts so they can assess project risks first (page 258).

Policies related to affected communities

Reference: pages 259-260.

Material items (page 259): a negative impact from disturbance of daily living conditions during construction, a positive impact from boosting local economic development, and a risk that failing to deal early with community opposition could delay or cancel projects. They arise mainly in Green Capacities.

Policies (page 260): the Code of Ethics; the Sustainability Policy (community involvement); the Environmental Policy (consider community interests, support education projects, report environmental goals to communities); the Financial Support and Humanitarian Aid Policy (updated July 2025 to include Ignitis Gamyba's area); Community Involvement and Relations Management Guidelines; Ignitis Renewables' Financial Support Management Rules; and its internal Community Engagement Strategy.

By year end the Group had received no information on human rights non-compliance affecting communities. It says no existing or planned project is in an area where indigenous people live, so the topic is not yet in its policies (page 259).

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

Reference: pages 261-262.

No severe human rights issues or incidents were identified for affected communities (page 261).

• Minimizing disturbance: Ignitis Renewables warns communities in advance of road closures and oversized cargo, waters roads against dust, repairs roads, and gives contact details for questions (page 261).
• Financial support: programs for community projects exist in Lithuania, Latvia and Poland, and a new one started for the Tume solar farm in Latvia. A mandatory generation fee began for communities near Mažeikiai wind farm. Kaunas CHP and Ignitis Gamyba also take applications (pages 261-262).
• Communication: more than 190 meetings with communities in 2025, and a second community gathering with 109 participants, where 90% of respondents said it was useful. Ignitis Renewables considers repeating the format in Latvia and Poland in 2026 (page 262).

The Group says it has no standardized process yet to evaluate the effectiveness of disturbance measures, financial support or communication (pages 261-262).

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

Reference: page 262.

The one target named is an internal 2025 target at Ignitis Renewables to update its Community Engagement Strategy with an engagement framework, so that existing practice is standardized and new practice is formed. The Group reports that the strategy was upgraded with extra standards for stakeholder engagement planning, grievance management, project exhibitions, newsletters and factsheets. The aim is common guidelines and tools for teams working in different markets.

The Group says affected communities and their representatives were not engaged directly in setting targets, tracking performance or identifying lessons (page 262).

The page gives no quantified Group-wide target for community impacts or for the community risk.

Policies related to consumers and end-users

Reference: pages 263-264, 270.

Material items: a positive impact from access to energy and a risk of high-impact cyber attacks (pages 263, 270).

Access to energy (pages 263-264): the Code of Ethics (privacy, equal treatment, non-discrimination), the Human Rights Due Diligence Guidelines (not public), and the EU Third Energy Package, which splits supply from network management so ESO and Ignitis each set their own policies. ESO has service standards, crisis protocols and last-resort supply terms. Ignitis uses a Customer Experience Book and pricing rules that require equal, non-discriminatory pricing. Both run grievance channels, backed by the Trust Line and the regulator's dispute process.

Cybersecurity (page 270): the Group Information Security Policy, the Personal Data Protection Policy and Guidelines, and the NIS2 Directive and GDPR. The policies stress limiting data collection, encryption, regular audits and breach reporting.

The datapoint list points S4-1 to pages 264 and 270 (page 177).

Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions

Reference: pages 267-268, 272.

Access to energy: ESO added pricing plans on 1 July, a nine-person Work Planning team to cut disconnections, and system alerts for low-voltage failures. Ignitis introduced 15-minute smart variable price plans. Its debt guidelines bar disconnection on Fridays, holidays and weekends, exempt critical institutions, and stop gas disconnection for heating in winter. Indebted private customers may repay over six months without financial documents (page 267). Transactional NPS at Ignitis rose to 74.3 (68.7) for private and 67.0 (64.0) for business customers (page 268).

Reliability: 365 km of 10 kV overhead line replaced by underground cable in 2025; over 37% of the grid is underground; about 1.3 million smart meters installed; planned winter outages are capped at six hours (page 268).

Cybersecurity (page 272): no high- or medium-impact cyber incidents in 2025; phishing arrived from compromised third-party accounts; several Group companies became essential entities under NIS2.

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

Reference: pages 269, 273.

Access to energy (page 269):

• ESO: average unplanned interruptions per customer per year (SAIFI) at or below 0.95 over 2025-2028; replace 2,000 km of overhead lines with underground cable by 2028; more than 1.2 million smart meters by 2026 (the Group reports about 1.3 million installed by the end of 2025, page 268).
• Ignitis: make services affordable through smart plans, grow users of the EnergySmart app, and build a leading EV charging network across the Baltic region.

Cybersecurity (page 273): for 2026, no sanctions from supervisory authorities for non-compliance with NIS2 or GDPR, on-time reporting of data breaches where required, and an 85% employee pass rate in basic digital security training.

The Group says it does not engage consumers directly when setting targets, tracking results or finding lessons. Targets use inputs from customer engagement and feedback (pages 269, 273).

Business conduct policies and corporate culture

Reference: pages 274-277.

Material items: positive impacts from a strong corporate culture, sustainable procurement, and contribution to energy security (page 274).

Policies (pages 275-277):

• Code of Ethics: applies to all staff, board members and business partners. Compliance runs through a three-line model, from managers to Business Resilience and Sustainability staff to Internal Audit and the Sustainability Committee.
• Anti-Corruption Policy: based on the UN Convention against Corruption and the Lithuanian anti-corruption law, applying to everyone acting for the Group. The anti-corruption management system follows ISO 37001.
• Trust Line: whistleblower channel for employees, contractors, suppliers and others, anonymous and consistent with Lithuania's Whistleblower Protection Law. The Group has no separate internal whistleblower policy and no plan for one.
• Supplier Code of Ethics and procurement policies (public procurement, commercial or regulated procurement, and use of collateral and supplier financial condition).

The statement notes that it does not disclose whether and how the Group assesses employees' trust in the reporting channels (page 276).

Targets related to business conduct

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

The Group sets no specific business conduct targets. On energy security it says it has no specific metrics and targets because energy security is a qualitative key target (page 281).

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

• The annual corruption risk assessment includes judging how well existing anti-corruption controls work, and new measures are planned where needed (page 279).
• The Head of Anti-Corruption Compliance monitors the control measures and escalates to the CEO (page 279).
• Code of Ethics compliance is tested by Business Resilience and Sustainability staff, who test employee knowledge and summarize results for Internal Audit and the Sustainability Committee (page 275).
• Supplier compliance is assessed annually, with a published monitoring report (page 278).
• Anti-corruption training coverage was 100% of functions-at-risk (page 280).

Incidents of corruption or bribery

Reference: page 280.

The Group reports nil for 2025, with the same result for 2024:

• Convictions for violating anti-corruption and anti-bribery laws: 0.
• Fines for violating those laws: EUR 0.
• Confirmed incidents of corruption or bribery: 0.
• Confirmed incidents in which own workers were dismissed or disciplined for corruption or bribery: 0.
• Confirmed incidents involving business partner contracts terminated or not renewed because of corruption or bribery violations: 0.

Reports arrive through the Trust Line channels, are logged in the Group's internal register, and are handled and investigated under the Group's internal legal acts and the rules of its Internal Investigation Commission (page 280). The EU datapoint list points to this page for the fines datapoint (page 177).

Political influence and lobbying activities

Reference: pages 280-281.

The Anti-Corruption Policy states that the Group does not tolerate illegal lobbying. The Group is registered in the EU Transparency Register. In Lithuania it takes part in energy legislation work within an exception to the Law on Lobbying Activities, so no registration is needed there. The Group Legal function oversees lobbying (page 280).

No lobbying records were registered in 2025 except in Latvia. SIA Ignitis Renewables Latvia hired professional lobbyists under a 2024 agreement that stayed in force in 2025, focused on possible changes to the Law on Environmental Impact Assessment and regional planning for wind energy (page 280).

The Financial Support Policy bars use of support for political parties, politicians or campaigns. No financial or in-kind political contributions were made in 2025 (page 280).

Three of the nine Supervisory Board members are civil servants, as the law requires for state-owned companies, and there are civil servants on the boards of three subsidiaries (page 281). The Group lists its trade association memberships (page 281).

Payment practices

Reference: page 281.

The Group's standard payment term is 60 calendar days, and terms are set in contracts by mutual agreement. It says its payment practices do not discriminate against small and medium enterprises.

It does not disclose the average time taken to pay an invoice. At the end of 2025 there were 3 legal proceedings outstanding for late payments.

Rules on preventing late payment are set in the internal procedures of Ignitis (Customers & Solutions) and ESO (Networks) and in the Lithuanian Law on the Prevention of Late Payment in Commercial Transactions (page 281).

The G1 chapter also presents an entity-specific positive impact on energy security. The Group says it has no specific metrics and targets for it, as it treats energy security as a qualitative key target (page 281).