Kemira

Reference: pages 74-76.

The Board of Directors and the President & CEO are responsible for Kemira's management and sustainability matters under the Finnish Companies Act and Kemira's Articles of Association. The Board has appointed the Audit Committee (financial and sustainability reporting, internal control, audit and assurance, compliance monitoring) and the Personnel and Remuneration Committee (compensation linked to sustainability KPIs). Kemira's new operating model, effective January 1, 2025, changed some organizational responsibilities.

The Board comprises 5-10 members under the Articles of Association; the AGM on March 20, 2025 elected eight members, re-electing six and adding Susan Duinhoven (Vice Chair) and Matti Lehmus. Annika Paasikivi chairs the Board. In 2025, 100% of Board members were independent and non-executive, the Board was 38% female (2024: 29%), and the Group Leadership Team was 20% female (2024: 25%).

Reference: page 77.

Kemira's Board received CSRD- and ESRS-related updates from management throughout 2025, covering sustainability strategy and targets, sustainability programs and policy updates, the 2024 Sustainability Statement review, the Modern Slavery statement, EU Taxonomy and CSRD developments, safety performance and other sustainability key figures, review of manufacturing sites' environmental status, the materiality assessment revision and results, and approval of the updated Code of Conduct.

The Audit Committee addressed sustainability reporting in every 2025 meeting, including CSRD/ESRS reporting developments related to the EU omnibus and "quick-fix" changes, the sustainability reporting assurance plan and process status, the CSRD and ESRS reporting process itself, and the materiality assessment revision process and its results.

Reference: page 78.

Kemira has integrated sustainability priorities into both its short-term and long-term incentive plans to keep the sustainability transformation a high priority. Safety, weighted at 5%, has been a short-term incentive KPI for several years, with a strategic revenue growth target added the previous year.

Sustainability targets are built into the long-term incentive program's overlapping performance periods (2023-2025, 2024-2026 and 2025-2027). Revenue Growth of Renewable Solutions and the Scope 1 and 2 climate target have carried a 10% weight each in the long-term plan since the start of 2023, with the climate target reflecting Kemira's Science Based Targets initiative commitment to an annual reduction rate. The Board of Directors defines and approves the incentive scheme principles; full detail is in Kemira's Remuneration Report.

Reference: page 78.

Kemira states that acting ethically and responsibly is both the right thing to do and something that benefits the business and stakeholders. It works in accordance with the UN Guiding Principles on Business and Human Rights, and its Sustainability Statement is structured around its due diligence processes: assessing impacts and risks under the General disclosure's material impacts, risks and opportunities section; integrating and acting to address them through actions in the topical standard sections; tracking effectiveness through topical targets; communicating impacts and risks through topical material impacts, risks and opportunities disclosures; and stakeholder engagement in due diligence through topical policies and the General disclosure's stakeholder engagement section.

Kemira also initiated a dedicated Due Diligence Program for 2025-2028 in response to the Corporate Sustainability Due Diligence Directive, covering own operations and the full value chain including logistics and warehousing.

Reference: pages 77-78.

The Board of Directors defines Kemira's risk management principles and approves the Group's Risk Management Policy. Business units and functions identify, assess and manage risks in their areas; the Group Risk Management team coordinates the process and reports risks to the Group Leadership Team and Board; Internal Audit monitors and evaluates the risk management system's effectiveness. The approach follows the Finnish Corporate Governance Code, the Code of Conduct and ISO 31000.

Sustainability reporting risks are managed through Kemira's Integrated Management System and Enterprise Risk Management process, with internal controls covering all Group operations. Risks identified relate mainly to completeness of qualitative and quantitative information and reporting timing. The Audit Committee regularly follows up on these risks, and sustainability reporting compliance is assured through limited assurance by the independent provider.

Reference: pages 79-80.

Kemira provides sustainable chemical solutions for water-intensive industries, operating in 37 countries with 58 manufacturing facilities at the end of 2025 across three regional business areas (EMEA, APAC, Americas). A new operating model effective from the start of 2025 introduced three business units: Water Solutions, Packaging & Hygiene Solutions and Fiber Essentials.

In 2025, 21 billion m3 of water was treated, reused or recycled with Kemira chemistry, and 64% of revenue came from products that improve customer resource efficiency. Kemira's value chain runs from upstream feedstocks (renewable, recycled, fossil-based and mineral) through global raw-material refining, to own manufacturing across the three regions, to customers and distributors. Kemira aims for EUR 500 million in renewable solutions revenue by the end of 2030.

Reference: pages 80-81.

Kemira regularly reviews stakeholders' expectations, with engagement ranging from information sharing to active dialogue and collaboration. Feedback is integrated into operational development, decision-making and strategy, and stakeholder views fed into the materiality assessment. During 2025 Kemira conducted a "Meaningful stakeholder engagement in the value chain" study to deepen dialogue with stakeholders, with particular attention to affected stakeholders.

A stakeholder engagement table covers own workforce, shareholders and lenders, customers, suppliers, affected communities, regulatory bodies, and trade associations, setting out the purpose of engagement, how it is organized (e.g. performance dialogues and an Ethics and Compliance hotline for employees, roadshows and CDP questionnaires for investors, supplier audits and due diligence for suppliers) and outcomes such as ESG rating improvement plans and supplier improvement plans.

Reference: pages 82-84.

Kemira's 2025 double materiality assessment identified 212 positive and negative impacts, risks and opportunities in total, of which 42 were found material, down from 50 material items the previous year; the most significant topics were Water and marine resources, Climate change, and Resource use and the circular economy. Two social standard topics, Affected communities and Consumers and end-users, were found not material, which the company says reflects its position in the value chain and business model.

A results table maps each material standard (E1-E5, S1, S2, G1) to its position in the value chain (upstream, own operations, downstream), the nature of the impacts and financial materiality, and the number of impacts, risks and opportunities identified per standard. Some standards were more widely represented because, for those topics, all sub-topics were found within the materiality scope.

Reference: pages 82-86.

Kemira's materiality assessment was based on its strategic priorities and management's view, linked to Kemira's internal Enterprise Risk Management scale for both impact and financial materiality. Six phases are used: scoping of impacts, risks and opportunities (documentation review plus an industry benchmark study); stakeholder engagement (interviews with management, subject matter experts, customers and investors); assessment in internal workshops (impact materiality scored for severity and likelihood, financial materiality for scale and likelihood); revision (2025 revision made no major scope changes versus the prior year, with some restructuring and rephrasing); prioritization against the set threshold; and management review and validation by the Group Leadership Team and Audit Committee.

Kemira identifies negative impacts, positive impacts, risks and opportunities separately for each material sub-topic, distinguishing upstream, own-operations and downstream positions and short/medium/long-term time horizons. The assessment is reviewed at least annually, and alignment with Enterprise Risk Management is due to be finalized in 2026.

Reference: pages 87-88.

Kemira's ESRS Content Index lists, with page references, the general disclosure requirements (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2), the environmental topical standards (E1 including the transition plan E1-1 and targets/metrics E1-2 to E1-9, E2-1 to E2-5, E3-1 to E3-4, E4-1 to E4-5, E5-1 to E5-5), the social standards (S1-1 to S1-11 and S1-13 to S1-17, and S2-1 to S2-5), and the governance standard (G1-1, G1-3, G1-4 and G1-5).

Not listed in the index, and therefore not separately disclosed for FY2025, are the "anticipated financial effects" disclosure requirements across E2, E3, E4 and E5, S1-12 (persons with disabilities), and G1-2 (supplier relationships) and G1-6 (payment practices). Kemira also has a separate table of datapoints deriving from other EU legislation (SFDR, Pillar 3, the Benchmark Regulation and the EU Climate Law), which marks several sub-datapoints, including S3 and S4 items, as "Not material".

Reference: pages 92-94.

Kemira's near-term Scope 1 and 2 target and long-term ambition follow an absolute contraction approach validated by the Science Based Targets initiative (SBTi) in 2024. The near-term plan targets a 51.2% reduction in Scope 1 and 2 emissions by 2030 versus the 2018 baseline (894 ktCO2e), reaching 436 ktCO2e; by end of 2025 emissions had fallen 43.1% to 509 ktCO2e. The long-term plan targets carbon neutrality in Scope 1 and 2 by 2045, prioritizing a 90% emissions cut with neutralization of the remainder. A parallel Scope 3 plan targets a 32.5% reduction by 2033 from a 2021 baseline of 2,337 ktCO2e; Scope 3 was down 26.0% by 2025.

The plan's decarbonization levers include energy efficiency, switching to emission-free electricity (nuclear, wind, hydro, solar), fuel switches and further electrification. Kemira states it is not excluded from the EU Paris-Aligned Benchmarks and reevaluates targets by 2029 at the latest.

Reference: pages 92-93. Back-filled from the E1 climate change chapter's scenario-analysis subsection, since E1-2 as a standalone disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Kemira's climate risk scenario analysis, initiated in 2022 and expanded in 2023 with external support, evaluated transition and physical risk across 11 manufacturing sites and 8 business functions over short-term (to 2030), medium-term (2030-2050) and long-term (2050+) horizons, using IPCC RCP 2.6 (below 2C) and RCP 8.5 (worst-case) pathways; it identified 15 transition risks and 5 physical risks.

In 2025 Kemira completed a dedicated transition risk assessment using IEA scenarios: NZE 2050 (1.5C pathway), APS (roughly 1.7C by 2100) and STEPS (2.4-2.5C, current policies only), assessed over short (2030), medium (2040) and long-term (2050) horizons with input from Business Controllers and Finance functions to evaluate financial impact. The most material risks identified relate to energy price volatility, extreme weather disrupting manufacturing and logistics, and the inability to transition from fossil-based raw materials.

Reference: pages 92, 99-100. Back-filled from the E1 climate change chapter, since E1-3 as a standalone resilience disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Kemira states that its "climate-related impacts, risks and opportunities are integrated to our business model and strategic planning," and that it assesses "climate resilience across our operations and value chain, following the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD)."

Adaptation and resilience measures described include reinforcing critical infrastructure, inspecting and maintaining heating and cooling systems, installing backup generators, increasing inventory levels ahead of severe weather seasons, preparing contingency plans with alternative suppliers under a dual-supplier policy, and constructing dykes and embankments at flood-susceptible sites. On the supply side, Kemira says it is "actively addressing the risk of locked-in emissions" from long-lived supplier infrastructure by prioritizing low-carbon procurement and phasing out fossil-based feedstocks.

Reference: page 95.

Kemira's climate policies sit within its Sustainability Policy, which commits the company to climate change mitigation and adaptation and to energy efficiency and renewable energy deployment, aligned with the Code of Conduct and Kemira's Group Risk Management Policy. Value chain partners are governed through the Code of Conduct for Business Partners, which sets environmental responsibility requirements; suppliers, agents and distributors go through due diligence and EcoVadis assessment.

Kemira is a member of the Renewable Carbon Initiative, reinforcing its commitment to shift from fossil-based to renewable carbon and raw materials, and states it is not excluded from the EU Paris-Aligned Benchmarks. Key contents, scope, process, accountability and availability of Kemira's policies are set out in the G1 Business Conduct section under Corporate Culture and Business Conduct Policies.

Reference: pages 97-100.

In 2025, Kemira's combined Scope 1 and 2 emissions accounted for about 23% of total GHG emissions (Scope 1 approximately 6%, Scope 2 approximately 17%). Scope 1 actions included 18 completed energy efficiency projects delivering 17,053 (2024: 20,675) MWh of savings worth EUR 1.2 (1.1) million under the EnRe5/E3plus programs, and a new energy core team established in January 2025 to run the long-term decarbonization roadmap. Since 2018, Kemira has invested about EUR 4.1 million in Scope 1 abatement and EUR 4.7 million in Scope 2 abatement, including wind PPAs and equity in low-carbon Finnish power producers Pohjolan Voima and Teollisuuden Voima, plus solar installations at the Mojave and Bartow sites.

Scope 3 actions focus on categories 3.1, 3.4 and 3.9 (about 70% of Scope 3), through a Supplier Engagement Program, renewable/recycled feedstock expansion, RSPO-certified palm oil derivatives (around 15% of AKD palm-oil derivatives in 2025), and the GLEC framework for logistics emissions.

Reference: page 96.

Kemira's Scope 1 and 2 near-term target, validated by SBTi in 2024, is an absolute contraction of 4.2% annually from the 2018 base year, totaling 51.2% by 2030 (894 to 436 ktCO2e). The Scope 3 target requires a 2.5% annual reduction from the 2021 base year, totaling 32.5% by 2033 (2,337 to 1,577 ktCO2e), covering categories 3.1, 3.4 and 3.9 which represent about 71% of total Scope 3 emissions. The long-term ambition is carbon neutrality by 2045 for combined Scope 1 and 2 market-based emissions.

As Scope 2 makes up about 75% of Scope 1 and 2 emissions (roughly 82% from purchased electricity), Kemira is prioritizing renewable energy investment, energy efficiency and electrification to meet the targets. Progress is reported quarterly to the Group Leadership Team, and targets will be reevaluated in 2029 at the latest, with new five-year targets set thereafter.

Reference: page 101.

Kemira reports energy consumption and mix for its operations, which are classified as a high climate impact sector under EU NACE codes. Total energy consumption in 2025 included fossil sources (crude oil and petroleum products, natural gas, other fossil fuels, and fossil-sourced purchased electricity, heat, steam and cooling), renewable sources (fuel from renewable sources including biomass, and purchased renewable electricity, heat, steam and cooling) and nuclear-sourced electricity, with year-on-year figures also disclosed for 2024 and 2023.

The renewable share of total energy consumption rose in 2025 versus the prior two years, consistent with Kemira's continued renewable PPA sourcing and its equity stakes in Finnish low-carbon power producers. Energy intensity is reported per net revenue from activities in high climate impact sectors, alongside energy production and greenhouse gas emissions intensity metrics for 2025, 2024 and 2023.

Reference: pages 101-103.

Kemira calculates its GHG inventory under the WRI/WBCSD GHG Protocol across all scopes. Gross Scope 1 emissions in 2025 were 129,379 tCO2eq, primarily from natural gas combustion in energy-intensive manufacturing; Scope 2 market-based emissions were 379,845 tCO2eq, down sharply from 477,937 tCO2eq in 2024 as the share of contractual renewable instruments for Scope 2 rose to 29.2% from 21.2%. Total Scope 1 and 2 (market-based) emissions were 509,224 tCO2eq, a 14.6% reduction versus the 2018 baseline of 894,303 tCO2eq.

Scope 3 emissions were 1,730,821 tCO2eq against a 2021 baseline of 2,337,475 tCO2eq, an 8.0% reduction, dominated by purchased goods and services (category 1) and upstream and downstream transportation (categories 4 and 9). Total GHG emissions (market-based) fell 9.6% year on year. Scope 2 market-based figures for 2023-2024 were restated following a revision to the calculation methodology and verification of site-specific supplier emission factors.

Reference: page 103.

Kemira states it "does not currently reduce its GHG emissions with carbon offsets," although it is "planning to look into available options in the future." The company views verifiable natural or technological carbon removals as a valid mid-term opportunity for GHG abatement, but says its current focus is on direct emissions reduction rather than offsetting, given "the uncertainty and low reliability of the offset market." Carbon offsets could be considered for long-term reductions "when the market is more mature."

No GHG removals from Kemira's own operations or value chain, and no GHG mitigation projects financed through carbon credits, are reported for 2025. Biogenic emissions or removals are not separately disclosed under this section; the company's decarbonization strategy relies instead on the levers described under Actions and resources in relation to climate change policies.

Reference: page 103.

Kemira introduced an internal carbon pricing sensitivity analysis in 2019 for investments exceeding EUR 500,000, updated in June 2022 to align with EU Emissions Trading Scheme prices at EUR 100 per tCO2eq. Since January 2024 the scope has broadened to apply globally across Kemira's value chain to all CapEx investments exceeding EUR 100,000. In 2025, internal carbon pricing was applied to projects with significant climate impacts totaling EUR 374,000, up from EUR 217,000 in 2024.

Kemira reports that in the short term the internal carbon price has raised internal awareness of current and future carbon costs and supported the corporate sustainability culture and external reputation, and that in the long term it has strengthened internal risk-management controls and helped identify decarbonization opportunities across own operations and the supply chain.

Reference: page 93.

Kemira's climate risk scenario analysis quantifies potential financial impacts of its material transition and physical risks, stated as potential estimates rather than exact expected effects. Energy price volatility (a transition risk concentrated in Fiber Essentials and Sourcing) could raise or lower revenue and variable costs; mitigations include energy sourcing, electrification, operational optimization and equity ownership in low-carbon energy. Physical risks from business interruption (all business units, own operations and downstream) could lower revenue and raise variable costs, insurance fees and reconstruction CapEx; mitigations include infrastructure resilience, insurance and emergency planning.

The inability to transition away from fossil-based raw materials is flagged as both a risk of lower revenue from decreasing demand and higher variable costs from carbon pricing, and an opportunity for higher revenue from demand for renewable chemicals and solutions, addressed through circular and low-product-carbon-footprint feedstocks, supplier engagement and long-term technology investment.

Reference: pages 106-107.

Kemira's pollution-related commitments sit within its Sustainability Policy, aligned with the Code of Conduct and its Product Stewardship Policy, Recruitment Policy, and Sourcing and Procurement Policy. Kemira runs a priority substance management process covering its entire value chain: it monitors the whole product portfolio, including raw materials and process chemicals, for substances of concern (SoC) and substances of very high concern (SVHC), and prepares management plans defining specific risks and mitigation options for each.

The materiality assessment identified actual negative impacts and risks from pollution of air, water and soil in the upstream value chain (raw material extraction), potential incidents at manufacturing facilities or during transportation, environmental liabilities from historical activities predating current regulations, and potential negative impacts from substances of concern or very high concern across the value chain. Normal-operations air emissions and water effluent within permit conditions were not found to be a material aspect.

Reference: pages 107-108.

Kemira's certified Integrated Management System sets global and site-level standards for permit and regulatory compliance, including spill prevention, process safety and maintenance standards, with all incidents logged in an internal reporting system. Sites are audited internally and externally against ISO 9001, ISO 14001 and ISO 45001, plus an annual third-party legal compliance audit program. In 2025, Kemira continued its Global Safety Training Program (all shift supervisors trained by year end) and its EMEA Transportation Safety enhancement program covering spill prevention in shipping and delivery operations.

On environmental liabilities, Kemira completed a soil and landfill remediation project at a former manufacturing site in Vaasa, Finland (historically contaminated with heavy metals and pesticides, started in 2022), plus smaller remediation projects elsewhere; provisions are reviewed quarterly by EHSQ and Finance & Accounting. Substance-of-concern management follows the priority substance process, with mitigation options including substitution, phase-out or exposure limits.

Reference: page 107.

Kemira tracks internal, voluntary indicators for pollution rather than ESRS-defined targets: the number of environmental incidents (ENV), loss of primary containment incidents (LOPC), reportable process safety incidents (RPSI) and environmental operating conditions (EOC). These are followed as part of the Integrated Management System and regularly reviewed and updated by Kemira.

The company states plainly that these indicators are "not defined as in ESRS," so pollution management is tracked through the operational indicators above rather than a quantified reduction target with a base year and target year, consistent with Kemira's broader statement that not all identified material impacts, risks and opportunities have associated targets aligned with the Minimum Disclosure Requirements.

Reference: pages 108-109.

Kemira collects data centrally and annually on air and water pollutant emissions from all manufacturing sites, reported in accordance with ESRS E2-4. The company reports emissions of ammonia to air and non-methane volatile organic compounds to air for 2025, 2024 and 2023, with the latter partly attributable to cutting-oil emissions at a UK site classified as a volatile organic compound. In 2025 Kemira reported no significant emissions to soil.

Emissions to air are estimated from direct measurements, published emission factors, mass balance or engineering calculations, with methodology varying by site. Environmental permits for all sites exceeding the European Pollutant Release and Transfer Register (E-PRTR) Annex II thresholds authorize the reported emissions, and the disclosed figures represent the consolidated total across all sites exceeding those thresholds.

Reference: page 109.

Kemira reports substances of concern (SoC) and substances of very high concern (SVHC) by hazard class and by year. SoC volumes are dominated by diesel oil, used mainly for steam generation critical to disinfection and temperature and humidity control in manufacturing, which the company says accounts for "approximately 99% of the total by weight" and was "largely unchanged" versus 2024. SVHC volumes are reported by hazard category (carcinogenicity, germ cell mutagenicity, reproductive toxicity, respiratory and skin sensitization), with a 2024 correction of 1,613 kg reclassified from SVHC to SoC following an internal review.

Only substances consumed at manufacturing sites with environmental permits are included; research and development facility use is treated as immaterial. Volumes are sourced from local ERP systems on transfer to production, with litres converted to kilograms using substance-specific factors where available.

Reference: page 112.

Kemira's Sustainability Policy commits the company to protecting the environment, including reducing water and material use and waste generation through circular economy principles, with the water-use commitment specifically covering material water consumption in water-risk and water-stress areas. The policy states that Kemira will "provide products for wastewater treatment that enable the availability of clean and high-quality water to people and nature, including water bodies."

Implementation of the policy on managing water and marine resource use and sourcing, and on preventing water pollution from Kemira's own activities, is described under the Actions related to water and marine resources and E2 Pollution sections. Kemira's Nature Stewardship program covers water, waste and biodiversity management together and reports to the Sustainability Steering Team; key contents, scope, process and accountability of Kemira's policies overall are set out in the G1 Business Conduct section.

Reference: pages 113-114.

Water Solutions became Kemira's largest business unit under the January 2025 operating model, reflecting the company's ambition to grow the water business organically and inorganically. In 2025, Kemira closed the acquisition of US Water Engineering Inc, an industrial water treatment services company, strengthening its North American position, and received full approval to invest in a reactivation plant for activated carbon at its Helsingborg, Sweden site to remove micropollutants including PFAS from drinking water. Kemira also announced a new production line for Aluminium Chloro Hydrate coagulant at its Tarragona site.

In the Paris region, Kemira's KemConnect DEX performic-acid disinfection solution was used by the Greater Paris Sanitation Authority to treat wastewater discharged to the Seine ahead of the 2025 public swimming season. Freshwater use in own operations is managed through the ISO 14001 system and the Nature Stewardship program; suppliers are assessed for water management via EcoVadis.

Reference: page 112.

Kemira set a voluntary target in 2021 to reach CDP Water Security's Leadership level (A/A-) by the end of 2025; it achieved an A- score in 2025, meeting the target, and ranks above European, Global and Chemical industry averages (all scoring C). During 2025 Kemira also developed a new positive water impact target: to grow the estimated quantity of water treated, reused and recycled by 3.5 billion m3 by the end of 2030 from a 2024 baseline of 20.9 billion m3 (2025 actual: 21.1 billion m3), aligned with its strategic priority to double water revenue and third-party verified for methodology.

Kemira is investigating whether to set a further water stewardship target focused on sites in water-risk areas during 2026. Site-level targets, where set, typically cover reductions in water consumption or improvements in wastewater discharge quality, based on site-specific materiality assessments.

Reference: pages 115-116.

Kemira reports total water consumption, water consumption in areas at water risk, water recycled and reused, and water intensity per net revenue for 2025, 2024 and 2023. Water consumption is defined as total withdrawals minus total discharges, calculated to be within +/-5% of measured or estimated water balances at most sites; recycled and reused water is mostly steam condensate directed back into process. Kemira has 12 of its 58 manufacturing sites (21%) located in water stress areas, identified using the WRI Aqueduct tool and the WWF Water Risk Filter.

Excluded from the scope are Kemira's R&I centers (Atlanta, Shanghai, Espoo), corporate and sales offices, toll and contract manufacturers, and former production sites under environmental liability management, each assessed as immaterial to total water consumption. Kemira also reports that 21 (21) billion m3 of water was treated, reused or recycled with the help of its chemistry in 2025, comparable to the consumption of roughly 372 million Europeans and North Americans.

Reference: page 117.

Kemira's single material E4 topic is "direct impact drivers of biodiversity loss," covering resource use and land-use change from resources extraction in the upstream value chain, and the removal of hazardous substances across downstream customer applications. Kemira states it "has initiated a transition plan in line with the time horizons applied in the double materiality assessment," tracked by the Nature Stewardship program.

An internal evaluation of direct biodiversity impacts, dependencies, risks and opportunities has been conducted, covering physical and transition risks in own operations and the upstream and downstream value chain; systemic risks were not evaluated. The results, giving an outlook up to ten years ahead, were communicated to the Board of Directors and Group Leadership Team. Kemira considers its business model "resilient to biodiversity and ecosystems-related risks," with the most significant indirect future impact expected in the upstream value chain from conventional and renewable raw material use.

Reference: pages 117-118.

Kemira's biodiversity commitments sit within its Sustainability Policy and Nature Stewardship program, aligned with the Code of Conduct, Product Stewardship Policy, Recruitment Policy and Sourcing and Procurement Policy. The Sustainability Policy commits Kemira to minimizing water and material use and waste through circular economy principles and to sustainable raw material sourcing, but the company states plainly it "has not adopted separate biodiversity and ecosystem protection policies" covering sites owned, leased or managed in or near biodiversity-sensitive areas, nor policies on sustainable land or agriculture, sustainable oceans or seas, or deforestation.

Kemira has initiated an assessment of actual and potential upstream biodiversity impacts for Tier 1 suppliers in its Pulp and Paper, Polymers and Coagulants product lines, following the Science Based Targets Network's Step 1a&b guidelines, finding the main indirect impacts come from terrestrial ecosystem use, water use, GHG emissions and pollution.

Reference: page 118.

Kemira reports that it "has not used biodiversity offsets in its action plans and does not plan to do so in the upcoming years," has not incorporated local and indigenous knowledge or nature-based solutions into biodiversity actions and does not plan to in the next two years, and has not concluded that dedicated biodiversity loss mitigation measures are necessary.

Instead, biodiversity-related action is channeled through Kemira's water-focused strategy: its Water Solutions business unit's growth in wastewater treatment, micropollutant removal and phosphorus recovery technologies is described as reducing pressure on biodiversity by lowering water withdrawal and discharge impacts, alongside R&I projects to develop new water-treatment and industrial-efficiency solutions and partnerships to recover nutrients from wastewater sludge.

Reference: page 118.

Kemira maintains internal indicators for biodiversity and ecosystems impacts, risks and opportunities rather than an ESRS-defined target. The company states these "targets are not defined as in ESRS" and that it "will continue the evaluation of these indicators in the following years," without disclosing a base year, target value or target date for biodiversity outcomes.

This mirrors the pattern across several of Kemira's environmental topics: rather than a quantified biodiversity target, management relies on the Nature Stewardship program's internal monitoring, alongside the site-proximity tracking described under Impact metrics related to biodiversity and ecosystems change.

Reference: pages 118-119.

Kemira states it "has not yet established metrics related to material impacts, risks and opportunities in the upstream and downstream value chain related to biodiversity and ecosystems," and that its Nature Stewardship program is developing at least internal quantitative indicators to track progress once a base period is set.

For own-operations siting, Kemira uses the Integrated Biodiversity Assessment Tool (IBAT) and the WWF Risk Filter Suite to monitor proximity of its sites to protected areas and key biodiversity areas, assessed annually and on acquisition. In 2025, Kemira had 10 (2024: 10) of its 58 manufacturing sites located in or near protected areas and key biodiversity areas. Based on environmental impact assessments conducted through the environmental permitting process, Kemira states its manufacturing sites do not negatively affect biodiversity-sensitive areas.

Reference: page 121.

Kemira's Sustainability Policy, Sourcing and Procurement Policy and Group Product Stewardship Policy set the principles for resource use and the circular economy, covering Kemira's global value chain in full. The company organizes its approach around five circular economy principles: transform raw material origin, increase efficiencies and reduce waste from own operations, help customer processes become more resource efficient, design beneficial end-of-life properties for customer products, and collaborate with the value chain to grasp circular economy opportunities.

Kemira states it "does not currently have a policy related to transitioning away from the use of virgin resources or the utilization of secondary resources," although its circular economy approach is embedded in the corporate sustainability program, and it is developing separate policies on sourcing renewable and secondary materials for future publication.

Reference: pages 123-124.

Kemira dedicated 42% (2024: 46%) of research and innovation OpEx to renewable materials and 23% (26%) to water treatment solutions in 2025. Renewable-materials work spans expansion of existing market chemistries, biomass-balanced solutions certified under ISCC PLUS, and new chemistries such as the Designed Enzymatic Biomaterial (DEB) platform developed with IFF and a three-year PHA polymer collaboration agreed with Bluepha in 2025. In 2025, 52% (49%) of purchased raw materials came from recycled sources, mainly by-products from smelters and steel and metal manufacturing, with coagulants sourcing up to 70-80% recycled content.

Suppliers are assessed via EcoVadis on sustainable procurement and environmental performance; in 2025, 71% of direct spend and 22% of indirect spend was EcoVadis-assessed, with an average spend-weighted rating of 68 out of 100, alongside quality and Corporate Social Responsibility supplier audits.

Reference: page 122.

Kemira holds a voluntary target that at least 50% of revenue come from products that improve customers' resource efficiency, calculated annually by rating 29 customer applications for impact on raw materials, energy, water, waste, yield or greenhouse gases; the company reached 64% in 2025, up from 58% in 2024, having "stayed well above the expected threshold." Kemira also targets renewable solutions revenue above EUR 500 million by the end of 2030 from a 2020 baseline, reaching EUR 240 million in 2025, and defines a "renewable solution" as a product where more than 50% of organic carbon derives from renewable sources.

A third target is to reduce disposed production waste intensity at manufacturing sites by 15% by the end of 2030 from a 2019 baseline of 4.4 kg/tonne of production; the 2025 intensity was 4.1, below the baseline. All three targets are voluntary and were approved by Kemira's highest management.

Reference: page 124.

Kemira has assessed resource inflows as a material sub-topic, with raw materials covering over 50% (52% in 2025) of total spend as the most material inflow category; plants and equipment, and water and packaging, were assessed as non-material based on spend or volume. In 2025, the total weight of products, raw materials and biological materials used was 2.6 million tonnes, of which 2.6% (67,340 tonnes) came from renewable (biological) sources and 52% (1.3 million tonnes) from recycled (secondary) sources.

Kemira's supplier base is tracked by region and category (direct materials and indirect goods and services) across EMEA, APAC and the Americas. Data comes from centralized financial and volume systems, with recycled and renewable content estimated in a two-step process using supplier-reported information combined with centralized system data.

Reference: page 125.

Kemira's product portfolio is split into products and solutions that enable and improve the customer process (e.g. pulping chemistries, water treatment coagulants and polymers, biogas yield improvement and digital services) and those that become part of the customer's end product (e.g. strength and coating chemistries, and fibers with renewable or recycled origin). The company states that durability or repairability are not seen as applicable attributes for its industrial chemical products, though its chemistries do contribute to customers' product durability, for example by enabling greater use of recycled fibers.

More than 90% of Kemira's products are delivered to customers as bulk transports with no packaging; the remainder use Intermediate Bulk Containers of plastic with metal frames, for which Kemira does not systematically track packaging recycling rates given the predominance of bulk transport.

Reference: pages 125-127.

Kemira generated 73,917 tonnes of waste from manufacturing in 2025, collected centrally across seven composition categories including chemical waste, sludge, metallic and mineral waste, soils and wastewater, with chemical waste and wastewater the most significant categories. Since 2019, Kemira's total manufacturing waste has fallen 51% (hazardous down 69%, non-hazardous down 41%). Separately, waste from liability-site management and demolition (soil, groundwater and landfill remediation) decreased significantly in 2025 as the Vaasa remediation project was completed.

About 68% of non-recycled waste is incinerated with energy recovery, including 49% of non-recycled waste piped from one site to an adjacent paper mill for incineration. Kemira's internally tracked recovery rate (reuse, recycling, incineration with energy recovery and other recovery) was 42% in 2025, down from 71% in 2024. Non-production waste (expired materials, spill debris, construction and demolition waste) and disposed products are excluded from the waste-intensity target.

Reference: pages 129-130.

Kemira's Code of Conduct outlines commitments to human rights and compliance with applicable laws and voluntary frameworks, including the UN Global Compact, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, the Universal Declaration of Human Rights and core ILO conventions. Kemira prohibits child labor, forced labor and unethical recruitment, and publishes a Board-approved Modern Slavery statement addressing human trafficking and child and forced labor prevention and remediation.

Supporting policies include the Recruitment Policy (fair and responsible hiring, respecting diversity and equal treatment), the Group Privacy Policy (personal data handling and breach response), and the Diversity & Inclusion statement, accessible to employees and the contingent workforce. Own workforce covers both employees and non-employees who are operationally embedded but employed through third parties or self-employment.

Reference: page 130.

Kemira runs continuous listening and feedback processes, using a confidential online pulse-survey provider since 2019, with participation typically 70-80%. Engagement pulse surveys are conducted about twice a year to track the Engagement Index and Inclusion Index, supplemented by pulse surveys on safety, ethics and compliance (Integrity Index), IT, and onboarding and offboarding. Regular meetings are held with Employee Resource Group leaders, including KemPride and the Women's Network.

The global Performance and Development Discussion (PDD) process covers target setting, competence development, career aspirations and continuous feedback. Works councils and employee representatives, including the Kemira European Forum, provide a further collaboration channel. Non-employees have a nominated supervisor and access to local communication channels, training, and the Ethics and Compliance hotline.

Reference: pages 131, 135.

Kemira's Ethics & Compliance Hotline, hosted by an external service provider, is available 24/7 to both employees and the contingent workforce in their own language by phone or web form, with an option to remain anonymous. Reports are reviewed by the Ethics & Compliance function and investigated under the Compliance Committee (comprising the Group General Counsel, EVP People & Culture, Chief Auditor, Ethics & Compliance Director, CFO and one Business Unit EVP), which classifies allegations, assigns investigations and reports to the Audit Committee.

Employees can also report unsafe conditions through an internal safety reporting system. During 2025, a total of 60 complaints were reported (26 through the hotline), of which 25 related to discrimination or harassment; 14 had been investigated and closed by year end, with 13 confirmed. Kemira reported no severe human rights allegations and paid no related remediation compensation in 2025.

Reference: page 131.

Kemira maintains a Health and Safety Management System covering systematic occupational and chemical risk assessments, Process Safety Management practices, a formal Management of Change procedure, employee-reported safety observations, behavior-based safety programs, and safety training and competence development. Emergency preparedness and incident reporting standards apply, with root cause analysis and preventive or corrective actions shared globally in monthly reports.

Agreed workforce-related actions are reviewed annually by the relevant leadership teams and followed by the Group Leadership Team. Effectiveness is tracked through incident frequency, the percentage of completed corrective actions, and leading safety indicators such as the number of hazardous-condition observations and behavior-based safety observations, alongside DEI and privacy actions described under the related policy sections.

Reference: page 131.

Kemira's Total Recordable Injury Frequency (TRIF) target, reviewed annually by the Group Leadership Team against prior performance and industry benchmarks, was set at 2.2 for 2025 and 2026 and 1.5 by the end of 2030; actual TRIF at end of 2025 was 2.7, an improvement on 2024's 3.2 but still behind target. To close the gap, Kemira plans to renew life-saving rules, update PPE and permit-to-work standards, improve contractor management and continue its behavior-based safety program.

Kemira also aimed to reach the top 10% for Inclusion across industries, measured via the Inclusion Index (Authenticity, Belonging, Growth, Inclusive Leadership) twice yearly, by the end of 2025; the December 2025 score of 76 (2024: 77) was 5 points below the top-10% cross-industry benchmark of 81, and targeted action plans continue into 2026. Both targets apply to all of Kemira's own workforce and were unchanged during the reporting period.

Reference: page 133.

At the end of 2025, Kemira employed 4,911 people, up from 4,698 at end of 2024, an increase of 213 driven mainly by the October 2025 acquisition of Water Engineering Inc. Of these, 1,324 were female and 3,587 male. Headcount by contract type shows 4,845 permanent employees and 66 temporary (down from 76 in 2024, concentrated in EMEA where temporary contracts are more common), and 4,829 full-time versus 82 part-time.

Employees are reported by country, with Finland, China and the United States each exceeding 50 employees and at least 10% of total headcount. Employee turnover was 8.7% in 2025 (410 leavers), down from 13.9% (646) in 2024. Kemira's reporting covers employees and operational employees at manufacturing sites as of 31 December 2025.

Reference: page 134.

Kemira's contingent (non-employee) workforce comprises workers employed by a third-party partner or self-employed individuals performing work on Kemira's behalf, typically providing temporary resourcing, specific skills, substitution or seasonal capacity. At the end of 2025, there were 392 contingent workers, down from 424 at the end of 2024.

The contingent workforce is operationally embedded in Kemira's organization and performs tasks directly supporting core operations. Working hours and safety incidents for contingent workers are included within Kemira's overall occupational safety statistics (TRI and LTI) rather than reported as a fully separate series, in line with the company's current reporting practice; each non-employee has a nominated Kemira supervisor and access to the Ethics and Compliance hotline.

Reference: page 134.

Kemira states it respects freedom of association and collective bargaining under its Code of Conduct and the UN Global Compact, providing regular training to raise employee awareness of these rights. In 2025, Kemira identified no violations of freedom of association or collective bargaining in its own operations. In 2025, 2,427 employees (51% of the global workforce) were covered by collective bargaining agreements, up from 2,225 employees (47%) in 2024.

For employees not covered by collective agreements, terms of employment are set by company policy and applicable local labor law. Workplace representation coverage is also disclosed by geography and coverage-rate band for the EEA and non-EEA workforce, including an existing agreement with the European Works Council in Finland, covering countries with at least 50 employees representing 10% or more of total headcount.

Reference: page 136.

Kemira monitors gender and age distribution to track diversity across the company. In Kemira's management population (Director, Vice President and Senior Vice President roles, excluding the Group Leadership Team), 43 of 150 managers were women in 2025 (29%), broadly stable versus 38 of 130 (29%) in 2024. By age group, 9% of the 4,911-strong 2025 workforce was under 30, 58% was 30-50, and 33% was over 50, similar to the 2024 and 2023 distributions.

The Board of Directors was 38% female and the Group Leadership Team 20% female in 2025 (see GOV-1). Diversity, Equity and Inclusion is supported through mandatory Code of Conduct and Human Rights & Business training for new white-collar hires, DEI training programs, and the KemPride and Women's Network employee resource groups established in 2022.

Reference: page 134.

Kemira states that "all employees at Kemira receive a salary above adequate wage." The adequate wage level is analyzed and confirmed by comparing salaries in the lowest pay categories against available data on adequate wages, benchmarked to collective bargaining agreement wage levels, national or sub-national legislation, or living wage references, depending on jurisdiction.

This assessment applies across Kemira's 37 countries of operation, reflecting the company's inbuilt structures for fair and objective pay decisions described under Compensation metrics, which combine market and salary data to evaluate, analyze and implement equitable remuneration and to support transparent pay-related decision-making globally.

Reference: page 137.

Kemira states that all its employees are covered by social protection against income loss from major life events, whether through national public systems or company-provided benefits. Coverage extends to sickness, unemployment, employment injury or acquired disability, parental leave, and retirement.

Because Kemira operates across 37 countries with differing national social security systems, the specific mix of public and company-provided protection varies by jurisdiction, but the company states protection against each of the listed life events is universal across its own workforce, without disclosing a country-by-country breakdown.

Reference: page 136.

Kemira's Learning and Development procedure, published globally in 2025, covers on-the-job training, buddy, coaching and mentoring initiatives, and classroom and digital learning formats. Average training hours in 2025 were 8.0 for women and 9.8 for men, a total average of 9.3 hours per employee (excluding the 188 Water Engineering Inc. employees whose onboarding was not completed in 2025).

Programs delivered in 2025 included eLearning on the Code of Conduct, human rights, anti-bribery and information security; DEI training; Compass sessions on Kemira's strategic principles (about 423 attendees); the "Learn & Grow" month with 11 virtual sessions and roughly 697 participants; sustainability-focused training; and mandatory EHSQ and safety-culture programs, alongside the Global Safety Training Program for site managers.

Reference: page 135.

Kemira's health and safety management system, meeting ISO 45001, covered 97% of its 69 tracked locations (manufacturing, R&I and main offices) in 2025, unchanged from 2024, with both employees and non-employees 100% covered. Kemira reported 33 Total Recordable Injuries (TRI) in 2025 (26 employees, 7 contractors), down from 43 in 2024, giving a TRI frequency (TRIF, per million working hours) of 2.7, down from 3.2. Lost Time Incidents (LTI) rose to 20 from 16, giving an LTI frequency of 1.6, up from 1.2; one minor permanent eye injury was reported.

There have been no fatalities involving Kemira employees, contingent workforce or contractors since 2005. External contractor injuries fell to 7 from 14, with contractor TRIF improving to 3.1 from 5.3.

Reference: page 134.

All Kemira employees (100%) are entitled to take family-related leave. In 2025, 14% of entitled employees made use of this leave overall (14% of women, 13% of men). Kemira frames family-related leave as central to balancing work and family life for employee wellbeing.

Coverage of the global Performance and Development Discussion process, which includes discussion of career aspirations and workload alongside performance, reached 97% of permanent employees in 2025 (98% of women, 96% of men), similarly high across white-collar (95%) and operational (98%) employee categories, providing a related channel through which work-life topics can be raised.

Reference: page 137.

Kemira reported an unadjusted gender pay gap of 6% in 2025, unchanged from 2024, covering all employees across its operating countries; the figure is calculated from gross annual average salaries converted to euros, excluding incentives, overtime, shift allowances and benefits. Kemira states it identified and closed its unexplained gender pay gap in September 2023, attributing remaining differences to justifiable factors such as location, position level, expertise, individual performance and local collective agreement requirements, with regular monitoring to detect and address any unjustified gaps.

The annual total remuneration ratio, comparing the President & CEO's total remuneration to the average of all other employees, was 50 in 2025, up from 27 in 2024, reflecting the CEO's substantial variable and long-term incentive weighting relative to less volatile employee remuneration.

Reference: page 135.

During 2025, Kemira recorded 60 complaints through its grievance channels (2024: 59), of which 26 came through the Ethics & Compliance Hotline and 25 related to discrimination or harassment. By year end, 14 of the total had been investigated and closed, of which 13 were confirmed as discrimination or harassment. Kemira states it "has not categorized the discrimination cases by gender, racial or ethnic origin, nationality, religion or belief, disability, age or sexual orientation."

Kemira states that during 2025 it "has not received any allegations of severe human rights incidents" and "has not paid any compensation for remediation of any human rights incidents or complaints in 2025." The Integrity Index, measuring employees' confidence that they can report unethical behavior without fear of retaliation, stood at 78 in December 2025.

Reference: page 140.

Kemira's Code of Conduct for Business Partners commits suppliers to respecting fundamental human rights, never using child or forced labor, and paying wages complying with applicable law, in line with the UN Universal Declaration of Human Rights and core ILO conventions; it is communicated to all suppliers through onboarding and the ordering process as part of Kemira's terms and conditions. The Group Product Stewardship Policy ensures products are handled and used safely across the value chain, and the Board-approved Modern Slavery statement addresses human trafficking and child and forced labor prevention and remediation.

Kemira has identified higher-risk countries in its upstream and downstream value chains for child and forced labor, particularly in the APAC region, using third-party human and labor rights indices. All policies apply to the whole value chain and all value chain worker groups.

Reference: page 141.

Kemira states it maintains active dialogue with upstream suppliers through regular audits and performance evaluations, with results reviewed jointly and improvement plans followed up. Downstream, Kemira runs an annual Voice of Customer relationship survey to understand customer needs, satisfaction with products, deliveries, safety and service, and the customer relationship. External contractors performing maintenance, repair, turnaround or specialty work at Kemira sites are engaged through regular contractor performance evaluations and local safety events.

Kemira explicitly states it "has not yet adopted a general process to engage with all workers in the value chain or with their legitimate representatives to hear their perspectives and needs" regarding Kemira's material impacts on them, distinguishing this broader gap from its supplier, customer and contractor-specific engagement channels.

Reference: page 141.

Kemira's Ethics and Compliance hotline, overseen by the Compliance Committee, is described under S1 Own workforce and is also the primary route for value chain workers' severe human rights or misconduct concerns; the Misconduct Reporting Policy protects whistleblowers. A customer and supplier complaint channel is available for raising concerns within the upstream and downstream value chain, though Kemira notes it is currently used mainly for quality-related complaints and is only indirectly available to value chain workers. An internal health, safety and quality issue-reporting system is similarly indirectly available for hazard and near-miss observations.

During 2025, Kemira received no allegations of severe human rights violations affecting value chain workers through these channels. The company states it "does not actively assess whether value chain workers are aware of or trust" its grievance channels or structures, and in 2025 finalized an internal grievance and remediation study whose approved development actions are being implemented into the due diligence program.

Reference: pages 142-143.

Upstream, Kemira's supplier management runs through Supplier Segmentation (strategic, critical, volume and base categories), Supplier Performance Evaluations, and the Vendor Value Program, supported by EcoVadis assessments across 21 sustainability criteria (Environment, Labor & Human Rights, Ethics, Sustainable Procurement) and third-party quality and Corporate Social Responsibility audits. Own operations and contractors are covered by a contractor management standard requiring mandatory safety induction and a "permit-to-work" process before site work begins.

Downstream, all Kemira products carry Safety Data Sheets prepared through its Product Lifecycle Management system in the relevant local languages, with substances of concern and very high concern actively monitored per the priority substance management process. Planned 2026 actions include continued EcoVadis, quality and CSR supplier audits, review of CSR audit methodology, and new contractor health and safety re-qualifications.

Reference: page 142.

Kemira tracks internal indicators for workers in the value chain rather than ESRS-defined targets, stating these "are not defined as ESRS targets" and that it "will continue the evaluation of the indicators in the following years." Upstream indicators, covered in more detail under E5 Resource use and circular economy, include the number of supplier quality and Corporate Social Responsibility audits; Kemira also tracks priority substance management plan coverage for Substances of Very High Concern and Substances of Concern, a program running since 2016.

For external contractors, Kemira's TRIF target (2.2 by end of 2025, 1.5 by end of 2030, shared with own workforce) also covers contractor injuries: contractor TRIF improved to 3.1 in 2025 from 5.3 in 2024, on 7 injuries (down from 14), reflecting planned contractor-management initiatives.

Reference: pages 145-148.

Kemira's Board-approved Code of Conduct translates the corporate values (committed to customers' success, driving performance and innovation, caring for people and the environment, succeeding together) into a framework covering standing for what is right, respecting human rights, protecting the environment, ensuring quality, doing business with integrity, and protecting assets and information. Kemira is a signatory of Responsible Care and supports the UN Global Compact, the UN Guiding Principles on Business and Human Rights, and the OECD Guidelines.

A table of key business conduct policies sets out scope, accountability, monitoring process and availability for the Code of Conduct, Code of Conduct for Business Partners, Sustainability Policy, Gifts, Entertainment and Anti-Bribery Policy, Recruitment Policy, Sourcing and Procurement Policy, Competition Law Compliance Policy, Product Stewardship Policy, Logistics and Transportation Policy, Trade Compliance Policy, and Misconduct Reporting Policy. Policies are reviewed every two years and trained to all employees at onboarding, with repeat training typically every two years.

Reference: page 150.

Kemira's policy on corruption and bribery, set out in the Code of Conduct and the Gifts, Entertainment and Anti-Bribery Policy, is a zero-tolerance stance consistent with the UN Convention Against Corruption; the Board of Directors is aware of the company's anti-corruption principles, and suppliers and vendors must commit to Kemira's business ethics principles as a condition of doing business. Anti-corruption training coverage for white-collar employees in functions at risk (completed at least once in the last three years) was 86% in EMEA, 96% in APAC and 88% in the Americas for 2025.

Prevention and detection relies on globally implemented key controls over company funds, assets, accounting and contracting, verified through a three-lines-of-defence model with Internal Audit reporting to the Board's Audit Committee, plus the Ethics and Compliance Hotline. Kemira flags heightened corruption risk from operating in 37 countries, selling to over 100 countries, and serving public utility customers such as municipal water treatment plants.

Reference: page 145. This disclosure requirement is renumbered from the 2023 ESRS's Minimum Disclosure Requirements on targets (MDR-T), which required disclosure of either a quantified target or, in its absence, how effectiveness is tracked.

Kemira states it holds internal indicators for business conduct impacts, risks and opportunities that "are not as defined in ESRS," and that it "will continue the evaluation of these indicators in the following years." In the absence of a quantified target, Kemira instead tracks effectiveness of its business conduct policies and actions "through Kemira's internal controls and audits and by following the reports filed with Kemira's Ethics and Compliance Hotline," with results reviewed periodically to identify and correct adverse deviations.

Kemira's management systems relevant to business conduct are certified under ISO 9001, ISO 14001, ISO 27001, ISO 45001 and ISO 50001, each requiring continuous monitoring and improvement under the Plan-Do-Check-Act cycle, which the company presents as part of how it tracks the effectiveness of its business conduct efforts.

Reference: pages 150-151.

Kemira reports that in 2025 it "did not have any convictions or fines for violation of anti-corruption and anti-bribery laws." During the year the company recorded 6 allegations related to violations of its internal anti-corruption and anti-bribery policies (2024: 8); internal investigation confirmed 4 incidents where own employees had breached internal procedures (2024: 7), and in total 5 employees were dismissed or otherwise disciplined for confirmed corruption or bribery-related incidents (2024: 7).

Allegations and detected incidents are investigated under the oversight of the Compliance Committee, with investigators separate from management involved in the matter; results are shared with relevant management and an overview of all investigations is reported to the Audit Committee of the Board of Directors and the Group Leadership Team.

Reference: page 151.

Kemira's Code of Conduct commits the company to a neutral stance toward political parties and candidates: "we do not engage in political activities or make corporate donations to political parties or candidates," a principle reinforced by the Sponsorship and Donation Policy and the Gifts, Entertainment and Anti-Bribery Policy. No financial or in-kind political contributions by Kemira came to the company's attention during 2025.

Kemira's EU engagement is run by its Public Affairs department under Corporate Communications, supervised by the Group Leadership Team, and covers chemicals policy, EU water and wastewater regulation, packaging regulation, food contact materials and bioeconomy, mainly through Cefic and Kemianteollisuus ry trade association membership, position papers and consultations. Kemira discloses that CEO Antti Salminen and Board member Timo Lappalainen have held public administration or comparable roles in the two years preceding 2025, and is registered in the EU Transparency Register.