Kingspan

The role of the administrative, management and supervisory bodies

Board governance

Good governance is front and centre to everything we do. In 2024, our Board continued to enhance our governance frameworks, ensuring alignment with best practices and stakeholder expectations. Engagement with our shareholders remains a key priority. Throughout the year, we maintained an open and constructive dialogue with our investors, addressing not only governance matters but also strategic direction and financial performance. This engagement ensures that we remain aligned with their expectations while benefiting from valuable insights that enhance our decision-making processes.

Board changes

Linda Hickey will retire from the Board at the conclusion of the Annual General Meeting in May 2025, after 12 years of service as a non-executive director. Throughout her tenure, and particularly in her role as Senior Independent Director and Chair of the Remuneration Committee, Linda has always provided invaluable expertise, sound judgment and steadfast commitment to our governance and strategic direction. On behalf of the Board, I would like to extend my sincere thanks to Linda for her significant contribution to the Company.

Following the Annual General Meeting we will welcome Eavan Saunders as a new independent non-executive director onto the Board. Eavan is the Managing Partner and founder of the Irish office of global law firm Dentons, with over 25 years' experience as a top-tier corporate lawyer specialising in international M&A and capital markets, bringing her wealth of international experience to the Board. I look forward to the benefit of her contributions to the Board in the years to come.

Integration of sustainability-related performance in incentive schemes

Overview

The remuneration principles and overall remuneration of the Group's executive directors are outlined in the Report of the Remuneration Committee section within this Annual Report.

The Group offers both short-term and long-term incentive schemes for members of management linked to sustainability related performance. This demonstrates the Group's commitment to achieving its sustainability strategy.

Roles Covered

Sustainability-related incentive schemes apply to:

• CEO (Gene Murtagh)
• Executive Directors (Geoff Doherty, Russell Shiels, Gilbert McCarthy)
• Company Secretary (Lorcan Dowd)
• Broader management (members of management)

Short-Term Incentives (STI)

Short-term incentives include an annual bonus based on:

• The Group's financial performance
• Customer performance indicator (Net Promoter Score)

Net Promoter Score (NPS) linkage to sustainability:

• A portion of the Net Promoter Score (NPS) is directly tied to the Group's perceived sustainability performance, reflecting key ESG elements
• This includes factors such as customer trust in our sustainable practices and the broader impact of our ESG initiatives on customer perception
• NPS accounts for 10% of the base salary component
• This represents 6.7% of the total maximum bonus opportunity

Health & Safety metric (from 2025):

• A new health & safety metric will also be included as part of the annual bonus performance targets from 2025

Long-Term Incentive Plan (LTIP) / Performance Share Plan (PSP)

The vesting of the 2024 PSP awards is based on achievement of the EPS, TSR and sustainability targets.

2024 PSP Award Structure:

¹ Straight line vesting between threshold and 100% vesting.

Sustainability Component Details:

• Sustainability related targets account for 10% of the vesting criteria applicable to the annual performance share plan award
• Increasing to 15% for 2025 awards
• These targets focus on nine of the Group's Planet Passionate environmental objectives, such as:
  • Reducing GHG emissions
  • Increasing renewable energy use
  • Rainwater harvesting
• These objectives directly contribute to the Group's overall climate strategy
• Performance is assessed against these targets, which align with the Group's GHG emission reduction targets under E1-4 – Targets

Performance Period and Target Structure

The performance share plan awards vest based on achievement of targets over a performance period. Awards granted in 2024 have earliest exercise dates starting 23/02/2025 and latest expiry dates ranging through 2031.

2024 PSP Awards Granted:

TSR Peer Group for 2024 PSP Awards

The TSR peer group includes:

• Armstrong World Industries Inc
• Boral Ltd
• Builders FirstSource Inc
• Carlisle Companies Inc
• Compagnie de Saint Gobain SA
• CRH plc
• Grafton Group plc
• Holcim AG
• Masco Corporation
• Mohawk Industries Inc
• Owens Corning Inc
• Recticel NV
• Rockwool A/S
• Sika AG
• Wienerberger AG

Governance and Review

The Board and the Remuneration Committee review sustainability linked incentives annually to ensure they align with the Group's evolving ESG priorities and long-term strategy.

For further information on the specific sustainability related targets included within the performance share plan, please see the Report of the Remuneration Committee within this Annual Report.

Disclosure of Payouts

The 2024 PSP awards granted during the year were subject to partial achievement of performance conditions in the prior period. Certain awards were cancelled on 24/02/2024 and 23/08/2024 due to partial achievement of performance conditions. The Statement does not provide detailed disclosure of actual payout amounts specifically against sustainability KPIs for the reporting period.

Strategy, business model and value chain

Our Business Model and Strategy

Our mission is to accelerate a net zero emissions built environment with people and planet at its heart.

Our Solutions

Insulated Panels: Kingspan Insulated Panels is the world's largest and leading manufacturer of high-performance insulated panel building envelopes. Powered by Kingspan's proprietary and differentiated insulation core technologies, our panelised envelope provides building owners with consistently superior build quality and lifetime thermal performance compared with built-up constructions using traditional insulation.

Insulation: Kingspan is a world leader in rigid insulation boards, which accounts for approximately two thirds of our Insulation division. Our advanced insulation technologies deliver superior thermal performance and air-tightness when compared with traditional insulation, resulting in more durable, thinner solutions that offer multiple advantages including more internal floorspace and daylight. More recently, we have been expanding our bio-based insulation offering through the acquisitions of Troldtekt and HempFlax, and the acquisition of 51% of Steico in early 2024.

Roofing + Waterproofing: Our recently developed roofing and waterproofing segment complements our insulation board offering. Roofing membrane and roofing components are essential elements for the energy efficiency and water protection of a building envelope. The acquisition of IB Roofing Systems and a controlling stake in Nordic Waterproofing increased Kingspan's proforma annual sales in the segment to c.€1bn. Going forward, we expect to offer single component membrane solutions and to also offer roof systems incorporating membrane and insulation, giving our customers increased warranty protection from a single trusted supplier.

Light, Air + Water: An established global leader, Kingspan Light, Air + Water provides a full suite of daylighting solutions, as well as natural ventilation and smoke management solutions, which complement our existing building envelope technologies. Thermal comfort, indoor air quality and natural daylighting are widely recognised as the most important factors affecting occupant wellbeing in buildings.

Data Solutions: Kingspan is the world's largest supplier of raised access flooring and data centre airflow management systems. Our raised access flooring systems have many benefits including optimising overall building height, achieving faster construction with greater design flexibility, enabling easier reconfiguration of a workspace, and improving indoor air quality. Our airflow management systems enable data centres to optimise cooling energy requirements while also protecting expensive equipment such as servers and storage devices.

Technical Insulation: Technical insulation is a segment which contains significant opportunity for Kingspan to expand in the future. The operation of buildings accounts for 28% of carbon emissions globally. While space heating is the largest consumer of energy in buildings, heating water and space cooling are also key energy consumers. Kingspan has innovative and ultra-performance products in both piping and ducting insulation and we service the district heating segment through supplying pre-insulated piping through our LOGSTOR business.

How we create value

• Product innovation and differentiation
• Excellent customer service
• Energy efficient and sustainable building envelope solutions
• We operate our businesses to the highest standards
• We acquire excellent businesses
• We recycle capital to optimise returns
• We maintain financial discipline
• We balance our portfolio of businesses across product and geography
• We are reducing our environmental impacts through our Planet Passionate initiatives

Strategic Pillars

Innovation: Kingspan's innovation agenda is driven across four key themes - performance, solutions, sustainability and digitalisation. We have a rigorous focus on iterative performance improvements in our current portfolio including characteristics relating to thermal, structural, sustainability, fire and smoke. We innovate solutions to enable architects and building designers to create sustainable buildings, such as our integrated insulated panel with solar-PV, PowerPanel® and by progressively surfacing our products digitally, we are making it easier to find them, specify them, buy them and track them.

Planet Passionate: Our Planet Passionate agenda is inextricably linked with innovation. Planet Passionate is Kingspan's environmental programme which aims to impact three big global challenges – climate change, circularity and protection of the natural world. By setting ourselves challenging targets in the areas of carbon, energy, circularity and water, we aim to make significant advances in both our business operations and our products.

Completing the Envelope: Our strategy of Completing the Envelope aims to take our innovation and sustainability DNA and apply them to a wider portfolio of products which are complementary to our current offering. Our systems and solutions driven approach deepens our relationships with our customers and extends the opportunities to make buildings better now and into the future.

Global: Kingspan is a truly global business, trading in over 80 countries with manufacturing sites across the globe. We aim to continue expanding globally to bring high-performance building envelope solutions to markets which are at an earlier stage in their evolution to sustainable and efficient methods of construction.

Our Global Reach

273 global manufacturing facilities across Americas, Europe, Middle East, Africa, Asia and Australasia.

Revenue by Geography (2024):

• Americas: 22%
• Central & Northern Europe: 27%
• Western & Southern Europe: 43%
• Rest of World: 8%

Revenue by Product (2024):

• Insulated Panels: 55%
• Insulation: 21%
• Roofing + Waterproofing: 7%
• Light, Air + Water: 11%
• Data Solutions: 6%

Interests and views of stakeholders

Overview

As a global leader in building envelope solutions, the Group engages with a diverse range of stakeholders at a local, regional and global scale. The Group defines stakeholders as individuals or groups whose interests are affected or could be affected by our activities and products.

Key stakeholder groups

Key stakeholder groups include:

• Employees
• Shareholders/Investors
• Financial institutions
• Suppliers
• Customers and end-users
• Regulatory bodies/government agencies/policymakers
• Industry associations/professional bodies
• Community organisations/Non-governmental organisations (NGOs)

How the company engages with stakeholders

We engage with key stakeholder groups through various methods, including direct meetings, surveys, industry forums and participation in working groups. The purpose of these engagements varies depending on the specific circumstances, but a common theme is understanding their views, needs and expectations. We recognise that collaboration with our stakeholders is crucial for achieving our business objectives, fostering growth and contributing to sustainable development. Maintaining an open dialogue allows us to build strong relationships across our value chain, within local communities and within the broader construction industry.

Integration into due diligence and strategy

Stakeholder engagement is a critical component of our ongoing due diligence and DMA processes, informing both our risk management approach and the development of collaborative projects. Stakeholder feedback and insights have been incorporated into our decision making process, especially within the context of our due diligence and DMA, as detailed in section IRO-1 of this Statement.

The feedback and insights gained from these engagements play a key role in shaping our business model and strategy. Stakeholder input directly influences decisions related to key sustainability initiatives, resource efficiency measures and employee wellbeing. Additionally, these insights help identify potential risks and opportunities, which guide the Group's long-term strategy for growth and sustainability. This ensures that our business model remains adaptive to evolving stakeholder expectations and market dynamics.

Specific stakeholder engagement processes

Workforce engagement

The Board recognises the importance of engaging with all of our key stakeholders. Elsewhere in this Annual Report we have detailed the long-lasting partnerships we have developed with customers, suppliers and communities. We greatly value engagement with our workforce. Our people are key to developing and delivering on our strategy, and are fundamental to our long-term success.

Linda Hickey, as Senior Independent Director, is appointed as the director responsible for workforce engagement, to facilitate the channelling of employee views to Board discussions. During the year, she had the opportunity to hear employee views on a range of topics through engagement with our People Passionate team, attendance at our European Works Council meeting in the Netherlands and by meeting employees onsite during Board visits.

European Works Council (EWC): In 2022, our first European Works Council (EWC) was established providing a platform to engage with our employees at a European level on the strategy and development of the business, as well as employment, investments and its transnational issues. The EWC met in person for its second plenary meeting at the Kingspan Unidek site in the Netherlands in November 2024. Eighteen representatives participated in a varied agenda that included business and financial updates and presentations on the wider business strategy. We also discussed Health & Safety matters and had updates on our People Passionate and Planet Passionate programmes. Senior management attended along with Linda Hickey, the Workforce Engagement Director. These meetings have been constructive with a very high level of engagement from the national employee representatives.

People Passionate Programme: We are People Passionate and during 2024 Kingspan continued to progress the design and implementation of the People Passionate programme across all its global businesses. This programme is a team-led initiative, designed to create the employee experience together. A global steering group representing all divisions held quarterly meetings during the year, establishing a fresh governance and reporting framework across the Group. The businesses have integrated the People Passionate pillars into their people and organisational plans and continue to report on progress and measure the effectiveness of their actions through feedback from employees.

Supplier engagement

The Group seeks to build and maintain long-term relationships with key suppliers and contractors. This vision assists in aligning goals and standards to address strategic global issues, emerging trends and ultimately our customer needs, while also respecting the interests, views and rights of workers employed by our suppliers.

Engagement with workers employed by the Group's suppliers occurs through various stages and formats. The views of workers are conveyed indirectly through a range of supplier management activities, which occur at varying frequencies depending on their nature. Ongoing processes such as contract negotiations, surveys and self-assessment questionnaires take place as part of routine operations, while broader engagements, including supplier forums, conferences and interviews, are conducted on a quarterly, semi-annual, or annual basis, depending on their purpose. The insights gathered from these indirect engagements help inform our decisions and actions aimed at managing actual and potential impacts on value chain workers.

The effectiveness of these engagement channels are assessed through ongoing two-way communication, including open dialogue and regular interactions with key suppliers and stakeholders. This open dialogue not only creates opportunities for value chain workers to share their perspectives, particularly those who may be vulnerable to impacts or marginalisation, but also supports the ongoing development and refinement of our due diligence process. Additionally, the Group engaged with NGOs during the DMA process to gain further insight.

By developing these processes, the Group aims to create opportunities for value chain workers to collaborate and share their perspectives, especially those who may be vulnerable to impacts or marginalisation. The divisional MDs take ultimate responsibility for the implementation of the SHREDD Policy.

Affected communities engagement

The Group promotes open dialogue and understands the importance of engagement and collaboration with its local communities. We engage in dialogue with local communities via several initiatives, the most significant being our Planet Passionate Communities initiative. Launched in 2021, the Planet Passionate Communities is the philanthropic arm of our 10-year sustainability programme, Planet Passionate. Through this initiative, we aim to support people and communities around the world. On a local level, our businesses are devoting a portion of their time and resources to support community projects. In 2024 we completed over 100 projects.

The scope, frequency and process for engagement differs across our Group, influenced by several factors. Engagement with local communities can be on an ad-hoc basis or through more formal initiatives. A site representative is responsible for overseeing community engagement and escalating any feedback or concerns to senior management if required.

An example of engagement would be for infrastructure projects. During the implementation of a key environmental project, a 1.5 MWh wind turbine installation at our site at Holywell, UK, we engaged extensively with the local community throughout the process which ran from 2011 – 2017. An example of a more formal engagement initiative is our Planet Passionate Community Fund in Ireland. We are currently reviewing our processes and will update them in 2025 if required to potentially include an assessment of the effectiveness of our engagement processes.

Consumer and end-user engagement

The Group aims to sustain long-term consumer relationships. Engagement occurs at various stages across the purchase cycle, with frequency dependent on the type of engagement. The effectiveness of engagement is assessed through various means including, but not limited to, follow-up surveys, customer satisfaction scores and regular review meetings, ensuring active consumer and end-user engagement.

Customer Experience Programme: The Customer Experience Programme places customers at the centre of the Group's operations, aiming to improve all aspects of the business to better serve them. In 2018, we launched the Worldwide Voice of Customer programme, led by our Global Customer Experience team. This initiative enables us to listen more closely to our customers and gain a deeper understanding of their experiences across the 200+ businesses and diverse brands within our Group. This programme helps the Group track evolving customer expectations and identify areas for improvement, driving changes in products, services, processes and advancing the Group's digital agenda.

Distinction between affected stakeholders and users of sustainability information

While not explicitly detailed in the extracted text, the Group's stakeholder engagement covers both affected stakeholders (those impacted by the business, including employees, suppliers, workers in the value chain, affected communities, and consumers/end-users) and users of sustainability information (shareholders/investors and financial institutions). The engagement mechanisms vary by stakeholder type, with direct operational engagement for affected stakeholders and financial reporting and investor relations activities for information users.

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

Overview

Kingspan's mission is to accelerate a net zero emissions built environment with people and the planet at its heart. The Group aims to achieve this through four strategic pillars: Innovation, Planet Passionate, Completing the Envelope and Globalisation. The business model and strategic pillars enable the ongoing transition to high-performance building envelopes, replacing outdated and inefficient construction methods.

Double Materiality Assessment Process

Kingspan completed a Double Materiality Assessment (DMA) in collaboration with both internal and external stakeholders. The process involved the identification of key impacts, risks and opportunities (IROs) across the value chain, spanning short, medium and long-term time horizons, evaluating both impact materiality (the effects of the Group's activities on society and the environment) and financial materiality (how sustainability factors could influence the Group's financial performance).

Time Horizons:

• Short-term: one year
• Medium-term: from the end of short-term up to five years
• Long-term: more than five years

DMA Methodology:

1. Scoping: The assessment included the Group's operational segments, upstream and downstream activities, geographical reach and key suppliers.

2. Identification: A list of actual and potential IROs was developed through desktop research, peer benchmarking, internal consultations with subject matter experts and input from external experts. Each identified IRO was mapped to ESRS topical standards.

3. Engagement: The Group engaged with over 50 stakeholders from a range of groups, including executives, customers, employees, NGOs and regulatory bodies, through surveys and interviews.

4. Consolidation: Feedback from stakeholders was analysed and integrated into the final DMA. The results were validated by the Group's management team.

5. Reporting: The outcome of the DMA identified material IROs across all ten ESRS topics, forming the basis for the Group's sustainability reporting.

Material IROs by ESRS Topic

The following table presents the Group's analysis of material IROs identified across the relevant ESRS topics:

Climate Change Material IROs

As climate change intensifies, it presents an urgent and multifaceted challenge. Climate change risks and opportunities are deeply embedded in Kingspan's strategy, R&D investment, products and business model.

Impacts

Positive Impact – Actual: Reduced energy used via insulation products & solutions

• Value chain stage: Downstream
• Description: Consumers can reduce energy usage and costs by better insulating their buildings (reducing usage) or through installing other insulation products. The Group is indirectly contributing to reduced energy usage and CO2e emissions downstream.
• Initiatives:
  • Product offering: The Group offers market leading products, particularly in the field of building insulation. High-performance insulation solutions help architects and building owners design buildings that consume less energy for the long-term.
  • Innovation strategy: Decarbonisation of the product portfolio is a key focus area for innovation through two main strategies: refining existing products with lower carbon alternatives and exploring new bio-based materials and solutions.

Negative Impact – Actual: GHG from operations

• Value chain stage: Own operations
• Description: The Group is an industry leader in manufacturing products which help mitigate climate risk in the construction sector. The Group has set itself industry leading targets with respect to direct carbon emissions. The Group has an extensive environmental sustainability programme, Planet Passionate, which has set ambitious direct renewable energy (60% by 2030) and GHG emissions reduction targets. In 2024, the Group achieved its 20% on-site renewable energy generation target.
• Initiatives:
  • Decarbonisation plan: The Group developed a transition plan for climate change mitigation. The Plan comprises mitigation levers for scope 1, 2 and 3 GHG emissions and is underpinned by carbon targets set out as part of the Planet Passionate programme.
  • Product offering: In recent years, the Group took significant steps forward in the development of lower embodied carbon (LEC) alternatives across portfolios (e.g. QuadCore LEC® insulated panel, RMG600+ and Tate Grid+ LEC). PowerPanel®, a fully integrated insulated panel with solar technology, is another solution that embodies the future of sustainable construction.

Negative Impact – Actual: GHG from value chain (scope 3 GHG emissions)

• Value chain stage: Upstream & downstream
• Description: The Group relies on the procurement of raw materials to manufacture its products. These raw materials include steel and chemicals - the embodied carbon of these products can be considered moderate to high. The vast majority of the Group's total carbon footprint derives from the procurement of these materials.

Positive Impact – Potential: Reduced embodied carbon of key raw materials we procure

• Time horizon: Medium/long-term
• Value chain stage: Upstream
• Description: The Group actively collaborates with its suppliers to assist them in reducing their embodied carbon, resulting in productive partnerships that aim for a significant 15% reduction in product CO2e intensity from primary supply partners by 2030.

Positive Impact – Potential: New, lower emission products

• Time horizon: Medium/long-term
• Value chain stage: Downstream
• Description: Innovation in the form of new Group products provides customers with superior products and added value. It may also aid customers in lowering their GHG emissions.
• Initiatives:
  • Product offering: In recent years, the Group took significant steps forward in the development of lower embodied carbon (LEC) alternatives (e.g. QuadCore LEC®, RMG600+ and Tate Grid+ LEC). PowerPanel®, a fully integrated insulated panel with solar technology, is another solution.
  • Innovation strategy: Decarbonisation of the product portfolio is a key focus area for innovation through refining existing products with lower carbon alternatives and exploring new bio-based materials and solutions.

Positive Impact – Potential: Solar panels - consumer benefits

• Time horizon: Short-term
• Value chain stage: Downstream
• Description: By installing PowerPanel®, consumers can experience multiple positive impacts including diversifying their energy sources to reduce dependency on the grid, decreasing their GHG emissions and potentially saving money on energy bills.
• Initiatives:
  • Innovation strategy: Decarbonisation of the product portfolio ensures products and systems help end users reduce the carbon footprint of the built environment.

Risks

Risk/Transitional (market): Changing customer behaviour

• Time Horizon: Medium-term
• Derives from: Other (market)
• Description: Failure to reduce the embodied carbon of products may lead to deselection by the market.
• Initiatives:
  • Innovation strategy: Decarbonisation of the product portfolio is a key focus area for innovation through refining existing products with lower carbon alternatives and exploring new bio-based materials and solutions.

Risk/Transitional (market): Substitution of existing products and services with lower emission options

• Horizon: Medium-term
• Derives from: Other (market)
• Description: If the Group does not continue to develop industry leading high-performance, low carbon insulation technologies, there is a risk that existing products are substituted by competitors.

Risk/Transitional (regulation): Carbon price mechanisms

• Time Horizon: Medium-term
• Derives from: Dependencies
• Description: If key suppliers fail to decarbonise in line with the latest climate science there is a risk they will pass through their increased cost to their customers.
• Initiatives:
  • Decarbonisation plan: The Plan for climate change mitigation comprises mitigation levers for scope 1, 2 and 3 GHG emissions and is underpinned by carbon targets set out as part of the Planet Passionate programme.

Opportunities

Opportunity: Use of public sector incentives

• Time Horizon: Short-term
• Derives from: Other (market)
• Description: In October 2020, the EU adopted the strategic communication on the Renovation Wave which contains an action plan aiming to at least double the annual energy renovation rate of buildings by 2030. A key facet is to improve the energy efficiency of the building envelope. The Group's high-performance insulation products are ideally suited for renovation given that dimension can be a key constraint in refurbishment.
• Initiatives:
  • Product offering: Development of lower embodied carbon (LEC) alternatives across portfolios. PowerPanel®, a fully integrated insulated panel with solar technology.
  • Innovation strategy: Decarbonisation of the product portfolio through refining existing products with lower carbon alternatives and exploring new bio-based materials and solutions.

Opportunity: Development of new products or services through R&D and innovation

• Time Horizon: Short-term
• Derives from: Other (products & services)
• Description: Should the Group innovate an energy efficient product with substantially superior carbon saving performance to alternatives, it could accelerate share gains from traditional insulation.

Opportunity: Development of climate adaptation, resilience and insurance risk solutions

• Time Horizon: Short-term
• Derives from: Other (products & services)
• Description: The EU is expected to include carbon emissions from buildings in the next phase of its Emissions Trading Scheme (ETS II). This will support demand for high-performance building envelope products as they help to lower the heating and cooling needs of a building.

Opportunity: Shift in consumer preferences

• Time Horizon: Medium-term
• Derives from: Other (market)
• Description: A significant proportion of a building's embodied and operational carbon impact comes from how the building has been designed and the materials used. Based on this, the Group has seen increased interest and engagement from top-tier customers seeking to develop strategic partnerships with key suppliers, enabling them to develop lower embodied carbon, net zero energy buildings. The Group regards this as a significant opportunity to strengthen its relationships with key customers who have similar strategic decarbonisation goals.

Opportunity: Expansion into new markets

• Time Horizon: Medium-term
• Derives from: Other (market)
• Description: The Group recently invested in additional manufacturing facilities in new territories. Over time, the Group will help to develop these markets and to educate building owners and regulators on the benefits of high-performance insulation and thermally efficient building envelopes.
• Initiatives:
  • Strategic pillar – Global: The Group aims to continue expanding globally to bring high-performance building envelope solutions to markets which are at an earlier stage in their evolution to sustainable and efficient methods of construction.
  • Strategic pillar – Completing the Envelope: The Group's strategy aims to take innovation and sustainability DNA and apply them to a wider portfolio of products which are complementary to current offering.

Climate Change Scenario Analysis and Resilience

During the year, the Group updated the resilience analysis of its strategy and business model. This update incorporated both quantitative and qualitative analyses, as well as internal expertise in the building materials industry.

Quantitative Analysis (2024): The Group worked with external experts to better understand the implications of a wider spectrum of physical and transition climate change risks across different scenarios and time horizons.

Physical risks: The Group examined eight physical hazards (extreme temperature, drought, wildfire, coastal flooding, fluvial flooding, pluvial flooding, tropical cyclone and water stress) across eight decades (2020 to 2100) and four climate change scenarios across a mix of Shared Socioeconomic Pathways (SSPs) and Representative Concentration Pathways (RCP): 1. RCP 8.5-SSP5, 2. RCP 7.0-SSP3, 3. RCP 4.5-SSP2 and 4. RCP 2.6-SSP1. Both the Group's own operations and key suppliers were included in the analysis.

Results showed exposure to minimal impacts due to temperature extremes and water stress in the higher climate change RCP-SSP scenarios starting from the 2040s and rising steadily until the 2090s. However, the financial impact of physical risks was not material to the Group's operations in the lower RCP-SSP scenarios.

Transition risks: The Group examined five transition risk types (carbon pricing, litigation, new technology, reputational damage and market) across eight decades (2020 to 2100) and four climate change scenarios.

Results showed that exposure to litigation, new technology, reputational damage and market risks were not material to the Group's operations in all scenarios examined. The exposure to the financial impact of carbon pricing was not found to be material in medium, medium high and high scenarios. However, exposure to carbon pricing increased only in the 2090s in the low (RCP 2.6-SSP1) scenario.

Qualitative Analysis: For several risks and opportunities, the Group faced constraints of publicly available scenarios. Specifically, quantitative scenario data for customer demand/market fluctuations for insulation products are not yet available, so the Group studied and used a mix of SSPs and related Integrated Assessment Models (IAMs) to construct a relevant narrative. The Group used SSP1 (low challenge to mitigation and adaptation), SSP2 (medium challenge) and SSP5 (high challenge to mitigation, low challenge to adaptation) and three RCP targets: 1.9, 3.4 and 6.0 w/m2 targets.

Conclusion: Based on these findings and the assertion that climate change risks and opportunities are already integrated into strategy, products and business model, the Group concluded that its business model and strategy are resilient across all SSPs. This includes the worst-case scenario of SSP3, which assumes lower demand for sustainable products, though insulating buildings will be mandated in all scenarios.

The Group will continue to refine strategic planning as more detailed tools on future demand for building and insulation products become available. While certain critical climate related assumptions used in the Financial Statements are largely compatible with the scenarios detailed above, the impairment tests are broader in scope, which includes additional factors such as macro-economic conditions and market dynamics. Additionally, the Group did not identify any assets or business activities that are incompatible with or require significant adjustments to align with the transition to a climate-neutral economy.

Integration with Strategy and Business Model

Climate change risks and opportunities are deeply embedded in the Group's strategy, R&D investment, products and business model. The Group has clear plans and actions in place to address impacts, manage risks and pursue opportunities.

Innovation as a Key Lever: The Group strives to be the market leader with the most advanced solutions. The Group targets to invest approximately 1% of revenue annually in R&D and digital transformation. Innovation efforts have led to breakthrough products such as QuadCore®, AlphaCore®, Optim-R® and Kooltherm®.

• QuadCore® is an insulated panel technology which is almost 20% more thermally efficient than a traditional PUR (polyurethane) core panel.
• Kooltherm® is an insulation board technology which is almost twice as efficient as traditional stonewool type insulation.
• Optim-R® is a high-performance rigid vacuum insulation panel (VIP) with a declared thermal conductivity of just 0.007 W/mK.

These innovative products and future innovative products, such as QuadCore LEC®, will continue to differentiate the Group from competitors and help to drive adoption of advanced materials to reduce the energy consumption of buildings.

Supplier Engagement: Supplier engagement is an integral part of the Group's strategy. The Group has made two public commitments to reduce scope 3 GHG emissions. Supplier engagement is generally prioritised based on size of expenditure with focus on key raw material suppliers. Procurement and sustainability teams work closely with key suppliers on decarbonisation strategy and product development.

The Group monitors key suppliers' carbon emissions performance annually, where available, to map progression against targets and engages to improve availability of supplier and product specific emissions data. Engagement to date has included site visits, meetings, conference calls, electronic communications between procurement and sustainability functions and testing/development of alternative materials.

Governance and Oversight

The Board, CEO and executive directors are informed about sustainability matters through internal reporting structures. These structures allow oversight of sustainability related IROs across the Group's operating divisions. This process includes reporting material issues to the Board, with updates on CSRD compliance provided at each of the four Audit & Compliance Committee meetings during the year ended 31 December 2024. Divisional management teams must assess sustainability progress and raise material IROs for escalation via structured internal reporting processes.

The Chief Sustainability, Digital and Marketing Officer provides periodic updates to the Board on the progress of the Planet Passionate programme. The Board reviews material sustainability topics, including climate initiatives, resource efficiency and employee wellbeing, ensuring that these topics are incorporated into the decision-making processes across the Group.

The Board also considers sustainability IROs when overseeing the Group's strategy and approving major transactions. The Board evaluates relevant factors including potential fit with sustainability goals, opportunities to leverage synergies and learnings and balancing short-term risks to the sustainability journey against longer-term success factors.

Financial Resources and Capital Allocation

The Group funds its operations and investments through a capital structure comprising a combination of equity and debt. Debt financing includes a green revolving credit facility and green private placement loan notes, reflecting the Group's commitment to sustainable development. In 2024, the Group established a Green Finance Framework to support the issuance of green finance instruments, enabling the financing or refinancing of projects that meet Taxonomy criteria and further advancing its sustainability initiatives.

Additional details on the Group's capital structure, financing arrangements and available headroom can be found in the Financial Review section of this Annual Report. For further information relevant to the Group's core funding and liquidity risk, please refer to Note 20 of the Financial Statements.

The Group's ability to implement its sustainability action plan is not dependent on external preconditions, such as financial support or public policy developments. While specific funding allocations per action are commercially sensitive and not disclosed, the Group's established financing structure ensures the flexibility and capacity to execute the action plan effectively.

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

Double Materiality Assessment Methodology

The Group completed a Double Materiality Assessment (DMA) which was carried out in collaboration with both internal and external stakeholders. The process involved the identification of key IROs across our value chain. This assessment spanned short, medium and long-term time horizons, evaluating both impact materiality (the effects of the Group's activities on society and the environment) and financial materiality (examining how sustainability factors could influence the Group's financial performance).

The Group's DMA methodology aligns with CSRD and ESRS requirements. This process was supported by third-party experts and included a detailed, multi-step approach.

Step-by-step Methodology

The DMA followed a structured five-step process:

1. Scoping

The scope of the assessment included, but was not limited to, a review of the Group's operational segments, encompassing upstream and downstream activities, geographical reach and key suppliers. Internal business knowledge and external expertise was utilised to ensure an evaluation of impacts.

2. Identification

A list of actual and potential IROs was developed through desktop research, peer benchmarking, internal consultations with subject matter experts and input from external experts. This assessment considered both the actual and potential impacts of the Group's business on society and the environment (impact materiality), as well as how sustainability matters could potentially affect the Group's financial performance and position (financial materiality). Additionally, publicly available tools were used to assess environmental risks. Each identified IRO was mapped to ESRS topical standards.

For impacts, the Group assessed materiality based on criteria of severity and likelihood, with thresholds set accordingly. This assessment considers activities, business relationships and geographies where adverse impacts may be more likely, factoring in resource dependencies, regulatory variations and market conditions that influence risk exposure. Severity is determined by the scale, scope and irremediable nature of negative impacts, as well as the scale and scope of positive impacts. In contrast, the financial materiality of risks and opportunities is assessed using thresholds based on the anticipated financial effects and likelihood of occurrence. This dual approach ensures that both the societal and environmental impacts, as well as financial risks and opportunities, are appropriately evaluated and prioritised for reporting purposes. This structured rating system is aligned with ESRS guidelines.

3. Engagement

The Group engaged with over 50 stakeholders from a range of groups, including executives, customers, employees, NGOs and regulatory bodies, through surveys and interviews. Also, input from NGOs and community organisations served as a valuable proxy to capture societal perspectives. This broad engagement ensured the validation of identified sustainability matters from both impact and financial perspectives, helping to prioritise IROs based on the significance of their potential societal and financial impacts.

4. Consolidation

Feedback from stakeholders was analysed and integrated into the final DMA. The results were validated by the Group's management team to ensure alignment with the Group's strategic priorities. The DMA process remained flexible, allowing for recalibration and refinement where necessary to reflect additional insights, emerging issues or regulatory guidance.

5. Reporting

The outcome of the DMA identified material IROs across all ten ESRS topics, as detailed in the topical ESRS standards, forming the basis for the Group's sustainability reporting. The findings were aligned with both impact and financial materiality, ensuring that the Group's sustainability efforts focus on the most significant societal, environmental and business risks and opportunities.

The assessment serves as a foundational tool for the Group's sustainability reporting. The dynamic nature of this process allows for continuous refinement and adjustment as new risks, opportunities and stakeholder expectations emerge. The Group monitors this assessment on an ongoing basis, with the findings integrated into the Group's overall risk management and decision making processes.

Inputs to the Assessment

The DMA utilised multiple inputs:

• Desktop research and peer benchmarking: Review of sector practices and ESRS guidance
• Internal consultations: Subject matter experts across the Group's divisions
• External expertise: Third-party experts supported the process and methodology
• Stakeholder engagement: Over 50 stakeholders from various groups (executives, customers, employees, NGOs, regulatory bodies) through surveys and interviews
• Publicly available tools: Used to assess environmental risks (e.g., WWF's Biodiversity Risk Filter, WRI's Aqueduct for water risks)
• Internal data: Raw materials, direct pollutant measurements, production volumes, water withdrawal and consumption data, GHG emissions data

Scoring Criteria

Impact Materiality

• Severity: Determined by scale, scope and irremediable nature of negative impacts, as well as the scale and scope of positive impacts
• Likelihood: Considered for assessing potential impacts
• Thresholds were set for assessing both actual and potential impacts

Financial Materiality

• Financial effects: Anticipated size of financial effects
• Likelihood: Probability of occurrence
• Thresholds were based on these two criteria to evaluate risks and opportunities

Threshold for Materiality

The Group applied a dual threshold approach:

• Impact materiality thresholds based on severity (scale, scope, irremediable character) and likelihood
• Financial materiality thresholds based on anticipated financial effects and likelihood of occurrence

This structured rating system is aligned with ESRS guidelines. IROs meeting either impact or financial materiality thresholds were identified as material.

Value Chain Mapping

The assessment considered activities across the entire value chain:

• Upstream: Key suppliers, raw material sourcing (metals, chemicals, mineral fibre, wood), procurement partners
• Own operations: 273 manufacturing, assembly and R&D sites across global locations
• Downstream: Distribution channels, customers, end-users, contractors, architects, developers, engineers, building designers, building owners, facilities managers, local authorities

For specific topics, value chain mapping was applied:

• Climate change: Physical and transition risks examined across own operations and key suppliers using scenario analysis
• Biodiversity: WWF's Biodiversity Risk Filter (BRF) tool combined location-specific data with corporate data
• Water: WRI's Aqueduct tool used to evaluate water risks; 29% of sites located in areas of high or extremely high water stress
• Pollution: Analysis of key chemical raw materials assessed by third-party experts
• Resource use: Analysis of material inflows (2023 raw material volumes and spend data) and outflows

Frequency and Review

The DMA was completed during 2024 for first-time CSRD reporting. The Group monitors this assessment on an ongoing basis. The dynamic nature of the process allows for continuous refinement and adjustment as new risks, opportunities and stakeholder expectations emerge. The findings are integrated into the Group's overall risk management and decision-making processes.

During the year, the Audit & Compliance Committee conducted oversight of the DMA process, with updates on CSRD compliance provided at each of the four Audit & Compliance Committee meetings during the year ended 31 December 2024.

Time Horizons

Unless otherwise stated, the Group defines time horizons as follows:

• Short-term: One year
• Medium-term: Period from the end of the short-term up to five years
• Long-term: More than five years

Topic-Specific Assessment Examples

E1 – Climate Change

To assess impacts on climate change, particularly GHG emissions, the Group has a Group-wide methodology for collecting, collating, analysing and reporting scope 1, 2 and 3 GHG emissions. Climate change scenario analysis was conducted in 2024, working with external experts to understand implications of physical and transition climate change risks across different scenarios and time horizons. The tool used is built on the latest climate change science with over 1,000 impact functions based on literature.

Quantitative analysis included:

• Physical risks: Eight physical hazards (extreme temperature, drought, wildfire, coastal flooding, fluvial flooding, pluvial flooding, tropical cyclone and water stress) examined across eight decades (2020 to 2100) and four climate change scenarios (RCP 8.5-SSP5, RCP 7.0-SSP3, RCP 4.5-SSP2 and RCP 2.6-SSP1)
• Transition risks: Five transition risk types (carbon pricing, litigation, new technology, reputational damage and market) examined across eight decades and four climate change scenarios

E2 – Pollution

The Group comprises several distinct manufacturing processes, with a variety of inputs, outputs and scale. To assess pollution-related IROs, the Group utilised internal expertise across divisions and engaged a third-party expert. Data examined included raw materials, direct pollutant measurements and production volumes.

E3 – Water and Marine Resources

To identify water-related IROs, the Group screened assets and activities using water withdrawal and consumption data collected across the Group and an external tool (WRI's Aqueduct) to identify and evaluate water risks. Dependencies on water were evaluated through detailed process analysis.

E4 – Biodiversity and Ecosystems

The Group used WWF's Biodiversity Risk Filter (BRF) tool that allowed combination of location-specific data on biodiversity integrity with corporate data (e.g., site importance and industry classification) to gain initial understanding of IROs. BRF covers both physical and reputational risks (transition and systemic were not included), with eight underlying risk categories.

E5 – Resource Use and Circular Economy

The Group screened activities and key manufacturing processes to understand related IROs. This screening included reference to available data on material inflows and outflows, market trends and regulatory drivers. The assessment was completed by the Group Sustainability team who engaged with divisional sustainability teams and procurement leads.

Material IROs Identified

The table below presents the Group's analysis of the material IROs identified across the relevant ESRS topics:

Materiality Thresholds: Material (✓) / Not Material (blank)

Detailed information on specific IROs and the actions taken to address them can be found in the corresponding topical ESRS sections of this report.

Transition plan for climate change mitigation

Overview and governance

The transition plan (the Plan) is managed through Kingspan's Planet Passionate environmental sustainability programme, which is one of the four strategic pillars. Aligned with climate IROs, the Plan is deeply integrated into the strategy, R&D investments, products and business model. The Plan has been approved by the CEO, who is the most senior person responsible for sustainability related issues.

Scope of the plan

The Plan comprises mitigation levers for scope 1, 2 and 3 GHG emissions and is underpinned by carbon targets. The boundary includes all manufacturing, assembly and R&D sites within the Group, including businesses acquired on or prior to 30 September 2024. The impact of acquisitions after this date were estimated and deemed not material at the Group level.

Net zero / carbon neutral target year

Not explicitly disclosed as a net zero target year. The Plan focuses on science-based absolute reduction targets aligned with 1.5°C.

GHG reduction targets and baseline

Scope 1 and 2 targets

Target #1: 65% absolute reduction - scope 1 and scope 2 emissions

• Base year: 2020 (870,482 tCO2e)
• Target year: 2030
• Scope: Scope 1 and 2 GHG emissions (market based) excluding biogenic emissions
• Coverage: All manufacturing, assembly and R&D sites within the Group, including businesses acquired on or prior to 30 September 2024
• 2024 emissions: 337,837 tCO2e
• Progress to date: 61% reduction achieved

Note on target update: Due to significant growth since the inception of the Planet Passionate programme, the externally verified scope 1 and 2 90% reduction target is under review. The updated target of 65% (including acquisitions to date and further potential growth) is projected to achieve an additional 197,000 tCO2e reduction by 2030, beyond the original commitment.

The target is science-based, developed based on the absolute contraction approach, compatible with limiting global warming to 1.5°C, but not externally assured.

Scope 3 targets

Target #2: 15% absolute reduction - scope 3 (C1) emissions

• Base year: 2020 (6,680,401 tCO2e)
• Target year: 2030
• Scope: Purchased goods and services
• 2024 emissions: 6,375,447 tCO2e
• Progress to date: 5% reduction achieved

Target #3: 42% absolute reduction - scope 3 emissions (overall)

• Base year: 2020 (8,130,451 tCO2e)
• Target year: 2030
• Scope: Covers purchased goods and services, use of sold products and end of life treatment of sold products (represented 92% of total scope 3 GHG emissions in 2024)
• 2024 emissions: 6,990,923 tCO2e
• Progress to date: 14% reduction achieved
• SBTi validation status: Verified by the Science Based Targets Initiative, in line with a 1.5°C trajectory

The 2020 baseline emissions are recalculated to account for acquisition impact, in line with the GHG Protocol's guidance.

Alignment with 1.5°C / Paris Agreement

The Group's carbon targets are aligned with a 1.5°C goal and the Paris Agreement. The Environmental Policy's Climate Change Section states that the Group's commitment is aligned with the Paris Agreement. During the development of the Plan and its decarbonisation levers, a climate scenario compatible with limiting global warming to 1.5°C was considered.

Key decarbonization levers and mitigation actions

Scope 1 and 2 Decarbonisation Roadmap

The following table summarizes progress and planned changes:

1. Energy Efficiency

Completed actions in 2024:

• 32 projects completed, including air compressor upgrades and LED light replacements
• Estimated annual GHG emission savings: 1,198 tCO2e (0.1% reduction)

Planned actions:

• Planned projects for 2025-2026 with estimated 1,374 tCO2e annual GHG emission savings (0.2% contribution to Target #1)
• Additional projects expected through 2030

2. Purchased Renewable Energy - Renewable Energy Contracts

Scope: Prioritized conversion to renewable electricity where available, focusing initially on European markets, with expansion to other markets (e.g. North America) as they develop.

Completed actions in 2024:

• 23 energy contracts converted to renewable energy
• Expected annual reduction: approximately 172,419 tCO2e (19.8% reduction in scope 2 GHG emissions)
• 53% realized in 2024, with further 9.2% reduction expected in 2025 when in place for full year

Planned actions:

• Nine further energy contracts planned for conversion between 2025-2026
• Expected reduction: approximately 1,259 tCO2e annually (0.1% contribution to Target #1)

3. Fuel Conversion and Process Electrification

Completed actions in 2024:

• 30 fuel conversion and electrification projects completed, including forklift electrification and conversion to biofuels
• Estimated annual savings: approximately 2,060 tCO2e (0.2% contribution to Target #1)

Planned actions:

• 51 further projects planned by 2030, targeting both mobile and stationary combustion
• Estimated savings: approximately 9,645 tCO2e annually (1.1% contribution to Target #1)

4. On-site Renewable Energy Generation

Completed actions in 2024:

• 24 projects including solar PV installation and expansion
• Estimated annual savings: approximately 1,381 tCO2e (0.2% contribution to Target #1)
• Achieved 30% on-site renewable energy generation through continued rollout of solar PV, wind and heat generation systems

Planned actions:

• 74 further projects planned between 2025-2030, including solar PV installation/expansion and heat pumps
• 10 key projects with estimated 6,119 tCO2e annual GHG emission savings (0.7% contribution to Target #1)

Target achievement: In 2024, the Group achieved its 20% on-site renewable energy generation target, reaching 30%.

5. Lower GWP Raw Materials

Scope: Phasing out use of high GWP blowing agents for production of insulation products where technically possible.

Completed actions in 2024:

• Further adoption of lower GWP blowing agents
• Reduction: 30,000 tCO2e in scope 1 GHG emissions from 2023 (3.4% contribution to Target #1)
• Prior to 2024, scope 1 process-related GHG emissions reduced by 85%

Planned actions:

• Continued adoption by 2030 expected to save further 5,000 tCO2e annually (0.5% contribution to Target #1)

Scope 3 Decarbonisation Levers

1. Data Collection and Reporting

Completed actions in 2024:

• Increased collection of supplier specific and product specific data
• 34% of scope 3 emissions calculated using primary data
• Implemented new scope 3 data collection and reporting system

• 70% of scope 3 C1 emissions calculated using physical emission factors (vs. monetary)

Planned actions:

• Further development of internal data collection methodologies
• Continued collection of supplier specific and product specific emissions information
• Led through supplier engagement programme

2. Supplier Engagement and Collaboration

Scope: Prioritise engagement with major suppliers of key raw materials, as C1 scope 3 emissions accounted for 91% of total scope 3 emissions.

Completed actions in 2024:

• Over 100 (internal and external) meetings on supply chain engagement
• Developed SHREDD Policy outlining supplier due diligence process
• Supplier engagement programme covers suppliers representing over 62% of C1 scope 3 emissions
• Holding open discussions with suppliers requesting decarbonisation roadmaps at company and product level

Planned actions:

• Continue supplier engagement to reduce embodied carbon of key raw materials
• Expand scope to include additional suppliers
• Public commitment to reduce upstream Scope 3 carbon emissions, particularly purchased goods and services (over 90% of total Scope 3 emissions in 2024)
• Target 15% reduction in product CO2e intensity from primary supply partners by 2030

3. Development of Lower Impact Products

Completed actions in 2024:

• 19 products with improved environmental performance brought to market to date
• 12 LEC (Lower Embodied Carbon) products launched in 2024, including:
  • AST LEC insulated panel
  • Kingframe LEC
  • Multichannel LEC
  • Tate Grid+ LEC
  • Tate Containment LEC
  • KILON LEC Multiwall
  • QuadCore LEC® insulated panel
  • RMG600+
• These products show reduced embodied carbon across lifespan (modules A-C) when compared to standard Kingspan products

Planned actions:

• Continue development of decarbonisation product roadmaps
• Expansion of LEC product range by 2030 and beyond
• Close collaboration with R&D teams

CapEx and investment commitments

• The Group targets to invest approximately 1% of revenue annually in R&D and digital transformation
• In 2024, established a Green Finance Framework to issue financial instruments (bonds and loans) to finance and refinance projects supporting transition to low carbon and climate resilient economy
• Organic expansion in 2024, including new lines and facilities, integrates energy efficiency and low carbon technologies
• Ongoing renovations of existing assets ensure operational improvements consistent with sustainability goals

Locked-in emissions and stranded assets

The Group has assessed that it does not have locked-in GHG emissions that might jeopardise the achievement of its targets or its transition plan for climate change mitigation.

The Group does not manufacture GHG-intensive or energy intensive products; the Group is focused on reducing the embodied carbon of its products, delivering enhanced value to its customers.

Use of carbon credits and removals

Internal Carbon Pricing:

In January 2023, an internal carbon charge of €70 per energy-related tCO2e was introduced across all manufacturing, assembly and R&D sites. Each operating business unit is charged for emissions, directly affecting divisional profitability and management remuneration. This supports deployment of decarbonisation projects including renewable energy contract conversions and forklift fleet decarbonisation.

The carbon charge price was determined through extensive review of carbon pricing guidance, existing mechanisms and rates, including EU ETS carbon price and trajectory.

Carbon Credits Strategy:

Towards the end of the decarbonisation roadmap, for hard to abate residual emissions, the Group plans to procure only high quality carbon credits to neutralise residual GHG emissions after meeting science-based absolute GHG emission reduction targets.

The Group will only procure credible, high-quality carbon credits that demonstrate and ensure additionality and permanence. Nature-based solutions, such as reforestation, cannot guarantee the permanence needed, so the Group will continue to closely monitor the market and invest in the most suitable solution in the coming years.

Consideration of future developments and scenario analysis

Energy infrastructure:

• Capacity of the electricity grid is a crucial consideration for future electrification efforts
• Availability of renewable electricity is critical to strategy; Group prioritises generating electricity through solar PV systems at sites
• Given limited access to renewable electricity in certain regions, will continue to monitor market developments and pursue renewable energy solutions as they become available
• Renewable fuel markets are relatively underdeveloped; as biofuel technology matures, committed to actively seeking biofuel suppliers to replace fossil fuel usage where suitable

Scenario analysis:

• Results of scenario analysis to assess resilience of business model and strategy in relation to climate change can be found in section ESRS 2, IRO-1
• During development of the Plan and decarbonisation levers, considered a climate scenario compatible with limiting global warming to 1.5°C
• Strategy seeks to minimise GHG emissions from organic growth of the business where possible
• Potential impact of organic growth is accounted for within the transition plan

Progress and trends:

• Since 2020, achieved 61% reduction in scope 1 and 2 emissions, a rate exceeding the minimum annual reduction needed to limit warming to 1.5°C above preindustrial levels
• Target monitored monthly by Group Sustainability team

Links to other disclosure requirements

EU Taxonomy alignment:

Article 8 disclosures detail the proportion of revenue, capex and opex currently eligible and aligned with EU Taxonomy, covering activities such as CCM 3.5 Manufacturing of Energy Efficiency Equipment for Buildings.

Manufacture of energy efficiency equipment for buildings (CCM 3.5):

• OpEx: 565m (41% of total)
• 100% taxonomy-aligned
• Substantial contribution to climate change mitigation: Y
• DNSH criteria met: Y
• Minimum safeguards: Y
• Enabling activity: Y

Over time, alignment with Taxonomy criteria is expected to evolve through continued investment in innovative, low carbon solutions and expansion of taxonomy-aligned revenue, capex and opex.

No fossil fuel investments:

The Group did not invest capex amounts in coal, oil and gas-related economic activities during the reporting year. Also, the Group is not excluded from EU Paris-aligned Benchmarks.

Policies related to climate change mitigation and adaptation

Kingspan has developed a Climate Change Section (CCS) within its Environmental Policy to manage, prevent, mitigate and remediate actual and potential impacts, to address risks and to pursue opportunities related to both climate change mitigation and adaptation.

Environmental Policy (Climate Change Section)

Approval and oversight:

• The updated Environmental Policy was approved in December 2024 and communicated to responsible parties
• Divisional managing directors (MDs) are responsible for the implementation of the CCS

Scope:

• The CCS's provisions relate to all climate-related material IROs
• It covers the Group's own operations and the upstream stage of the value chain, as these two were the stages with material IROs

Key content / principles:

• The CCS addresses climate change mitigation, climate change adaptation, energy efficiency and renewable energy generation
• The policy outlines the Group's commitment to mitigate scope 1 and scope 2 (market based) GHG emissions
• Via the policy, Kingspan highlights that its commitment is aligned with the Paris Agreement
• The policy was designed to support the Group's transition plan for climate change mitigation

Public availability:

• The CCS is available on the Group's website
• Kingspan policies can be accessed at: https://www.kingspangroup.com/en/about/policies/
• The CCS was made available to all stakeholders responsible for its implementation

Monitoring implementation:

• Monitoring of the CCS is performed as part of the Planet Passionate programme, which includes targets that were designed to help achieve policy objectives
• The policy is underpinned by externally verified scope 1 and 2 reduction targets

Development process:

• The CCS was developed based on the identified impacts, risks, dependencies and opportunities related to biodiversity and ecosystems
• When setting the policy, Kingspan considered the views and expectations of key stakeholders as part of the DMA process

Training:

• A training programme is in development, which will be rolled out to relevant stakeholders throughout 2025

Link to transition plan:

• The Environmental Policy's Climate Change Section is integrated with the Group's transition plan for climate change mitigation
• The Plan is managed through the Planet Passionate environmental sustainability programme and is underpinned by GHG reduction targets
• The Plan has been approved by the CEO, who is the most senior person responsible for sustainability related issues

Actions and resources in relation to climate change policies

Kingspan's climate actions are managed through the Planet Passionate environmental sustainability programme, underpinned by GHG reduction targets and approved by the CEO. The Transition Plan focuses on scope 1, 2, and 3 emissions through multiple decarbonisation levers.

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Scope 1 & 2 Emissions Reduction Actions

Target: 65% reduction by 2030 (from 2020 baseline), including acquisitions. Updated from 90% to reflect business growth. Projected to achieve an additional 197,000 tCO2e reduction by 2030.

Progress: 61% reduction achieved since 2020; 14.4% reduction in 2024 (10% from energy initiatives, ~4% from process emissions).

Decarbonisation Lever 1: Energy Efficiency

• Completed 2024: 32 projects including air compressor upgrades and LED light replacements
  • Annual savings: 1,198 tCO2e (0.1% reduction)
• Planned 2025-2026: Projects with estimated 1,374 tCO2e annual savings (0.2% contribution to Target #1)
• Scope: Own operations (manufacturing, assembly, R&D sites)
• Expected outcomes: Continuous efficiency improvements; additional projects beyond 2026

Decarbonisation Lever 2: Fuel Conversion and Process Electrification

• Strategy: Electrify process equipment (e.g., insulated panel manufacturing) to reduce fossil fuel emissions
• Considerations: Grid capacity constraints; monitoring biofuel market development as technology matures
• Scope: Own operations
• Time horizon: 2025-2030

Decarbonisation Lever 3: On-site Renewable Energy Generation

• Completed 2024: Not specified quantitatively in excerpts
• Planned 2025-2030: 74 projects including solar PV installations and heat pumps
  • 10 key projects: Estimated 6,119 tCO2e annual savings (0.7% contribution to Target #1)
  • Additional project: Expected 1,381 tCO2e annual savings (0.2% contribution)
• Scope: Own operations
• Resources: Non-financial - prioritising solar PV installations at sites

Decarbonisation Lever 4: Renewable Electricity Contracts

• Strategy: Procure renewable electricity; monitor market developments especially in regions with limited access
• Scope: Own operations
• Time horizon: Ongoing through 2030

Decarbonisation Lever 5: Lower GWP Raw Materials

• Completed pre-2024: 85% reduction in scope 1 process emissions through phasing out high GWP blowing agents
• Completed 2024: Further adoption of lower GWP blowing agents
  • Impact: 30,000 tCO2e reduction from 2023 (3.4% towards Target #1)
• Planned by 2030: Continued adoption
  • Annual savings: 5,000 tCO2e (0.5% contribution to Target #1)
• Scope: Own operations (insulation product manufacturing)
• Time horizon: Short to medium term (through 2030)

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Scope 3 Emissions Reduction Actions

Target #2: 42% absolute reduction by 2030 (from 2020 baseline), covering C1, C11, C12 (92% of scope 3 emissions). Science-based target (1.5°C aligned).

Target #3: 15% reduction in carbon intensity of key raw materials by 2030 (from 2020 baseline of 2.540 tCO2e/t).

Progress: 14% absolute reduction to date; 3.9% intensity reduction (2024: 2.440 tCO2e/t).

Decarbonisation Lever 1: Data Collection and Reporting

• Completed 2024:
  • Increased supplier-specific and product-specific data collection: 34% of scope 3 emissions now use primary data
  • Implemented new scope 3 data collection and reporting system
  • >70% of C1 emissions calculated using physical emission factors (vs. monetary)
  • Sourcing environmental product declarations and product carbon footprints from suppliers and annual reports
• Planned: Further development of internal data collection; transition to physical emission factors; increased supplier-specific data
• Scope: Upstream value chain (purchased goods and services)
• Resources: Non-financial - new IT system implementation

Decarbonisation Lever 2: Supplier Engagement and Collaboration

• Strategy: Prioritise engagement with major suppliers of key raw materials (metals, chemicals, mineral fibre - 76% of raw material emissions in 2024)
• Approach: Maintain long-term relationships; ensure alignment with environmental objectives; collect supplier-specific emissions data
• Scope: Upstream value chain
• Time horizon: Ongoing through 2030
• Dependencies: Progress relies on key suppliers' decarbonisation strategies and industry-wide decarbonisation in metals and chemicals
• Resources: Non-financial - procurement team collaboration

Decarbonisation Lever 3: Development of Lower Impact Products

• Innovation strategy: Two main approaches:
  1. Refining existing products with lower carbon alternatives
  2. Exploring new bio-based materials and solutions
• Product offering: Market-leading high-performance insulation solutions reducing buildings' operational energy and emissions
• Downstream impact: Products enable reduced energy usage and CO2e emissions in use phase (C11)
• Scope: Downstream value chain; own operations (R&D)
• Expected outcomes: Meet customer demand for lower embodied carbon, net-zero energy buildings; strengthen strategic partnerships
• Time horizon: Medium to long term

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Strategic Initiatives

Shifting Products and Services Portfolio

• Driver: Increased engagement from top-tier customers seeking strategic partnerships for lower embodied carbon, net-zero energy buildings
• Action: Prioritise innovative, sustainable product solutions (high-performance insulation, low-carbon materials)
• Link to IRO: Addresses "Reduced energy used via insulation products & solutions" (positive impact, downstream)
• Outcomes: Secure Group position as leader in sustainable building solutions; evolve portfolio to align with market needs
• Resources: R&D investments in decarbonisation of product portfolio

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Monitoring and Governance

• Target monitoring: Monthly basis by Group Sustainability team
• Programme management: Planet Passionate programme, approved by CEO (most senior person responsible for sustainability)
• Integration: Deeply integrated into strategy, R&D investments, products, and business model
• Scenario alignment: Plan developed considering 1.5°C climate scenario; use of scenario analysis to inform strategic decisions (see ESRS 2 IRO-1)

Targets related to climate change mitigation and adaptation

Kingspan has established three science-based GHG emission reduction targets aligned with limiting global warming to 1.5°C. These targets are developed using the absolute contraction approach and are compatible with the Paris Agreement, though not all are externally assured by SBTi.

Target 1: Scope 1 and 2 GHG Emissions Reduction

Context: Originally set as 90% reduction target in 2019. Updated in 2024 to 65% to reflect significant growth since 2020. The updated target is projected to achieve an additional reduction of 197,000 tCO2e by 2030 beyond the original commitment.

Decarbonisation levers:

• Energy efficiency
• Purchased renewable energy (renewable energy contracts)
• Fuel conversion and process electrification
• On-site renewable energy generation
• Lower GWP raw materials

Target 2: Scope 3 GHG Emissions Reduction

Context: 2020 baseline emissions are recalculated to account for acquisition impact per GHG Protocol guidance. Majority of reduction attributable to C1 (~24%) and C11/C12 (~65%).

Target 3: Carbon Intensity of Key Raw Materials

Context: Originally set at 50% reduction, updated to 15% in 2024 to reflect pace of development by suppliers, regulators and customers. Achievement dependent on progress made by key raw material suppliers and industry decarbonisation.

Decarbonisation levers:

• Data collection and reporting
• Supplier engagement and collaboration
• Development of lower impact products

Additional 2025-2030 Programme Targets

The Group has set three new operational targets reflecting strong momentum:

1. ISO 50001 energy management certification on all large sites by 2030
2. 1.5 million tonnes of recycled and renewable raw material use annually by 2030
3. Facilitate 20 product takeback and recycling schemes by 2030

Additional Context

• Energy use and baseline GHG emissions have increased by over 300% and 100% respectively since 2020 due to organic growth and acquisitions
• Annual replacement of zero emissions company cars will be >90% from 2025
• The Group did not invest capex in coal, oil and gas-related economic activities during the reporting year
• Progress is monitored monthly by the Group Sustainability team

Energy consumption and mix

Total energy consumption and mix (2024)

Scope and methodology: Boundary covers all manufacturing, assembly and R&D sites within the Kingspan Group, excluding acquisitions made after 30 September 2024. The impact of acquisitions after this date were estimated and deemed not material at the Group level. Historical figures have been restated due to improved data collection and change in calculation methodologies. 'Other fossil sources' includes other non-renewable, non-fossil sources. The Group does not actively source energy from nuclear sources.

Energy intensity: Not disclosed in the excerpts provided.

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1 & 2 GHG emissions

Kingspan achieved a 61% reduction in Scope 1 & 2 GHG emissions against the 2020 base year in 2024.

Scope 1 & 2 emissions (excluding biogenic emissions, market-based Scope 2):

Notes:

• Excluding biogenic emissions
• Scope 2 GHG emissions calculated using market-based methodology
• ¹ Underlying business includes manufacturing, assembly and R&D sites within the Kingspan Group in 2020 and all organic growth to date
• ³ Whole business includes manufacturing, assembly and R&D sites within the Kingspan Group, excluding acquisitions made after 30 September 2024 and three minor sites acquired in 2023, which have negligible environmental impacts due to data unavailability
• ² Restated figures due to improved data collection, change in calculation methodologies and site disposal
• ⁴ GHG emissions were recalculated due to acquisitions that occurred in 2021 through to 30 September 2024

The Group achieved an 80% reduction in like-for-like (underlying business) Scope 1 & 2 emissions since 2020, despite business growth.

Year-on-year change: Scope 1 and 2 GHG emissions reduced by 27% year on year (2024 vs 2023).

Scope 2 breakdown

Scope 2 emissions are reported using the market-based methodology as primary disclosure. Location-based methodology is not separately disclosed in the extracts provided.

Scope 3 GHG emissions

Kingspan achieved a 14% reduction in Scope 3 GHG emissions against the 2020 base year in 2024.

Key Scope 3 information:

• Purchased goods and services account for over 90% of total Scope 3 emissions in 2024
• The Group engaged with key raw material suppliers throughout 2024, with over 100 internal and external meetings on supply chain engagement

Specific Scope 3 category breakdowns and quantitative data for 2024 are not disclosed in the extracts provided.

Total GHG emissions

Total GHG emissions across all scopes are not explicitly stated in a single consolidated figure in the extracts provided.

GHG intensity

No GHG intensity metric (e.g., tCO2e per million euro revenue) is disclosed in the extracts provided.

Biogenic emissions

Biogenic CO2 emissions are reported separately and excluded from Scope 1 & 2 totals. Specific quantitative data for biogenic emissions is not disclosed in the extracts provided.

Product lifecycle emissions impact

Kingspan's insulation systems sold in 2024 are estimated to save 172 million tonnes of CO2e over their lifetime (assuming 60-year product life). This figure represents avoided emissions from energy savings during product use phase, not the Group's operational emissions.

Regulated emissions

No specific disclosure of EU ETS or other regulated emissions is provided in the extracts.

Methodology notes

• The Group follows the GHG Protocol Corporate Accounting and Reporting Standard
• Scope 2 emissions use market-based methodology as primary disclosure
• Biogenic emissions are excluded from Scope 1 & 2 totals
• Base year (2020) figures have been restated due to improved data collection, methodological changes, and site disposals
• Whole business figures include acquisitions through 30 September 2024, with some exclusions due to data unavailability
• Carbon targets were updated in 2024 to reflect the significant increase in scope and scale from acquisitions

Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Phase-in exemption applied

Kingspan has applied the transition exemption for ESRS E1-9 (Anticipated financial effects from material physical and transition risks and potential climate-related opportunities) for the 2024 reporting period.

This is confirmed in the disclosure requirements table where E1-9 is listed with "Transition exemption" as the reason for omitting.

Benchmark regulation disclosures

While substantive financial quantification is not provided under the transition exemption, the following related datapoints are referenced:

• ESRS E1-9 Exposure of the benchmark portfolio to climate-related physical risks (Data point 66) - listed as using transition exemption
• ESRS E1-9 Disaggregation of monetary amounts by acute and chronic physical risk; location of significant assets at material physical risk (Data points 66(a) and 66(c)) - transition exemption applied
• ESRS E1-9 Breakdown of the carrying value of real estate assets by energy-efficiency classes (Data point 67(c)) - transition exemption applied
• ESRS E1-9 Degree of exposure of the portfolio to climate-related opportunities (Data point 69) - transition exemption applied

Policies related to pollution

Kingspan has developed a Pollution Section (PS) within its Environmental Policy to address pollution-related impacts, risks, and opportunities.

Environmental Policy – Pollution Section

Approval and communication:
The Group's updated Environmental Policy was approved in December 2024 and communicated to responsible parties. A training programme is in development, which will be rolled out to relevant stakeholders throughout 2025.

Scope:
The Pollution Section of the Environmental Policy recognizes the importance of pollution as a critical global issue. The policy outlines the Group's objectives in relation to material pollution related to identified IROs, including the commitment to develop a process to identify and monitor these IROs within operations. Specifically, it outlines the aim to manage material IROs related to pollution to air, water and soil (including pollution from microplastics and of living organisms and food resources).

The policy covers the Group's own operations. As the company did not identify any material pollution-related IROs for its own operations, the policy does not include provisions related to substituting or minimizing substances of concern or incident and emergency prevention at the Group level.

Governance and oversight:
Divisional managing directors (MDs) are responsible for the implementation of the Pollution Section.

Public availability:
Kingspan policies can be accessed on the company website: https://www.kingspangroup.com/en/about/policies/. The Environmental Policy was made available to all stakeholders responsible for its implementation.

Monitoring:
Monitoring of the Pollution Section is performed as part of the Planet Passionate programme, which includes targets designed to help achieve policy objectives. The company plans to establish a Group-level reporting mechanism to enhance monitoring and management of pollution-related IROs. As a first step, the company aims to gather more comprehensive and accurate data on key value chain partners' pollution-related impacts by consulting with internal experts and third-party consultants.

Implementation measures:

• Certifications: In 2024, 50% of the company's sites held ISO 14001 certification, reflecting the implementation of environmental management systems.
• Environmental permits: Manufacturing sites hold environmental permits or equivalent, where applicable, in line with national and/or regional requirements. Compliance includes monitoring and reporting of air emissions, water discharges and soil contamination. Environmental permits outline local pollution regulatory thresholds and limits, providing clear guidance and thresholds for manufacturing sites to operate within.
• Monitoring: The company monitors material environmental breaches and/or concerns raised by local communities (those in or around business locations). No material fines or breaches have been reported for 2024.

Additional policies:
The company has established clear standards for ethical practices and sustainability expectations across its supply chain through key policies, including the SHREDD Policy (Supplier Human Rights, Environmental Due Diligence Policy), which outlines the Group's supplier due diligence process and aims to reduce environmental impacts by collaboration with critical suppliers and holding them accountable to the Group's environmental standards.

Materiality context

The company assessed that pollution to air, water and soil (including generation and use of microplastics) is not material at the Group level for its own operations based on current assessment. However, given the nature, extent and complexity of its value chain, the company assessed that this topic is material for its upstream value chain, while not material for its downstream value chain.

Regarding substances of concern (SoC) and substances of very high concern (SVHC), using a risk-based approach, the company identified key chemical raw materials from a Group level, which were further assessed by a third-party expert. The company has not identified any material IROs related to SoC or SVHC within its operations.

Due to the complexity of the topic and unique regional requirements, management of IROs related to substituting or minimizing substances of concern and incident and emergency prevention are not addressed in the Environmental Policy at the Group level. This topic is managed by local teams at the site level, in line with applicable regulations and giving consideration to unique local circumstances.

Actions and resources related to pollution

Kingspan has determined that pollution is not material at the Group level for own operations, and therefore has not set Group-level pollution targets or related actions. However, the company manages pollution at the site level and is developing enhanced monitoring processes.

Site-Level Management Approach

Scope: Own operations (manufacturing sites)

Time horizon: Ongoing

Key activities:

• Manufacturing sites hold environmental permits or equivalent, where applicable, in line with national and/or regional requirements
• Compliance includes monitoring and reporting of air emissions, water discharges and soil contamination
• Environmental permits outline local pollution regulatory thresholds and limits, providing clear guidance and thresholds for manufacturing sites to operate in
• Monitoring of material environmental breaches and/or concerns raised by local communities (i.e. those in or around business locations)
• No material fines or breaches have been reported for 2024

Resources allocated: Not quantified

Link to policy: Pollution Section (PS) of Environmental Policy

ISO 14001 Environmental Management Systems

Scope: Own operations (manufacturing sites)

Time horizon: Ongoing

Progress:

• At the end of 2024, 50% of manufacturing sites have achieved ISO 14001 certification

Resources allocated: Not quantified

Expected outcomes: Support in tracking the effectiveness of the PS of the Environmental Policy

Planned Group-Level Reporting Mechanism

Scope: Own operations and upstream value chain

Time horizon: Short-term (first step underway)

Planned activities:

• Establish a group level reporting mechanism to enhance the monitoring and management of pollution-related IROs
• As a first step, consulting with both internal experts and third-party consultants to gather more comprehensive and accurate data on key value chain partners' pollution-related impacts
• Develop an effective process to manage material impacts in upstream value chain (where pollution is identified as material)

Resources allocated: Non-financial resources mentioned (internal experts and third-party consultants), but not quantified

Expected outcomes: Increased visibility will facilitate the development of an effective process to manage material impacts

Link to policy: Environmental Policy

Ongoing Materiality Monitoring

The company states: "Although we have not identified any material IROs at a group level for our own operations, this topic is managed by our local teams at the site level, in line with applicable regulations and giving consideration to unique local circumstance. We will continue to monitor the materiality of our IROs and reassess our approach if needed."

Targets related to pollution

Kingspan has not disclosed any pollution-related targets in the extracted excerpts.

The company explicitly states:

"As we did not identify any material pollution related IROs for our own operations, we did not set Group level pollution targets or related actions, but we will continue to monitor the materiality of our IROs and reassess our approach if needed."

The company notes that while pollution is not material at the Group level for own operations, it is material for the upstream value chain. However, no specific targets for the value chain are disclosed in relation to pollution.

The company commits to developing a group level reporting mechanism to enhance monitoring and management of pollution-related IROs, and aims to gather more comprehensive data from value chain partners, but no quantified targets or timelines are provided.

Pollution of air, water and soil

Material IROs Assessment

As a global manufacturer of building materials with 273 manufacturing sites, the sub-topic of pollution to air, water and soil is considered relevant and IROs were identified and assessed in further detail. Both impact and financial materiality were assessed and Kingspan concluded that based on the assessment to date, this sub-topic is not material at the Group level for our own operations.

Given the nature, extent and complexity of our value chain, Kingspan has assessed that this topic is material for our upstream value chain, while not material for our downstream value chain.

Policy and Management Approach

In the Pollution Section (PS) of our Environmental Policy, Kingspan recognises the importance of pollution, as a critical global issue. The policy outlines objectives in relation to material pollution related to IROs, including commitment to develop a process to identify and monitor these IROs within operations. Specifically, it outlines the aim to manage material IROs related to pollution to air, water and soil (including pollution from microplastics and of living organisms and food resources).

As Kingspan did not identify any material IROs at a group level for our own operations, no Group level pollution targets or related actions were set, but the company will continue to monitor the materiality of IROs and reassess the approach if needed.

Local Management

Although no material IROs were identified at a group level for own operations, this topic is managed by local teams at the site level, in line with applicable regulations and giving consideration to unique local circumstance.

• Manufacturing sites hold environmental permits or equivalent, where applicable, in line with national and/or regional requirements
• Compliance with these requirements may include, but is not limited to, the monitoring and reporting of air emissions, water discharges and soil contamination
• Environmental permits outline the local pollution regulatory thresholds and limits, thus providing clear guidance and thresholds for the manufacturing sites to operate in
• Kingspan monitors material environmental breaches and/or concerns raised by local communities (i.e. those in or around business locations) and no material fines or breaches have been reported for 2024

Environmental Management Systems

• At the end of 2024, 50% of Kingspan's manufacturing sites have achieved ISO 14001 certification
• ISO 14001 environmental management systems are implemented at sites

Future Plans

Kingspan plans to establish a group level reporting mechanism to enhance the monitoring and management of pollution-related IROs. As a first step, by consulting with both internal experts and third-party consultants, the company aims to gather more comprehensive and accurate data on key value chain partners' pollution-related impacts. This increased visibility will facilitate the development of an effective process to manage material impacts.

Quantified Emissions

No quantified emissions data for air, water or soil pollutants is disclosed in the excerpts provided.

The company notes that:

• Emissions to water, air and soil are managed at site level through environmental permits
• Monitoring and reporting may include air emissions, water discharges and soil contamination per local regulatory requirements
• No E-PRTR or similar regulatory disclosure data is provided at group level
• The company references ESRS E2-4 datapoint 28 in Appendix 4, stating that pollutants listed in Annex II of the E-PRTR Regulation are "Not material"

Substances of concern and substances of very high concern

Assessment and Management Approach

The Group collaborated with a third-party expert in the chemical industry to assess the presence and use of substances of concern (SoC) and substances of very high concern (SVHC) throughout the lifecycle of manufactured products.

Based on this assessment, the Group determined that:

• The Group's manufacturing activities do not use or produce any substances listed in the Climate Delegated Act (EU 2021/2139), under points (a) to (d) of Appendix C: Generic Criteria for DNSH to pollution prevention and control regarding use and presence of chemicals
• All substances used by the Group are either not restricted under EC 1907/2006 Annex XVII or are used in full compliance with the conditions specified in that Annex

REACH Compliance

Regarding the REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) Regulation:

• Substances used by the Group are either not restricted by EC 1907/2006 Annex XVII or are used in full compliance with the specified conditions
• This applies to both formaldehyde and methylene diphenyl diisocyanate (MDI)

Formaldehyde

• Classified as CMR (Carcinogenic, Mutagenic, or Reprotoxic)
• Used as a building block for phenolic resins in the manufacture of phenolic foam insulation
• In the final product there is very little residual formaldehyde left and hazard thresholds are not knowingly breached
• Exposure limits for workers set at EU level

Methylene Diphenyl Diisocyanate (MDI)

• Used as a building block for polyurethane (PU) and polyisocyanurate (PIR) in the manufacture of PU/PIR foam insulation
• The residual presence of MDI is minimal in final products

Microplastics Compliance

The Group's products meet the requirements of EC 1907/2006 Annex XVII with respect to microplastics, since they are either:

• Used in industrial settings, or
• Encapsulated in final products

Therefore they meet the stated exemption requirements.

Materiality Conclusion

The results of the assessment allowed the Group to consider the materiality of SoCs and SVHCs in relation to overall materials procured and product portfolio. Based on the assessment completed to date, the Group concluded that SoCs and SVHCs are not a material sub-topic at the Group level for current operations.

Given the nature, extent and complexity of the value chain, the Group has determined that this topic is likely material for the upstream value chain.

Future Development

The Group has begun the assessment of the availability of information on substances of concern throughout the lifecycle. As availability of primary data increases through the development of a group-level reporting mechanism, the Group will continue to refine and review its assessment.

Anticipated financial effects from pollution-related impacts, risks and opportunities

Kingspan has applied the transition exemption for this disclosure requirement. Additionally, the company cites sensitive information as a reason for omission.

No quantified financial effects, methodology, or time horizons are disclosed for pollution-related impacts, risks and opportunities.

Policies related to water and marine resources

Environmental Policy (Water Section)

Kingspan has developed a dedicated Water Section (WS) within its Environmental Policy to manage, prevent, mitigate and remediate actual and potential impacts, to address risks and to pursue opportunities related to water and marine resources.

Alignment with international standards: The Group's SHREDD Policy (referenced in section S2-1) is aligned with several international guidelines and principles, including:

• OECD Guidance for Multinational Enterprises (MNCs) on Responsible Business Conduct (RBC) (OECD, 2023)
• UN Guiding Principles on Business and Human Rights (UNGP, 2011)
• International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work (ILO, 1998)

Scope and implementation: The Water Section of the Environmental Policy includes provisions for:

• Identifying priority sites using relevant criteria such as exposure to water stress and dependency on water
• Developing site-specific action plans focused on the local nature of water and local circumstances
• Applying the precautionary principle

Monitoring: The Group tracks the effectiveness of the Water Section of its Environmental Policy through internal environmental data collection and reporting processes.

Public availability: The document does not explicitly provide a URL or specific location where the Environmental Policy can be accessed publicly.

Actions and resources related to water

Kingspan states that no priority sites were identified in 2024, therefore there are no specific actions at the Group level related to water in the reporting period.

Planned approach to water management

The company outlines a planned, site-specific approach:

• Scope: Own operations (priority sites to be identified)
• Approach: Site-specific action plans will be developed as needed, with a focus on the local nature of water and local circumstances
• Site identification criteria: Priority sites will be identified using relevant criteria such as:
  • Exposure to water stress
  • Dependency on water
  • Action plans to be developed as needed

Governance and policy framework

• Water Section (WS) developed within the Environmental Policy to manage, prevent, mitigate and remediate actual and potential impacts, to address risks
• Management approach and water-related topics tackled will depend on the local context of water and specific needs and circumstances at priority sites
• The Group tracks effectiveness of the WS through internal environmental data collection and reporting processes

Resources allocated

No specific resources (financial or non-financial) are disclosed for water-related actions.

Targets and methodology

As stated: "In 2024, we have not set targets related to our material IROs for E3."

The company notes that "a Group-wide target based on absolute reductions is neither the most efficient nor the most strategically relevant option" due to the local context of water and variation of impacts and dependency across the Group. Instead, resources will be focused on sites addressing their water-related challenges.

As methodologies evolve with company growth, the approach to identifying priority sites and actions may be reassessed.

Targets related to water

Kingspan explicitly states that no Group-wide targets have been set for water (E3-3).

Company's rationale

As stated in the disclosure:

"As outlined above, our impacts and dependency on water vary across our Group. This fact, along with the local context of water, means that a Group-wide target based on absolute reductions is neither the most efficient nor the most strategically relevant option. Instead, we are focusing our attention and resources on sites and helping to address their water-related challenges."

The company further confirms:

"In 2024, we have not set targets related to our material IROs for E3."

Management approach

Rather than setting Group-wide quantified targets, Kingspan's approach is to:

• Identify priority sites using criteria such as exposure to water stress and dependency on water
• Develop site-specific action plans focused on local water context and circumstances
• Track effectiveness through internal environmental data collection and reporting processes

Note: In 2024, no priority sites were identified, therefore there are no specific actions at the Group level related to water.

Water consumption

Materiality Assessment

Kingspan assessed water-related impacts, risks and opportunities (IROs) using the WRI Aqueduct tool and internal water withdrawal and consumption data. The Group concluded that water is not material at the Group level due to:

• 90% of sites (manufacturing, assembly and R&D) withdraw less than 10,000 m³ of water per year (categorized as very low)
• 29% of sites are located in areas of high or extremely high water stress, but these facilities represent only 9% of total water withdrawals
• 27.5% of sites consume water as an integral part of manufacturing processes, while 72.5% use water only for social purposes
• No priority sites (>100,000 m³ annual withdrawal in high water stress areas) were identified during the reporting year

Given the nature and variety of operations and geographical spread of facilities, the Group concluded that impacts and dependencies are not material at the Group level.

Water Withdrawal by Stress Level

Kingspan's Water Heatmap

Note: Water withdrawal categories based on WWF (2024) WWF Risk Filter Suite version 2.0

Targets and Actions

The Group has set a voluntary water-related target under the Planet Passionate programme:

• Target: Harvest 100 million litres of rainwater annually by 2030
• Scope: All Group manufacturing, assembly and R&D sites
• Purpose: Reduce impacts and alleviate stress on local aquifers and water systems by withdrawing less freshwater from third-party providers or groundwater sources

Note: This target was not designed to address material impacts or risks, as water was deemed not material, but supports global environmental challenges and community stewardship.

Management Approach

No priority sites were identified in 2024, therefore there are no specific Group-level actions related to water. The Water Section of the Environmental Policy outlines that priority sites would be identified based on:

• Exposure to water stress
• Dependency on water (water withdrawal volumes)
• Water consumption levels

Site-specific action plans would be developed as needed, focusing on local water context and circumstances.

Upstream Value Chain

The Group identified material water impacts in its upstream value chain due to key suppliers operating in water-intensive industries (e.g., steel and chemicals). Publicly available sectoral water assessment tools and internal expertise were used for this assessment.

EU Taxonomy DNSH - Water

As part of the Do No Significant Harm (DNSH) assessment for sustainable use and protection of water and marine resources:

• The majority of sites withdraw less than 10,000 m³ of water per year
• Sites with withdrawals exceeding 10,000 m³ per year were assessed for water quality risks
• None of the examined sites have high or very high operational risks related to water quality
• No priority sites requiring water use and protection management plans were identified during the reporting year

Anticipated financial effects from material water and marine resources-related impacts, risks and opportunities

Kingspan has applied the transition exemption for this disclosure requirement and has not disclosed anticipated financial effects from material water and marine resources-related risks and opportunities in the 2024 reporting period.

Transition plan and consideration of biodiversity and ecosystems in strategy and business model

Integration of biodiversity in strategy and business model

Planet Passionate, our Group environmental sustainability programme, which is one of our four strategic pillars, aims to help tackle climate change, promote circularity and the protection of the natural world. Planet Passionate is deeply embedded in our business model and strategy.

The Group did not perform a resilience analysis related to biodiversity because we're still exploring the implications of different biodiversity-related scenarios on our strategy. We aim to do so in the coming years pending the availability of relevant tools and guidance.

Based on the above analysis and the nature and materiality of our biodiversity IROs, we believe that our business model/strategy is to a large extent compatible with global public policy ambitions and targets. For example, many of the Kunming-Montreal Global Biodiversity Framework's targets are not relevant for the Group (e.g. invasive species, wild species, genetic resources and biotechnology), showing that much of the international focus is in areas where the Group is not involved in.

With a trading presence in over 80 countries and 273 manufacturing facilities, our geographical diversification enhances the resilience of our business model, reducing exposure to localised biodiversity risks and allowing us to adapt to regional ecosystem-related regulatory changes, while also capturing opportunities for sustainable growth.

Material biodiversity impacts and linkage to transition plan

The results of the DMA showed that our most material impact on biodiversity from our operations (based on the type and nature of our activities) is pollution and our most material dependency is water availability. As presented in the E3 – Water and marine resources section, our water-related impacts are not deemed material, so in turn, we do not consider our dependency and hence risks, on the biodiversity water provisioning services as material.

Material impacts related to Biodiversity and ecosystems

Climate change as key biodiversity transition plan

We recognise that climate change is inextricably linked with biodiversity loss and ecosystem integrity, so we also consider our impact via climate change as a key pressure on biodiversity as material. The Group developed a detailed transition plan for climate change mitigation to ensure our business model is compatible with a 1.5°C future, in line with the Paris Agreement.

Assessment approach and value chain scope

Even though Material impacts related to Biodiversity and ecosystems effort, to assess our value chain IROs in detail. In the meantime and in the absence of conclusive evidence, we have applied the precautionary principle as part of our current supplier due diligence process. We aim to further progress our analysis when tools and guidance mature.

Given the location specific nature of biodiversity, assessing IROs across our extensive value chain poses a greater challenge.

Site materiality and proximity to biodiversity-sensitive areas

Due to the type and nature of our material impacts on biodiversity, we have not provided a list of material sites with activities that negatively affect biodiversity sensitive areas. We recognise that further analysis is needed to determine the existence and magnitude of impacts on biodiversity sensitive areas. We aim to do so in the coming years pending the availability of detailed biodiversity footprinting tools.

Due to the location of our activities, the nature of our impacts and our proactive management approach, we assessed that we do not have operations that affect threatened species. As we refine our approach and more sector-specific tools and guidance mature, we aim to further progress our analysis.

In 2024, no priority sites were identified, therefore there are no specific actions at the Group level related to water. As the Group grows, our methodologies will evolve.

Biodiversity impact drivers assessment

Key biodiversity impact drivers (source: CSRD, ESRS 4 – paragraph 4):

» Climate change – material covered in E1 - Climate change; » Land-use, freshwater and sea-use change – not applicable; » Direct exploitation – not applicable; » Invasive alien species - not applicable; and » Pollution - deemed not material for our own operations (see E2 – Pollution for more information).

Finally, we have not identified material negative impacts with regards to land degradation, desertification or soil sealing.

Other material IRO assessments

» Impact – water: deemed to be not material after additional analysis (see E3 - Water and marine resources section for more detail); » Impact – pollution: deemed not material for our own operations (see E2 - Pollution section for more detail).

Similarly, as outlined in the E2 – Pollution section, we do not consider pollution to air, water and soil and pollution caused by SoC/SVHC as material sub-topics for our own operations based on our assessment to date. The Paper & Forest Products parts of our business are associated with an increased number of material impacts and dependencies, but their contribution to the Group-level materiality was assessed and deemed not material (based on contribution to revenue and size).

Policies related to biodiversity and ecosystems

Kingspan has developed biodiversity-related policies aligned with their identified material impacts, risks and opportunities.

Environmental Policy - Biodiversity Appendix (BA)

Policy name: Environmental Policy - Biodiversity Appendix (BA)

Key content and principles:

• Developed based on identified impacts, risks, dependencies and opportunities related to biodiversity and ecosystems
• Aims to manage and mitigate material direct impact drivers identified in the materiality analysis (e.g. climate change)
• Supports traceability of timber products by obtaining relevant certification for material timber quantities
• Covers all sites that are in or near biodiversity areas
• Does not cover: sustainable land/agricultural practices, invasive alien species, sustainable oceans/seas practices, deforestation commitments, production, sourcing or consumption from ecosystems that are managed to maintain or enhance conditions for biodiversity, and social consequences of biodiversity and ecosystems-related impacts

Scope:

• Applies to Group operations
• Covers sites in or near biodiversity areas
• Does not use biodiversity offsets in any action plans

Governance and oversight:

• Divisional MDs (Managing Directors) are responsible for implementation of the Biodiversity Appendix

Monitoring:

• Based on the nature and materiality of IROs, the company concluded it is not necessary to implement biodiversity mitigation measures identified in EU directives (Directive 2009/147/EC on conservation of wild birds; Council Directive 92/43/EEC on conservation of natural habitats and wild fauna and flora)

Link to strategy:

• The company has a detailed transition plan for climate change mitigation to ensure the business model is compatible with a 1.5°C future, in line with the Paris Agreement
• The plan helps reduce GHG emissions and climate-related biodiversity impacts
• No biodiversity-specific resilience analysis performed yet; company aims to do so in coming years pending availability of relevant tools and frameworks
• The company assessed that it does not have operations that affect threatened species
• Due to location of activities, nature of impacts and proactive management approach, the company assessed it does not have operations that affect threatened species

Actions and resources related to biodiversity

Kingspan states that its material biodiversity-related IROs are connected to climate change for its own operations. To address biodiversity IROs related to climate change, the company has developed actions outlined below.

Climate change mitigation actions

The company references its climate change mitigation strategy as the primary action addressing biodiversity impacts. As stated: "our material biodiversity-related IROs are connected to climate change for our own operations. To address the biodiversity IROs related to climate change, we have developed a [strategy]".

Specific climate-related actions referenced include:

• Decarbonisation strategy: Science-based 1.5°C aligned decarbonisation targets and actions (detailed in E1 Climate section)
• Internal carbon pricing: €70 charge per tCO2e introduced in January 2023 across manufacturing, assembly and R&D sites

Circular economy and product innovation actions

While primarily addressing resource use (E5), several actions have indirect biodiversity benefits through reduced resource extraction:

• LIFECycle Product Framework - Input Materials: Aims to increase use of recycled and renewable raw materials to reduce upstream resource depletion
• Product innovation: Development of lower-carbon alternatives and bio-based materials including:
  • QuadCore LEC® insulated panel
  • RMG600+
  • Tate Grid+ LEC
• LIFECycle Product Framework - Cycling: Developing options to keep materials circulating through partnerships and in-house mechanical and chemical recycling facilities (e.g., Winterswijk's glycolysis plant, Derbigum's No Roof to Waste Scheme)

Site analysis

The company conducted an analysis on sites near or in biodiversity-sensitive areas (referenced as "site materiality and site proximity to biodiversity-sensitive areas section"), though specific actions resulting from this analysis are not detailed in the provided excerpts.

Resources allocated: €70 internal carbon price applied to all manufacturing, assembly and R&D sites (charged per tCO2e, affecting divisional profitability and management remuneration). No other biodiversity-specific financial or human resources are quantified.

Time horizon: Not specified for biodiversity actions.

Scope: Own operations primarily, with indirect upstream value chain impacts through material sourcing.

Link to policy: Actions link to the Environmental Policy which incorporates biodiversity considerations (updated in 2024) and aligns with IFC Performance Standard 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources.

Targets related to biodiversity and ecosystems

The Group has not set additional biodiversity-specific targets.

As stated in the disclosure:

"Our targets relate to our material IROs for our own operations (i.e. climate change). They are not directly linked to ecological thresholds nor informed by relevant, global/regional biodiversity frameworks and strategies. For targets that address the climate change-related biodiversity IROs, we have set GHG mitigation targets that serve as the basis for our transition plan. More details on the targets are presented in the E1- Climate change section of this Report. The Group has not set additional biodiversity specific targets."

The company has identified a recycled and renewable raw materials target mentioned in the context of reducing resource depletion (which relates to biodiversity IROs), but the specific quantified target values, baseline year, and target year are not disclosed in the E4-4 section. The target is referenced indirectly as:

• References to "increase use of recycled and renewable raw materials, in line with our new recycled and renewable raw materials target"
• This target appears to be linked to addressing biodiversity-related impacts from resource depletion
• The target details are not provided in the E4-4 disclosure

The company addresses biodiversity-related impacts primarily through climate change mitigation targets (disclosed under E1) rather than biodiversity-specific targets.

Impact metrics related to biodiversity and ecosystems change

Not disclosed.

The company states on page 198 of the CSRD Sustainability Statement:

"We are not reporting impacts metrics related to biodiversity and ecosystems change for this reporting period as we have concluded we do not materially contribute to:

• the impact drivers of land-use change, freshwater-use change and/or sea-use change;
• the accidental or voluntary introduction of invasive alien species; and
• the state of species."

The company acknowledges that:

• Further analysis is needed to determine the existence and magnitude of impacts on biodiversity sensitive areas
• They aim to provide detailed biodiversity footprinting in coming years pending availability of detailed tools
• Due to the location and nature of activities, they assessed that they do not have operations that affect threatened species
• They have not provided a list of material sites with activities that negatively affect biodiversity sensitive areas

For analysis on sites near or in biodiversity sensitive areas, the company refers readers to the site materiality section, but no quantified metrics are provided.

Anticipated financial effects from biodiversity and ecosystem-related impacts, risks and opportunities

Kingspan has applied the transition exemption for ESRS E4-6 and has not disclosed anticipated financial effects from material biodiversity and ecosystem-related risks and opportunities in this reporting period.

Policies related to resource use and circular economy

Kingspan states: "As a global manufacturer, we are committed to helping to accelerate the use of circularity practices within our industry. To achieve this, we have included a dedicated" approach within their strategy.

The excerpt indicates that the company has developed a Circular Economy Strategy (CES) and references circularity considerations within their Environmental Policy, but does not provide detailed policy disclosure under ESRS E5-1.

Environmental Policy

• Scope: The excerpt mentions that circularity practices are included "within our Environmental Policy" but does not specify the full scope.
• Key content: The CES "aims to further integrate circular economy into our environmental strategy and consider circularity principles throughout the Group's operations and product development processes. The CES aims to achieve this by outlining our approach to managing, preventing and..."
• Stakeholder engagement: As part of the DMA process, key internal and external stakeholder groups including regulatory bodies, shareholders, customers, employees, industry associations and community organisations were consulted through surveys and interviews. Their feedback has been considered in the CES, along with circularity principles.
• Links to international standards: The excerpt references the World Economic Forum Centre for Nature and Climate in relation to the circular economy approach.

Circular Economy Strategy (CES)

• Key content: The strategy aims to integrate circular economy into environmental strategy and consider circularity principles throughout operations and product development. It outlines the approach to managing and preventing resource-related impacts.
• Implementation: Circular economy is considered as part of the sustainability focused innovation strategy during the development of new products. A sustainable design review process has been incorporated into the product development stage gate process including considerations for longevity, reusability, disassembly and recyclability.

The disclosure does not provide complete information on formal policy names, approval and oversight bodies, public availability/URLs, or monitoring mechanisms as typically expected under ESRS E5-1.

Actions and resources related to circular economy

Kingspan's strategic actions related to resource use and the circular economy are underpinned by the LIFECycle Product Circularity Framework, which is aligned with internationally recognised principles. Actions are designed to help address material impacts, risks and opportunities identified through the Double Materiality Assessment (DMA).

LIFECycle Product Framework Actions

The company has structured its circular economy actions around themes within the LIFECycle Product Framework:

1. Innovation: Decarbonisation of product portfolio

• Description: Refining existing products with lower carbon and increased recycled content alternatives and exploring new bio-based materials and solutions
• Examples: QuadCore LEC® insulated panel, RMG600+ and Tate Grid+ LEC
• Scope: Own operations (product development)
• Time horizon: Not specified
• Resources: Not quantified
• Link to targets: Supports the 1.5 million tonnes recycled and renewable materials target

2. LIFECycle Product Framework - Cycling

• Description: Developing a range of options to help keep materials and products that reach the end of their service life circulating within the economy
• Approach: Partnerships and deployment of in-house mechanical and chemical recycling facilities
• Examples:
  • Winterswijk's glycolysis plant
  • Derbigum's No Roof to Waste Scheme
• Scope: Own operations and downstream value chain
• Time horizon: Not specified
• Resources: Not quantified
• Link to targets: Aligned with product takeback and recycling schemes target

3. Supplier engagement programme

• Description: Increasing the procurement of lower embodied carbon and high recycled content raw materials
• Scope: Upstream value chain
• Time horizon: 5 year target period (starting 2025)
• Resources: Not quantified
• Expected outcomes: Progress towards 1.5 million tonnes recycled and renewable materials target by 2030
• Link to targets: Directly supports Target 1 - 1.5 million tonnes recycled and renewable raw materials used annually

4. Repurpose and recycling partnerships

• Description: Repurposing and recycling materials from manufacturing processes into other products through established partnerships with other industry stakeholders
• Scope: Own operations and value chain
• Time horizon: Not specified
• Resources: Not quantified
• Link to targets: Contributes towards mitigating resource depletion by consuming secondary recycled raw materials

Circular Economy Section (CES)

A dedicated Circular Economy Section (CES) within the Environmental Policy has been established, informed by:

• Key internal and external stakeholder consultations (regulatory bodies, shareholders, customers, employees, industry associations, community organisations) through surveys and interviews
• Circularity principles outlined in the UN Environment programme and World Economic Forum Centre for Nature and Climate

Objectives of the CES:

• Further integrate circular economy into environmental strategy
• Consider circularity principles throughout the Group's operations and product development processes
• Manage, prevent and reduce circular economy-related impacts

Monitoring and Data Collection

• Data is collected at site level and reported through Group wide sustainability reporting software platform
• Product takeback and recycling schemes target has been set based on an assessment of material flows and product families

Targets related to circular economy

Kingspan has set circular economy targets built on the recommendations from their Double Materiality Assessment (DMA) and designed to help address material impacts, risks and opportunities identified. The targets are aligned with their LIFECycle Product Circularity Framework.

Target 1: 1.5 million tonnes recycled and renewable raw materials used annually

Target metric: Recycled and renewable raw materials used annually

Target value: 1.5 million tonnes

Target year: 2030

Baseline year: 2025 (5 year target starting in 2025)

Baseline value: Not disclosed

Type: Absolute target

Scope: Raw materials used in the manufacture of products, including materials such as metals, chemicals, mineral fibre and bio-based materials

External validation: Not specified (internally set based on DMA recommendations)

Target context: Aim to increase use of recycled and responsibly sourced, renewable materials in material inflows. Renewable content must be procured from sources using responsible production practices, in line with Environmental Policy. Target addresses material IROs related to material inflows and aims to mitigate negative impacts on biodiversity and ecosystem degradation.

Progress monitoring: Progress will be made through supplier engagement programme, increasing procurement of lower embodied carbon and high recycled content raw materials. This is a 5 year target starting in 2025.

Linked LIFECycle themes: Input materials

Target 2: Facilitate 20 product takeback and recycling schemes

Target metric: Number of product takeback and recycling schemes

Target value: 20 schemes

Target year: 2030

Baseline year: 2025 (5 year target starting in 2025)

Baseline value: Not disclosed

Type: Absolute target (number of schemes)

Scope: Key products in key markets

External validation: Not specified (internally set based on assessment of material flows and product families)

Target context: Aim to improve end of life or end of first use options for products and materials. Target designed to manage IROs for resource outflows through solutions aiming to reduce material leakage from the economy. Provides driver for circular product design to consider use phase and end of functional life to improve durability, disassembly, repairability and recyclability.

Progress monitoring: 5 year target starting in 2025. Group is managing progress through partnerships and deployment of in-house mechanical and chemical recycling facilities (e.g., Winterswijk's glycolysis plant, Derbigum's No Roof to Waste Scheme).

Linked LIFECycle themes: Cycling (developing options to keep materials and products circulating within the economy)

ESRS E5-4 Resource Inflows

Recycled and Renewable Raw Materials Target

Kingspan has set a target to use 1.5 million tonnes of recycled and renewable raw materials annually by 2030 (starting in 2025). This target aims to increase the recycled and renewable content in raw materials used in the manufacture of products, including materials such as metals, chemicals, mineral fibre and bio-based materials.

The target supports the embedding of circular design principles and aims to increase the circular material use rate. To mitigate negative impacts on biodiversity and ecosystem degradation, renewable content must be procured from sources using responsible production practices, in line with the Group's Environmental Policy.

2024 Achievement

In 2024, Kingspan achieved its target to recycle 1 billion PET bottles annually into its manufacturing processes, one year ahead of schedule. This target contributes towards mitigating resource depletion by consuming secondary recycled raw materials.

Material Inflows Strategy

The Group's Input Materials lever of its circular economy programme was designed to help increase the use of recycled and renewable raw materials. Key initiatives include:

• Steel: Steel significantly contributes to the embodied carbon of insulated panel products. In 2021, the Group invested in Stegra (formerly H2 Green Steel), reflecting its intention to establish a long-term supply agreement to meet a share of its future steel requirements using green steel.

• Bio-based Materials: In 2023, the Group launched HemKor®, its first bio-based insulation product range largely made of hemp. In 2024, the Group acquired a controlling stake in Steico, a wood fibre insulation manufacturer, increasing the use of renewable raw materials.

• Recycled Content Products: The Group has developed multiple products with increased recycled content, including:

  • RMG600+ (80% recycled content)
  • Multichannel LEC (75% recycled content)
  • Kilon LEC Multiwall (50% recycled content)
  • QuadCore LEC® (48% recycled content)
  • Tate Grid+ LEC (61% less embodied carbon)

Data Collection

Information related to the procurement of key raw materials is collated monthly at group level. The total weight of technical and biological raw material disclosure is based on a variety of data sources. The Group's disclosure is informed by third-party verified Environmental Product Declarations (EPDs), available on the company website.

Supplier Engagement

The Group's supplier engagement programme covers suppliers representing over 62% of scope 3 Category 1 emissions. In 2024, the Group increased collection of supplier-specific and product-specific data, resulting in 34% of scope 3 emissions being calculated using primary data. Over 70% of scope 3 Category 1 emissions are calculated using physical emission factors rather than monetary factors.

Material Intensity Reduction

Through procurement strategies and supplier engagement, the Group has reduced the intensity of carbon in its key raw materials by 3.94% in the reporting period.

Resource outflows

Kingspan discloses several product innovations focused on recyclability, recycled content, and lower embodied carbon:

Recycled Content:

• Derbicoat® NT (base sheet): 30% recycled content
• Kilon LEC Multiwall: 50% recycled content
• QuadCore LEC®: 48% recycled content (100mm panel)
• RMG600+: 80% recycled content
• Multichannel LEC: 75% recycled content

Bio-based Content:

• HemKor®: 80% bio-based content
• Wood Fibre Insulation: 80%+ bio-based content

Recycling & Circularity:

• In 2024, Kingspan recycled 1.1 billion waste plastic bottles into manufacturing processes
• The Group has commissioned glycolysis processes in Spain and the Netherlands to convert waste insulation back into polyol raw material for new insulation products
• 12 sites producing QuadCore® products utilizing recycled PET (target achieved in 2024)
• Target to facilitate 20 product takeback and recycling schemes by 2030
• An insulated panel take-back processing plant was approved for development at Joris Ide in Belgium
• In Brazil, a new product called EcoPIR was developed using remanufactured production waste from scrap PIR insulated panels, rolled out in three Brazilian sites

Product Durability:

• Insulation systems sold in 2024 are estimated to save 755m MWh of energy and 172 million tonnes of CO2e over their lifetime (assuming 60-year product life)
• Rainwater harvesting systems have a 20-year product life assumption
• Daylighting systems create 3.8 billion lumens of natural light annually

Design for Circularity:

• Lower Embodied Carbon (LEC) product development is central to innovation strategy
• In 2024, 12 new LEC products were brought to market, including AST LEC insulated panel, Kingframe LEC, Multichannel LEC, Tate Grid+ LEC, Tate Containment LEC, and KILON LEC Multiwall
• LEC products show reduced embodied carbon across lifecycle modules A-C:
  • Kilon LEC Multiwall: 36% less embodied carbon
  • QuadCore LEC®: 16% less embodied carbon
  • RMG600+: 57% less embodied carbon
  • Multichannel LEC: 63% less embodied carbon
  • Tate Grid+ LEC: 61% less embodied carbon

Planet Passionate Programme Targets:

• Recycle 1 billion PET bottles into manufacturing processes annually by 2025 (achieved: 1,102 million bottles in 2024)
• 1.5 million tonnes of recycled and renewable raw material use annually by 2030
• Target to have QuadCore® products utilising recycled PET at all sites (achieved 12 sites in 2024)

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

Phase-in exemption applied

Kingspan has applied the transition exemption for E5-6 Anticipated financial effects from material resource use and circular economy-related risks and opportunities. No quantified anticipated financial effects are disclosed for the reporting period.

Waste

Waste Performance 2024:

Kingspan's Planet Passionate programme includes a target of zero company waste to landfill by 2030. In 2024:

• The Group completed 24 landfill diversion projects resulting in over 2,140 tonnes of waste being diverted from landfill
• 69% of waste was recycled in 2024
• Waste to landfill (whole business): 12,536 tonnes in 2024, compared to 7,088 tonnes in 2023 (underlying business: 18,622 tonnes in 2020 baseline, 7,088 tonnes in 2024)

Waste Management Approach:

The Circularity pillar of Kingspan's Planet Passionate programme focuses on delivering solutions that support the transition to a circular economy within the construction sector.

Key waste reduction and recycling initiatives:

• EcoPIR Product (Brazil): A new product developed using remanufactured production waste from scrap PIR insulated panels, rolled out in three Brazilian sites in 2024

• Polycarbonate Recycling (Ireland): The Daylight Centre of Excellence facility in Kingscourt, Co. Cavan installed a compounder recycling facility with capacity to recycle up to 2,000 tonnes per year of polycarbonate, producing key raw materials for daylighting products

• Glycolysis Processes: Two glycolysis processes are operational in Spain and the Netherlands, converting waste insulation back into polyol raw material for new insulation products. Additional plants planned at key insulation sites worldwide

• Product Take-back: Target to facilitate 20 product takeback and recycling schemes by 2030. An insulated panel take-back processing plant approved for development at Joris Ide in Belgium

• PET Bottle Recycling: In 2024, Kingspan recycled 1.1 billion waste plastic bottles (equivalent number by weight) into manufacturing processes

• Recycling Trials: Ongoing trials to investigate ways in which Kingspan production waste could be reutilised to add value while diverting waste from landfill

Planet Passionate Circularity Targets:

¹ Underlying business includes manufacturing, assembly and R&D sites within the Kingspan Group in 2020 and all organic growth to date. ² Whole business includes manufacturing, assembly and R&D sites within the Kingspan Group, excluding acquisitions made after 30 September 2024 and three minor sites acquired in 2023. ³ Restated figures due to improved data collection, change in calculation methodologies and site disposal. ⁴ Updated target: 1.5 million tonnes of recycled and renewable raw material use annually by 2030 replaces the 1 billion PET bottles target.

The waste to landfill target achieved 100% of 2024 milestone, with actual landfill waste (7,088 tonnes) below the 2024 target (11,173 tonnes).

Policies related to own workforce

Our people

Our people are the cornerstone of our success. Their resilience, creativity and dedication have been instrumental in driving our achievements in 2024. We are committed to fostering a culture of inclusivity, innovation and excellence, and we continue to invest in their development and wellbeing through initiatives such as our People Passionate programme.

Our Culture and Values

Kingspan has grown from a family business and many of the values associated with family businesses form the backbone of our culture today. The business has been built on trust in the integrity of our people and of our offering. We value this trust and recognise it as being fundamental to our ongoing success. We are entrepreneurial, collaborative, honest, and we stand behind a common cause – better buildings for a better world.

We are innovative. We are the market leader in the field of high-performance building envelope solutions, which ensure lifetime carbon and resource savings. We have gained this position through a creative and solutions driven mindset, which continues to inform our innovation agenda today.

We think long-term. The strategy of the business is driven by long-term ambitions and not by quarterly performance. The success of this strategy can be seen in our long-term growth. This ethos is apparent in our multi-year commitments such as our Planet Passionate programme which will drive real, positive impact for the environment and forms a common global goal across the business.

In 2023, we launched our People Passionate programme which focuses on the development and retention of our most important resource, our people.

Code of Conduct

Kingspan expects the highest standards of integrity, honesty and compliance with laws and regulations from our employees, our directors and our partners, globally. We actively encourage our employees to speak out if they experience instances that are not in keeping with the principles outlined in our Code of Conduct.

All new joiners in Kingspan must complete training on our Code of Conduct. Our business success is linked to our behaviours, and our aspiration is to maintain a culture where our everyday actions are built on five core principles:

• Clear, ethical and honest behaviours and communications;
• Compliance with the law;
• Respect for the safety and wellbeing of colleagues;
• Protection of our Group assets; and
• Upholding our commitment to a more sustainable future.

Taking action on material impacts on own workforce

The Group has developed a framework to address workforce engagement, wellbeing, career development, health and safety, and ethical labour practices. These initiatives are guided by senior leadership to ensure that the Group continues to foster a positive and supportive workplace environment.

The Group identifies appropriate actions through a combination of employee feedback and regular risk assessments. These processes allow the Group to proactively address potential risks and capitalise on opportunities for workforce development and wellbeing.

Resources allocated: Examples of dedicated resources include, but are not limited to:

• Dedicated human resources teams
• Digital learning platforms
• Employee feedback tools such as pulse surveys
• Leadership and management development programmes aligned to the Group's Business drivers

People Passionate Programme

The People Passionate programme, endorsed by the Group CEO, is the Group's global initiative, launched in 2023, focused on enhancing employee engagement, career development and wellbeing.

Phase 1 (2024-2026): Communicated to the Group in 2023. This programme builds on the Group's past successes while identifying areas for improvement.

Scope: Aligned with the Group's strategy and material IROs related to own workforce. Multi-year initiative addressing critical workforce priorities.

Focus areas:

• Performance
• Learning and career development
• Health and safety
• Ethical labour practices

Governance: Managed through a Global Steering Group representing all divisions, established in 2023 to contribute to the design and implementation of this global programme. Key metrics such as retention rates are reviewed regularly to ensure alignment with business objectives.

Phase 2 (2027-2029): Will be informed by a comprehensive employee feedback exercise planned for 2026. This complements current feedback mechanisms, including employee surveys and regular management evaluations and reinforces a continuous feedback loop, ensuring that the relevant people policies and initiatives remain responsive to material IROs related to own workforce.

Tracking effectiveness: The Group tracks the effectiveness of its policies through qualitative assessments such as surveys, feedback and management reviews. While specific quantitative targets and a base year have not yet been adopted, insights gathered during Phase 1 will guide the development of measurable targets and baselines in future phases.

Learning and Development Programmes

The Group offers a range of learning and development initiatives designed to support talent progression, upskilling and leadership development.

Programmes include:

Resources: Examples of dedicated resources include, but are not limited to, learning and development teams, digital learning platforms, mentorship programmes and financial support for further education.

Tracking effectiveness: The Group tracks the effectiveness internally through KPIs such as improving employee engagement scores. Tracking these metrics allows the Group to assess the success of its initiatives and make informed adjustments as needed.

Occupational Health and Safety

The Group takes a proactive approach to occupational health and safety, implementing the ISO 45001 standard across manufacturing facilities.

Framework includes:

• Regular training
• Internal audits
• Prompt corrective actions when non-compliance is identified

Resources: Dedicated divisional health and safety professionals.

Tracking progress: The Group continuously tracks progress on ISO 45001 certification through internal KPIs, including:

• Monthly reports
• Best practice league tables (provided by the Group Health and Safety Auditor)

These help to ensure continuous improvement, accountability and alignment with the ISO 45001 standard. Health and safety is prioritised at every level of the organisation, with management and employees actively promoting a stronger culture of safety through collaboration and the sharing of best practices.

Resources: Examples of dedicated resources include, but are not limited to, health and safety personnel, comprehensive training programmes, provision of safety equipment and investments in new safety technologies.

Human Rights Policies and Due Diligence

The Group has developed a Human Rights Policy and Human Rights Charter which includes an insight into the ongoing development of due diligence processes that promote and safeguard ethical labour practices across operations.

Objective: This policy is designed to:

• Mitigate human rights violations where possible, such as modern slavery and human trafficking
• Promote ethical standards throughout the workforce

Reporting mechanisms: The Group provides employees with anonymous reporting channels through the confidential independent hotline, allowing concerns about ethical or human rights violations to be raised and addressed confidentially. All reported cases are investigated and findings are shared with the Audit & Compliance Committee. This approach ensures that the Group maintains high ethical standards while mitigating the risks associated with human rights breaches.

Climate Change Section (CCS) within Environmental Policy

The Group has developed a Climate Change Section (CCS) within its Environmental Policy to manage, prevent, mitigate and remediate actual and potential impacts, to address risks and to pursue opportunities related to both climate change mitigation and adaptation.

Policy approval: The Policy was approved in December 2024 and communicated to responsible parties.

Scope: The CCS's provisions relate to all climate-related material IROs and it covers:

• Own operations
• Upstream stage of the value chain (these two were the stages with material IROs)

Focus areas: The CCS addresses:

• Climate change mitigation
• Climate change adaptation
• Energy efficiency
• Renewable energy generation

Alignment: Via the policy, the Group highlights that its commitment is aligned with the Paris Agreement. When setting the policy, the Group considered the views and expectations of key stakeholders as part of the DMA process.

Responsibility: The divisional managing directors (MDs) are responsible for the implementation of the CCS.

Monitoring: Monitoring of the CCS is performed as part of the Planet Passionate programme, which includes targets.

Training: A training programme is in development, which will be rolled out to relevant stakeholders throughout 2025.

SHREDD Policy

In 2024, the Group developed a SHREDD Policy which outlines the Group's supplier due diligence process. Through this process, the Group aims to reduce environmental impacts by collaboration with critical suppliers of key raw materials and holding them accountable to the Group's environmental standards.

Targets related to own workforce

Kingspan's disclosure on S1-5 does not include specific quantified targets with baseline years, target years, or measurable values. Instead, the company describes a programmatic approach:

People Passionate Programme

The Group's People Passionate programme is aligned with the Group's strategy and material IROs related to own workforce. The programme is a multi-year initiative which aims to address critical workforce priorities:

• Phase 1 (2024-2026): Focusing on:

  • Performance
  • Learning and career development
  • Health and safety
  • Ethical labour practices

• Phase 2 (2027-2029): Will be informed by a comprehensive employee feedback exercise planned for 2026. This complements current feedback mechanisms, including employee surveys and regular management evaluations and reinforces a continuous feedback loop, ensuring that the relevant people policies and initiatives remain responsive to material IROs related to own workforce.

Measurement approach

The Group tracks the effectiveness of its policies through qualitative assessments such as surveys, feedback and management reviews.

While specific quantitative targets and a base year have not yet been adopted, insights gathered during this phase will guide the development of measurable targets and baselines in future phases. This phased approach ensures the programme evolves to meet workforce needs while remaining aligned with the Group's strategy.

Internal tracking

The Group's divisions track metrics internally, such as improving employee engagement scores. Tracking these metrics allows the Group to assess the success of its initiatives and make informed adjustments as needed.

Characteristics of the undertaking's employees

Total headcount and FTE

The total headcount for the Group and the headcount of countries with greater than 10% of the total headcount are reported in section S1-6 of the Statement.

Headcount by region

For total revenue breakdown by the Group's operating segments please refer to Note 2 of the Financial Statements.

Commentary on employee characteristics

The Group's operations span 273 manufacturing sites globally. The total headcount for the Group is referenced in multiple sections:

• The report notes that "our people are the cornerstone of our success" and discusses the People Passionate programme as part of employee development and wellbeing initiatives.

• The Group has expanded significantly since 2020, with this expansion (both organic growth and acquisitions) contributing to increased operations.

• Employee-related metrics are incorporated within the Group's broader sustainability framework, including health and safety certifications (122 manufacturing sites accredited to ISO 45001) and training programmes.

Limitations

The excerpts provided do not contain detailed quantitative breakdowns of:

• Total headcount numbers (current period and prior year)
• Full-time equivalent (FTE) counts
• Headcount by gender (male/female/other/not disclosed)
• Headcount by specific country or region with numerical values
• Headcount by employment contract type (permanent/temporary/non-guaranteed hours)
• Headcount by employment type (full-time/part-time)
• Employee turnover rate or number of employees who left
• New hires (number or rate)

While the report references that "The total headcount for the Group and the headcount of countries with greater than 10% of the total headcount are reported in section S1-6 of the Statement," the actual numerical data tables are not included in the provided excerpts.

Characteristics of non-employees in the undertaking's own workforce

Disclosure Status

Kingspan has applied the one-year transition exemption for ESRS S1-7. Non-employee workers such as agency staff and sub-contractors are excluded from the scope of the S1 disclosures for the 2024 reporting period.

Scope Definition

As stated in the CSRD Sustainability Statement:

"The scope of this section includes only employees with direct employment contracts, encompassing full-time, part-time and temporary staff across various roles and functions. In accordance with the one year transition exemption, non-employee workers, such as agency staff and sub-contractors, are excluded from the scope of this section."

Definitions Applied

• Agency workers: Individuals employed by an agency that has been hired to supply staff for specific tasks over a short period, without placing the individual on a short-term employment contract with the Group.
• Sub-contractors: Employed by third parties and hired to perform specific tasks, either for a fixed price or a daily rate, but are not on short-term employment contracts with the Group.

Health and Safety Data Collection

While non-employees are excluded from S1-7 metrics, the Group does track health and safety data for non-employee workers:

"Our total number of work-related accidents includes Group employees with a contract of employment, as well as agency workers and sub-contractors."

Health and safety metrics for non-employees are included in the S1-14 disclosure but are not broken down separately by worker type.

Planned Actions

The Group is expected to include non-employee worker disclosures in future reporting periods following the expiration of the transition exemption in 2025.

Collective bargaining coverage and social dialogue

Coverage metrics

In 2024, 71% of the Group's total employees within the European Economic Area (EEA) were covered by collective bargaining agreements. This figure excludes employees in non-EEA countries, in line with the one-year transition exemption for non-EEA data collection.

Collective bargaining and social dialogue coverage by country

For countries representing at least 10% of total employees:

European Works Council

In 2022, Kingspan's first European Works Council (EWC) was established providing a platform to engage with employees at a European level on the strategy and development of the business, as well as employment, investments and its transnational issues.

The EWC met in person for its second plenary meeting at the Kingspan Unidek site in the Netherlands in November 2024. Eighteen representatives participated in a varied agenda that included business and financial updates and presentations on the wider business strategy. The meetings covered Health & Safety matters and updates on People Passionate and Planet Passionate programmes. Senior management attended along with Linda Hickey, the Workforce Engagement Director. These meetings have been constructive with a very high level of engagement from the national employee representatives.

Works councils and employee representatives

There is positive interaction with employee representatives and works councils at the local level. Internal communications are supported by a network of communication champions across each division.

Methodology notes

The number refers to employees at 31 December 2024 and includes estimates for acquisitions completed in 2024. Non-EEA data is excluded under transition exemption provisions.

Diversity metrics

Gender composition of total workforce (2024)

Gender composition of top management (2024)

Note: Top management is defined as senior leadership roles reporting directly to the CEO and two levels below the CEO. This includes divisional MDs and their direct reports.

Age band distribution of total workforce (2024)

Board gender composition (2024)

The Board currently comprises seven male and four female directors (including the Senior Independent Director) with female directors representing 36% of the Board. The Company continues to make progress towards meeting the Board's Diversity Policy target of 40% female representation, along with its broader gender and international diversity objectives.

Senior leadership pipeline (2024)

• 31% of senior leadership roles reporting directly to the CEO are held by females
• 20% of attendees on Kingspan's senior management development programme were female
• 44% of attendees on graduate development programmes were female

Methodology notes

Employee metrics encompass all businesses controlled by the Group as of the end of 2023, with additional estimates reflecting acquisitions made in 2024. This encompasses employees with direct employment contracts, including full-time, part-time and temporary staff. Employee numbers are expressed as headcount. The Group's current methodology does not support a breakdown of employee numbers by gender at the country level. Includes estimates for acquisitions completed in 2024.

Adequate wages

Benchmark used

Kingspan defines an adequate wage using national minimum wage in each jurisdiction, as specified by national legislation or collective agreements. The company does not apply a living wage benchmark.

Policy statement

"All employees across the Group are paid an adequate wage, in line with applicable benchmarks. For the purpose of defining an adequate wage, we use the national minimum wage in each jurisdiction, as specified by national legislation or collective agreements."

Methodology

"The adequate wage indicator is calculated by comparing the wages of employees earning the lowest wage (basic wage plus fixed additional payments) with market data on the minimum wage in the respective area."

Commitment

"The Group is committed to ensuring that all employees receive at least the legal minimum wage in every country where we operate. As outlined in our People and Organisation Policy, the Group provides fair compensation for work performed, including overtime, in accordance with local laws, individual contracts, or union agreements. We regularly monitor local wage standards to maintain full compliance with applicable laws and regulations."

Rationale

"In alignment with our Human Rights Policy, this approach to assessing and maintaining adequate wages helps to mitigate potential salient human rights risks related to wages and benefits. By ensuring that all employees are fairly compensated for their work, the Group reduces the risk of economic exploitation, poverty-level wages and inequitable treatment across its global operations. Beyond meeting legal requirements, we actively assess our global compensation packages to ensure they remain competitive and aligned with market benchmarks."

Coverage and geographic scope

No specific percentage coverage or geographic exclusions disclosed. The statement refers to "all employees across the Group" and "every country where we operate" on a global basis.

Targets

No forward-looking targets or commitments to transition to living wage benchmarks disclosed.

Social protection

Kingspan has applied the transition exemption for ESRS S1-11 (Social protection) in its first year of CSRD reporting.

According to the ESRS index table on page 241, S1-11 Social protection is listed with "Transition exemption" and no page reference is provided.

Pension provision disclosure

While full S1-11 metrics are not disclosed, the following information on retirement benefits is available in the remuneration and financial statements:

Retirement benefit provision:

• The primary method of pension provision for current employees is by way of defined contribution arrangements
• The Group has three legacy defined benefit schemes in the UK which are closed to new members and to future accrual
• Total pension contributions to UK defined benefit schemes for the year: €nil (2023: €0.8m)
• Expected contributions for 2025: €nil
• Smaller defined benefit pension liabilities exist in Mainland Europe
• Net pension liability in respect of all defined benefit schemes: €37.5m at 31 December 2024 (2023: €37.0m)

Executive director pensions (from remuneration policy):

• Kingspan operates a defined contribution pension scheme for executive directors
• Pension contributions are calculated on base salary only
• Incumbent executive director pensions will be reduced to 10% of salary from 2025
• Newly appointed executive director pensions will be capped at the rate generally applicable in the relevant market
• Alternatively, Kingspan may pay a cash amount subject to all applicable employee and employer payroll taxes and social security

Persons with disabilities

Kingspan has applied the transition exemption for ESRS S1-12 (Persons with disabilities metrics) in the 2024 reporting year.

No metrics on the percentage of employees with disabilities are disclosed for 2024.

Health and safety metrics

Kingspan discloses health and safety metrics for its own workforce, with a primary focus on manufacturing site employees. The metrics cover 2024 performance.

Coverage of health and safety management system

84% of the workforce is covered by the health and safety management system. This figure pertains exclusively to employees in manufacturing sites, as these are the primary focus of the Group's health and safety management system. 122 of Kingspan's manufacturing sites are accredited to ISO 45001, an internationally recognised framework for managing occupational health and safety risks.

Health and safety performance metrics (2024)

Notes:

1. The percentage of workforce covered by the health and safety management system pertains exclusively to employees in manufacturing sites, as these are the primary focus of the system.
2. Fatalities refer to the number of employees who lost their lives due to work-related injuries or ill health.
3. Injuries that result in more than one day away from work.
4. Assumes 8-hour workday and 225 workdays per year.

Boundary: Includes all businesses controlled by the Group as of the end of 2023, as well as any material acquisitions made in 2024.

Scope of work-related accidents: The Group's total number of work-related accidents includes Group employees with a contract of employment, as well as agency workers and sub-contractors. Agency workers are defined as individuals employed by an agency that has been hired.

Fatality context: The Group is deeply saddened to report that during the year a fatal accident occurred at one of its recently acquired Steico facilities. Training has been undertaken and policies updated to incorporate learnings from this tragic incident and to strengthen the commitment to health and safety.

Days lost to work-related injuries

Number of days lost to work-related injuries, fatalities and work-related ill health is not disclosed for 2024.

Compensation metrics

Pay gap

The gender pay gap as of 2024 is 3.75%.

This represents the difference between the average gross hourly pay of male and female employees, expressed as a percentage of the average male gross hourly pay. Average gross hourly pay represents total remuneration.

Remuneration ratio

The total remuneration ratio for 2024 is 121:1.

This represents the ratio of the highest paid individual's remuneration to the median total remuneration of all employees. Total remuneration includes base salary, bonus, cash benefits, non-cash benefits and long-term incentives (i.e. share options).

Methodology

Reporting period: The metrics are based on the period from November 2023 to October 2024. As this differs from the financial reporting period timeline, the figures should be considered an estimate.

Gender pay gap calculation: The calculation adheres to ESRS standards and detailed guidance to ensure compliance and accuracy. The Group leverages data obtained in calculating total remuneration to assess the average gross hourly pay levels of male and female employees. The gender pay gap shows the pay gap between men and women without adjusting for other factors impacting pay levels (e.g. career level and work experience).

Remuneration ratio scope: Covers all employees excluding the highest-paid individual.

Total remuneration data: Collected at the global divisional level using a standardised template that includes base salary, bonuses paid during the relevant period, benefits-in-kind, and the total fair value of all annual long-term incentives per employee.

Incidents, complaints and severe human rights impacts

The information presented below has been gathered using the methodologies specified in sections S1-6 and G1-1 of this report. Section S1-6 details the process for collecting complaints raised through local channels, such as reporting directly to a line manager. In contrast, section G1-1 outlines the procedure for handling complaints submitted via EthicsPoint, the Group's confidential and independent hotline.

The Group is committed to creating an open working environment where employees feel comfortable reporting issues directly to their line manager. However, in exceptional cases where an employee is uncomfortable or unable to do so, concerns can be reported to Group legal teams or through EthicsPoint, the Group's anonymous and independently managed hotline. Whilst all complaints are fully investigated not all are substantiated.

Metrics

¹ Including complaints filed through EthicsPoint.

² Excluding incidents of discrimination, including harassment.

³ Includes estimates for acquisitions completed in 2024.

Note: The metrics are based on the period from November 2023 to October 2024. As this differs from our financial reporting period timeline, the figures should be considered an estimate.

Policies related to value chain workers

Kingspan has developed several policies that apply to value chain workers, covering ethical practices, human rights, and environmental responsibility. The divisional Managing Directors (MDs) take ultimate responsibility for the implementation of these policies.

Code of Conduct

• Scope: All directors, officers and employees across the Group
• Governance: Board of Directors (approval); publicly available on the Group website
• Key content: Sets out fundamental principles for meeting ethical standards, business integrity, and compliance expectations
• Alignment with international standards: Aligned with ILO conventions and UN principles
• Public availability: https://www.kingspangroup.com/en/about/policies/

Supplier Policy (also referred to as Supplier Code of Conduct)

• Scope: All Group suppliers and contractors globally
• Governance: Board of Directors (approval); divisional MDs responsible for implementation
• Key content: Sets expectations of suppliers in terms of:
  • Business Integrity
  • Ethical Employment Practices
  • Anti-Bribery and Corruption
  • Environmental practices
• Key principles: Promotes long-term relationships with suppliers aligned to Group goals and standards; reserves the right to terminate supplier relationships if standards are not upheld
• Public availability: Available on Group website: https://www.kingspangroup.com/en/about/policies/
• Monitoring: ESG performance monitoring of upstream suppliers using ESG rating tools such as EcoVadis; supplier audits and corrective action plans

Supplier Human Rights, Environmental Due Diligence Policy (SHREDD Policy)

• Scope: Applies to the Group, its subsidiaries, joint ventures, directors, procurement teams and their key raw material suppliers
• Governance: Board of Directors (approval); divisional MDs responsible for implementation
• Key content: Establishes a due diligence process to identify, prioritise and mitigate risks related to human rights violations and environmental impacts across the supply chain. Built on three phases:
  1. Identification: Suppliers assessed based on inherent risk factors
  2. Prioritisation: Suppliers categorised by risk level (low, medium, high)
  3. Due Diligence Execution: Audits, corrective action plans and regular reviews for high-risk suppliers
• Alignment with international standards:
  • OECD Guidance for Multinational Enterprises (MNCs) on Responsible Business Conduct (RBC) (OECD, 2023)
  • UN Guiding Principles on Business and Human Rights (UNGP, 2011)
  • International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work (ILO, 1998)
• Public availability: Internal policy; developed and released across the Group in 2024
• Monitoring: Dynamic policy allowing the Group to stay abreast of current and emerging regulations; effectiveness tracked through qualitative reviews such as supplier assessments and risk evaluations; process in early phase of implementation

Human Rights Policy

• Scope: All Group businesses, subsidiaries, joint ventures and their directors, officers and employees
• Governance: Board of Directors (approval); publicly available on Group website
• Key content: Outlines commitment to upholding and promoting human rights values in all aspects of operations; addresses risks including child labour, human trafficking and anti-slavery
• Alignment with international standards: Aligned with ILO conventions and UN principles; aligned with UN Guiding Principles on Business and Human Rights
• Public availability: https://www.kingspangroup.com/en/about/policies/
• Reporting mechanisms: Various channels available for stakeholders to raise concerns, including confidential independent hotline (EthicsPoint) for both internal and external stakeholders; third parties can contact the Group directly via website

Environmental Policy

• Scope: All Group businesses wherever conducted
• Governance: Board of Directors (approval); updated in 2024
• Key content: Details commitments and approach to five key environmental topics: Climate Change, Pollution, Water, Biodiversity, and Resource Use & Circular Economy
• Expectations: Group expects the same high standards of its contractors, suppliers and other business partners
• Public availability: https://www.kingspangroup.com/en/about/policies/

Additional relevant policies

The Group has also developed the following policies that indirectly support ethical practices with value chain workers:

• Anti-Fraud, Bribery and Corruption Policy
• Competition Law Compliance Policy
• Sanctions Compliance Policy

All policies are approved by the Board of Directors and publicly available on the Group website.

Taking action on material impacts on value chain workers

Kingspan's actions related to value chain workers are primarily delivered through the SHREDD (Supplier Human Rights and Environmental Due Diligence) Policy and supplier engagement programmes targeting decarbonisation and improved environmental/social performance.

1. SHREDD Policy Implementation

Scope: Tier 1 direct suppliers (upstream value chain)

Action description: The SHREDD Policy establishes a due diligence process to identify, prioritise, and mitigate risks related to human rights violations and environmental impacts across the supply chain. The process is aligned with OECD Guidelines, UN Guiding Principles, and ILO Standards.

Key phases:

• Identification: Suppliers assessed based on inherent risk factors (raw material type, country of manufacture, spending levels, ESG performance)
• Prioritisation: Suppliers categorised by risk level (low, medium, high), determining level of due diligence required
• Due Diligence Execution: Range of mechanisms including audits, corrective action plans, and regular reviews for high-risk suppliers

Time horizon: Short to medium-term (policy developed and released across the Group in 2024)

Resources allocated:

• Subscriptions to various ESG rating platforms
• Additional personnel allocated
• Structured collaboration across divisions and functions within the global Group

Expected outcomes:

• Mitigate risks including forced labour and child labour
• Ensure ethical standards are upheld across supply chain
• Right to terminate supplier relationships for non-compliance

Linked to: Human Rights Policy, Code of Conduct, Supplier Policy

Note: Training and awareness programmes on SHREDD Policy will be provided to employees where applicable.

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2. Supplier Engagement Programme (Decarbonisation Lever)

Scope: Upstream value chain - major suppliers of key raw materials (covering over 62% of Category 1 scope 3 emissions)

Action description: Collaboration with key suppliers to reduce embodied carbon of raw materials, maintain long-term relationships, and ensure alignment with environmental objectives.

Completed actions (2024):

• Open discussions with suppliers on decarbonisation challenges and opportunities
• Request for decarbonisation roadmaps at company and product level from key raw material suppliers
• Collection of supplier-specific and product-specific data (34% of scope 3 emissions calculated using primary data in 2024)
• Implementation of new scope 3 data collection and reporting system

Planned actions:

• Continue supplier engagement to reduce embodied carbon of key raw materials
• Expand engagement programme to include additional suppliers
• Identify opportunities for collaboration

Time horizon: Ongoing (contributing to 2030 targets)

Linked to: Target #1 (20% increase in recycled and renewable content by 2030) and Target #2 (42% absolute reduction in scope 3 emissions by 2030)

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3. Data Collection and Reporting (Decarbonisation Lever)

Scope: Internal and external data collection from upstream value chain

Action description: Improvement of data collection methodologies to accurately report scope 3 GHG emissions and support strategic decision-making.

Completed actions (2024):

• Increased collection of supplier-specific and product-specific data (environmental product declarations and product carbon footprints)
• Implemented new scope 3 data collection and reporting system
• Calculated >70% of scope 3 Category 1 emissions using physical emission factors (vs. monetary)

Planned actions:

• Further development of internal data collection methodologies
• Continue collection of supplier-specific and product-specific emissions information
• Transition towards emissions calculated using physical emission factors

Time horizon: Ongoing

Linked to: Scope 3 GHG reduction targets

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4. Development of Lower Impact Products (Decarbonisation Lever)

Scope: Upstream value chain (driving demand for lower embodied carbon raw materials)

Action description: Development and expansion of lower embodied carbon (LEC) product ranges to provide market routes for products with enhanced environmental performance.

Completed actions (2024):

• Brought 19 products with improved environmental performance to market to date, including 12 LEC products launched in 2024
• Helps drive demand upstream for lower embodied carbon raw materials

Planned actions:

• Develop further decarbonisation product roadmaps
• Continue expansion of LEC product range and other products with improved environmental performance by 2030 and beyond

Time horizon: Short to long-term (ongoing through 2030 and beyond)

Resources allocated:

• The Group targets to invest approximately 1% of revenue annually in R&D and digital transformation

Linked to: Scope 3 GHG emissions reduction targets and supplier engagement strategy

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5. Reporting and Grievance Mechanisms

Scope: Upstream value chain workers

Action description: Confidential independent reporting channels for value chain workers to raise concerns about ethical or human rights violations.

Resources:

• Anonymous reporting channels outlined in Supplier Policy
• Concerns addressed through appropriate processes

Linked to: Human Rights Policy, Supplier Policy

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Effectiveness Tracking

Effectiveness is tracked through:

• Qualitative reviews: Supplier assessments and risk evaluations
• ESG performance monitoring: Key suppliers' carbon emissions performance monitored annually
• SHREDD process metrics: Progress in identifying, prioritising, and mitigating risks
• Scope 3 emissions reduction: 14% reduction in scope 3 GHG emissions achieved from 2020 base year

Note: Specific quantitative targets for SHREDD implementation have not yet been adopted as the Group is in early phase of implementation (2024), but the focus is on developing the due diligence framework.

Targets related to value chain workers

Disclosure Summary

The section S2-5 states:

"The Group is in the early phase of implementing its SHREDD process, which was developed and released across the Group in 2024. The SHREDD process is focused on mitigating risks related to human rights violations and environmental impacts across our supply chain. Specific quantitative targets have not yet been adopted, but the Group is focusing on developing its due diligence framework to identify, prioritise and mitigate risks."

Context

While the company has set science-based targets for Scope 3 emissions reduction (which includes supply chain emissions), these are disclosed under climate/environmental targets (ESRS E1), not as value chain worker-specific targets under S2-5.

The company's SHREDD (Supplier Human Rights and Environmental Due Diligence) Policy establishes a due diligence process aligned with OECD Guidelines, UN Guiding Principles and ILO Standards, but no quantitative targets for value chain workers have been set as of the reporting period.

Training and Awareness

The disclosure mentions:

"Training and awareness programmes on the SHREDD Policy will be provided to employees where applicable."

However, no specific target timeline or coverage metrics are provided.

Policies related to affected communities

Communities

Kingspan is part of the communities where we operate and we support those communities through educational, humanitarian, environmental and cultural initiatives.

As we grow our footprint, we regenerate unused manufacturing sites, increase employment opportunities and launch community projects.

Planet Passionate Communities

Via our Planet Passionate Communities programme, Kingspan supports the communities where we operate through educational, humanitarian, environmental and wellbeing initiatives. Our colleagues and local businesses provide time, insight, resource and creativity in support of diverse projects ranging from community ambulances and search and rescue, to mental health and wellbeing, to biodiversity initiatives like replanting and insect hotels, to community sports, artistic and cultural endeavours. We also seek to have a positive impact beyond our business operations, such as completion of the Puerto Cortés Hospital project in Honduras in partnership with GOAL.

Community Impact Examples

163 community projects across our footprint

Examples include:

• Colleagues in Roofing + Waterproofing donated and installed a roofing solution to Stepney City Farm which serves as an education resource for children and an animal refuge.
• Colleagues in Light, Air + Water partnered with Just a Drop to support water and sanitation initiatives in Nairobi.

Taking action on material impacts on affected communities

Kingspan states that it currently does not have a Group policy specifically addressing potential negative impacts on affected communities. Consequently, no direct action is in place to mitigate these potential impacts within the upstream value chain at this time.

The company notes:

"As outlined in section S3-1, we currently do not have a Group policy specifically addressing this potential negative impact on affected communities. Consequently, no direct action is in place to mitigate these potential impacts within our upstream value chain at this time."

Planned approach

Kingspan states it aims to develop targeted actions as part of a dynamic and evolving framework, informed by the availability of reliable data and industry best practices. However, no definitive timeline is provided.

SHREDD Process

Action name: SHREDD process (Supplier Human Rights and Environmental Due Diligence Policy)

• Description: Developed and released across the Group in 2024. Its primary objective is to proactively address, prevent and mitigate impacts on human rights, the environment and associated individuals, communities and ecosystems.
• Scope: Value chain (suppliers and affected communities)
• Time horizon: Ongoing (released 2024, continued development and roll-out)
• Link to policy: Aligns with Human Rights Policy, Code of Conduct, Supplier Policy, Corporate Citizenship Policy, Environmental Policy and SHREDD Policy
• Resources allocated: Not quantified
• Expected outcomes: Help mitigate potential negative impacts related to affected communities

Precautionary Principle

The Group applies the precautionary principle to account for potential impacts related to affected communities where evidence or data may currently be insufficient.

Current status

• No actual impacts on local communities identified
• No relevant issues or concerns identified that would be material at the Group level
• No targets deemed necessary at this time related to local communities and indigenous peoples
• Company will re-examine the setting of relevant targets in coming years as IRO and engagement processes are refined

Targets related to affected communities

Kingspan states:

We currently do not have any actual impacts on local communities. We haven't identified any relevant issues or concerns that would be material at the Group level and therefore have not deemed it necessary to set targets pertaining to local communities and indigenous peoples. As we continue to refine both our IRO process and our process of engaging with local communities, we will re-examine the setting of a relevant target in the coming years.

The company references that for targets related to the Group's SHREDD process (which addresses human rights, environment and communities), see section S2-5 Targets of the report.

No specific quantified targets related to affected communities (S3-5) are disclosed.

Policies related to consumers and end-users

Customer Benefits

Our range of solutions provide:

• Single System Warranty
• Product Quality/Integrity
• Simplified Supply Chain
• Innovation

Supporting customers' carbon ambitions and future proofing asset values

Asset values beginning to reflect energy performance of buildings:

• 72% of the top 100 office occupiers in NYC have carbon commitments
• 80% of the top 100 office occupiers in Paris have carbon commitments
• 7.1% North America average rental premium for green-certified, class A office stock across 8 major markets in the US and Canada
• 11.6% London average rental premium for green-certified, office stock
• 9.9% Asia average rental premium for green-certified, class A office stock across 9 major markets in Asia
• 4.2% JLL's study highlights that each additional 'step' of an Energy Performance Certificate (EPC) results in an average 4.2% increase in rents

Source: The commercial case for making more sustainable buildings, JLL

Taking action on material impacts on consumers

Kingspan has developed a framework to manage product quality, safety and integrity, ensuring these elements are prioritised throughout product development, testing, support and marketing. The following actions support the Group's approach to addressing impacts, risks and opportunities for consumers and end-users.

Product Safety and Compliance Initiatives

Product Compliance Framework

• Description: Comprehensive framework to manage and monitor product quality, safety and compliance across the organisation, supported by robust internal control system and overseen by the Audit & Compliance Committee
• Scope: Own operations (global manufacturing sites)
• Time horizon: Long-term (ongoing programme with annual certification targets through 2025)
• Resources allocated:
  • Non-financial:
    • 28 product lead compliance officers appointed across the business
    • Over 6,000 people trained in product compliance
    • Product compliance team
    • IKON and FERC testing facilities
  • Financial: Not quantified
• Expected outcomes/KPIs:
  • As of December 2024: 85 global sites certified to ISO 37301 standard for compliance management
  • Target: 105 sites certified by end of 2025
  • 153 manufacturing sites accredited to ISO 9001 standard for quality management
  • 123 internal audits conducted in 2024
• Policy link: Group Compliance Manual; ISO 37301 standard for compliance management

Product Compliance Register (PCR)

• Description: Centralised record of approved products, detailing applicable legal obligations and standards in their commercial markets. Marketing materials, product labels and order forms required to adhere to PCR to ensure compliance
• Scope: Own operations and downstream (commercial markets)
• Time horizon: Not specified
• Resources allocated: Not quantified
• Expected outcomes/KPIs: Tracked through regular reporting and key performance indicators (KPIs) providing oversight into impact of product compliance and integrity programme
• Policy link: Product compliance framework

Digital Solutions for Enhanced Consumer Experience

BIM & Digital Integration

• Description: Process leveraging data to create comprehensive plans and models in construction, improving customer workflows by integrating products seamlessly into projects. BIM adoption and digital project delivery being expanded across divisions to enhance project collaboration and efficiency
• Scope: Downstream (customer-facing)
• Time horizon: Long-term (ongoing expansion across divisions)
• Resources allocated: Not quantified
• Expected outcomes/KPIs:
  • Enhanced project collaboration and efficiency
  • Improved customer workflows
  • Currently utilised in UK and Ireland markets within Insulated Panels division, with plans to expand into new markets in coming years
• Policy link: Customer experience strategy

Worldwide Voice of Customer Programme

• Description: Launched in 2018 and led by Global Customer Experience Team. Initiative enables listening more closely to customers and gaining deeper understanding of their experiences across 200+ businesses and diverse brands within the Group. Programme helps identify areas for improvement, stay attuned to changing customer expectations and uncover new opportunities to innovate
• Scope: Downstream (across all customer touchpoints)
• Time horizon: Long-term (ongoing since 2018)
• Resources allocated:
  • Non-financial: Global Customer Experience Team
  • Financial: Not quantified
• Expected outcomes/KPIs:
  • Net Promoter Score (NPS) tracking for brand loyalty and customer experience measurement
  • Independent third-party validation of NPS scores and methodology
  • CEO and CFO performance goals linked to NPS (detailed in Report of the Remuneration Committee)
  • Results tracked annually to align with stakeholder expectations
  • NPS of 44 achieved (target range 42-48) contributing 42.9% of weighted bonus measure
• Policy link: Customer experience programme; executive remuneration policy

Human Rights Monitoring

Human Rights Reporting Channels

• Description: Monitoring and maintaining channels for reporting and addressing potential breaches of human rights related to consumers and end-users. To date, no cases of non-respect to principles relevant to consumers and end-users have been identified through these channels
• Scope: Own operations and value chain
• Time horizon: Ongoing
• Resources allocated: Not quantified
• Expected outcomes/KPIs: Not specified
• Policy link: Human Rights Policy (aligned with ILO conventions and UN principles)

Consumer Engagement and Feedback Mechanisms

Consumer Engagement Processes

• Description: Engagement occurs at various stages across the purchase cycle. Issues or concerns are monitored using various platforms and systems which differ between divisions and regions. Each division employs its own methods to foster improvement in addressing and resolving consumer and end-user concerns
• Scope: Downstream (consumer-facing)
• Time horizon: Ongoing
• Resources allocated: Not quantified
• Expected outcomes/KPIs:
  • Effectiveness assessed through follow-up surveys, customer satisfaction scores and regular review meetings
  • Customer insights gathered through surveys and engagement channels to refine product offerings
• Policy link: Customer engagement framework

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Note on Target Setting: While formal targets and base years are yet to be defined for some initiatives, the Group leverages existing compliance processes and customer feedback to inform future target setting and performance evaluations. Data gathered through these mechanisms may assist in development of measurable targets and a base year for tracking progress.

Targets related to consumers

Kingspan has not disclosed quantified targets for consumers and end-users under ESRS S4-5.

Disclosure Statement

The company states:

"While formal targets and base years are yet to be defined, the Group leverages existing compliance processes and customer feedback to inform future target setting and performance evaluations."

Current Tracking Mechanisms

The Group tracks effectiveness through:

• ISO 37301 certification: Progress on the number of sites achieving ISO 37301 certification is assessed annually and reported to the Audit & Compliance Committee
• Net Promoter Score (NPS): CEO and CFO performance goals are linked to NPS, with results tracked annually. Details are provided in the Report of the Remuneration Committee
• Customer insights: Gathered through surveys and engagement channels to refine product offerings and customer satisfaction initiatives
• Independent evaluations: Including NPS tracking to provide qualitative indicators of performance

The company monitors compliance processes and customer feedback to inform future target setting, but no specific quantified targets, baseline years, or target years are currently defined for consumer-related impacts.

Business conduct policies and corporate culture

Code of Conduct

Kingspan expects the highest standards of integrity, honesty and compliance with laws and regulations from our employees, our directors and our partners, globally. We actively encourage our employees to speak out if they experience instances that are not in keeping with the principles outlined in our Code of Conduct.

All new joiners in Kingspan must complete training on our Code of Conduct. Our business success is linked to our behaviours, and our aspiration is to maintain a culture where our everyday actions are built on five core principles:

• Clear, ethical and honest behaviours and communications;
• Compliance with the law;
• Respect for the safety and wellbeing of colleagues;
• Protection of our Group assets; and
• Upholding our commitment to a more sustainable future.

Our Culture and Values

Kingspan has grown from a family business and many of the values associated with family businesses form the backbone of our culture today. The business has been built on trust in the integrity of our people and of our offering. We value this trust and recognise it as being fundamental to our ongoing success. We are entrepreneurial, collaborative, honest, and we stand behind a common cause – better buildings for a better world.

We are innovative. We are the market leader in the field of high-performance building envelope solutions, which ensure lifetime carbon and resource savings. We have gained this position through a creative and solutions driven mindset, which continues to inform our innovation agenda today.

We think long-term. The strategy of the business is driven by long-term ambitions and not by quarterly performance. The success of this strategy can be seen in our long-term growth. This ethos is apparent in our multi-year commitments such as our Planet Passionate programme which will drive real, positive impact for the environment and forms a common global goal across the business.

Management of relationships with suppliers

Responsible supply chain partnerships

We operate our businesses to the highest standards and maintain responsible supply chain partnerships as part of how we operate.

Planet Passionate Supply Chain Target

¹ Underlying business excludes Steico and Nordic Waterproofing ² Whole business includes Steico and Nordic Waterproofing

Prevention and detection of corruption and bribery

Kingspan has established a comprehensive system to prevent, detect and respond to allegations or incidents of corruption and bribery.

Anti-Fraud, Bribery & Corruption Policy

Policy name: Anti-Fraud, Bribery & Corruption Policy

Scope: All businesses wherever they are located, including the Group, its subsidiaries, joint ventures and their directors, officers and employees.

Governance and oversight:

• Ultimate responsibility held by divisional Managing Directors (MDs)
• Board oversight
• Audit & Compliance Committee oversight
• Internal Audit & Compliance team oversees investigations
• Divisional MDs responsible for delivering training

Key content and principles:

• Zero tolerance approach to bribery and corruption
• Mandates that all incidents or suspicions are promptly investigated
• Appropriate recovery and disciplinary actions taken for violations
• Failure to comply may result in disciplinary action, up to and including dismissal or prosecution
• IT users identified as being at the highest risk for corruption and bribery
• Comprehensive system including fraud risk assessments, third-party due diligence, continuous communication and training
• Establishes prevention, detection and response framework with clear ownership and measures

Public availability: The Group policies can be accessed on the website: https://www.kingspangroup.com/en/about/policies/

Links to international standards: Not explicitly stated for this specific policy.

Implementation and monitoring:

• Supported by internal Group Accounting Manual (GAM), which governs financial and legal compliance
• Mandatory training for all employees delivered on a two-year cycle
• 100% of employees in identified at-risk functions received access to training during the reporting period
• Confidential independent hotline (EthicsPoint) available for anonymous reporting
• All investigations conducted independently by the Group Head of Internal Audit & Compliance and the Internal Audit & Compliance Team
• Reports and outcomes presented to the Audit & Compliance Committee
• Action plan incorporates fraud risk assessments, due diligence and mandatory anti-corruption training
• Group Legal team provides divisional teams with standardised training content
• Divisional teams monitor training rollout rates

Reporting mechanisms:

• Suspected or confirmed incidents must be promptly reported to the Group CFO, Group Head of Internal Audit & Compliance, Group Head of Legal, Group Financial Controller and Group Treasurer
• EthicsPoint hotline - confidential and anonymous reporting tool available to internal and external stakeholders
• Employees encouraged to report concerns directly to line managers, or escalate to Group Legal team or through EthicsPoint
• All fraud and cybercrime attempts reported to the Audit & Compliance Committee

Performance: During the financial year, the Group reported zero convictions for violations of anti-corruption and anti-bribery laws.

Code of Conduct

Policy name: Code of Conduct

Scope: All directors, officers and employees.

Key content and principles:

• Sets out fundamental principles which the Group requires all its directors, officers and employees to adhere to
• Includes a confidential independent hotline policy
• States that retaliation or reprisals will not be tolerated

Public availability: Publicly available on the Group's website.

Implementation and monitoring:

• Supported by EthicsPoint hotline for confidential and anonymous reporting
• Training provided through a variety of mediums in key areas of legal and regulatory compliance
• Suite of mandatory training for those that join Kingspan

Incidents of corruption or bribery

Kingspan has established a comprehensive framework to prevent, detect and respond to incidents of corruption and bribery, as outlined in its Anti-Fraud, Bribery & Corruption Policy. The Group maintains a zero-tolerance approach to fraud, bribery and corruption, supported by a confidential independent hotline for anonymous reporting and a dedicated Internal Audit & Compliance team who oversee investigations to ensure objectivity and impartiality.

Investigation and reporting procedures

Any suspected or confirmed incidents of fraud, bribery, corruption, sanctions violations, or anti-competitive behaviour must be promptly reported to the Group CFO, Group Head of Internal Audit & Compliance, Group Head of Legal, Group Financial Controller and Group Treasurer. Allegations may be addressed through the confidential independent hotline and all investigations are conducted independently by the Group Head of Internal Audit & Compliance and the Internal Audit & Compliance Team. Findings are regularly reported to the Audit & Compliance Committee to ensure accountability and oversight.

The Group's action plan incorporates measures such as fraud risk assessments, due diligence and mandatory anti-corruption training, which is delivered every two years to all employees, with particular focus on functions identified as at-risk (all IT users are considered at risk due to their access to sensitive systems and data).

Failure to comply with these policies may result in disciplinary action, up to and including dismissal or prosecution.

Confirmed incidents and convictions

During the financial year 2024, the Group reported:

During the financial year, the Group has reported zero convictions for violations of anti-corruption and anti-bribery laws.

Political influence and lobbying activities

Zero declaration

Kingspan has disclosed that neither the Company nor any of its subsidiaries have made any political donations in the year which would be required to be disclosed under the Electoral Act 1997.

Political contributions

No political donations were made in 2024 (2023: €nil).

ESRS disclosure table reference

In the ESRS content index, Kingspan has indicated that G1-5 Political influence and lobbying activities is not material to the Group.