Kitron ASA

Reference: page 18

The Board of Kitron ASA has overall responsibility for safeguarding shareholder and stakeholder interests, supervising management and overseeing implementation of policies such as the Anti-Corruption Policy and Ethical Code of Conduct. There are 8 non-executive board members, three of which are employee-elected, and 100% of shareholder-elected members are independent. The Board bears ultimate responsibility for Kitron's sustainability statement, which it discusses and approves. The Audit and Risk Committee oversees internal controls, risk management and reporting, with its mandate amended to include sustainability reporting from 2025. The Corporate Executive Management (CMT) has seven members and is responsible for strategy, compliance, oversight of impacts, risks and opportunities, and setting and reaching targets. The CFO is responsible for sustainability reporting, performance monitoring and risk management oversight. Material IROs are included in ordinary risk management and discussed at least half-yearly at CMT meetings. The sites handle day-to-day environmental work, and an Ethics Committee, chaired by the Chief HR Officer, supports anti-corruption activities.

Reference: page 21

Considerations regarding material impacts, risks and opportunities are an inherent part of Kitron's strategic reviews and decision making. In 2024, the CMT considered all material IROs in connection with the double materiality analysis. For example, investment decisions regarding production facilities take into account GHG emissions reductions and physical climate risk on a regular basis, and risk management regarding 3TG (conflict minerals) is integrated into Kitron's regular practices for managing supply chain risk. The CMT oversees the risk management process formally once a year but assesses and manages risks throughout the year in weekly CMT meetings. To date, no material trade-offs among material IROs have been identified. Further details on the risk management procedures are described in the chapter on risk management and internal controls.

Reference: page 21

Kitron's incentive schemes are updated and reviewed annually by the HR and Remuneration Committee and approved by the Board. Under the Remuneration Guidelines, Senior Executives had an annual variable pay scheme with a maximum potential of 85 percent of base salary, with stepped targets representing 0-100% of bonus achievement for EBIT, ROOC R3, Growth and ESG separately. The Corporate management Short Term Incentive has 10 percent connected to sustainability, linked to the share of renewable energy in total energy consumption of Kitron's facilities. The KPI is the percentage share of renewable energy of total scope 2 energy consumption at the sites, identified as a key GHG reduction measure addressing scope 2 emissions and scope 3 emissions related to leased facilities. The Board does not have performance-related remuneration, and there are no additional incentives directly tied to other climate-related considerations.

Reference: page 21

Kitron provides a statement of its due diligence process through a mapping table (Table 2 5) that links the core elements of due diligence to the relevant paragraphs and disclosure requirements in the sustainability statement. Embedding due diligence in governance, strategy and business model is covered by ESRS2 GOV-1, GOV-2, GOV-5 and SBM-1. Engaging with affected stakeholders in all key steps is covered by ESRS2 SBM-2 and SBM-2 in connection with S1. Identifying and assessing adverse impacts is covered by ESRS2 SBM-3 and GOV-1. Taking actions to address those adverse impacts is covered by ESRS2 E1-3. Tracking the effectiveness of these efforts and communicating is covered by ESRS2 GOV-1 and GOV-2.

Reference: page 22

The sustainability reporting process, along with the due diligence steps, is overseen by the group CFO. Outputs of relevant processes such as the stakeholder dialogue, annual risk review and data gathering on energy use and GHG emissions are monitored throughout the year. Risk assessments regarding the availability of information and data for sustainability reporting are conducted annually by the CFO together with the group quality and sustainability function and HR function. Risks are prioritized qualitatively in discussions, and mitigating actions are initiated and reviewed by the CMT if needed. During FY24, the main risks identified related to the availability of granular data on Kitron's upstream and downstream value chain, such as supplier scope 3 data, and the risk of inaccurate resource in- and outflow data due to estimation uncertainty. These findings were discussed with the CMT throughout FY24. In FY25, risk management and internal controls over sustainability reporting will be further streamlined and integrated into financial reporting processes, supported by the amended Audit Committee mandate approved on 12 February 2025.

Reference: page 22

Kitron is an Electronics Manufacturing Services (EMS) company providing services in the manufacturing, assembling and testing of electronic products for the professional market. Core areas are electronics, testing, assembly and system testing, system integration, repairs and upgrades. Total revenue for 2024 was 647.2 MEUR, and at the end of the period Kitron had 2564 employees across the Nordics, Central and Eastern Europe, North America and Asia. Kitron sorts customers into five market sectors: Connectivity, Electrification, Industry, Medical devices and Defence and Aerospace. Customers are international, predominantly Northern European, and also include China and North America. The value chain includes upstream mining and processing companies and manufacturers of components, PCBs and mechanics, Kitron's own EMS operations, and downstream customers who own the product IP and distribute to end users. The Corporate management has evaluated that the group operates in only one segment, EMS, so there is no separate segment reporting.

Reference: page 25

The views of stakeholders are taken into account in relevant processes such as strategic discussions and decision making. Members of the CMT are represented in the stakeholder dialogue, and the CMT and Board are informed about important findings, including sustainability-related impacts, as part of regular dialogue at CMT and Board meetings. Findings are discussed and, if necessary, decisions are made to mitigate impacts and risks or pursue opportunities, allowing Kitron to adapt its strategy and business model. Transitioning to green energy and adequate supplier risk management schemes are examples of how Kitron has adapted its business practices, and no further changes are currently planned. For the double materiality analysis, Kitron considered its activities across the entire value chain to identify relevant stakeholders. Key stakeholders, described in Table 2 7, include investors and banks, customers, consumers and end-users, suppliers, workers in the value chain, employees, society and affected communities, and nature as a silent stakeholder.

Reference: page 26

Table 2 8 provides an overview of Kitron's material impacts, risks and opportunities identified in the double materiality assessment. Kitron considers its business model resilient in regard to the IROs identified, and risk management practices have proven effective. Based on the resilience analysis in connection with climate risk (E1), the measures taken to reduce risks are considered adequate, and Kitron regards its policies and practices for managing the other identified risks as sufficient. Material IROs are organized under five topical standards: ESRS E1 Climate change, ESRS E5 Circular economy, ESRS S1 Own workforce, ESRS S2 Workers in the value chain, and ESRS G1 Business conduct. These cover impacts such as GHG emissions, resource outflows and waste, working conditions, conflict-affected sourcing and corruption, located across own operations, upstream and downstream. All IROs are covered by the ESRS with no entity-specific IROs, and there are no changes compared to the previous period since this is the first year of CSRD reporting.

Reference: page 27

In 2024 the double materiality analysis was carried out by the group finance and sustainability function with internal and external experts, overseen by the group CFO. The assessment followed four steps. In Understand, Kitron analysed its value chain and own operations and identified relevant stakeholders. In Identify, in-house information such as GHG emissions and work-related accident statistics, stakeholder engagement insights, assumptions for the upstream and downstream value chain, and the annual risk review were used, with the ESRS 1 AR16 topic list as a basis to identify potentially material IROs and where in the value chain they are most relevant. In Evaluate, IROs were scored on five-step scales for scale, scope, irremediability, likelihood and magnitude of financial effects, with severity taking precedence over likelihood for potential negative human rights impacts. In Decide, material IROs were determined against thresholds defined in the appendix and matched to topical disclosures using EFRAG Q&A ID 177. All metrics associated with material IROs are reported on.

Reference: page 16

Kitron discloses the disclosure requirements complied with in preparing its sustainability statement and their location in the report through a content index. The index organizes disclosures by ESRS standard and category and lists the page number for each disclosure requirement, marking those not applicable due to phase-in provisions as N/A. Based on the double materiality assessment, the material topical standards are ESRS E1 Climate change, ESRS E5 Circular economy, ESRS S1 Own workforce, ESRS S2 Workers in the value chain and ESRS G1 Business conduct. The topics ESRS E2 Pollution, ESRS E3 Water and marine resources, ESRS E4 Biodiversity and ecosystems, ESRS S3 Affected communities and ESRS S4 Consumers and end-users were assessed but not found material. For each material standard, the index sets out the ESRS 2 SBM and IRO disclosures together with the topic-specific policies, actions, targets and metrics and their page references.

Reference: page 36

Kitron states it has not yet developed a transition plan that fully aligns with CSRD requirements but is committed to implementing one no later than 30 June 2026. The resilience analysis underpinning this work was conducted in autumn 2024 and updated in February 2025 (the Board approved the climate change mitigation transition plan on 12 February 2025). The company identified both physical and transition risks across its value chain. Physical risks include facility vulnerability to extreme weather (snowstorms in Norway, Sweden and the US; forest fires in Norway; storms and typhoons in Asia) and short-term supply chain disruptions. Transition risks centre on customer expectations for sustainable operations. Resilience was assessed against two NGFS scenarios, Net Zero 2050 and Hot House World, over short- (2025), medium- (2030) and long-term (2050) horizons. Kitron considers its business model highly adaptable, not dependent on fixed locations and not reliant on external financing for climate measures.

Reference: page 38

Kitron has not yet established formal policies for climate change mitigation and adaptation. The company recognises the importance of managing climate-related risks and opportunities and is committed to developing relevant policies, aiming to have them in place by 30 June 2026 to support its sustainability efforts and long-term business resilience. Kitron has also defined an ambition to achieve 100% renewable energy usage across all its sites and uses this as a key indicator to evaluate progress, tracking the effectiveness of its renewable energy actions by monitoring Scope 1 and 2 energy consumption on a quarterly basis.

Reference: page 38

Kitron identified energy consumption for production and the heating/cooling of facilities as the largest source of Scope 1 and 2 CO2 emissions. It has implemented and planned several non-quantifiable key actions. Sourcing renewable energy: solar panels were installed at sites in Sweden and Lithuania between 2022 and 2024, which combined with guarantees of origin raised the Scope 2 market-based renewable energy share from 64.4% in 2022 to 96.2% in 2024, with an aim to reach 100% by 2025. Energy efficiency in new investments: from 2024 onwards, energy efficiency requirements are integrated into all new equipment and facility investments. Waste reduction initiatives are implemented across all sites in line with environmental certification standards and reviewed annually. Actions cover all sites globally, focusing on own operations (Scope 1 and 2) and parts of the upstream supply chain. Actions are funded through operational budgets and do not require significant external financing.

Reference: page 38

Kitron has set targets to reduce location-based GHG emissions in Scope 1 and 2 by 50% and Scope 3 emissions by 25% before 2050. Interim Scope 1 and 2 location-based reduction targets are 30% by 2030 and 50% by 2050; the Scope 3 reduction target is 15% by 2030 and 25% by 2050. The base year is 2022 for Scope 1 and 2 reduction targets and 2024 for Scope 3. The 2025 target values reflect a 10% reduction in Scope 1 and 2 and a 5% reduction in Scope 3. The market-based target is set at 100% renewable energy, planned to be reached in 2025 mainly through purchasing guarantees of origin. The targets are not science-based or proven compatible with limiting global warming to 1.5C.

Reference: page 39

Total energy consumption in 2024 was 26,313.7 MWh, based on site-specific data. Total fossil energy consumption was 4,796.4 MWh (18% of the total), comprising coal and coal products 225.8 MWh, crude oil and petroleum products 750.6 MWh, natural gas 3,425.2 MWh, and purchased electricity, heat, steam and cooling from fossil sources 394.8 MWh. Consumption from nuclear sources was 0.0 MWh. Total renewable energy consumption was 21,517.4 MWh (82% of the total), comprising purchased renewable electricity, heat, steam and cooling of 21,288.1 MWh and self-generated non-fuel renewable energy of 248.8 MWh. Energy intensity for high climate impact sectors was 0.04 MWh/KEUR, derived from total energy consumption of 26,313 MWh and net revenue of 647,150 KEUR (647.2 MEUR).

Reference: page 39

Kitron applies an operational control approach in line with the GHG Protocol. For 2024 (N): Gross Scope 1 GHG emissions were 848.4 tCO2eq (base year 2022: 841). Gross location-based Scope 2 emissions were 5,963.7 tCO2eq and gross market-based Scope 2 emissions were 369.5 tCO2eq (base year 2022). Gross Scope 3 GHG emissions were 88,624.8 tCO2eq (base year 2024), made up of purchased goods and services 77,827.6, capital goods 2,314.7, fuel and energy-related activities 1,626.6, upstream transportation and distribution 3,507.6, waste generated in operations 174.3, business travel 852.1 and employee commuting 2,321.8. Total GHG emissions were 95,436.9 tCO2eq location-based and 89,842.7 tCO2eq market-based. Scope 1 and 2 are calculated mainly from invoice data; Scope 3 uses the spend-based method (91.72%), supplier data (5.95%) and distance (2.33%).

Reference: page 42

Kitron states it has not yet adopted or implemented any policies to manage its material impacts, risks and opportunities related to resource use and circular economy in line with ESRS requirements (under ESRS 1 paragraph 33). The company recognises the importance of managing these impacts, risks and opportunities and is committed to developing respective policies. Kitron aims to have policies in place by 30 June 2026 to support its sustainability efforts and long-term business resilience. The double materiality analysis confirmed resource use may have a material negative impact in the medium term, with links to climate change, pollution, biodiversity, supply chain risk and human rights.

Reference: page 42

Kitron reports it has not yet adopted or implemented any actions and resources to manage its material impacts, risks and opportunities related to resource use and circular economy in accordance with ESRS requirements. The company recognises the importance of managing these matters and is committed to developing the relevant actions and resources, aiming to have them in place by 30 June 2026 to support its sustainability efforts and long-term business resilience. Kitron notes it can influence resource inflows through its choice of suppliers and materials and through sourcing of components, PCBs and other mechanical parts, and can reduce downstream risk through increased dialogue and knowledge sharing with customers on recyclability and repairability.

Reference: page 42

Kitron reports it has not yet adopted or implemented any targets to manage its material impacts, risks and opportunities related to resource use and circular economy in accordance with ESRS requirements (under ESRS 1 paragraph 33). The company recognises the importance of managing these impacts, risks and opportunities and is committed to developing respective targets. Kitron aims to have these targets in place by 30 June 2026 to support its sustainability efforts and long-term business resilience. No quantitative resource use or circular economy targets are stated for the reporting period.

Reference: page 43

Kitron's production inputs fall into three categories: electronic components, mechanical drawing parts, and PCBs (Printed Circuit Boards), sourced with few exceptions outside Norway. Electronic components include silicon, copper, tin, gold, silver, tungsten, lead and aluminum, sourced from close to 1407 manufacturers through approximately 1255 supply partners. Mechanical drawing parts range from metal casting and machine parts to injection molded plastic, sheet metal and aluminum die casting. PCBs are mainly composed of a substrate (fiberglass-reinforced epoxy resin, FR-4) and copper foil. Production process materials include tin for soldering, solvents to clean boards, and conformal coating. Packaging materials are pallets, carton boxes and ESD bags/bubble wrap. Use of biological materials is limited to packaging (pallets and carton boxes). Secondary reused or recycled use covers packaging only; pallets are normally reused while carton boxes and ESD bags are rarely reused. Most input materials and components do not originate from secondary sources.

Reference: page 44

Kitron is an electronics manufacturing services company producing PCBAs, modules or complete systems for customers who own the design, intellectual property and choice of materials. Core sectors are connectivity, electrification, industry, medical devices, and defence/aerospace. Most of Kitron's products end up as electronic waste (e-waste) at end-of-life. Because products combine vast amounts of minerals, metals, plastics and cables and are customer-specific, exact product composition cannot be broken down generally. Kitron does not control products' end-of-life so durability is hard to estimate. It offers maintenance, repair and refurbishment programs, in-house software and hardware redesign expertise, and component information systems (CIS) to identify replacements for obsolete components. Products are packaged in loading pallets, carton boxes and ESD bags; PCBAs are mainly delivered in ESD bags (pink antistatic, metallized shielding, moisture barrier), which are recyclable to varying degrees. Kitron has no statistics on packaging recycling after shipment to customers.

Reference: page 45

Kitron calculates waste data from reports received when delivering sorted waste to recycling plants, by factory, covering all production sites. In 2024 Kitron produced a total of 1017 tons of waste across ten manufacturing sites. Of this, 960 tons (94 percent) was non-hazardous and 57 tons (6 percent) was hazardous. Around 66 percent of waste was recycled and around 34 percent was disposed to incineration or treatment. Table 5-7 shows recycled waste of 669 tons (66 percent), incineration of 347 tons (34 percent), and treated waste of 1.4 tons (0.1 percent), with no preparation for reuse, other recovery or landfill. Kitron does not generate any radioactive waste. Waste streams include electronic waste from production scrap and inventory, hazardous waste from PCB washing machines, conformal coating, oils, cleaners and cooling liquid, plus packaging and municipal waste. Composition includes used flux, cleaning water, solvents, absorbents, plastics, metals, electronic components, paint and varnish.

Reference: page 50

Kitron's Ethical Code of Conduct is the central workforce policy, setting standards employees must follow and committing Kitron to safe, healthy workplaces, fair employment practices (with local norms, laws or collective bargaining as the basic standard), training and skills development, and elimination of discrimination on grounds such as race, nationality, gender, sexual orientation or religion. It applies to the entire workforce including Board members, permanent and temporary employees, hired staff, consultants and intermediaries. The policy aligns with the UN Universal Declaration of Human Rights, the UN Convention on the Rights of the Child and ILO Conventions, and Kitron is a UN Global Compact signatory. It explicitly addresses trafficking, forced and compulsory labour and child labour. The CEO Peter Nilsson and Board Chairman Tuomo Lahdesmaki are accountable for implementation, supported by an Ethics Committee. Employee representatives were involved in drafting. The code is publicly available, reviewed at least every other year, and monitored through annual employee surveys. Kitron has no separate accident-prevention or anti-discrimination policy beyond the code.

Reference: page 53

Kitron has not adopted a formal general approach to engaging with its own workforce, but uses several engagement forms. An annual employee survey (currently on the Eletive platform) invites all employees to give feedback, with results analysed and action plans developed. Engagement with workers' representatives varies by organisational structure and location: some sites use formal forums, others use focus groups based on survey results. The managing director at each site is responsible for coordinating communication with workers' representatives and implementing actions. Employee representatives sit on the Kitron ASA Board (eight meetings a year) and a European Workers Council discusses strategic topics affecting the workforce. In the Nordics engagement is regulated by law and agreements, with monthly or quarterly meetings. Kitron will consider and assess the need to adopt a general approach in the coming year.

Reference: page 53

Kitron is committed to providing or cooperating in remediation where it causes or contributes to a material negative impact, though no such impact was identified in the reporting year. It has established multiple channels for employees and value chain workers to raise concerns or grievances. Employees can report to their immediate superior, the superior's superior, an employee representative, the HSE manager, company health service, Finance Manager, or designated site contacts (Managing Director, HR Manager, main employee representative). They may escalate to the Chairman of the Group Ethics Committee, the CHRO, or the Chairman of the Audit Committee. A whistleblowing procedure allows anonymous or direct reporting, handled confidentially by the Ethics Committee. Awareness is built through onboarding and biennial Ethical Code of Conduct training. Statistics on cases handled by the Ethics Committee are reported annually. Retaliation against anyone raising a good-faith concern is not tolerated. Kitron has not yet formally assessed worker trust in the process or value chain workers' awareness.

Reference: page 54

Kitron has not yet implemented specific action plans or allocated dedicated resources to manage material impacts on its own workforce. It manages identified material risks and opportunities using existing resources within budget, with approaches varying across sites. No additional actions beyond existing measures are taken, planned or underway, and no material impacts requiring remedial action were identified, so there is no system to track effectiveness of such measures. Actions to address negative impacts may be defined by local management based on employee survey results, feedback in relevant forums, or input from employee representatives, with focus groups set up where needed. Survey results form the basis for initiatives delivering positive impacts. There are no specific actions planned to pursue material opportunities, and no specific measures taken to mitigate negative impacts arising from the transition to a greener, climate-neutral economy.

Reference: page 54

Kitron has set a target of zero fatalities, aligned with its commitment to employee health, safety and well-being and embedded in its Ethical Code of Conduct and health and safety policies. The target is measurable and absolute, covering the totality of Kitron's workforce. The baseline value is the current number of fatalities, which is zero, with a baseline year of 2024, the most recent reporting year, in which zero fatalities were recorded. The target applies indefinitely with the goal of maintaining zero fatalities on an ongoing basis. Given its absolute nature there are no specific interim targets. Stakeholders, including the workforce and workforce representatives, were not directly involved in setting the target or tracking performance, and have not yet been engaged in identifying lessons or improvements from performance.

Reference: page 55

Kitron reports 2,564 total employees by headcount at end of period: 1,215 male and 1,349 female, with 0 reported as other or not reported. By employment type: 2,269 permanent (1,071 male, 1,198 female), 268 temporary (125 male, 143 female), and 27 non-guaranteed hours employees (19 male, 8 female). Countries with at least 50 employees representing at least 10% of the total are Norway (534), Sweden (329), Lithuania (604) and China (459). During 2024, 646 employees left the undertaking; with an average of 2,803 employees, average turnover was 23.0%. Temporary staff reflect Kitron's customer-centred model and fluctuating demand; workforce reductions were undertaken due to lower demand in 2024 versus 2023. The workforce comprises own employees, third-party provided personnel and self-employed people, categorised as direct and indirect labour. Employee data was aggregated by local HR and consolidated at group level on a headcount, end-of-period basis.

Reference: page 56

58% of Kitron's total employees are covered by collective bargaining agreements. Sweden, Norway and Lithuania are countries with significant employment, each accounting for more than 10% of total employees, and all three have collective bargaining agreements, placing them in the 80-100% coverage bracket. For social dialogue, Norway and Sweden have 100% of employees represented by workers' representatives (80-100% bracket), while Lithuania's workplace representation falls in the 0-19% bracket. Kitron has a European Workers Council agreement.

Reference: page 56

Gender distribution at top management level (defined as the group Corporate Management Team, plus one and two levels below the CMT) is 7 people total: 6 male (85.7%) and 1 female (14.3%). Age distribution of the total workforce of 2,564: employees under 30 years old number 551 (21%), those between 30 and 50 years old number 1,352 (53%), and those over 50 years old number 661 (26%).

Reference: page 56

Kitron reports that 100% of its workers are paid an adequate wage. No workers are paid less than the minimum wage or adequate wage, meaning all workers are paid an adequate wage in line with applicable benchmarks. The minimum wage is defined as the lowest wage employers are legally obliged to pay. The lowest wage was analysed for the lowest pay category, excluding interns and apprentices, and was based on the basic wage plus any fixed additional payments guaranteed to all employees.

Reference: page 57

100% of Kitron's workforce is covered by the company's health and safety management system; all companies have either a legal requirement or ISO certification for a health and safety management system. In the reporting period there were 0 fatalities in the own workforce from work-related injuries and ill health, and 0 fatalities among other workers on the undertaking's sites. There were 7 recordable work-related accidents for the own workforce, defined as events where the employee was afterwards unable to work for one or more days. The rate of recordable work-related injuries in the own workforce is 1.34. Work-related ill health is defined per the ILO List of Occupational Diseases.

Reference: page 58

Kitron reports a gender pay gap of 39%, based on annual average pay in KEUR of 38.6 for males and 23.6 for females. The pay gap is affected by the lower number of females than men in indirect and higher positions. Average pay is calculated by site, multiplied by headcount to derive total pay per site, then summed and divided by headcount per gender for the group. Annual total remuneration for the highest paid individual is 1,181 KEUR. The estimated median annual total remuneration, based on the weighted average of site medians (median multiplied by headcount, summed and divided by total headcount), is 25.2 KEUR, giving a ratio of 1,181/25.2 = 46.9. Kitron employs a substantial number of employees in CEE and Asia, with headquarters in Scandinavia.

Reference: page 58

There was one reported incident of discrimination through the whistleblowing channel, which was investigated and followed up by a third party; the investigation found no evidence of discrimination in the filed case. Thus there were no work-related incidents of discrimination on grounds of gender, racial or ethnic origin, nationality, religion or belief, disability, age, sexual orientation or other relevant forms, including harassment, involving internal or external stakeholders during the reporting period. There were no complaints filed to the National Contact Points for OECD Multinational Enterprises. There were no fines, penalties or compensation for damages relating to discrimination, harassment or complaints, so no relevant amounts appear in the financial statements. Kitron has a system for reporting irregularities or concerns on social and human rights matters, which was consulted to compile these disclosures. There were no severe human rights issues or incidents connected to the own workforce, no cases of non-respect of UN Guiding Principles or OECD Guidelines, and no related fines, penalties or compensation.

Reference: page 60

Kitron's Supplier Code of Conduct is the main policy for value chain workers. It sets requirements for labour rights, health and safety, environmental practices and anti-corruption, including freely chosen employment, child labour avoidance, working hours, wages and benefits, humane treatment, non-discrimination and freedom of association. It applies to all suppliers and sub-contractors, who must comply with local legislation, and where local law conflicts with the code the highest standard applies. The policy supports the UN Universal Declaration of Human Rights and requires suppliers not to be complicit in human rights abuses. It addresses responsible sourcing of minerals and conflict minerals, given the significant risk of child labour and forced or compulsory labour in the mining sector flagged by the UN. Forced, bonded or prison labour is prohibited and child labour (generally under 15) is not allowed at any manufacturing stage. The code is approved by the Board of Kitron ASA, accessible online, and overseen within the CMT by the COO and Supply Chain Director. Policies are aligned with the UN Universal Declaration of Human Rights but not with the UN Guiding Principles on Business and Human Rights.

Reference: page 62

Kitron does not engage directly with value chain workers or their representatives. However, the company has established mechanisms so these workers have the opportunity to report any irregularities and concerns. Through Kitron's whistleblowing channel, value chain workers can confidentially raise issues related to their working conditions, human rights and other ethical concerns without fear of retaliation. Reports are handled thoroughly to ensure issues are addressed appropriately. The whistleblowing channel is open to both internal and external stakeholders. Because Kitron has not conducted direct stakeholder dialogue with value chain workers, no such engagement has been relayed to the Board or the Corporate Management Team.

Reference: page 62

Kitron's processes to remediate negative impacts and the channels for value chain workers to raise concerns are identical to those open to its own workforce (see S1-3). The company is committed to upholding human rights across its operations and supply chain and will disengage with any supplier found violating its human rights guidelines, providing or cooperating in remediation where appropriate. Although Kitron has not yet encountered a situation requiring remediation, it has mechanisms in place, such as its whistleblowing channel, to report and address concerns. Available channels where value chain workers can raise concerns are described online. Kitron is committed to investigating and resolving any human rights issues that may arise, ensuring a responsible and ethical business environment.

Reference: page 63

No specific action plans or resources have been allocated to address material impacts, risks and opportunities related to value chain workers, and no specific actions are planned or underway to prevent, mitigate or remediate negative impacts or to pursue opportunities. Instead, Kitron relies on its Supplier Code of Conduct. Its general approach links to supplier management: Kitron performs supplier due diligence through a three-step procedure of supplier onboarding, supplier assessment and supplier audits to identify and assess potential negative impacts. The company works on responsible sourcing of minerals and operates a Preferred Partner program. In 2024, procurement from preferred partners was 15 percent for mechanical drawing parts, 52 percent for electronic components and 52 percent for printed circuit boards. Kitron continuously tracks the source of 3TG content (tin, tantalum, tungsten and gold) in raw materials and strives to be conflict-free, requiring suppliers to exercise due diligence on source and chain of custody. No actual material impacts have been identified, and no severe human rights issues or incidents in the value chain have been brought to its attention. Effectiveness of these processes has not yet been assessed.

Reference: page 64

Kitron has not set targets related to managing material negative impacts, advancing positive impacts, or managing material risks and opportunities for value chain workers. Consequently, the company has not engaged with value chain workers, their legitimate representatives, or credible proxies on this matter. Because there are no targets, Kitron does not report associated indicators or tracking of effectiveness for value chain workers, beyond addressing irregularities or concerns brought to its attention.

Reference: page 65

Kitron has three policies to manage material impacts, risks and opportunities related to business conduct and corporate culture: the Ethical Code of Conduct, the Supplier Code of Conduct, and the Anti-Corruption Policy. The Anti-Corruption Policy sets ethical standards and legal requirements for all employees and individuals working for Kitron, covering bribery of public officials, public sector bribery and facilitation payments, the roles of the Ethical Committee and Corporate Management Team (CMT), risk analysis, monitoring, record-keeping and training. The CMT is the most senior level accountable for implementation and reports to the Board; the head of the Ethical Committee drafts reports on corruption risks. Corporate culture is developed through ethical guidelines training at onboarding in Kitron Academy, repeated every other year, a leadership program, annual performance reviews and an annual employee survey. Kitron operates a whistleblowing procedure open to internal and external stakeholders, with multiple reporting channels including directly to the Chairman of the Group Ethics Committee, the CHRO or the Chairman of the Audit Committee. Anonymous reporting is allowed and whistleblowers are protected from retaliation. The Anti-Corruption Policy has not been verified for alignment with the UN Convention against Corruption.

Reference: page 67

Kitron's general policy is that debt should be paid when due, including to SMEs. Outstanding payments are visualised and explained in the monthly report to the CMT, and late supplier payments are followed up in every financial reporting to the Board. In selecting suppliers, Kitron applies high standards and expects suppliers to adhere to applicable laws and to the ethical standards in the Ethical Code of Conduct and Supplier Code of Conduct, which is an integrated part of the commercial contract. Conflict mineral compliance is integral to the Supplier Code of Conduct, expecting suppliers to ensure tantalum, tin, tungsten and gold do not finance or benefit armed groups, and to exercise due diligence on source and chain of custody. New suppliers undergo a rigorous onboarding process including a Request for Information and supplier and manufacturer risk assessment, with conflict minerals data sheets reviewed and records kept in the ERP system. Existing suppliers are regularly assessed using a supplier scorecard and yearly risk assessment, with high-risk suppliers subject to audits and follow-up. Social and environmental criteria are taken into account in supplier selection.

Reference: page 68

Kitron has an Anti-Corruption Policy, available on its website, and regularly assesses exposure to external and internal corruption risk to reduce overall exposure. Based on this risk assessment, the head of the Ethical Committee drafts a report, with input from the business, for the CMT and the Board, describing identified corruption risks and recommendations to mitigate each one. Additional controls include follow-up of action lists, review of due diligence reports of counterparts, review of the training log, review of internal transactions, segregation of duties for outgoing payments and a two-eyes requirement for changes to supplier payment details. Potential allegations of fraud or incidents are handled by the Ethics Committee. Currently the investigators are not separate from the chain of management involved in prevention and detection, and there is no established process for reporting investigation outcomes to the CMT and Board, but Kitron is committed to improving this within two years. All employees, including management, receive periodic anti-corruption and anti-bribery training in the ethical guidelines, repeated every other year. Functions most at risk include sales, sourcing, procurement, finance and leadership. Of those in high-risk positions, 92.5 percent of 80 have completed their training.

Reference: page 68

Kitron has had no convictions or fines for violations of anti-corruption and anti-bribery laws during the reporting period. There were zero confirmed incidents. No specific action plans or resources have been allocated to address breaches in procedures related to corruption and bribery.