Kitron ASA

Governance roles

Reference: pages 20-22. Listed in Kitron's disclosure requirement index at page 20 (index, pages 18-19).

The Board of Directors has ultimate responsibility for Kitron's sustainability, and "the annual report, including Kitron's sustainability statement, is discussed and approved by the Board" (page 20). It has 8 non-executive members, three employee-elected, and "100% of the shareholder elected members are independent" (page 20). Table 2-2: non-executive Board 4 male / 4 female (50/50); corporate management team 6 male / 1 female, 85.8% male (page 21).

The Audit & Risk committee oversees internal controls, risk management and reporting; "The Board's mandate was amended in 2024 to include sustainability reporting", and material risks, impacts, due diligence and performance are reviewed half-yearly by the Board (page 20). Board responsibility for overseeing IROs "was formalized in 2025 in a Guideline for Double Materiality Assessment" (page 20).

The Corporate Management Team (CMT), 7 members, is responsible for oversight of IROs, target-setting and implementation; the CFO is responsible for group sustainability reporting (pages 20-21). An Ethics Committee chaired by the CFO meets at least three times a year and reports to the CEO and directly to the Board's Audit Committee (page 21). A 2024 competence mapping of Board and CMT is at page 22.

Information provided to and matters addressed by the administrative bodies

Reference: page 23 (index, page 18).

Kitron reports under section 2.5, "How Kitron has addressed impacts, risks and opportunities during the reporting period": "Considerations regarding material IROs are an inherent part of strategic reviews and decision-making. 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" (page 23).

Frequency is disclosed: "The CMT oversees the risk management process formally once a year but assesses and manages risks all year in the weekly CMT meetings" (page 23). Material IROs "are included in the groups' ordinary risk management and discussed at least half-yearly at CMT meetings", and the CMT "regularly monitors performance towards group targets, including our GHG emissions reductions target" by reviewing quarterly site reports (page 20). Sites report progress against sustainability targets quarterly to the group CFO (page 21).

On trade-offs, the company states plainly: "So far, no material trade-offs among material IROs have been identified" (page 23).

Sustainability performance in incentive schemes

Reference: page 23 (index, pages 18-19; listed under both ESRS 2 and E1).

Kitron's incentive schemes "are annually updated and reviewed by the HR and Remuneration Committee and approved by the Board". Senior Executives have "an annual variable pay scheme with a maximum potential of 85% percent of the base salary", with stepped targets covering "EBIT, ROOC R3, Growth and ESG separately" (page 23).

The sustainability component is quantified and climate-linked: "The Corporate management Short Term Incentive (STI) has 10 % connected to sustainability, which is linked to the share of renewable energy in the total energy consumption of Kitron's facilities. The KPI is the % share of renewable energy of total energy scope 2 consumption at the sites. This target has been identified as a key GHG reduction measure, primarily addressing scope 2 emissions, as well as Scope 3 emissions related to leased facilities" (page 23).

Two limits are disclosed: "The Board does not have performance-related remuneration, and there are no additional incentives directly tied to other climate-related considerations" (page 23). No percentage of variable remuneration linked to climate targets is given beyond the 10% sustainability weighting.

Statement on due diligence

Reference: page 23 (index, page 18).

Section 2.7 presents Table 2-4, a mapping of the core elements of due diligence to the paragraphs of the sustainability statement that cover them (page 23):

• Embedding due diligence in governance, strategy and business model - ESRS 2 GOV-1, GOV-2, GOV-5, SBM-1
• Engaging with affected stakeholders in all key steps - ESRS 2 SBM-2, SBM-2 S1, SBM-2
• Identifying and assessing adverse impacts - ESRS 2 SBM-3, GOV-1
• Taking actions to address those adverse impacts - "ESRS2 E1-3"
• Tracking the effectiveness of these efforts and communicating - ESRS 2 GOV-1, GOV-2

The mapping is thin at two points worth noting: the row on taking action cites only the climate actions DR (E1-3), and no S1, S2 or G1 action disclosure; and the tracking row points back to the two governance DRs rather than to the topical targets and metrics. Kitron does not name the OECD Guidelines or the UN Guiding Principles in this table, though the Ethical Code of Conduct is aligned with the UN Universal Declaration of Human Rights and ILO conventions (page 52).

Risk management and internal controls over sustainability reporting

Reference: page 24 (index, page 18).

"The sustainability reporting process, as well as the steps of the due diligence process described above, is overseen by the group CFO", with outputs from stakeholder dialogue, the annual risk review and data gathering monitored through the year. "Risk assessments regarding the availability of information and data for the sustainability reporting process are conducted annually by the CFO in cooperation with the group's quality and sustainability function and HR function. Risks are prioritized on a qualitative basis in discussions" (page 24).

The main reporting risks are named: "connected to the availability of granular data regarding Kitron's upstream and downstream value chain, i.e. supplier data on scope 3 emissions... Furthermore, Kitron has identified the risk for resource in- and outflow data being inaccurate due to estimation uncertainty" (page 24).

Kitron is candid about the control gap: "For the time being, no dedicated internal controls, other than the follow-up on site specific internal controls mentioned above, are applied to sustainability matters" (page 35). The Audit committee's mandate was amended to include sustainability reporting, "approved by the Board at the meeting 12 February 2025" (page 24).

Strategy, business model and value chain

Reference: pages 24-26 (index, page 18).

Kitron is an Electronics Manufacturing Services (EMS) company covering "electronics, testing, assembly and system testing, system integration, repairs and upgrades". Total revenue for 2025 is EUR 738.3 million and headcount at period end 2,830 (page 24). Customers are sorted into five market sectors: Connectivity, Electrification, Industry, Medical devices and Defence & Aerospace (page 24). Employees by region: Nordics 1,030; Central & Eastern Europe 1,113; North America 147; Asia 540 (page 24).

The value chain map (page 25) runs from upstream mining and processing of "silica, copper, gold, tantalum, and rare earth elements", through component, PCB and mechanics manufacturers, to Kitron's own EMS operations, then distributors, around 300 customers who own the product IP, and end users. Production inputs divide into electronic components, mechanical drawing parts and PCBs; Kitron purchases components "from close to 1601 manufacturers through approximately 1243 supply partners" and most PCBs from China (pages 25-26).

Fossil fuel exposure is disclosed under paragraph 40(d): "Kitron is not active in the fossil fuel (coal, oil and gas) sector... No revenue stream comes directly from coal or oil and gas", with subsea oil extraction electronics at "around 1.5%" of revenue (page 26).

Interests and views of stakeholders

Reference: pages 27-28 (index, pages 18-19; also cross-listed under S1 at page 49 and S2 at page 28).

Table 2-6 sets out each stakeholder group, the purpose of engagement and its frequency (pages 27-28): investors and banks (3-4 times a year, handled by the CFO); customers ("some as often as every week, but formal meetings more normally on a quarterly basis"); suppliers (COO, Group Sourcing director); workers in the value chain ("At present, Kitron has not engaged directly with these workers"); employees (annual employee survey, more frequent union meetings); society and affected communities ("Kitron does not have regular engagement"); and nature, described as "a silent stakeholder".

Consumers and end-users are explicitly out of scope: "Kitron does not engage with consumers and end-users directly since we manufacture products on demand and as a service for our customers, who distribute them to consumers and end-users" (page 27).

Views reach the top: CMT members participate in stakeholder dialogues and "The Board is also kept informed as part of the regular dialogue during CMT and Board meetings" (page 27). Past adaptations are named: "Transitioning to the use of green energy and implementing adequate supplier risk management schemes are examples of past adaptations... Currently, no further changes are planned or deemed necessary" (page 27).

Material impacts, risks and opportunities

Reference: pages 29-30 (index, page 18; topic-level SBM-3 also at pages 38, 44, 51, 61 and 67).

Table 2-7 (page 30) lists Kitron's material IROs by topical standard, with columns for type (I/R/O), positive or negative, actual or potential, timeframe and value chain position. Deduplicated, it holds 22 rows across five standards: E1 six (two actual negative impacts, three risks, one opportunity), E5 five, S1 five, S2 three, G1 three. The footnote states: "All IROs identified are covered in the ESRS (no entity-specific IROs)."

On resilience: "Kitron considers its business model to be resilient in regard to the IROs identified. Risk management practices have proven to be effective... Based on our resilience analysis in connection with climate risk... we consider the measures taken to reduce risks to be adequate" (page 29).

On the 2025 acquisition: "Kitron announced its acquisition of DeltaNordic AB in late 2025... The acquired business is very similar to Kitron's existing operations, and as such, no new significant IROs are expected to arise" (page 29).

Reader note: the footnote says there are no changes versus the previous period "since this is the first year of reporting under the CSRD" (page 30), which does not sit with Kitron having published an FY2024 statement.

Processes to identify and assess material IROs

Reference: pages 31-35 (index, page 18; topic-specific IRO-1 at pages 32-33 for E1, E2, E3, E4, E5 and G1).

The process is "formalized in Kitron's Guideline for Double Materiality Assessment", overseen by the Group CFO. A material limitation is disclosed up front: "In 2025, Kitron decided to roll over the outcome of the previous year's materiality assessment, based on the conclusion that no significant adjustments to the IROs were needed. This decision was approved by the Board" (page 31).

Four steps are described - Understand, Identify, Evaluate, Decide (pages 31-32). "The complete list of topics in ESRS 1 AR16 was then used as a basis to identify potentially material impacts, risks and opportunities"; company-specific topics "were considered but none was identified". Stakeholder input is not fresh: it "has been made for earlier materiality analysis" (page 31).

Scoring uses five-step scales; negative impacts score "the average of scale, scope and irremediable character... * likelihood", risks and opportunities "likelihood x magnitude" (pages 31-32). Thresholds are published in appendices 9.2 and 9.3 (pages 77-78). Material IROs were "matched according to the mapping of sustainability matters to topical disclosures published by EFRAG (Q&A ID 177)" (page 32). On enterprise risk management: "However, not all of Kitron's material IROs are covered" (page 35).

Disclosure requirements covered by the statement

Reference: pages 18-19 (the index itself), page 35, and appendices 9.1-9.3 (pages 71-78).

Kitron prints a genuine "Disclosure requirement index" at chapter 1, pages 18-19, tagged IRO-2. It is tabulated by ESRS standard, category and disclosure requirement, with a page number in the report for each. Standards covered are ESRS 2, E1, E5, S1, S2 and G1. Entries carry one of three values: a page number, "Not material" (E1-7, E1-8) or "N/A (Phase-in)" (E1-9, E5-6, S1-7, S1-11, S1-12, S1-13, S1-15). BP-2 is marked "(Reported alongside the disclosures to which they refer)". E2, E3, E4, S3, S4 and the DRs G1-5 and G1-6 do not appear in the index at all.

Section 2.17 adds: "See chapter 9.1 List of datapoints in cross-cutting and topical standards that derive from other EU legislation. MDR-P, A, M and T, as well as descriptive information on IROs as required by ESRS 2 par 46, are disclosed in connection with topical ESRS" (page 35).

Appendix 9.1 (pages 71-76) is the Appendix B table of datapoints derived from other EU legislation, each row carrying SFDR, Pillar 3, Benchmark Regulation and EU Climate Law references, a material Y/N flag and a page number.

Transition plan for climate change mitigation

Reference: page 38 (index, page 18, which lists E1-1 as covered).

Kitron discloses that it has no compliant transition plan. The whole of section 4.1 reads: "Kitron has not yet developed a transition plan that fully aligns with the requirements of the CSRD. However, we are committed to implementing such a plan no later than June 30, 2026" (page 38).

That is the complete E1-1 disclosure. None of the ESRS E1-1 content elements - decarbonisation levers with quantified contributions, locked-in emissions, CapEx and OpEx aligned to the plan, or explicit Board approval of a plan - is provided under this heading, because no plan exists to describe.

Material supporting from elsewhere in the E1 chapter: reduction targets of 50% for Scope 1 and 2 (location-based) and 25% for Scope 3 by 2050, from base years 2022 and 2024 respectively (pages 40-41); two named mitigation actions, renewable electricity sourcing and energy-efficiency requirements in new investments (page 40); and the statement that "The targets are not science- based or proved to be compatible with limiting global warming to 1.5C" (page 40). Funding is addressed only qualitatively: "Kitron's current climate-related actions are primarily funded through operational budgets and do not require significant external financing" (page 40).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 in connection with E1 (pages 32-33) and the E1 chapter (pages 38-39). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification (paragraph 15). Table 2-7 splits the E1 IROs into physical risks (extreme weather disrupting upstream supply; sites affected by "flood, forest fires or similar weather events") and a transition risk plus matching opportunity, both downstream and tied to customer expectations (page 30).

Methodology (paragraph 16). Acute hazards are "wildfires, storms, flooding, and heatwaves", with "increased precipitation patterns" the chronic risk. "To assess exposure and sensitivity to these hazards, Kitron conducts structured mapping processes in collaboration with site managers" (page 32). Findings name water hazards at Asian facilities, snow and winter storms in Norway, Sweden and the US, and wildfires in the US and Norway (page 33). Transition events were screened for "regulatory changes, market shifts, technological developments and reputational factors" (page 33).

Scenarios (paragraph 17). Two NGFS scenarios, Net Zero 2050 and Hot House World - Current Policies (pages 32-33, 39). Under Hot House World "global temperatures could rise by 3°C"; Net Zero 2050 "limits warming to 1.5°C". The analysis dates from autumn 2024, updated February 2025, and was not re-run for FY2025 (page 38).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 as presented in the E1 chapter, section 4.3 (pages 38-39). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Scope and timing. "Kitron conducted a resilience analysis in autumn 2024 in parallel with the double materiality analysis, with updates in February 2025. The analysis remains relevant, as no significant changes have occurred" (page 38). It "focused on Kitron's entire value chain" (pages 38-39).

Results (19(a)). Under Net Zero 2050, tightening regulation and "higher carbon prices" present transition risk but also opportunity "to strengthen its market position by providing low-carbon solutions". Under Hot House World, "Kitron may face more frequent and intense extreme weather events such as floods, storms, forest fires and heatwaves, potentially disrupting production sites, supply chains, and logistics" (page 39).

Capacity to adapt (19(c)). "Kitron is not dependent on fixed locations, making it possible to relocate or adapt operations as needed... Kitron does not rely on external financing to implement climate adaptation and mitigation measures" (page 39).

Uncertainty (19(b)). Addressed briefly only: "While uncertainties remain regarding future climate developments, Kitron has based its analysis on best available knowledge and scenario projections" (page 39). No quantified financial resilience testing is presented.

Policies related to climate change mitigation and adaptation

Reference: page 40 (index, page 18; section 4.4 is tagged "E1-2 | E1-4").

"In 2025, Kitron refined its existing HSE Policy into a focused Environmental Policy to comprehensively address the environmental- and climate-related IROs identified from the double materiality assessment" (page 40).

Scope and content: "The policy applies to all of Kitron's operations and aims to reduce environmental impact while maintaining high-quality electronic manufacturing services. It outlines Kitron's principles and actions to support sustainable development, reduce emissions, and promote responsible resource use across all operations. The policy mandates regular reviews of material impacts, risks and opportunities associated with climate change and the circular economy" (page 40).

Accountability and availability, the MDR-P elements: "Oversight of the policy rests with the Director of Quality and Operational Excellence, with final approval granted by the Board. The policy is communicated to all employees, made accessible to stakeholders, and is subject to annual review to ensure ongoing relevance and effectiveness" (page 40). The same policy is cited as the E5 policy (page 44).

The disclosure does not state whether the policy addresses climate change adaptation separately from mitigation, nor does it name third-party standards or initiatives the policy adheres to.

Actions and resources in relation to climate change policies

Reference: page 40 (index, page 18; section 4.5).

"Kitron has identified that energy consumption for production and the heating/cooling of facilities is the largest source of CO2 emissions under Scope 1 and 2. To mitigate these emissions, the company has implemented and planned several non-quantifiable key actions" (page 40). Two are named:

• Sourcing renewable electricity - "Solar panels were installed at sites in Sweden and Lithuania between 2022 and 2024. This, combined with purchasing guarantees of origins, has made the Scope 2 market-based renewable energy share increase from 64.4 % in 2022 to 99,7% in 2025. Only one site reported 95% renewable electricity. Kitron aims to reach 100 % scope 2 market-based renewable electricity by 2026" (page 40).
• Energy efficiency in new investments - "From 2024 onwards, Kitron has integrated energy-efficiency requirements into all new equipment and facility investments. This is an ongoing initiative without a fixed end date" (page 40).

Scope: the actions "cover all Kitron's sites globally, focusing primarily on its own operations (Scope 1 and 2), but also impacting parts of the upstream supply chain" (page 40). Resources are qualitative only: the actions "are primarily funded through operational budgets and do not require significant external financing" (page 40). No CapEx or OpEx figure is attached.

Targets related to climate change mitigation and adaptation

Reference: pages 40-42 (index, page 18; section 4.4 is tagged "E1-2 | E1-4", target table at page 42).

"Kitron aims to reduce location-based GHG emissions in Scope 1 and 2 by 50 % and GHG emissions in Scope 3 by 25 % before 2050... 2022 is the base year for the reduction targets in scope 1 and 2, while 2024 is the base year for the reduction targets in scope 3" (page 40).

Interim milestones (page 41): "Scope 1 and scope 2 location-based targets are calculated as a reduction from base year (2022) of 30% until 2030 and 50% until 2050... The Scope 3 target is calculated as a target reduction from the base year (2024) of 15% until 2030 and 25% until 2050." Table 4-2 gives target values for 2025, 2030 and 2050 per scope alongside actuals (page 42).

Kitron states the limit plainly: "The targets are not science- based or proved to be compatible with limiting global warming to 1.5C" (page 40). A separate ambition is disclosed: "Kitron has also defined an ambition to achieve 100% renewable electricity usage across all its sites", tracked quarterly (page 40). No stakeholder engagement in target-setting is described, and no decarbonisation lever is quantified against the pathway.

Energy consumption and mix

Reference: page 41 (index, page 18; section 4.6 and Table 4-1).

"Energy consumption and mix are based on site-specific data. Kitron's energy intensity, calculated as total energy consumption per net revenue for activities in high climate impact sectors (Section C - Manufacturing, see Annex I in Regulation (EC) No 1893/2006), is 0.037 MWh/KEUR for 2025 (2024: 0.04 MWh/KEUR). This is derived from a total energy consumption of 27 480.9 MWh and a net revenue of EUR 738.3 million" (page 41).

Table 4-1 reports total fossil energy consumption of 4,666.8 MWh (2024: 4,796.4), a 17% fossil share (2024: 18%); nuclear consumption of 0.0 MWh and a 0% nuclear share; and total renewable energy consumption of 22,814.1 MWh (2024: 21,517.4), an 83% renewable share (2024: 82%). Total energy consumption rose from 26,313.7 MWh in 2024 to 27,480.9 MWh in 2025 (page 41).

Kitron flags the limits of the figures: "The estimates on energy consumption and mix have not been validated by an external body other than the assurance provider" (page 41). No energy production is disclosed.

Reader caution: in the published table the row labels for the fossil sub-lines appear misaligned against their values (the four sub-rows sum to the total fossil figure of 4,666.8 MWh, but are labelled as renewable categories), so only the totals and shares are relied on here.

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 41-43 (index, page 18; sections 4.7 and 2.7.1, Tables 4-2 and 4-3).

2025 (Table 4-2, page 42), tCO2e: Scope 1 878.1 (2024: 848.4, +4%); Scope 2 location-based 6,047.8 (2024: 5,963.7, +1%); Scope 2 market-based 134 (2024: 369.5, -64%); Scope 3 87,174.8 (2024: 88,624.8, -2%). Totals: location-based 94,101 (-1.40%) and market-based 88,187 (-1.80%). Largest Scope 3 lines: purchased goods and services 74,985.4 (-4%) and upstream transportation and distribution 5,488.2 (+56%). Scope 1 from regulated emissions trading schemes: 0%.

Intensity (Table 4-3, page 43): 127.5 location-based and 119.5 market-based tCO2e per monetary unit of net revenue (2024: 147.46 and 138.82), on net revenue of EUR 738.3 million.

Method (pages 41, 43): operational control, GHG Protocol, CEMAsys, factors from DEFRA, IEA and Ecoinvent. "95.25% of the emissions in scope 3 are calculated based on spend, 2.11%... on supplier-provided data, and 2.64 %... on distance". "99.7% of the electricity consumption across the group's sites is covered by Guarantees of Origin", which "explains the significant difference between market-based and location-based scope 2 emissions". Processing, use and end-of-life of sold products "are the responsibility of the product owner and fall outside Kitron's reporting scope" (page 43).

Policies related to resource use and circular economy

Reference: page 44 (index, page 18; section 5.3 is tagged "E5-1 | E5-2 | E5-3").

Kitron uses a single environmental policy for both climate and circularity: "As addressed in the Climate chapter, Kitron established a dedicated Environmental Policy in 2025. In addition to addressing material IROs related to climate, the Policy also addresses material resource use and circular economy related IROs including the use of recyclable packing and recycled packing materials and waste handling. The policy applies to all of Kitron's operations and aims to reduce environmental impact while maintaining high-quality electronic manufacturing services. For further details see E1-2" (page 44).

The MDR-P elements are carried across from the E1-2 description: oversight rests with the Director of Quality and Operational Excellence, final approval with the Board, communication to all employees, accessibility to stakeholders and annual review (page 40).

What the policy does not cover is disclosed by omission rather than statement: no policy commitment is reported on sustainable sourcing of raw materials, on moving away from virgin resources, or on waste hierarchy application beyond packaging and waste handling. Kitron notes that as an EMS provider "resource input and output, including the selection of materials and product design, are largely determined by its clients" (page 44).

Actions and resources related to resource use and circular economy

Reference: page 44 (index, page 18; section 5.3).

Two actions are disclosed. First, packaging: the 2025 packaging-material target is supported by data collection, "For packaging-related material... Kitron has initiated data collection to monitor performance against the newly defined target" (page 45). Second, waste: "Kitron has initiated waste reduction measures across all sites, in line with environmental certification standards and are reviewed annually. This long-term commitment aims to minimise landfill waste and improve resource efficiency" (page 44).

Product-level circularity actions are described under resource outflows: "We offer maintenance, repair and refurbishment programs. Refurbishment programs help extend the product's lifecycle, including both software and hardware upgrades. We have in-house software and hardware design expertise if a redesign is required. Kitron also has component information systems (CIS) to assist its customers in identifying replacements for obsolete components" (page 46).

Kitron states the structural limit on its own actions: "Since Kitron manufactures products which have been designed and specified by customers the means to influence this matter is limited compared to companies designing their own products" (page 44). No CapEx, OpEx or headcount is allocated to the E5 actions, and no time horizon is attached to the waste reduction measures beyond "long-term".

Targets related to resource use and circular economy

Reference: page 44 (index, page 18; section 5.3).

One measurable target is disclosed: "In 2025, Kitron formally approved a packaging material target, committing to ensure that, by 2030, at least 80% of packaging materials used to package the products sent to our clients shall be recyclable, with 2025 being the base year. Estimates for 2025 indicate a baseline value of approx. 55%. The target aligns with the company's policy on recyclable packing and recycled materials. The target was established by the Director of Quality and Operational Excellence and the CFO and subsequently approved by the Board" (page 44).

The MDR-T elements present are the target level, the base year and value, the target year, the scope (outbound product packaging) and the approval route. Not present are stakeholder involvement in setting the target, interim milestones between 2025 and 2030, and any methodology note on how "recyclable" is determined.

No target is set for the other material E5 IROs - resource outflows as products sold, resource outflows as waste, input material selected by clients, or scarcity of minerals (page 30). Effectiveness of the waste measures is tracked through the annual review against environmental certification standards (page 44) and the annual waste figures at page 48.

Resource inflows

Reference: page 45 (index, page 18; section 5.4).

Inflows fall in three categories: "electronic components, mechanical drawing parts, and PCBs (Printed Circuit Boards). The inputs are, with few exceptions, sourced and produced outside Norway. Electronic components include silicon, copper, tin, gold, silver, tungsten, lead, and aluminum, and are sourced from close to 1407 manufacturers through approximately 1255 supply partners." PCBs are "1) Substrate... typically made of fiberglass-reinforced epoxy resin (FR-4)... and 2) Copper Foil". Process materials include "tin for soldering components, various solvents to clean the boards, and conformal coating"; packaging is "pallets, carton boxes, and ESD bags/bubble wrap" (page 45).

Biological materials: "Kitron's use of biological materials in production is limited to the materials used in product packaging, with the use of pallets and carton boxes" (page 45).

Secondary materials are addressed qualitatively and the gap explained: "most input materials and components do not originate from secondary sources... making it unfeasible to estimate the rates of secondary used materials across suppliers" (page 45). No tonnage of total resource inflows and no percentage of secondary reused or recycled components is given. Pallets "are normally reused"; carton boxes and ESD bags "are normally customized to fit the product and are therefore rarely reused".

Resource outflows

Reference: page 46 (index, page 18; section 5.5), with waste at page 48.

Products. "Kitron is an Electronics manufacturing services company and produces electronics for our customers who own the Intellectual Property of the product... In all the processes, the customer owns and decides the design and choice of materials" (page 46).

Durability, reparability, recyclability. "Since Kitron does not control the products' end-of-life, it is challenging to estimate the exact durability of its products... However, Kitron does control the design and redesign of its products and regularly estimates how long it will take before the products require redesign, also known as New Product Introduction (NPI) design or revision lifetime." On repair: "The general procedure is to repair the products. However, end-of-life repair is not always possible" (page 46).

Packaging recyclability is described by bag type - pink antistatic bags (LDPE), and metallized shielding and moisture barrier bags, "often categorized under mixed plastics (Code 7)" (page 46).

Limits are disclosed: "Most of Kitron's products end up as electronic waste (e-waste) at end-of life... it is challenging to break down the exact product composition on a general basis", and "Kitron currently has no statistics on packaging material recycling after it has been shipped to the customer" (page 46). No rate of recyclable content in products is quantified.

Waste

Reference: page 48 (section 5.6, within the E5 chapter whose E5-5 disclosure the index places at page 46).

Method. "Kitron is calculating waste data based on the reports received when delivering sorted waste to the recycling plants, by factory. The reports are attached to invoices from the recycling plants and apply to all Kitron's production sites" (page 48).

2025 totals (Table 5-1, page 48), tonnes. Total waste 1,125 (2024: 1,017), across ten manufacturing sites. 1,063 t (94.5%) non-hazardous (2024: 960) and 62 t (5.5%) hazardous (2024: 57). By route: recycled 734.5 t (65%), of which 673 non-hazardous and 61.3 hazardous; incineration 390 t (34%), all non-hazardous; treated waste 0.49 t (0.1%), all hazardous. Preparation for reuse, other recovery operations and landfill are all zero.

Composition. "Kitron mainly has electronic waste from scrap in production or from inventory. Hazardous waste comes from washing machines that PCBS are washed in, in addition to different types of conformal coating, oils and cleaners from the production machinery" (page 48).

Radioactive waste. "Kitron does not generate any radioactive waste through its operations" (page 48). The figures "have not been validated by an external body other than the assurance provider".

Policies related to own workforce

Reference: pages 52-53 (index, page 19; section 6.3).

The anchor policy is the Ethical Code of Conduct, mapped to each material impact: health and safety ("the commitment to providing a safe, healthy, and satisfactory workplace, in addition to the HSE Policy"); adequate wages ("Kitron upholds fair employment practices where local norms, laws, or collective bargaining agreements serve as the basic standard"); and training and skills development (page 52). The CEO and Chairman of the Board "are accountable for the implementation of the policy, alongside the Ethics Committee". It is public and "reviewed at least biannually" (page 52).

Alignment is stated with the UN Universal Declaration on Human Rights and ILO conventions, and Kitron "is also a UN Global Compact Signatory" (page 52). A group-wide HSSE Policy was implemented in 2025, "approved by the Board of Directors" (page 53).

Three gaps are disclosed plainly: "Beyond our Ethical Code of Conduct, we have no specific policies aimed at the elimination of discrimination"; "Kitron does not have any inclusion or positive action for people from groups at particular risk of vulnerability within the workforce"; and "Kitron currently does not have specific procedures to implement its Ethical Code of Conduct" (page 53). On remedy: "Kitron has not yet encountered a situation necessitating the remediation of human rights impacts" (page 52).

Processes for engaging with own workforce and workers' representatives

Reference: page 54 (index, page 19; section 6.4).

"In 2025, Kitron established a general process for engaging with its workforce and workers' representatives, aimed at fostering meaningful dialogue, transparency, and responsiveness to employee needs. This process is integral to Kitron's due diligence efforts to manage and mitigate impacts on the workforce" (page 54).

The channels: "Engagement occurs both directly with employees and through workers' representatives, tailored to the organisational structure and local context of each site. Annual employee surveys are conducted... Regular dialogue is maintained with union representatives where formal representation exists, while engagement in other locations is facilitated through forums or focus groups" (page 54). Under SBM-2 the survey platform is named as Eletive, alongside "representation on the Kitron ASA Board, the European Workers Council, and annual surveys" (page 28).

Vulnerable groups: "Kitron is committed to understanding the perspectives of vulnerable workforce groups, including women, migrants, and persons with disabilities" (page 54).

Responsibility sits locally: "Managing directors at each site review engagement outcomes, communicating with worker representatives and taking necessary actions" (page 28). No single global function is named as accountable, and no assessment of the effectiveness of the engagement is reported.

Processes to remediate negative impacts and channels to raise concerns

Reference: page 54 (index, page 19; section 6.5). A related datapoint row appears in appendix 9.1 as "ESRS S1-3 Grievance/complaints handling mechanisms" (page 75).

The escalation path: "Employees can report issues to their immediate superior, the superior's superior, or an employee representative. Environmental and safety concerns can be reported to the relevant representative, HSE manager, or company health service, while financial matters may be reported to the Finance Manager. Each site has designated contact persons... If necessary, employees can also report directly to the Chairman of the Group Ethics Committee or the CFO or to the Chairman of the Audit Committee for Kitron ASA" (page 54).

A whistleblowing procedure allows employees and value chain workers to raise concerns "either anonymously or directly", with the Ethics Committee concluding cases. Awareness is supported "through onboarding training and biennial training sessions on the Kitron Ethical Code of Conduct" (page 54).

Effectiveness tracking is partial and Kitron says so: "Statistics on the number of cases handled by the Ethics Committee are presented annually", but "no formal investigation has been conducted to assess the trustworthiness of the procedure beyond this observation" (page 54). Retaliation is prohibited "even if the report does not turn out to be an actual violation".

Taking action on material impacts on own workforce

Reference: page 55 (index, page 19; section 6.6).

Kitron opens with the limitation: "Kitron have not yet implemented specific action plans or allocated dedicated resources to manage material impacts. Kitron is continuously working on managing identified material risks and opportunities related to its own workforce, utilizing existing resources within its budget. The approach and efforts vary across different sites" (page 55).

Measures taken in 2025: "A new Health, Safety, Security and Environment (HSSE) policy has been introduced... Kitron has conducted interviews with HR representatives at most of its sites. Kitron uses the Cornerstone system for e-learning across all sites... Kitron is currently expanding the rollout of the digital performance review system to additional sites, beginning with Denmark, the Czech Republic, Malaysia, India, and Suzhou" (page 55).

Three explicit nil returns follow: "No material impacts necessitating remedial action have been identified. Hence, there are no actions planned or underway to mitigate material risks... nor is there a system in place to track the effectiveness of such measures"; "there are no specific actions planned or underway to pursue material opportunities"; and "no specific measures have been taken to mitigate negative impacts on workers arising from the transition to a greener, climate-neutral economy" (page 55).

Targets related to own workforce

Reference: page 55 (index, page 19; section 6.7).

One target is disclosed: zero fatalities. "The target of zero fatalities aligns with Kitron's commitment to ensuring the health, safety, and well-being of all employees. This objective is embedded in our Ethical Code of Conduct and Health, Security, Safety and Environmental policy... The target is measurable and absolute, and the scope includes the entirety of Kitron's workforce. The baseline value for this target is the current number of fatalities, which is zero. The baseline year is the most recent reporting year, 2025... The target applies indefinitely... Given the absolute nature of the target, there are no specific interim targets" (page 55).

Workforce involvement is disclosed as absent: "There was no direct involvement of the workforce or workforce representatives in setting the target or tracking performance against the target of zero fatalities" (page 55).

No target is set for the other material S1 IROs - adequate wages, working conditions, employee engagement, or training and skills development (page 30). Performance is reported under S1-14: zero fatalities in own workforce and zero among other workers on Kitron sites in both 2025 and 2024 (page 59).

Characteristics of the undertaking's employees

Reference: page 56 (index, page 19; section 6.8, Tables 6-1 to 6-3).

Headcount at end of period 2025: 2,830 (2024: 2,564), of which 1,361 male and 1,469 female; "Other" and "Not reported" are both zero (Table 6-1). By contract type: 2,510 permanent (1,194 / 1,316), 309 temporary (160 / 149) and 11 non-guaranteed hours employees (7 / 4) (Table 6-3, page 56).

Countries with at least 50 employees representing at least 10% of the total: Norway 559, Sweden 326, Lithuania 680, China 458 (Table 6-2, page 56). By region: Nordics 1,030, Central & Eastern Europe 1,113, North America 147, Asia 540 (page 24).

Turnover is given with its working: "474 of our employees left the undertaking in 2025. Average number of employees: 2 728. Average turnover: 474/2 728=17.0%. In 2024, 646 of our employees left... the average turnover was 646/2803=23.0%" (page 56).

Growth and method: "In 2025, driven by increased orders from the defence sector, Kitron saw an increase in demand... Employees are reported on the headcount level and at the end of the period" (page 56). Employees are not broken down by gender within each country.

Collective bargaining coverage and social dialogue

Reference: page 57 (index, page 19; section 6.9, Table 6-4).

"Sweden, Norway and Lithuania are countries with significant employment with a coverage rate of at least more than 10% of our total employees. All three countries have collective bargaining agreements. 53,5% of Kitron's total employees are covered by collective bargaining agreements. For Norway, Sweden and Lithuania, 100% are represented by workers' representatives (2024: Lithuania workplace representation was in the 0-19% bracket)" (page 57).

The restatement is explained: "Since 2024, Kitron has better gained better clarity in the collective bargaining coverage and social dialogue situation across its locations and has therefore update the coverage rate for Lithuania" (page 57). Table 6-4 places Norway, Sweden and Lithuania in the 80-100% band for both collective bargaining coverage and social dialogue.

"Kitron has a European workers council agreement" (page 57).

Two limits are visible. The 53.5% group figure covers all employees, but the country breakdown is given only for the three EEA countries with significant employment; no coverage rate is reported for employees outside the EEA, including the 458 employees in China and the workforce in Malaysia and India. Kitron does not report on employees covered by workers' representatives outside the EEA.

Diversity metrics

Reference: page 58 (index, page 19; section 6.10, Tables 6-5 and 6-6).

Gender at top management (Table 6-5, page 58): 6 male (85.7%) and 1 female (14.3%), total 7, unchanged from 2024. Kitron defines the population twice, and the two definitions do not agree: "Top management is defined as the group corporate management team. Kitron has used the definition of top management as one and two levels below the CMT" (page 58).

Age distribution (Table 6-6, page 58): under 30 - 634 (22%) (2024: 551, 21%); 30 to 50 - 1,459 (52%) (2024: 1,352, 53%); over 50 - 737 (26%) (2024: 661, 26%); total 2,830 (2024: 2,564).

Board and management diversity is reported separately under GOV-1: 50% of Board members are female, all Board members are over 50, "86% of the CMT members are male", and "43% of CMT members are between the age of 40 and 50 and 57% are more than 50 years old" (page 21). Table 2-2 gives the CMT split as 6 male / 1 female, 85.8% / 14.2% (page 21).

The company's general position is stated under S1-6: "Kitron has a balanced gender distribution, though this varies across different parts of the company and regions" (page 56). No diversity metric other than gender and age is reported.

Adequate wages

Reference: page 58 (index, page 19; section 6.11, Table 6-7).

The metric is a nil-exception return: "Kitron has no workers being paid less than the mandated minimum wage in regions where Kitron operates. This means all our workers are paid at least minimum wage in line with applicable benchmarks." Table 6-7 reports 100% in total for both 2025 and 2024 (page 58).

Method is disclosed: "The minimum wage is the lowest wage that employers are legally obliged to pay their employees. The lowest wage was analysed for the lowest pay category, excluding interns and apprentices. It was based on the basic wage plus any fixed additional payments that are guaranteed to all employees" (page 58).

The benchmark used is the legal minimum wage, not an adequate-wage benchmark of the kind ESRS S1-10 contemplates for countries without one. That matters because Kitron itself identifies the risk in regions "with lower wage levels or limited labour protections", noting that "Kitron operates in different jurisdictions and geographies, with different definitions of adequate and fair wages. Some countries operate with minimum wages, and others do not" (page 51). No percentage is reported by country or by employee category, and no figure is given for how far above minimum wage the lowest-paid employees sit.

Health and safety metrics

Reference: page 59 (index, page 19; section 6.12, Table 6-8).

Coverage: "Number of people that are covered by the company's health and safety management system - 100%" in both 2025 and 2024, because "All companies have either a legal requirement and/or an ISO certification for Health and Safety Managements system" (page 59).

Incidents 2025 (2024): fatalities in own workforce from work-related injuries and ill health 0 (0); fatalities among other workers on Kitron sites 0 (0); recordable work-related accidents for own workforce 48 (7). The rate of recordable work-related injuries is 2.01 (2024: 1.34) (page 59).

Kitron explains the rise: "The increase in number of recordable work-related accidents for own workforce is a result of improved reporting culture, with Kitron encouraging its employees to report all type of injuries, regardless of severity. In 2025, only 4 of the incidents resulted in employees being unable to work for one or more days. Combined, the injuries caused a total of 7 days lost" (page 59).

"Work-related ill health is defined in accordance with the International Labour Organization (ILO) List of Occupational Diseases" (page 59). Cases of recordable work-related ill health and days lost to ill health are not separately reported, and the metrics cover own workforce only.

Compensation metrics (pay gap and total compensation)

Reference: page 59 (index, page 19; section 6.13, Table 6-10).

Gender pay gap (Table 6-10, page 59), KEUR annual average pay: male 39, female 27, gap 31% (2024: male 38.6, female 23.6, gap 39%). The gap narrowed by 8 percentage points year on year.

Total remuneration ratio: "The annual total remuneration for the highest-paid individual is recorded at 2,476 KEUR (2024: 1181 KEUR)"; median pay is 29.9 KEUR (2024: 25.2 KEUR); and "The ratio of the highest-paid individual's remuneration to the median pay is calculated as 62.7 (2024: 46.9)" (page 59). The ratio rose by about a third, driven by the doubling of the highest individual's remuneration.

Method is disclosed for both metrics: average pay is calculated site by site, "multiplied by the headcount to determine the total pay", then aggregated and divided by headcount by gender; median pay is "based on the weighted average of the median pay per site, calculated by multiplying the median by the headcount and dividing the sum by the total headcount" (page 59).

Two explanations are offered for the level of the gap: "The pay gap is influenced by the lower representation of females compared to males in indirect and higher-level positions", and "Kitron employs a substantial number of employees in CEE and Asia. The company's headquarter is in Scandinavia" (page 59).

Incidents, complaints and severe human rights impacts

Reference: page 60 (index, page 19; section 6.14).

Discrimination incidents: "In 2025, five incidents of discrimination were reported through our whistleblowing channels, which are currently under investigation and are being followed up. There have not been reported any other incidents of discrimination on the grounds of gender, racial or ethnic origin, nationality, religion or belief, disability, age, sexual orientation, or other relevant forms of discrimination... This includes incidents of harassment as a specific form of discrimination" (page 60).

Complaints and severe impacts: "There have been no complaints filed with the National Contact Points for OECD Multinational Enterprises." "There have been no severe human rights issues or incidents connected to our own workforce, no cases of non-respect of UN Guiding Principles and OECD Guidelines for Multinational Enterprises, and no fines, penalties, or compensation for such issues" (page 60).

Fines: none "as a result of incidents of discrimination, including harassment and complaints filed", and none "as a result of violations regarding work-related discrimination and harassment, and therefore no relevant amounts are presented in the financial statements" (page 60).

The five open cases are the only S1 incident figure that is not a nil return, and no outcome is reported for them.

Policies related to value chain workers

Reference: pages 62-64 (index, page 19; section 7.3).

The instrument is the Kitron Supplier Code of Conduct, which "outlines requirements for labour rights, health and safety, environmental practices, and anti-corruption measures. It includes standards for freely chosen employment, child labour avoidance, working hours, wages and benefits, humane treatment, non-discrimination, freedom of association, occupational safety, emergency preparedness, pollution prevention, and business integrity" (page 62). It applies to "all suppliers and their sub-contractors" and "to both suppliers and sub-suppliers" (pages 62, 64).

It is mapped to the material impacts: "The policy addresses the responsible sourcing of minerals and has requirements for suppliers that they shall have policies related to responsible sourcing as well as exercising due diligence on the source and chain of custody of minerals", and it "addresses labour rights, including working hours, wages and benefits and freedom of association" (page 62). MDR-P elements: "approved by the Board of Kitron ASA", overseen "by the COO and the Supply Chain Director", accessible online (page 63).

Two limits are disclosed: "However, Kitron's policies are not aligned with the United Nations (UN) Guiding Principles on Business and Human Rights", and "Kitron's supplier code of conduct does not explicitly address trafficking in human beings" (page 64).

Processes for engaging with value chain workers about impacts

Reference: page 64 (index, page 19; section 7.4).

The disclosure is short and its central fact is a nil return: "Kitron does not engage directly with value chain workers or their representatives. However, Kitron has established mechanisms to ensure that these workers have the opportunity to report any irregularities and concerns. Through the whistleblowing channel, value chain workers can confidentially raise issues related to their working conditions, human rights, and other ethical concerns without fear of retaliation" (page 64).

The same position is stated twice more. Under SBM-2: "At present, Kitron has not engaged directly with these workers, but addresses human and labor rights through engagement with our suppliers" (page 27). And again at page 64: "However, value chain workers can engage with Kitron if they need to report irregularities or concerns."

No stage of engagement, frequency, accountable function or assessment of effectiveness is reported, because no engagement takes place. Kitron adds that it "has not conducted an analysis to understand how workers with particular characteristics, those working in specific contexts, or those undertaking particular activities may be at greater risk of harm" (page 62).

Processes to remediate negative impacts and channels for value chain workers to raise concerns

Reference: page 64 (index, page 19; section 7.5).

"Kitron has a whistleblowing procedure that allows workers in the value chain to voice their concerns either anonymously or directly to the Kitron Ethics Committee or the Chairman of the Risk and Audit Committee. The Ethics Committee will then follow up and conclude the case, ensuring that all reports are handled with confidentiality and integrity, as described in S1-3" (page 64).

Kitron discloses that it has not tested whether the channel reaches the people it is meant for: "Kitron has yet to evaluate the extent to which value chain workers are informed about and have confidence in these structures and processes" (page 64).

On remedy, the S2-4 text is consistent: "Kitron will provide for and cooperate in enabling a remedy where relevant... As Kitron has not encountered material negative impacts to date, the effectiveness of these processes has not yet been assessed" (page 66). Kitron also states it "will disengage with any supplier found to be violating its human rights guidelines" (page 64). No grievance mechanism operated by or with suppliers is described, and no number of reports from value chain workers is given.

Taking action on material impacts on value chain workers

Reference: pages 65-66 (index, page 19; section 7.6).

The disclosure opens with a nil return on resources: "No specific action plans or resources have been allocated to address material impacts, risks and opportunities related to value chain workers. There are currently no specific actions planned or underway to prevent, mitigate, or remediate material negative impacts on value chain workers" (page 65). Also: "Kitron has no additional initiatives or processes specifically aimed at delivering positive impacts for value chain workers. Consequently, Kitron do not assess or track effectiveness beyond addressing irregularities or concerns brought to our attention."

What is in place is supplier management: due diligence "comprises a three-step procedure: supplier onboarding, supplier assessment, and supplier audits" (page 65). Table 7-1 gives the share procured from Preferred Partners by value: mechanical drawing parts 14% (2024: 15%), electronic components 50% (2024: 52%), PCBs 64% (2024: 52%) (page 65).

On minerals: "Kitron secures responsible sourcing by continuously tracking the source of the 3TG12 content in raw materials and strives to be conflict-free" (page 66). "Kitron will update the Supplier Code of Conduct in 2026" (page 65). "No severe human rights issues or incidents connected to our upstream and downstream value chain have been brought to Kitron's attention" (page 66).

Targets related to value chain workers

Reference: page 66 (index, page 19; section 7.7).

The disclosure is a two-sentence nil return, quoted in full: "Kitron has not set targets related to managing material negative impacts, advancing positive impacts, or managing material risks and opportunities. Consequently, Kitron has not engaged with value chain workers, their legitimate representatives, or credible proxies on this matter" (page 66).

Under MDR-T, the alternative to a target is a description of how effectiveness is tracked. Kitron states that it does not track it: "Kitron has no additional initiatives or processes specifically aimed at delivering positive impacts for value chain workers. Consequently, Kitron do not assess or track effectiveness beyond addressing irregularities or concerns brought to our attention" (page 65).

This sits against three material negative impacts identified for S2 in Table 2-7 - sourcing from conflict-affected or high-risk areas, fair wages and working conditions for value chain workers, and value chain workers being prohibited from organising, all upstream (page 30). The only quantified S2 series in the statement is the share of procurement from Preferred Partners (page 65), which is a supplier concentration measure rather than a worker outcome measure.

Business conduct policies and corporate culture

Reference: pages 67-69 (index, page 19; section 8.2, tagged "[MDR-P] G1-1").

Three policies are named: "Kitron's Ethical Code of Conduct (See S1), Kitron's Supplier Code of Conduct (See S2), Kitron's Anti-Corruption Policy" (page 67). The Anti-Corruption Policy "includes the ethical standards and legal requirements that employees must adhere to, the roles and responsibilities of the Ethics Committee and Corporate Management Team (CMT), risk analysis and monitoring procedures, types of corruption... and training protocols... It covers... bribery of public officials, public sector bribery, and facilitation payments", which are excluded "only in situations where there is a serious medical or safety emergency" (page 67). Accountability for implementation sits with "the CMT, which reports to the Board of Directors."

Corporate culture is built through Kitron Academy onboarding repeated every other year, a leadership programme, and the annual employee survey "used as input to evaluate the corporate culture" (page 68).

Three gaps are disclosed: the Anti-Corruption Policy "has not been verified for alignment with the United Nations Convention against Corruption, and there are currently no plans to make adjustments"; "Kitron has no procedures to investigate business conduct incidents other than the Whistleblowing Routine"; and "Kitron has no formal policy for training within the organisation on business conduct" (pages 68-69).

Management of relationships with suppliers

Reference: page 69 (index, page 19; section 8.3).

"At Kitron, we use the highest standards in the selection of our suppliers... We expect our suppliers to adhere to all applicable laws and regulations, and to the highest ethical standards defined in the Ethical Code of Conduct and Supplier Code of Conduct. Our Supplier Code of Conduct is an integrated part of the commercial contract with suppliers" (page 69).

Social and environmental criteria in selection: "New suppliers undergo a rigorous onboarding process, including a Request for Information (RFI)... Existing suppliers are regularly assessed using a supplier scorecard and risk assessment, and those identified as high-risk are subject to audits and follow-up actions... We also perform risk assessments yearly for all suppliers" (page 69).

On conflict minerals: "we expect our suppliers to have policies to ensure that tantalum, tin, tungsten and gold don't directly or indirectly finance, or benefit armed groups... Kitron is subject to legislation related to conflict minerals, such as the Dodd-Frank Act" (page 69).

Payment practices toward SMEs are addressed here rather than under a numbered DR: "Kitron's general policy is that debt should be paid when it is due. This includes SMEs... Kitron follow up on late supplier payments in every financial reporting to the Board" (page 69). No supplier vulnerability analysis is reported.

Prevention and detection of corruption and bribery

Reference: page 70 (index, page 19; sections 8.4 and 8.5, where the G1-3 tag sits alongside the prevention and training text).

"As outlined in our policy, we regularly assess exposure to external and internal risk of corruption... Based on this risk assessment, the head of the Ethics Committee drafts a report, with input from the business, to be submitted to the Kitron CMT and the Board... we have implemented controls, such as follow-up of action lists from corruption risk assessment, review of due diligence reports of counterparts, review of training log and review of internal transactions. Kitron has procedures for segregation of duties regarding outgoing payments and a 'two eyes' requirement for changes to supplier payment details" (page 70).

Kitron discloses a specific non-conformity: "Currently, the investigators or investigating committee are not separate from the chain of management involved in the prevention and detection of corruption or bribery and there is no established process for reporting outcomes of investigations to CMT and Board. However, we are committed to improving our efforts... within the next two years" (page 70).

Training: all employees receive periodic anti-corruption training, repeated every other year. Completion: "As of 2024, 92.5% of 80 in high-risk positions had completed their training. The situation is unchanged for 2025" (page 70).

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T disclosures rather than as a numbered disclosure requirement. G1-3 Targets became a standalone DR only in the 2025/2026 ESRS; Kitron's statement is prepared under the 2023 ESRS.

Kitron discloses one long-term business conduct target, under SBM-1 rather than in the G1 chapter: "We carry out an annual ethics and corruption awareness training, and our long-term (2030) target is zero incidents of corruption" (page 26). No baseline year, interim milestone or stakeholder involvement in setting it is reported.

Within the G1 chapter itself Kitron states the opposite and falls back on MDR-T's other limb: "Kitron currently has no specific targets related to business conduct and corporate culture governance but maintains policies and ongoing evaluation processes to manage its material impacts, risks, and opportunities in these areas" (page 67).

Effectiveness in the absence of targets is tracked through the annual corruption risk assessment reported to CMT and Board with mitigation recommendations, controls including "review of training log and review of internal transactions" (page 70), the training completion rate of 92.5% of 80 people in high-risk positions (page 70), the annual employee survey used "as input to evaluate the corporate culture" (page 68), and annual statistics on Ethics Committee cases (page 54).

Incidents of corruption or bribery

Reference: page 70 (index, page 19; section 8.5).

The disclosure is a nil return, quoted in full: "Kitron has had no convictions or fines for violations of anti-corruption and anti-bribery laws during the reporting period. No specific action plans or resources have been allocated to address breaches in procedures related to corruption and bribery (same as in 2024)" (page 70).

Kitron reports no confirmed incidents of corruption or bribery, no dismissals or disciplinary actions arising from such incidents, and no contracts with business partners terminated or not renewed on those grounds. No public legal cases regarding corruption or bribery are reported for the period.

Handling arrangements are described elsewhere: "Potential allegations of fraud or incidents of corruption or bribery are handled by the Ethics Committee" (page 70). Read against the G1-3 admission that investigators "are not separate from the chain of management involved in the prevention and detection of corruption or bribery and there is no established process for reporting outcomes of investigations to CMT and Board" (page 70), the nil return rests on a detection system Kitron itself describes as incomplete.