Kongsberg Automotive

The role of the administrative, management and supervisory bodies

Reference: pages 40-42. Composition, competences, meeting attendance, independence and diversity datapoints are incorporated by reference to the Corporate Governance section (pages 17-18 for Board profiles, pages 14-15 for reporting points 8-10) and to page 82 for diversity metrics.

"The Board is the highest governing body for sustainability issues and approves sustainability-related group policies of strategic relevance, including the group's Code of Conduct" (page 40). More specific policies are approved by the CEO or the Executive Leadership Team (ELT).

The organisational chart on page 41 sets out the bodies and their sustainability roles:

• Board of Directors - oversight and alignment of business conduct practices with long-term corporate goals
• Audit Committee - "Oversees financial, sustainability, and risk reporting"
• Compensation Committee - executive remuneration structure including sustainability target incentives
• Compliance Committee (General Counsel, CFO, Head of People and Culture) - compliance policies, investigation of reported incidents
• Internal Audit, ELT, a Sustainability Expert, and a BA Sustainability Responsible in each of the two business areas, Drive Control Systems and Flow Control Systems

Governance changed during the year: in 2024 and early 2025 KA had a Corporate Sustainability Manager and a Sustainability Steering Committee; from the second quarter of 2025 a reorganisation established a new ELT and new business units, moving corporate functions into the business areas (page 40).

Information provided to and sustainability matters addressed by the bodies

Reference: pages 40-41.

The Board "is the highest governing body for sustainability issues and approves sustainability-related group policies of strategic relevance" (page 40), and the Audit Committee "Oversees financial, sustainability, and risk reporting" (page 41). The ELT "Decides the strategic direction, targets, roadmaps, investments, and reporting" (page 41).

On risk, "The Board oversees the risk management process and carries out annual reviews of the company's most important risk categories and internal control arrangements. The group implemented ownership to indicators published in the sustainability statements, with Board oversight of material topics" (page 41).

On the double materiality assessment, the material topics were presented to the Sustainability Steering Committee for validation, which "did not propose any changes. Finally, the ELT and the Board signed off on the results" (page 46).

The statement is candid about the effect of the 2025 restructuring on decision-making: "During this reorganization process, no strategic decisions on additional sustainabilty-related initiatives were made. However, the initiatives as set out in KA's existing roadmap were executed as scheduled on an operational level" (page 40). Frequency of reporting to the Board on individual sustainability matters is not disclosed.

Integration of sustainability-related performance in incentive schemes

Reference: pages 41-42. Details of the incentive programmes are incorporated by reference to the 2025 Remuneration Report, paragraph "Long-term incentive plan 2025 for management" (pages 53, 54).

KA changed its approach in 2025: "KA strategically removed the ESG targets from its top management incentive schemes and integrated them into the company's formal annual performance management process. Under this revised framework, ESG objectives are defined as individualized performance targets, developed jointly between employees and their direct managers" (pages 41-42).

The stated rationale is that role-specific objectives beat generic ones: "By shifting from generic, standardized ESG targets to role-specific, influence-based objectives, KA enhances accountability among the same group of top managers" (page 42).

The link to pay is through the salary review rather than a bonus formula: "The outcome from the annual performance management process is reflected in the annual salary review process" (page 42). The Compensation Committee "Determines the executive remuneration structure including sustainability target incentives" (page 41).

No percentage of variable remuneration linked to sustainability or climate targets is given, and no GHG-linked incentive metric is disclosed.

Statement on due diligence

Reference: page 40.

KA defines sustainability due diligence (SDD) as "the process through which KA identifies, prevents, limits, and reports actual and potential negative impacts on the environment and people resuling from its activities", extending to "changes in the operation's strategy, business model, activities, business relationships, actual operations, and the context of acquisitions or divestments" (page 40).

The mapping table required by ESRS 2 GOV-4 is provided in full (page 40):

KA also reports separately under the Norwegian Transparency Act; the 2025 report "will be published by June 2026" (page 39).

Risk management and internal controls over sustainability reporting

Reference: page 41.

"The group's risk management process and internal control system aim to identify, assess, and manage risk factors that may potentially have adverse effects on the overall operational performance of the group. This includes sustainability-related risks" (page 41).

Method: "The importance and priority of the material topics is defined through an assessment that evaluates the impact and likelihood of the related risks versus their control effectiveness at the time of the assessment." Expert functions own their topics and the related data-capturing processes, and "develop and maintain existing controls through the implementation of action plans, cross-functional workshops, and follow-up sessions" (page 41).

Data cadence and assurance of quality: "Contingent on topic importance, data is gathered quarterly or annually in an effort to support the path toward maturity. Data quality in 2025 was ensured through the 'three lines model,' consisting of line management, Risk and Internal Control, and KA Internal Audit" (page 41).

The two processes are linked in both directions: the main risks (pages 19-21) feed the double materiality process, and "additional significant risks identified during the double materiality process are considered and included in the risk management process by the corporate sustainability manager" (page 41). No findings, deficiencies or remediation from internal control testing are reported.

Strategy, business model and value chain

Reference: page 42. Overall strategy, business model, products, markets and customers are incorporated by reference to pages 23-27, sustainability-related strategy to pages 26-27, and headcount by geographical area to page 28 (page 53).

"KA's operations are part of the automotive value chain... KA develops and offers a wide range of products for passenger cars, commercial vehicles, and the off-highway markets. The differences between KA's BAs (Drive Control Systems and Flow Control Systems) are mainly in terms of materials, suppliers, and products, but the main steps in the value chain are the same" (page 42).

The value chain diagram (page 42) runs: raw material extraction and mines (suppliers' suppliers, tier X - metals, monomers, polymers) → suppliers tier 1 (polymers, steel, brass, rubber, electronics) → KA's own production → customers' manufacturing → end customers (product use) → recycling and disposal, with transport between stages.

Strategic direction is tied to the powertrain transition: "A key driver is the transformation from internal combustion engines (ICE) to battery-electric vehicles (BEV). KA supports and contributes to this transition by developing and supplying products for use in BEV and hybrid vehicles" (page 42), with product development focused on lower weight, longer durability and recyclability. A comprehensive review of the sustainability strategy, including possible revision of long-term targets, is planned for 2026.

Interests and views of stakeholders

Reference: page 43.

"In Kongsberg Automotive's most recent stakeholder assessment, the following five stakeholder groups were identified: customers, investors and shareholders, employees, suppliers, and local communities" (page 43).

Engagement channels and reported outcomes (page 43):

• Customers - website, trade fairs, customer meetings, surveys and assessments, request-for-quotation processes. Outcomes: product recyclability, BEV innovation, sustainability performance ratings
• Investors and shareholders - Capital Market Days, AGM, annual and quarterly reports, breakfast meetings. Outcome: sustainability ratings
• Employees - intranet, town halls, board representation for employees, day-to-day union cooperation, staff meetings, social events. Outcomes: health and safety as a top focus for plant management, wellbeing topics to be developed
• Suppliers - supplier days, meetings and visits, surveys, quoting processes. Outcomes include supplier sustainability risk assessments, human rights and working conditions, responsible sourcing of minerals, and a KA Supplier event with a sustainability section on 15 January 2025
• Local communities - open house days, press releases, university collaboration. Outcomes: the KA Mexico Scholarship Program and participation in "Future of Mobility" (Spain)

Ratings platforms (CDP, EcoVadis, SupplierAssurance) are used as an element of stakeholder engagement, and "The stakeholder perspective is reflected in regular dialogs between KA's Executive Leadership Team (ELT) and the Board of Directors" (page 43).

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

Reference: pages 48-52, with the same IROs repeated at the head of each topical chapter (E1 page 63, E4 page 71, E5 page 73, S1 page 76, S2 page 87, G1 page 98, entity-specific page 103).

The cross-cutting table gives, for each IRO, a name, a type, a description, time horizon flags (short, medium, long) and the value chain stage (upstream, own operations, downstream). Counted across pages 48-52 there are 39 rows: E1 7, E4 2, E5 6, S1 7, S2 8, G1 6 and entity-specific product quality and safety 3. No total is stated by the company.

Examples of how the IROs are located in the value chain (pages 48-52):

• E1 - "CO2 emissions (Scope 1, 2, and 3)", actual negative impact, upstream "Purchased goods and services", own operations "KA plant's operations and emissions", downstream "Distribution"
• E4 - "Land degradation", actual negative impact, upstream only ("Suppliers of raw material"): "Mining of ores (iron, copper, zinc, and aluminum) all require drastic interventions in local ecosystems"
• S2 - "Inadequate wages in producing countries", potential negative impact, upstream "Suppliers": "Excessive working hours or low and non-transparent or partly non-legal wages and benefits"

The DMA "established that material factors under ESRS S2 (workers in the value chain) are limited to upstream value chain impacts, risks, and opportunities with suppliers. This aligns with KA's role as an automotive supplier to Original Equipment Manufacturers (OEMs)" (page 47).

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

Reference: pages 45-46.

"Kongsberg Automotive (KA) revisited and reconfirmed its double materiality assessment from 2024 for the 2025 reporting year, led by the Group Sustainability Manager" (page 45). The original 2024 assessment used four steps.

Step 1 - preparation and topic list. "The ESRS 1 longlist of sustainability topics served as the starting point", reviewed against previous KA materiality processes and other sources to add KA-specific topics (page 45).

Step 2 - impact materiality. Four criteria "in accordance with the GRI and ESRS 1 guidelines" - scale, scope, irremediability and likelihood - "scored from 0 ('no impact') to 4 ('very high/likely') for each topic at each value chain stage. External experts performed the assessment using both internal documents and external sources". The product of the four scores is taken per value chain stage and summed, "Thus, the impacts of all three stages of the value chain are weighted equally" (page 45).

Step 3 - financial materiality. Three weighted parts: analysis of external documents 20%, risk and opportunity workshops with in-house experts 56% combined, external expert evaluation 24%, assessed on magnitude and likelihood (page 45).

Step 4 - consolidation and approval. "The material topics are selected by setting a 50% threshold... Particular care was taken to ensure that no topics with a high impact at any stage of the value chain are excluded" (page 46). SteerCo validated, ELT and Board signed off.

Time horizons: short under one year, medium one to five years, long more than five years (page 45).

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

Reference: page 47 (material topic list) and pages 53-56 (the disclosure requirement tables).

KA prints a full ESRS content index. "The following tables list all of the ESRS disclosure requirements in ESRS 2 and the six topical standards that are material to Kongsberg Automotive (KA) and have guided the preparation of KA's sustainability statements. The company has omitted all the disclosure requirements in the topical standards E2, E3, S3, and S4, as these are below materiality thresholds" (page 53).

The index also carries incorporation by reference: to the Corporate Governance section for GOV-1, to the Remuneration Report for GOV-3 and ESRS E1 paragraph 13, and to pages 23-28 for SBM-1 (pages 53-54).

The convention for gaps is stated: "In cases where no information related to a disclosure requirement is available, no reference is made" (page 53). Nine rows carry "n/a" instead of a page reference - E1-7, E1-8, E1-9, E4-6, E5-6, S1-12, S1-15 and G1-5 - and five of those additionally carry a "Phase-in option used" flag in the Additional Information column (pages 54-55). G1-5 is annotated "Subtopic not material" (page 56).

The basis for preparation records the reliefs relied on: "KA has not opted to omit information corresponding to intellectual property, know-how or results of innovation, but opted to use the applicable phase-in provisions listed in ESRS 1 Appendix C" (page 39).

Transition plan for climate change mitigation

Reference: pages 64-66.

"KA's climate change transition plan covers Scope 1 and 2 and is based on several key elements. It does not cover Scope 3 yet" (page 64). Three long-term strategic goals are set out (page 64):

• Carbon-neutral products by 2039
• 100% renewable purchased energy by 2030
• Reduction of Scope 1 and 2 CO2e emissions by 85% (base year 2023) by 2030 and zero Scope 1 and 2 CO2e emissions by 2035

Decarbonisation levers, with estimated contribution to the 2035 target (page 65):

"KA's target setting is in line with European climate neutrality targets and also reflects the Science Based Targets Initiative (SBTi) recommendations. KA is not excluded from the EU Paris-aligned benchmarks. The targets and transition plan have been approved by the ELT" (page 64).

Locked-in emissions are addressed qualitatively: "Potential locked-in GHG emissions are limited but relevant in relation to KA's partially fossil fuel-based production sites and machinery" (page 65). On funding: "To achieve the above key actions, opex and capex are necessary and are considered within the annual budget planning process" (page 65) - no amounts are given.

2025 progress was limited by the restructuring: "No further significant actions or the development of Scope 3 targets and roadmaps were initiated in 2025" (page 64).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 impacts, risks and opportunities section, where this content is disclosed in the FY2025 report (pages 45-46, 62-63). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against; the ESRS content index maps ESRS 2 IRO-1 for climate to pages 45-46 and 62 (page 54).

Risk classification (paragraph 15). The E1 IRO table splits risks explicitly into physical and transition: "Climate change adaptation - physical risks" is typed Physical risk, while "CO2 emissions (Scope 1, 2, and 3)", "Climate change adaptation - transitional risks" and "Renewable energies" are typed Transitional financial risk (pages 48, 63). "KA faces both physical and transitional dimension risks of climate change" (page 62).

Methodology (paragraph 16). "KA has reviewed climate-related physical risks affecting its own operations as well as in its value chain. The assessment considered its exposure to climate-related hazards of lower and higher magnitudes (above and below the 1.5°C global warming scenario). Discussions on transitional risks within the double materiality process were mainly driven by the anticipated shift of the global automotive industry as a whole to lower- and zero-emission vehicle solutions and the industry's alignment with the Paris Climate Agreement" (page 62). The DMA time horizons apply to both risk types.

Scenario analysis (paragraph 17) was not performed. "KA has not performed a separate formal climate risk scenario analysis, and no external climate risk simulation tools or standards have been used" (page 62). The basis for preparation confirms the deferral: "comprehensive climate change scenario analysis or formal resilience analysis" has "been deferred to 2026" (page 39). Because no scenario analysis was used, paragraph 17 does not apply and its absence is not a gap.

Climate-specific risk identification is also presented under ESRS 2 IRO-1 and SBM-3 in this report.

Resilience in relation to climate change

Back-filled from the E1 actions and transition plan section and the basis for preparation, where this content is disclosed in the FY2025 report (pages 39, 64). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

No ESRS resilience analysis was carried out. "A formal resilience analysis was not conducted in 2025. KA will consider conducting a formal resilience analysis in the comprehensive review of its sustainability strategy in 2026" (page 64). The basis for preparation gives the reason: the 2025 reorganisation meant "limited new environmental initiatives were launched in 2025... The same goes for comprehensive climate change scenario analysis or formal resilience analysis" (page 39).

What is disclosed instead is a qualitative argument from the product portfolio. The report maps KA's product groups (thermal management, gear control systems, clutch actuation, fluid management, electric actuators, vehicle dynamics, compressed air management, steering columns, pedals) against ICE, HEV, PHEV and BEV/FCEV drive systems, and concludes: "KA's product groups are already applied in multiple powertrains, underlining the resilience in the product portfolio to climate-related megatrends such as electrification" (page 64).

Two further resilience statements appear in the report, though outside E1: KA's response to the E1 physical-risk IRO cites "ISO 14001 certification of all plants", a "Broad supplier portfolio and supplier risk mapping" and an "Internal team of sustainability experts" (page 63); and in E4, "Due to KA's diversified supply chain, no short- or mid-term risks that could negatively affect KA's resilience in this context have been identified" (page 71).

No uncertainties analysis (paragraph 19(b)) and no capacity-to-adapt assessment (paragraph 19(c)) are provided.

Policies related to climate change mitigation and adaptation

Reference: page 63.

"KA's Sustainability Policy articulates the key areas of its own operations approach addressing climate change mitigation as well as renewable energy deployment and is approved by the CEO. The two key pillars are: Alignment of KA's climate goals with the Paris Climate Agreement [and] Reduction of CO2e emissions through the increased usage of renewable energy and alternative raw materials" (page 63).

The company is explicit about how thin the policy is: "The policy does not include further elaborations. It was developed to provide general guidance, and further details in terms of actions and targets are laid out in the sustainability roadmap instead" (page 63).

Two upstream policies also address climate: "there are two policies (KA's Supplier Declaration and KA's Supplier Sustainability Manual) that both focus on upstream value chain and address the need for suppliers to mitigate and adapt to climate change within their operations" (page 63), described further in the S2 chapter from page 86.

Two gaps are stated by the company rather than left to inference: "KA has not adopted formal policies addressing climate change adaptation or energy efficiency. The transition plan for KA's own operations is laid out in KA's sustainability roadmap and not as a policy" (page 63). Energy efficiency is nonetheless the subject of targets and actions (pages 65-66).

Actions and resources in relation to climate change policies

Reference: pages 64-66.

Own operations. Four decarbonisation levers are tabled with 2025 progress (page 65): energy efficiency and energy use reduction - "Energy reduction initiatives across plants resulted in a total energy reduction of 595 MWh in 2025"; switch to renewable electricity - "Increased number of plants using 100% renewable electricity (renewable energy share of 58%)"; electrification of processes, replacing fossil-fuel heating, machinery and vehicles by 2035 - "No update"; and Scope 3.1 - "Roadmap for Scope 1 and 2 emissions is defined. No progress for Scope 3 in 2025". The concrete 2025 action was the Wuxi plant in China switching to 100% renewable electricity in May 2025 (page 66). Key activities included "air leak reduction programs, replacing old equipment with newer and more energy-efficient devices, and reusing waste/process heat" (page 66).

Value chain. "KA initiated two-way communication and engagement with suppliers on decarbonization targets and environmental responsibility. KA's risk assessments, the decarbonization questionnaire, and onsite sustainability audit checklist address environmental and energy management policies and systems, yearly environmental targets, and employee training" (page 65). KA requests supplier data on renewable energy share in electricity and heating and collects primary data "to enable future hybrid Scope 3 upstream emission calculations". A planned Supplier Academy was not delivered: "KA has not established a Supplier Academy yet in 2025, but still plans to do so" (page 65).

The company states plainly that little was added: "No additional upstream or downstream value chain-related actions were introduced in 2025" (page 66). Removals, offsets and internal carbon pricing are not used (page 65). Resources are described only as opex and capex "considered within the annual budget planning process" (page 65).

Targets related to climate change mitigation and adaptation

Reference: pages 66-67 (milestone targets and 2025 outturn), with target values also tabled on page 68.

Milestone targets for combined Scope 1 and 2, 2023 baseline (page 66): 12% absolute reduction by 2025, 85% absolute reduction by 2030, and net zero (100% absolute reduction) by 2035, market-based. Alongside these sit the 100% purchased renewable energy by 2030 goal and carbon-neutral products by 2039 (pages 64, 66).

The 2025 target was missed. "In 2025, the group's CO2e emissions (Scope 1 and 2) were approximately 16,320 tonnes of CO2e (market-based), which equates to a 10% reduction from the 18,113 tonnes of CO2e emitted in 2023 (base year). In 2025, despite the positive development compared to the 2023 base year, the target of -12% CO2e emissions (Scope 1 and 2) compared to 2023 was not achieved. This was partly due to increasing emission rates in one of the largest plants that has not yet switched to renewable electricity" (page 67).

Method and validation: "The described targets follow the absolute contraction approach as there is no sectoral decarbonization pathway for KA's industry defined by any institution... The targets are compatible with limiting global warming to 1.5°C, considering the SBTi target setting tool and the SBTi Net-Zero tool." KA notes its 100%-by-2035 target exceeds the SBTi tool's 63% and the Net-Zero tool's 90% for the same period. But "The targets were developed through workshops with operations management. They are based on internal reduction scenarios and are not externally assured" (page 66).

No Scope 3 target exists. "Up until the end of 2025, no Scope 3 targets or roadmaps were developed" (page 67). Annual energy targets are also set: every plant has a 2026 target to cut energy intensity by 2% against 2025 (page 66).

Energy consumption and mix

Reference: pages 67 and 70 (accounting policies).

Energy consumption, MWh (page 67; 2024 and 2025 figures exclude fuel consumption of company cars):

Absolute energy use fell 0.7%, but intensity rose 9.8%: "This increase is partly due to the lower level of sales compared to a similar number of production sites. A significant portion of the energy consumption (such as heating and cooling) is not influenced by production volumes" (page 66). "All KA revenue relates to high-climate-impact sectors as defined by EU 2022/1288" (page 70).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 68-70 (metrics table and accounting policies).

Emissions, tCO2e (page 68; comparatives restated for a sector-mapping revision in Scope 3.1 and 3.3):

Intensity per net revenue, tCO2e/mEUR: location-based 4,483 and market-based 4,476 in 2025, down from 5,420 and 5,416 in 2024 (page 68).

Scope 3 is dominated by category 11: use of sold products 2,973,658 tCO2e, then purchased goods and services 169,513, upstream transport and distribution 9,275, processing of sold products 5,982, capital goods 5,395. "KA has identified four out of the fifteen categories defined by the GHG Protocol as not applicable, and calculated CO2e emissions for the other eleven categories" (page 69).

Method: Scope 1 uses UK DESNZ factors; Scope 2 location-based uses Carbon Footprint/CaDI 2025 grid factors, market-based uses contractual instruments with residual mix for sites without them; Scope 3.1 uses a spend-based EEIO model (estell by Systain Consulting); Scope 3.11 uses average product weight against vehicle weight over a 10-year assumed lifetime for passenger cars, trucks, buses and sports vehicles (pages 69-70).

Transition plan on biodiversity and ecosystems

Reference: page 71. The index titles this row "Transition plan and consideration of biodiversity and ecosystems in the strategy and business model" (page 54).

"Kongsberg Automotive (KA) has identified biodiversity and ecosystems as a standalone material topic" (page 71), but no transition plan exists. The chapter's position is that the topic is recognised and deferred: "This topic was added to KA's material topics list recently, and there is an understanding within KA that this topic will become more of a focus area in the long term. However, the concrete consequences remain unspecified, and the risks remain abstract. Due to these reasons and for the purpose of internal resource prioritization, KA will monitor developments on this topic" (page 71).

Where the impact sits is stated clearly: "KA has identified its main impact and risks related to biodiversity and ecosystems, primarily concentrated in the upstream value chain, especially for raw materials extraction and mining... The analysis resulted in no impacts or risks directly related to KA sites. The potential impacts and risks are limited to the upstream part of KA's supply chain" (page 71).

Two limits on the identification process are disclosed: "During this process, KA has not consulted with potentially affected communities or other external parties, and no external tools were used in the screening of this topic" (page 71). On resilience, "Due to KA's diversified supply chain, no short- or mid-term risks that could negatively affect KA's resilience in this context have been identified" (page 71).

Policies related to biodiversity and ecosystems

Reference: page 71.

"Currently, KA does not have a specific biodiversity policy. However, given its high relevance in the supply chain, biodiversity requirements are incorporated into KA's supplier policies, including the Supplier Declaration and Supplier Sustainability Manual" (page 71), with further detail in the S2 chapter from page 86.

The reason for not having a dedicated policy is given rather than left implicit: "This topic was added to KA's material topics list recently, and there is an understanding within KA that this topic will become more of a focus area in the long term. However, the concrete consequences remain unspecified, and the risks remain abstract. Due to these reasons and for the purpose of internal resource prioritization, KA will monitor developments on this topic" (page 71).

The two material E4 IROs both sit upstream: "Land degradation" (actual negative impact) - "Land degradation due to mining operations for raw materials. Mining of ores (iron, copper, zinc, and aluminum) all require drastic interventions in local ecosystems and can cause damage" - and "Exploitation" (physical risk) - "Risks to operation/value of services (provisioning) at stake due to progressed exploitation" (pages 49, 71).

No policy content on deforestation, land-use change, invasive species or biodiversity offsets is disclosed.

Actions and resources related to biodiversity and ecosystems

Reference: page 71.

One screening action is reported: "KA conducted an analysis by using the WWF Risk Filter with a focus on Key Biodiversity Areas (KBAs). KBAs are places in the world with a high relevance for species and their habitats. KA used the Risk Filter to screen its locations for proximity to KBAs in 2024" (page 71).

The result and its consequence: "There is only one location (Ramos Arizpe, Mexico) that is directly located in a KBA, and no material negative impacts on the surrounding area were identified. Therefore, no mitigating actions were taken in 2024 or 2025. KA will continue to analyze potential implications and, if relevant, determine the requisite follow-up actions in subsequent steps" (page 71).

The upstream impacts identified in the DMA - land degradation from the mining of iron, copper, zinc and aluminium ores - are not addressed by any action described in the E4 chapter; the response recorded in the IRO table is monitoring: "There is an understanding within KA that this topic will become more of a focus area in the long term. However, the concrete consequences (mechanism of action) remain unspecified. The risks remain abstract. KA will monitor this topic" (page 71).

No resources, budget or time horizon for biodiversity actions are disclosed.

Targets related to biodiversity and ecosystems

Reference: page 71.

The disclosure is a nil return: "Currently, no quantitative metrics or targets have been defined" (page 71). The index lists E4-4 against page 71 (page 54), so the absence of targets is the reported content rather than an omission.

The stated reason sits in the policies subsection: the topic "was added to KA's material topics list recently, and there is an understanding within KA that this topic will become more of a focus area in the long term. However, the concrete consequences remain unspecified, and the risks remain abstract. Due to these reasons and for the purpose of internal resource prioritization, KA will monitor developments on this topic" (page 71).

No ecological threshold, no biodiversity-related target with a base year or target year, and no measure of progress is given. The only quantified biodiversity-adjacent datapoint in the report is the KBA screening result: one site, Ramos Arizpe in Mexico, directly located in a Key Biodiversity Area (page 71).

Impact metrics related to biodiversity and ecosystems change

Reference: page 71.

As with targets, the disclosure is a nil return: "Currently, no quantitative metrics or targets have been defined" (page 71). The index lists E4-5 "Impact metrics related to biodiversity and ecosystems change" against page 71 (page 54).

The only quantitative biodiversity datapoint in the statement is the outcome of the 2024 WWF Risk Filter screening: "There is only one location (Ramos Arizpe, Mexico) that is directly located in a KBA, and no material negative impacts on the surrounding area were identified" (page 71). No land-use metrics, no area of sites owned or managed in or near protected areas or Key Biodiversity Areas beyond that single site count, no species metrics and no ecosystem condition metrics are reported.

The company's own account of why is that the risks "remain abstract" and the "concrete consequences (mechanism of action) remain unspecified", so it will monitor rather than measure (page 71).

Policies related to resource use and circular economy

Reference: page 73.

"KA's Environmental Policy, Sustainability Policy, and the Supplier Sustainability Manual outline the company's commitment to circular economy principles through efficient material use and improved waste management. The Environmental and Sustainability Policies are approved by the CEO, and the Supplier Sustainability Manual is approved by the Executive Vice President Purchasing" (page 73).

Scope of the commitments: "The Environmental Policy includes the commitment to optimize resource use, including the reuse, recycling, and recovery of materials to minimize waste. Due to the nature of the products and business, the focus is on prevention of waste, reduction, reusage, recycling, and recovery. Repair, refurbishment, remanufacturing, and repurposing are less applicable" (page 73). "The Sustainability Policy includes a commitment to produce safe and sustainable products promoting circular business models and the use of recycled materials."

Coverage of the material IROs is stated explicitly: "The policy content addresses the material negative impact of material/resource inflows as well as the circular principles opportunity directly, and the other risks indirectly" (page 73).

The company records the policy set as incomplete: "KA has policies and initiatives in place and is monitoring resource use, but recognizes that the actions and initiatives require further development. The company continues to investigate approaches for advancing and formalizing corresponding initiatives" (page 73).

Actions and resources related to resource use and circular economy

Reference: page 73.

Standing measures: "KA maintains a continuous focus on product innovations aimed at increasing durability, enhancing post-use recyclability, reducing product weight, and minimizing production resource requirements. All KA manufacturing locations are certified according to the ISO 14001 Environmental Management Systems standard... Waste KPIs and local measures are reported monthly for all manufacturing locations and are also reviewed in formalized monthly discussion calls" (page 73).

2025 activity is described as continuation rather than new action: "Actions often depend on local circumstances and individual local initiatives. A few initiatives in 2025 have been continued from 2024, including the reuse of scrap, specifically for plastics and brass, the testing of new material solutions and redesigns in the Research and Development department, and an increase of recycling share through enhanced local waste separation processes" (page 73).

One quantified initiative is disclosed: "The waste oil reuse program of one location from 2023, which reduced virgin oil purchases by approximately 90%, is being expanded to more of the companies' locations" (page 73).

The company states the limit plainly: "No notable additional actions were taken in 2025. Further actions will be determined as part of the sustainability roadmap, including corresponding time horizons and the resources necessary" (page 73), and in the IRO table, "No progress has been made toward this in 2025" (page 73). No monetary resources are quantified.

Targets related to resource use and circular economy

Reference: page 73, with the outturn on page 74.

One annual target is set, expressed through a company-defined index: "To track the effectiveness of KA's actions, an annual global target for own operations was set to reduce the Disposed Waste Index as defined by KA. The target for 2025 was set to -2% compared to 2024 target values as agreed between internal corporate and plant level stakeholders. The target addresses both resource inflows and outflows through the minimization of waste and the promotion of recyclable resource inputs" (page 73).

Basis and limits of the target are disclosed: "The reduction target is not mandated by law. The target is based on the involvement of internal experienced stakeholders and is not based on external scientific evidence" (page 73). The index itself is defined as "The sum of the weight of the total waste disposed to landfill sites and total hazardous waste regardless of whether it is diverted or disposed of, divided by total product sales" (page 75).

Outturn. "The disposed waste index for 2025 amounted to 0.782 (2024: 0.966), depicting a decrease of -19% compared to 2024. Thus, the target for 2025 was surpassed, largely due to the lower amount of total waste directed to disposal" (page 74). A footnote corrects a prior-year error: "0.976 was 2023 Index number, while 0.966 was 2024 Index number" (page 74).

"The annual target for 2026 has already been set as well as a reduction of -2% on the Disposed Waste index compared to 2025" (page 73). No recycled-content or secondary-material target is set.

Resource inflows

Reference: pages 72-75.

Materials used, with the input mix described first: "KA's primary input materials include different metals (e.g. brass and steel) and plastic (e.g. PTFE and polyamide). These materials are either directly assembled or transformed during production processes such as molding, braiding, or stamping... The use of water within the manufacturing processes is limited, and biological materials are not used" (page 72). Packaging "is mainly made from cardboard and plastics, which are fully recyclable, and in some instances, products are delivered in multi-use boxes provided by the customers themselves" (page 72).

Metrics (page 74):

The secondary-materials figure is deliberately conservative and understated: "The use of secondary or recycled components includes brass that is treated by external suppliers and then reused at the Raufoss plant. In practice, the recyclable rate of resource inflows, metals in particular, is higher, but the corresponding data is not available for the 2024 and 2025 reporting periods" (page 73). The accounting policy repeats this: base materials "do have a recycled portion. However, this is not actively tracked internally, and a conservative approach was applied" (page 75). The 2024 figure was restated "due to an improvement in data availability for treated and reused brass in Raufoss" (page 74).

Estimation basis: actual data 1 January to 10 December 2025 with December estimated; production machinery inflows excluded for lack of weight data (page 75).

Resource outflows

Reference: pages 72, 74-75.

Products. "KA's products mainly consist of metals and plastic in a variety of degrees depending on the product group. The durability of the products has to align at least with the lifetime of the vehicle they are built into as defined by industry standards, typically 10-15 years. In general, most product materials are recyclable, but the actual recycling rate is dependent on the recycling infrastructure for vehicles in the different countries. Some products would be repairable, but repairing could be less efficient than recycling and replacing parts with new ones" (page 72).

The recyclability metric: "The overall recyclable content of products sold in 2024 and 2025 based on weight is between 80%-90% of total weight. The actual recycling rate of products sold in 2024 and 2025 is dependent on the recycling infrastructure for vehicles in the different countries at the end of the lifetime of these products, which is at least 10-15 years into the future" (page 74). It is calculated from total weight of products sold by product group, applying "The average recyclable rate of the product groups, based on respective product group experts" (page 75).

Waste. "The majority of KA's generated waste is diverted from disposal, and the percentage of non-recycled waste also decreased from 14% in 2024 to 13% in 2025. Total waste generated decreased by -3.5% compared to 2024. The share of landfilled waste of total waste also decreased from 6% to 5%, while the share of incinerated waste stayed stable at 8%" (page 74). The full waste table is reproduced under E5-5 Waste.

No recycled-content percentage for packaging and no reused-product metric are disclosed.

Waste

Reference: page 74 (resource outflows table), accounting policies page 75.

Waste, tonnes (page 74):

Waste streams: "The materials present in KA's waste include scrap metal, wood, electronic waste, paper, cardboard, plastic, lubricants, and solvents" (page 72).

Method (page 75): waste is "collected by third-party waste management companies and waste intended for collection. It is measured through invoiced amounts from waste management companies. No radioactive waste is generated by KA's own operations." A simplification is disclosed: "We estimate the preparation for reuse and other recovery operations to be negligible. Therefore, all diverted waste is classified as recycled", and the hazardous-waste treatment split of the plants with data "has been applied to all locations, assuming similar treatment across all plants."

The Disposed Waste Index fell to 0.782 from 0.966, a 19% reduction, beating the -2% target (page 74).

Policies related to own workforce

Reference: pages 78, 81, 84.

Code of Conduct - "the cornerstone of its ethics framework... It outlines expectations for behavior, decision-making, and interactions with stakeholders. This includes topics such as general behavior expectations, anti-corruption and bribery, anti-fraud, conflict of interest, compliance with laws, equal treatment, anti-harassment, data privacy, and responsible communication" (page 78), available in 12 languages and approved by the Board (page 99).

Human Rights Policy - "outlines our commitment to respecting human rights, including labor rights, of people in KA's own workforce and its value chain. It also specifically addresses human trafficking, forced or compulsory labor, and child labor. KA applies international, best-practice standards in circumstances where local laws and regulations set lower standards... The policy is approved by the ELT and was published in December 2024" (page 78).

Diversity and Inclusiveness Policy - "In 2025, the Diversity and Inclusiveness Policy was updated to protect groups at particular risk of vulnerability within KA's own workforce" (page 81).

Remuneration policy - "defines salary-setting structures, position evaluation, and variable salary frameworks... The policy covers all employees at the company and focuses on the office employees" (page 81).

HSE policy - "setting the standards for how the company protects and ensures the wellbeing of its employees... The policy covers all KA employees and facilities", supported by ISO 9001, ISO 14001 and ISO 45001 certification (page 84).

One planned policy was dropped: a global internal mental wellbeing policy was assessed in 2025, but "it became clear that a global policy does not easily capture all the local requirements and that the existing local policies already address the topic more appropriately" (page 84). A revision of the training policy was postponed to 2026 (page 81).

Processes for engaging with own workforce and workers' representatives about impacts

Reference: pages 43, 77.

"KA engages with its own workforce both directly and indirectly through multiple processes to inform them about decisions and provide frequent updates. KA uses platforms such as the KA Intranet and regular global town hall meetings, followed by individual meetings for functions and business units. Daily interaction with trade unions and their representatives completes the picture" (page 77).

New in 2025: "In 2025, KA started a regular engagement survey to collect structured feedback to understand what matters most to KA's employees. These surveys are followed up by local action plans to improve employee engagement. Social events are also an important factor to promote team spirit" (page 77). The survey is also listed as one of KA's responses to the S1 IROs: "Introduction of an Employee Engagement Survey, with regular iteration to measure results of the action plans" (page 76).

Employees are one of the five stakeholder groups in the SBM-2 table, engaged through "KA intranet, Town hall meetings, Board representation for employees, Day-to-day cooperation between unions and employers, Staff meetings, Social events", with outcomes recorded as "Health and safety as a top focus for plant management" and "Wellbeing topics to be developed" (page 43).

On representation: "There is no European works council in place, but rather local unions and committees. KA cooperates with and maintains an open and trusting relationship with trade union representatives" (page 79). No single named senior executive is identified as operationally responsible for engagement.

Processes to remediate negative impacts and channels for own workforce to raise concerns

Reference: pages 77, 102.

"SpeakUp® is KA's communication channel for internal and external parties to report breaches or suspected breaches of company policies, the Code of Conduct, or other regulations. This channel is provided by an external service provider and offers full anonymity to employees and stakeholders reporting misconduct. The system enables two-way communication and maintains global privacy and security standards through routine audits" (page 77).

Handling and escalation: "All reported concerns are received by KA's General Counsel and EVP HR. The General Counsel is responsible for ensuring that grievances are investigated using the appropriate means, e.g. internal resources from Finance, Legal, or HR, or retained external resources. The General Counsel provides quarterly reports to the CEO of all ongoing and closed matters concerning potential Code regarding Conduct violations. Significant and serious matters are reported to the Board of Directors" (page 77).

Protection from retaliation: "KA ensures whistleblowers who report potential violations in good faith are protected from retaliation and any other negative consequences" (page 77), and concerns are handled "without fear of retaliation in line with the EU Whistleblower Protection Directive (EU Directive 2019/1937)" (page 102).

Access: "KA's Code of Conduct outlines how individuals can report a concern via SpeakUp's® web or phone lines" (page 77), with links on the external website and intranet (page 102).

Effectiveness is not measured by an awareness or trust metric for own employees; the report notes only that the rise in cases "shows an increase of awareness of and engagement with the available channels" (page 80).

Taking action on material impacts on own workforce

Reference: pages 78-79, 81, 84-85.

Working conditions. "The Code of Conduct training is an integral part of the onboarding process. To ensure a consistent and constant update for all KA employees, the company rolled out a new process in Q4 2025 which provides transparency on training completion status. The challenges mainly related to documentation for non-IT users were solved" (page 78). "Infringements reported internally or via the SpeakUp® hotline are systematically investigated" (page 78).

Social protection and wages. The workforce is covered by social protection "primarily through national country legislation and supplemented by additional company benefits", with company benefits filling gaps specifically in India and the US (pages 78-79). On adequate wages, "A structured approach requires job grading and benchmarking to assess wage alignment and define adequacy across the countries in which the company operates. These initiatives are still in progress" (page 79).

Equal opportunities. The remuneration policy and global HR Procedure "were reviewed and updated in 2025". "The company conducts annual performance and career development reviews for approximately 98% of its office employees" (page 81). A structured job architecture project was started in 2025 for completion in 2026 (page 81).

Health and safety. "Safety First is KA's company-wide initiative to develop a value-based and sustainable health and safety culture, supporting the goal of zero accidents" (page 84). "New in 2025 is the introduction of a monthly review covering all new and existing activities in KA's facilities and work areas." Every manufacturing facility has a health and safety committee "authorized to halt any hazardous processes", and 668 HSE audits were performed in 2025 (pages 84-85). Resources allocated to these actions are not quantified.

Targets related to own workforce

Reference: pages 81-82, 79 and 85.

KA is explicit that most own-workforce targets are qualitative: "Global targets set in the working conditions area are of a qualitative nature. There are no quantitative targets for this area, but insights are used for individual follow-ups. Internal benchmarks and comparisons with industry standards are regularly applied" (page 79). The same wording is repeated for equal opportunities: "Global targets in the equal opportunities area are of a qualitative nature. There are no quantitative targets for this area" (page 81).

Targets that are stated and tracked:

• Learning platform. "One of the main targets for 2025 was the further development of the Percipio learning platform to support professional development, which was achieved through enhanced employee engagement with the platform. In 2025, 483 employees have engaged with the platform, dedicating more than 1,000 hours to their personal and professional growth" (page 81). The 2026 target is "to further enhance employee and leadership development" through a leadership development programme, summer internships and a graduate programme.
• Equal pay. "As part of the equal pay initiative, a key target for 2026 is the establishment of a robust job architecture with globally consistent job levels defined across the organization to increase comparability" (page 82).
• Health and safety. "KA's 2026 target is to reduce the incident rate below 0.90" (page 85), against 0.99 achieved in 2025.

Workers are not described as involved in setting targets; metrics "are reviewed on a regular basis with the ELT" (pages 79, 81).

Characteristics of the undertaking's employees

Reference: pages 79-80.

Headcount fell during the restructuring. Total employees, including external workers, were 4,505 in 2025 (2024: 4,921) (page 79):

Countries with at least 50 employees representing at least 10% of the total: Mexico 908 (2024: 1,024), Poland 521 (573), Norway 519 (537) (page 79).

By contract type (page 79): permanent 4,183 (2024: 4,550); temporary 322 (181); full-time 4,358 (4,780); part-time 141 (119). Internal employees excluding external workers were 4,228 (2024: 4,595) (page 82).

Turnover: "The turnover in 2025 showed a downward trend, standing at 20% (2024: 33%), including all types of reasons for departure", 892 leavers in absolute terms against 1,477 in 2024. "Besides further announced reductions in overhead areas which reside mainly in involuntary turnover, KA recognized a postive downward trend for voluntary leavers... The overall number of employees decreased to comply with the market demands, and as announced improve KA's cost structure" (page 79).

Method: "Headcount is counted as 1 for active, short-term leave, long-term leave, and suspended employees, regardless of whether they are full time or part time... Employee data is based on KA's SAP SuccessFactors system" (page 80).

Characteristics of non-employee workers

Reference: pages 79-80.

"At the end of 2025, KA's workforce included 277 external workers (2024: 326), representing 6% (2024: 7%) of the total workforce. The most common type of external workers are those who cover fluctuations in production capacity or bring in additional skills" (page 79).

External workers are also shown in the employee table under "Not reported" gender, 277 in 2025 against 326 in 2024, within a total workforce of 4,505 (page 79). The distinction between internal and external workers is carried through the diversity table, where internal employees total 4,228 in 2025 (2024: 4,595) against the 4,505 total workforce (page 82).

Definition: non-employees are "external workers or consultants who do not have a direct contract with KA but have a direct contract with an agency company" (page 80). Headcount is measured at year end.

The disclosure gives the total and its share of the workforce but does not break external workers down by type (self-employed versus provided by an undertaking primarily engaged in employment activities) or by country.

Collective bargaining coverage and social dialogue

Reference: pages 79-80.

"KA respects the right of its employees to associate freely and to join or not to join trade unions and works councils without fear of discrimination or retaliation. There is no European works council in place, but rather local unions and committees. KA cooperates with and maintains an open and trusting relationship with trade union representatives" (page 79).

Coverage rose sharply: "In 2025, 63% (2024: 50%) of KA's internal employees were covered by collective bargaining agreements", split into "EEA countries: 69% (2024: 74%)" and "Non-EEA countries: 57% (2024: 30%)" (page 79). The jump is driven by the non-EEA figure nearly doubling; no explanation for the change is given.

Country tables for locations with more than 50 employees representing more than 10% of the population show, for 2025, Poland in the 0-19% coverage band, Norway in the 60-79% band and, for non-EEA employees, Mexico and Norway in the 80-100% band, with Poland and Norway also carrying workplace representation entries (page 80). The 2024 table was "Restated... to include only countries above the threshold of >50 employees and >10% of population for comparability purposes with 2025" (page 80).

Method: "Total headcount covered by collective bargaining agreements divided by total headcount of KA's internal employees" (page 80). Terms of employment for internal employees are "based on individual agreements and may refer to the existing collective bargaining agreements" (page 79).

Diversity metrics

Reference: page 82.

"In 2025, women made up 37% of the total workforce, which remained unchanged compared to 2024, and 0% of the ELT. This was also driven by a significant reduction in the size of the ELT" (page 82).

Age distribution of internal employees (page 82): under 30, 673 (16%); 30-50, 2,231 (53%); over 50, 1,324 (31%).

On the Board requirement: "As a Norwegian public listed company, KA is required to have at least 40% female representation on the Board of Directors (the Board), excluding employee representatives. By the end of 2025, KA's Board (excluding employee representatives) comprised five members, two of whom were women, maintaining the ratio from 2024 and fulfilling the requirement" (page 82).

KA names the gap itself: "The company has identified a potential leadership pipeline gap, where women are well represented in the workforce but are less frequently represented in management positions" (page 82). Senior management is defined as those reporting directly to the CEO, covering C-level or EVP areas (page 83).

Adequate wages

Reference: page 82 in the ESRS content index (page 55); the substantive text sits on page 79.

No adequate-wage benchmark, and no percentage of employees paid at or above one, is disclosed. What KA reports is a commitment and a project not yet complete: "KA is committed to fair compensation and ensuring employees receive an adequate wage that secures a decent living. A structured approach requires job grading and benchmarking to assess wage alignment and define adequacy across the countries in which the company operates. These initiatives are still in progress and will serve as a foundation for determining an adequate wage in the future. The goal is to establish a sustainable framework that upholds fair pay for all employees in line with company values" (page 79).

The obstacle is the same one that blocks the pay gap analysis: "Currently, the company does not have global job levels defined for the entire work force. Global job levels exist for less than 10% of the workforce" (page 81), and a "structured job architecture implementation project" was started in 2025 for completion in 2026 (pages 81-82).

The remuneration policy is described as covering "all employees at the company", with "Salary structures... based on job leveling and benchmarking, ensuring equitable pay across roles and locations", but it "focuses on the office employees" (page 81).

Where wages in the supply chain are concerned, KA reports separately that suppliers, "especially smaller ones, focus on legal minimum wages without living wage considerations" (page 93).

Social protection

Reference: pages 78-79.

"KA's entire workforce is covered by social-protection measures, primarily through national country legislation and supplemented by additional company benefits, ensuring financial security across various circumstances. This coverage, provided mostly through public programs, protects against the loss of income due to sickness, unemployment, employment injury, parental leave, retirement, and acquired disability" (page 78).

The disclosure covers all five ESRS events - sickness, unemployment from the point of own-worker's own job loss, employment injury and acquired disability, parental leave, and retirement.

KA also qualifies the level of protection rather than stopping at coverage: "It is important to note that the secured income provided during these circumstances is typically limited to a percentage of the employee's salary, with the exact percentage varying by country and aligned with the norms of the respective social security systems. Additionally, where social security measures are limited and do not cover loss of income, employees are safeguarded through additional company benefits, reflecting KA's commitment to their well-being throughout their professional and personal lives. This specifically applies to India and the US" (page 79).

No country-by-country table of which events are covered by public schemes and which by company benefits is provided beyond the India and US note.

Training and skills development metrics

Reference: pages 81-82.

The performance review metric is given: "The company conducts annual performance and career development reviews for approximately 98% of its office employees, promoting growth and alignment with organizational goals. The process excludes employees who joined in the last quarter, as their tenure is insufficient for meaningful evaluation. The structured assessment includes setting targets, employee self-assessment, manager evaluation, calibration for fairness, and transparent communication of outcomes to employees" (page 81).

Learning platform engagement is quantified: "In 2025, 483 employees have engaged with the platform [Percipio], dedicating more than 1,000 hours to their personal and professional growth" (page 81).

Context on the learning approach: "In recent years, KA has initiated various projects related to improving the learning experience for employees. These include regular campaigns to develop a learning culture to enhance employee skills and capabilities. The external training content is supplemented by content developed in-house" (page 81). Training and development platforms named in the S1 IRO response are SuccessFactors and Percipio, alongside a graduate programme, summer internships and a structured succession process (page 76).

Two limits are visible. The review percentage covers office employees only, not the production workforce, and the average number of training hours per employee - the ESRS datapoint - is not disclosed by gender or at all. A revision of the training policy planned for 2025 "was postponed to 2026" because of the reorganisation (page 81).

Health and safety metrics

Reference: page 85.

"For the year 2025, there were a total of eight recorded work-related accidents, all of which involved KA's own employees. Four accidents resulted in lost time, while four incidents required medical treatment (stitches, prescription medication), with employees returning to work afterwards. The overall number of accidents has decreased by four, compared to 2024, with lost days increasing to 285 from 158. The number of plants that remained accident-free in 2025 remained stable at 17" (page 85).

"The incident rate decreased from 1.36 per million hours worked in 2024 to 0.99 per million hours worked in 2025. KA's 2026 target is to reduce the incident rate below 0.90" (page 85).

"In 2024 and 2025, there were no reported cases of work-related ill health or occupational diseases affecting the incident rate, and no work-related fatalities" (page 85).

Coverage: "KA's KPIs cover all of its operations worldwide, including employees and contractors. The company's workforce within manufacturing locations is engaged with formal joint management worker health and safety committees, and all of KA's operational sites conduct employee health and safety risk assessments in line with KA's minimum requirements" (page 85). Manufacturing facilities are certified to ISO 45001 (page 84).

Audits (page 85): internal 628 in 2025 (2024: 500), external 40 (42), total 668 (542). "The number of internal audits performed is a combination of risk assessments and audits."

Definitions for accidents, ill health, incident rate, lost days and fatalities are given, each covering full-time, part-time and temporary workers (page 85). The percentage of own workers covered by a health and safety management system is not stated as a figure.

Compensation metrics (pay gap and total compensation)

Reference: page 83.

Both figures are reported as printed in the statement. KA's commentary: "The gender pay gap at the group level is 70% and reflects the composition of KA's workforce and industry dynamics. This gap was slightly increased by 1% compared to the previous year. The gap is influenced by the distribution of men and women across different roles, with a higher proportion of men in senior and technical positions, as well as broader industry trends and career progression patterns" (page 83).

KA warns against relying on the number: "As mentioned earlier, the formal job leveling system is under development; for this reason, this figure should be considered a rough estimation rather than a precise measure, nor is it a direct indication of unequal pay for equal work" (page 83).

On the pay ratio: "The ratio of the highest-paid individual's base salary to the median base salary of all employees is 20 compared to 17 in 2024. This reflects the company's diverse geographical footprint" (page 83).

Methods (page 83): the pay gap is "the difference between the average annualized base salary for men and women divided by the average annualized base salary for men", full-time basis, all internal employees except interns and working students, "based on annual base salary, excluding fixed allowances and variable components due to limited global data availability". The pay ratio excludes the highest-paid individual from the median.

Incidents, complaints and severe human rights impacts

Reference: pages 77, 80.

(page 80)

"In 2025, one incident of discrimination was reported (2024: no cases). Further, no legal cases, fines, or penalties regarding discrimination were brought against the company or its employees. The total number of cases collected and tracked throughout various channels amounted to 37 (2024: 5 cases). The number of tracked cases shows an increase of awareness of and engagement with the available channels" (page 80).

The seven-fold rise is attributed to awareness rather than to deterioration. The whistleblowing disclosure in G1 gives the resolution rate for the same population: "In 2025, 37 whistleblower reports were received, of which 30 were resolved within the reporting year. In 2024, five reports were received, of which four were resolved within the same reporting year" (page 102).

Channels and handling are described under S1-3: SpeakUp® run by an external provider, anonymity, receipt by the General Counsel and EVP HR, quarterly reporting to the CEO and escalation of serious matters to the Board (page 77).

No severe human rights incidents in own operations are reported, and no monetary amount of fines is disclosed because there were none.

Policies related to value chain workers

Reference: pages 88-89.

"Corporate and supply chain policies outline KA's human rights and labor rights commitments, applying to all suppliers and value chain workers" (page 88). The instruments are:

• Supplier Declaration, with reference to the more detailed Supplier Sustainability Manual, which "summarizes the most important environmental, social, and ethical requirements for suppliers and, in turn, their suppliers. These requirements were updated in 2024 to include new legal and industrial requirements and standards, especially regarding human and labor rights" (page 88)
• Responsible Minerals Sourcing Position Statement, "which was updated in 2025 and assesses suppliers' compliance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas" (page 88)
• Human Rights Policy, "which applies to its business partners and workers in the value chain" (page 88)
• Supplier Quality Manual, which "specifically refers to the regulations on the Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH)" (page 88)

Alignment is stated against the UN Universal Declaration of Human Rights, the UN Global Compact and UNGPs, OECD guidelines, the ILO Declaration on Fundamental Principles and Rights at Work, RBA and RMI guidelines, and named legislation including the Norwegian Transparency Act, the Canadian Forced and Child Labour in Supply Chains Act, the US UFLPA, the UK Modern Slavery Act, the CSDDD, the German LkSG and the CSRD (page 88).

Implementation and review: "All purchase orders generated through SAP and Jaggaer systems contain explicit references to sustainability requirements"; "KA reviews these documents through memberships and benchmarking approximately every two years or as needed" (page 88). A gap is admitted: "The company also identified a minor gap with regard to customer-directed suppliers" (page 89).

Processes for engaging with value chain workers about impacts

Reference: pages 94-95.

Engagement is indirect, through suppliers, with direct worker contact limited to audits: "KA engages with supply chain workers through regular supplier assessments, audits, site visits, and business meetings to evaluate labor conditions and management system implementation. On-site audits of selected high-risk suppliers include worker interviews as the primary engagement method" (page 94).

Who is targeted: "Individual and group interviews aim to gather insights from potentially vulnerable or marginalized workers, including migrant workers, minorities, blue-collar workers, women, and workers with disabilities. Interview findings provide guidance for KA's ongoing supplier engagement practices, including plans for corrective action as well as revisions of policies and processes. Where possible, trade union and worker council representatives participate in these interviews" (pages 94-95).

Supplier-level engagement runs through the buyers: "The Sustainable Purchasing teams maintain direct contact with suppliers and proactively encourage dialog. Beyond annual business reviews, additional engagement occurs through: New business opportunities, Escalation situations, New tasks and issues, Ad hoc inquiries" (page 94).

KA names the limit on how representative this is: "Limited resources for audits and individual meetings affect comprehensive representation. This is compensated for by drawing on research, databases, and guidance on both an industry and global scale" (page 95). In 2025 the base was five on-site first audits and three online follow-up audits (page 91).

Vulnerable groups are also identified upstream: workers "involved in the mining of conflict minerals in high-risk areas", those "exposed to elevated health and safety risks through chemical handling or machine operation", and migrant workers and women (page 87).

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

Reference: page 95.

Three channels are described (page 95):

• "KA's internal whistleblowing system, SpeakUp®, enables both internal and external stakeholders to report and record concerns"
• "Media monitoring: A global media screening tool (RiskMethod) monitors suppliers, their industries, and geographical locations, triggering alerts for publicly identified human or labor rights issues. Alerts prompt immediate buyer notifications and investigative action"
• "Corrective action: KA supports development and improvement where negative impacts are identified"

KA is unusually candid about whether the grievance channel actually reaches supply chain workers: "Workers in the supply chain have free access to use the KA SpeakUp® service. While suppliers are informed of this resource, there is no evidence yet of supply chain workers' awareness or trust in the reporting system. No supply chain-related reports were received in 2024 or 2025" (page 95).

On remediation: "In 2024 and 2025, no financial remediation was required as KA contributed to but did not directly cause negative impacts through its business relationships" (page 95), and "No cases of forced labor or child labor were identified in KA's operations or supply chain in 2024 or 2025. Therefore, no remediation activities were required" (page 95).

Escalation exists but is under repair: "A formal escalation process provides guidance for addressing sustainability-related risks or incidents (including human and labor rights) through the Supplier Risk Team. Due to the recent organizational changes, the risk escalation process needs to be revised and relaunched" (page 93).

Taking action on material impacts on value chain workers

Reference: pages 88-94, 96.

Due diligence runs on three levels (page 90): "I. The ESG-related risks associated with the supplier's country of origin are analyzed. II. Suppliers are expected to share or conduct an evidence-based, externally validated self-assessment questionnaire covering KA's required topics and issues. III. KA conducts on-site sustainability audits, performed by independent third-party auditors, with follow-up audits conducted by second-party auditors."

2025 results (pages 90-91, 96):

• "In 2025, 90% (2024: 86%) of direct material spend was with suppliers who have signed the Supplier Declaration. 10% (2024: 9%) of indirect material suppliers have signed the Declaration"
• "By the end of 2025, 469 suppliers, covering 90% (2024: 88%) of KA's yearly direct material purchasing spend, completed the questionnaire or provided an equivalent, valid sustainability risk assessment" (the SAQ on the Supplier Assurance platform, SAQ 5.0 from 2025)
• "In 2025, KA commissioned five (2024: eight) on-site first audits and three online follow-up audits (2024: one), all conducted by a third party"
• "42 suppliers received individual recommendations and explanations. By year-end, 15 suppliers improved from high to medium risk, and 18 suppliers improved from medium to low risk"
• "Global training activities reached 98.6% coverage within KA's Purchasing departments" (2024: 96.7%)
• Conflict minerals: 427 suppliers assessed with an 89% CMRT response rate, and 240 suppliers with a 65% EMRT response rate (page 94)

Audit findings carry severity labels: missing formal human and labour rights policies, missing management systems, weak grievance mechanisms and a focus on legal minimum wages rather than living wages are all "widespread, systematic"; excessive working hours are "individual incidents" (page 93).

Outcome: "In 2024 and 2025, no significant breaches or human rights impacts were identified, particularly regarding child or forced labor. No supplier relationships were terminated for such or any sustainability conformity reasons in either year" (page 93).

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

Reference: pages 96-97.

KA sets one-year KPI targets rather than a baseline-and-horizon structure: "Rather than setting a baseline year, KA compares performance against the previous two years, continuously striving for improvement" (page 96). Long-term targets are qualitative because of "the complexity of human and labor rights issues in the global automotive industry... along with global and country-specific trends and regulations beyond KA's control" (page 97).

Main KPIs and one-year targets (page 97):

Mid-term targets include maintaining ">90% Supplier Declaration acceptance; >90% supplier risk assessment coverage" and training "purchasing staff (>95% coverage)". Long-term targets are qualitative (page 97).

Workers are not directly involved: "While supply chain workers and their representatives are not directly engaged in target setting, their input is incorporated through publicly available guidelines, research findings, and insights from ongoing engagement processes" (page 96).

Business conduct policies and corporate culture

Reference: pages 99-100.

"KA's Code of Conduct is the cornerstone of its ethics framework and is available in 12 languages. It outlines expectations for behavior, decision-making, and interactions with stakeholders. This includes topics such as general behavior expectations, anti-corruption and bribery, anti-fraud, conflict of interests, compliance with laws, equal treatment, anti-harassment, data privacy, and responsible communication among others" (page 99).

Ownership: "The Code of Conduct is approved by KA's Board while the CEO holds the ultimate accountability for its implementation. The General Counsel is designated as the functional owner of the Code of Conduct, responsible for monitoring and updating it to keep it current and effective. The expected behavior for suppliers is outlined in a separate supplier's Code of Conduct" (page 99). Four stated principles govern conduct: integrity, compliance, transparency and accountability (page 99).

Culture: "one of the communicated key priorities 2026 of the newly established ELT is to strengthen KA culture. This is also underlined by the recent structural changes of moving several corporate functions into the BAs, promoting greater ownership and accountability" (page 99).

Training coverage is not reported for 2025. "The completion rate of the Code of Conduct training was 64% in 2024. This figure is rather conservative, because the verification of classroom attendance for workers without a personal computer is quite difficult. In 2025, KA reevaluated the Code of Conduct and its training materials and postponed the refresher to 2026 with the release of a revised Code of Conduct. Therefore, the global completion rate was not compiled for 2025" (page 100). A tablet-based attendance tracking process was rolled out late in 2025 to fix the measurement problem.

Sanctions compliance is described at length, including counterparty screening and contractual commitments not to re-export to Russia and Belarus (pages 99-100).

Management of relationships with suppliers

Reference: pages 102 and 88-93.

"Fair payment terms, such as reasonable payment periods and transparent agreements, foster trust, strengthen business relationships, and encourage collaboration between KA and its suppliers... KA's payment terms align with industry practice and apply consistently across all supplier categories" (page 102).

The supplier base: "Kongsberg Automotive (KA) has a significant global footprint through its 1,465 (2024: 1,475) direct material suppliers in 40 (2024: 38) countries and 5,520 (2024: 5,588) indirect suppliers in 44 countries (2024: 43)" (page 86). Local sourcing is high and is treated as a policy: "Local suppliers account for 88% of direct material purchase spend (88% in 2024) and 98% of indirect spend (97% in 2024). Through local purchasing, KA proudly contributes to regional economic development and employment while reducing environmental impact" (page 86).

Concentration: "In 2025, approximately 7% of suppliers (271 direct material and 304 indirect suppliers) account for 80% of the annual purchasing spend" (page 86).

Vulnerability of suppliers is addressed indirectly, through the SME-aware assessment tooling: "In 2025, SAQ 5.0 was introduced with improvements designed to make the assessment more adaptable and modular for small and micro-sized organizations", and support "will be available to all suppliers, regardless of size" (pages 91, 95).

Relationship management favours development over exit: "KA's approach to business relationships emphasizes supplier development over termination. Business relationships continue when suppliers demonstrate the willingness and ability to improve, with KA providing necessary support" (page 93). "KA seeks to replace suppliers that do not comply with the expected standards despite improvement measures" (page 91).

Prevention and detection of corruption and bribery

Reference: page 101.

"Kongsberg Automotive (KA) has zero tolerance for corruption or bribery. The anti-bribery and corruption policy is laid out in the Code of Conduct. This includes offering, soliciting, or accepting improper payments or gifts in exchange for business advantages. The Code also includes a red flag list, raising employees' awareness of potential occurrences. All employees who have received training on the Code of Conduct are required to provide written confirmation of their understanding of the requirements in relation to corruption and bribery" (page 101).

Reporting and investigation are separated from the operating line: "All cases of bribery or corruption related to KA, its personnel, and representatives must be reported to the General Counsel either directly or via the whistleblowing service SpeakUp® line. This applies even if the bribery attempt is rejected or unsuccessful. All reports or concerns relating to the Code of Conduct will be considered by the General Counsel. The General Counsel is responsible for ensuring that grievances are investigate using the appropriate means, e.g. internal resources from Finance, Legal or HR, or retained external resources" (page 101).

Training is universal rather than risk-targeted, and KA says so: "The Code of Conduct training includes a large section of anti-corruption and bribery training. KA has not defined functions at risk. However, the Code of Conduct training is mandatory for all employees, and potential at-risk functions are therefore included as well" (page 101).

Detection: "Reports of breaches of the Code of Conduct are included in the quarterly plant reporting to Internal Audit... Site audits by Internal Audit also include an assessment of business ethics and the internal control environment. In 2025, three site audits were performed (2024: five site audits) and no incidents were identified during those audits" (page 101).

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS; the 2023 ESRS G1 used G1-3 for corruption prevention.

KA discloses no measurable outcome-oriented business conduct target. The three G1 subsections are each headed "ACTIONS, TARGETS, AND METRICS" (pages 100, 101, 102), but the content under each is action and metric, not target.

Consistent with MDR-T's alternative limb, effectiveness is tracked in the absence of targets:

• Internal audit and plant reporting. "Reports of breaches of the Code of Conduct are included in the quarterly plant reporting to Internal Audit... Site audits by Internal Audit also include an assessment of business ethics and the internal control environment. In 2025, three site audits were performed (2024: five site audits) and no incidents were identified during those audits" (page 101)
• Whistleblowing throughput. "In 2025, 37 whistleblower reports were received, of which 30 were resolved within the reporting year. In 2024, five reports were received, of which four were resolved within the same reporting year" (page 102)
• Training completion. Tracked as a metric, though the 2025 figure was not compiled: "the global completion rate was not compiled for 2025" after the refresher was postponed to 2026 (page 100)
• Payment practices. "In 2025, the average invoice payment time was 78 days (2024: 75 days), with no legal proceedings for late payments" (page 102)

The one quantified forward commitment in the business conduct area sits in the supply chain rather than in G1: the S2 target table sets 2026 targets for Supplier Declaration acceptance and risk-assessment coverage at >90% (page 97).

Incidents of corruption or bribery

Reference: page 101.

"Reports of breaches of the Code of Conduct are included in the quarterly plant reporting to Internal Audit. No such cases were reported in 2024 and 2025. Site audits by Internal Audit also include an assessment of business ethics and the internal control environment. In 2025, three site audits were performed (2024: five site audits) and no incidents were identified during those audits. Furthermore, no confirmed cases of corruption or bribery were reported through the SpeakUp® line in 2024 and 2025 either" (page 101).

"In conclusion, there were no confirmed incidents of corruption reported or identified in 2024 and 2025. Further, no legal cases regarding corruption were brought against the company or its employees" (page 101).

The nil return covers all three detection routes KA operates - quarterly plant reporting to Internal Audit, Internal Audit site audits, and the SpeakUp® whistleblowing line - and both the current and comparative year. No convictions and no fines for violation of anti-corruption and anti-bribery laws are reported because there were none.

For context on volume through the same channel, 37 whistleblower reports were received in 2025 across all subject matter, of which 30 were resolved within the year (page 102), and 37 cases were tracked through the channels for own workforce, of which one was a discrimination case and none was substantiated (page 80).

Payment practices

Reference: page 102.

"Timely payments are crucial for ensuring supplier sustainability and growth. KA's payment terms align with industry practice and apply consistently across all supplier categories. In 2025, the average invoice payment time was 78 days (2024: 75 days), with no legal proceedings for late payments" (page 102).

Both required datapoints are present: the average time to pay invoices, and the number of outstanding legal proceedings for late payments, which is nil for the year.

Accounting policies (page 102): "Average number of days to pay invoices - Average number of days based on accounts payable divided by the sum of cost of the goods sold (direct materials.)"; "Number of outstanding legal proceedings for late payments - Number of outstanding legal proceedings (litigation or arbitration) for late payments."

The rationale given for the disclosure is relational rather than compliance-driven: "Fair payment terms, such as reasonable payment periods and transparent agreements, foster trust, strengthen business relationships, and encourage collaboration between KA and its suppliers. More information on KA's approach to its relationship with suppliers can be found in chapter S2 - Workers in the value chain" (page 102).

The disclosure does not break the average out by supplier size or state the standard contractual payment terms, and does not say what proportion of payments were made within those terms. Payment time lengthened by three days year on year.