Lenzing

Governance roles

Reference: pages 63-65. Indexed under "Governance" (page 53).

Two-tier board: a four-member Managing Board and a fifteen-member Supervisory Board. The Managing Board "is tasked with steering the company's strategic direction and operational management. This includes overseeing the implementation of policies and procedures to manage material impacts, risks and opportunities" (page 64).

• Corporate Sustainability reports directly to the CEO (page 63).
• CEO Rohit Aggarwal "was formally responsible for sustainability in 2025. Since February 2026, Georg Kasperkovitz has assumed responsibility for sustainability matters" (page 64).
• A Managing Board ESG Committee meets quarterly (page 66).
• Supervisory Board oversight sits with the Strategy & ESG Committee and the Audit Committee, "scheduled to meet at least twice a year" (page 65).

Composition (page 64): 19 members (2024: 18), 2 female and 17 male (11 percent female), 4 aged 30-50 and 15 over 50, 5 employee representatives, and 100 percent of Supervisory Board members independent under the Austrian Code of Corporate Governance.

GOV-1 paragraphs 22 b, 22 c i and 22 c iii are incorporated by reference to the Corporate Governance Report and the Risk report (page 57).

Information provided to the boards

Reference: pages 65-66. Indexed to the "ESG committee" section (page 53).

The Managing Board ESG Committee "has been established to accelerate the implementation of the sustainability agenda by strengthening cross-functional alignment... It convenes quarterly" (page 65). It comprises the Managing Board and functional leaders, is led by Corporate Sustainability, and monitors progress on sustainability targets and "evaluate[s] the effectiveness of Lenzing's approach to managing all aspects of sustainability" (page 65).

Topics addressed by both boards in 2025 committee meetings (page 65): climate strategy; customer engagement; sustainability target governance; climate risk management, carbon footprint and LCA; biodiversity approach and conservation projects; industry ratings and benchmarks such as CDP and Canopy; conservation solutions; opportunities for differentiation; and ESRS/CSRD-aligned non-financial reporting and double materiality.

Alignment frequency (page 63): Supervisory Board at least quarterly, Managing Board monthly, ESG Committee quarterly. "Specific targets are established, approved, and regularly monitored by the Managing Board ESG Committee" (page 65).

Sustainability in incentive schemes

Reference: pages 66-67. Indexed as "Board remuneration" (page 53).

The Managing Board Remuneration Policy "is linked to both financial performance and non-financial sustainability criteria (ESG)", and the long-term incentive (LTI) has been expanded to include sustainability targets (page 66). Variable remuneration linked to sustainability "amounts to 6 to 10 percent for the Chairperson of the Managing Board and 4 to 7 percent for its members" (page 66).

Stated twice, and material: "There was no remuneration linked to sustainability in 2025, based on the 2023 tranche, as it was replaced by a special bonus" (page 66), and for climate, "There was no remuneration linked to climate considerations in 2025" (page 67).

LTI-linked targets across three-year tranches (pages 66-67): ZDHC aspirational level at lyocell facilities by 2028; specific GHG emissions per ton of pulp and fiber down 45 percent by 2025 and 47 percent by 2026 (2017 baseline); at least 5 alternative feedstock providers by 2030; 22.5 percent women in positions graded 5a and above by 2025, plus a three-percentage-point average improvement across seven Health Climate Survey categories by 2026; and TRIFR down to 0.8 by 2027.

Remuneration is approved by the Supervisory Board Remuneration Committee (page 66).

Statement on due diligence

Reference: page 67. Indexed as "Statement on due diligence" (page 53) and flagged as an SFDR-derived datapoint (page 83).

Lenzing prints the full GOV-4 mapping table, linking each core element of due diligence to the sections that cover it (page 67):

• (a) Embedding due diligence in governance, strategy and business model – Governance structure (GOV-2), Board remuneration (GOV-3), Material IROs (SBM-3), plus the topical SBM-3 sections in E1 (Risk and opportunity assessment), E4 (Resilience assessment), S1 (Managing social sustainability) and S2 (Workers across the value chain).
• (b) Engaging with affected stakeholders – Governance structure, Stakeholder management (SBM-2), Own workforce (S1 SBM-2), Workers in the value chain (S2 SBM-2), Double materiality analysis (IRO-1).
• (c) Identifying and assessing adverse impacts – Double materiality analysis (IRO-1), Material IROs (SBM-3) and the four topical SBM-3 sections.
• (d) Taking actions – the Actions section "In each material topical chapter" (E1-E5, S1, S2, G1), plus the E1 climate action plan (E1-1), E4 Strategy (E4-1) and G1 Sourcing (G1-2).
• (e) Tracking effectiveness and communicating – Metrics and Targets in each material topical chapter.

Risk management and internal controls over sustainability reporting

Reference: page 68. Indexed as "Risk management reporting" (page 53).

Scope. "A formal sustainability reporting process document also covers internal controls. It outlines the procedures required to generate sustainability disclosures and deliberately excludes activities that fall within other departments such as data quality management."

Approach. The Enterprise Risk Management system "features quantitative risk and opportunity modelling using Monte Carlo simulations, incorporates ESG-related risks and opportunities, and includes climate-related risk assessment in line with TCFD recommendations. The ERM process involves half-yearly risk interviews with relevant internal stakeholders at Group and site level." It "is inspired by the COSO ERM framework and combines both top-down and bottom-up methodologies".

Main risk. "Sustainability reporting is exposed to the risk of misstatement particularly due to human error or incomplete data."

Controls: formal review of reporting requirements by the core project team; topic-specific reviews by Corporate Sustainability experts with cross-checks and dual-control proofreading; Managing Board review and approval of all key disclosures, with the Audit Committee evaluating the final draft and issuing a sign-off recommendation; and limited external assurance. Findings go to the Managing Board and the Audit Committee twice a year.

Strategy, business model and value chain

Reference: pages 58-61. Indexed to "Value creation at the Lenzing Group; Sustainability strategy" (page 53).

"The Lenzing Group forms part of the chemical industry and serves the fiber market with regenerated cellulose fibers... The significant product groups according to ESRS are regenerated cellulose fibers and dissolving wood pulp" (page 58). Production runs in two stages: dissolving wood pulp from three biorefineries in Lenzing (Austria), Paskov (Czech Republic) and Indianopolis (Brazil), then fibers "using viscose, modal and lyocell technologies across seven production sites" (page 59).

Value chain (pages 58-59): upstream wood, external pulp, process chemicals sourced predominantly regionally, water and energy; downstream textile and nonwovens manufacturing, brands and retailers, consumer use, then compostability/biodegradability, recycling or incineration.

Employees (page 59): 8,129 head count (2024: 8,228) – Austria 3,418, Indonesia 1,322, Brazil 1,282, China 802, Czech Republic 528, Thailand 276, UK 227, USA 201, others 73.

Strategy. "Naturally Positive" sits within the corporate strategic drivers of sustainability, innovation, premiumization and excellence, on three principles: driving systemic change, advancing circularity, greening the value chain (pages 60-61).

The datapoints table marks SBM-1 40d i-iv (fossil fuel, chemical production, controversial weapons, tobacco) as "Not material" (page 83).

Interests and views of stakeholders

Reference: page 69, with topic-specific SBM-2 sections for own workforce and value chain workers on page 70.

"The Lenzing Group's key stakeholders are individuals or entities that may be affected by its operations, business conduct, and strategic targets or that are in a position to contribute to achieving these targets... The most important stakeholder group are Lenzing's employees" (page 69). The stakeholder map names employees, the Supervisory Board, customers and value chain partners, brands and retailers, consumers, suppliers and contractors, investors, rating agencies, NGOs, industry associations, multi-stakeholder initiatives, academia, media, governments, local communities, certification bodies and competitors.

A stakeholder interests table records what each group cares about, for example investors in "return on investment, resilience, opportunities, risks" (page 69).

Input feeds the DMA: internal stakeholders (Managing Board, department heads, experts) and external stakeholders (suppliers, customers, NGOs, the Supervisory Board, investors, academia) "participated in a survey", and affected communities are consulted regularly on noise and odor at Nanjing (China), Lenzing (Austria) and Purwakarta (Indonesia) (page 81).

Value chain workers (page 70): "Lenzing primarily relies on information from credible external sources, including NGOs, NPOs, trade unions, risk databases and governmental reports".

Material impacts, risks and opportunities

Reference: pages 71-78. Indexed as "Material impacts, risks and opportunities" (page 53).

Lenzing prints one Group-wide IRO table covering E1, E2, E3, E4, E5, S1, S2 and G1 (pages 71-75), giving per row the type, actual or potential, own operations or value chain, time horizon and description. "Short-term refers to one year (the reporting year), medium-term to two to five years and long-term to more than five years" (page 71). The table runs to 42 rows.

Current financial effects (page 76). These "mainly related to its revenue from specialty (net-benefit) products, the Group's investments activities to implement climate and pollution targets in line with the corporate strategy, the impairment testing of assets and the valuation of biological assets."

Investments named (page 76): the Nanjing (China) gas pipeline, boiler and turbine replacing coal-based steam, operational 2025; gas boiler replacement at Mobile (USA); the Grimsby (UK) wastewater treatment plant; an extraction agent purification plant at Lenzing (Austria).

Changes versus 2024 (page 76). "The number of material IROs was significantly reduced. While they are no longer considered material, the affected IROs remain relevant and will continue to be monitored periodically." A two-page removed-IRO table (pages 77-78) gives each removal and its reason, including all of S4 Consumers and end-users and the E5 Waste and E2 Microplastics sub-topics.

Process to identify and assess material IROs

Reference: pages 79-83. Indexed as "Double materiality analysis" (page 53).

Method. Lenzing "revised the methodology in the reporting year to improve structural clarity while maintaining the original assessment parameters (such as scale, scope and likelihood)" after its first ESRS-compliant DMA in 2024 (page 79). The automatic-materiality rule was dropped: "the previous rule of automatic materiality - triggered when a single parameter was scored at highest level - was removed. Instead, such cases were subject to further scrutiny to determine actual materiality" (page 79).

Impacts (page 80). Scale, scope, irremediability and likelihood scored zero to five. Severity above the materiality threshold of 3.7 makes an impact material; potential impacts run through a severity/likelihood matrix, with a separate matrix for human rights where "severity takes precedence over likelihood".

Risks and opportunities (pages 80-81). Financial magnitude one to four (four being over EUR 3 mn) and likelihood one to five, at sub-topic level.

Tools (pages 79-80). Annual site context analysis, LCA, Higg FEM, the ZDHC Gateway, the WRI Aqueduct Water Risk Atlas and the WWF Water Risk Filter.

Two stated limits: "The assessment of social impacts on workers in the value chain is an area where Lenzing recognizes the need for further improvement" (page 80), and "impacts are not part of the risk management process" (page 79).

Disclosure requirements covered

Reference: pages 53-55 (ESRS content index) and pages 83-85 (datapoints from other EU legislation).

Lenzing prints a full ESRS content index listing each disclosure requirement covered and the section carrying it (pages 53-55). It covers ESRS 2 BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1 and IRO-2; E1-1 to E1-6; E2-1 to E2-5; E3-1 to E3-4; E4-1 to E4-5; E5-1 to E5-5; S1-1 to S1-7 and S1-9 to S1-17; S2-1 to S2-5; and G1-1 to G1-4, plus the topical GOV-1, SBM-2, SBM-3 and IRO-1 entries. S3 and S4 do not appear, and neither do E1-7 to E1-9, E2-6, E3-5, E4-6, E5-6, S1-8, S1-10, G1-5 or G1-6.

"The information disclosed is based on the material impacts, risks, and opportunities identified in Lenzing's double materiality analysis. Following the identification of material (sub-)topics, materiality was evaluated at both the disclosure requirement and data point levels" (page 55).

The datapoints from other EU legislation table (pages 83-85) maps each SFDR, Pillar 3, Benchmark and EU Climate Law datapoint to a section or a status. Only E1-9 carries "Material; Phase-in" (paragraphs 66, 66a, 66c, 69); E1-9 67c and E1-7 56 are "Not material" (page 84). Several read "Not material (but can be found in Annex)", including E5-5 37d and 39 waste and S1-17 103a and 104a.

Transition plan for climate change mitigation

Reference: pages 92-93 ("Climate action plan"), indexed at page 53.

"By 2030, the company plans to reduce absolute GHG emissions by 42 percent in Scope 1 and 2 and by 25 percent in Scope 3 (baseline 2021)... The Lenzing Group is included in the EU Paris-aligned benchmarks" (page 92). Net zero is targeted for 2050.

The plan quantifies the 2021-2030 path in kt CO2e: from a 3,592 base to a 1,825 target, with cuts of 255 (continuous improvement), 90 (renewable electricity), 242 (low-carbon fuels), 79 (electrification) and 671 (Scope 3), against a 169 kt increase from expansions (page 92).

Alignment. "The climate action plan for mitigation, approved by the Managing Board, is part of Lenzing's long-term business strategy" (page 92).

Stated gap. "Lenzing is working to strengthen the plan to meet the formal requirements for a transition plan as defined under the European Sustainability Reporting Standards (ESRS) by 2028" (page 92).

Locked-in emissions (page 93). "Lenzing's coal boilers at the site in Purwakarta (Indonesia) and the waste incineration plant at the site in Lenzing (Austria) are significant sources of future locked-in GHG emissions throughout their operational lifetimes."

Barriers (page 93): grid renewable electricity availability, the cost of green hydrogen and ammonia, no level playing field for low-carbon products, and limited partner willingness to share investment costs and risks.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 E1 IRO-1 (pages 81-82) and E1 SBM-3 (pages 94-96), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification. The E1 IRO table separates physical risks (chronic hazards, wood scarcity from non-resilient forests) from transition risks (carbon pricing regulation, reputational risk, RED II/III biomass reclassification) (pages 71-72, 90-91). Results are split into transition categories (policy, technology, consumer sentiment, liability, investor sentiment, reputation) and physical categories (facility disruption, supply risk) (pages 94-96).

Method. "The assessment uses a digital twin approach, which models Lenzing's assets and business activities in a virtual environment including the value chain" (page 82). Horizons are 5, 10 and 20 years.

Scenarios (page 94). NGFS Current Policies (SSP3-7.0, 3.0 degrees C by 2100), NDCs (SSP2-4.5, 2.3 degrees C) and Net Zero 2050 (SSP1-2.6, 1.4 degrees C), with global carbon prices of USD 13, 107 and 244. Storylines were updated to NGFS Phase V in 2025 (page 82).

Limitation. The supply-risk model "currently covers only spruce and eucalyptus"; beech is "not yet available in the model, thus a comprehensive risk analysis of the entire raw material supply base was not yet possible" (page 95).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 (page 76) and the risk assessment sections (pages 82, 94-96). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Result. "Lenzing's strategy and business model were reviewed for climate resilience on the basis of multiple scenario analyses" (page 76).

"Lenzing demonstrates strategic and operational resilience, supported by scenario-based risk assessments, execution of sustainability targets... However, resilience highly depends on continued execution of climate and biodiversity strategies, regulatory developments, access to renewable energy, and collaboration with key value chain partners" (page 76).

Barriers named (page 76): "limited access to grid-based renewable electricity, cost disparities between renewable fuels (green hydrogen, ammonia) compared to fossil alternatives, the lack of a level playing field for low-carbon products, and the willingness of business partners to share the costs and risks."

Uncertainty. "Climate risk quantification involves inherent uncertainty due to complex interdependencies and evolving external conditions. For this reason... results are presented qualitatively" (page 82). AR 9 permits a non-annual refresh.

Adaptive capacity (page 96): supplier diversification, the "Safe Supply" project with "around 300 initiatives for alternative suppliers and supply routes", and flood protection plans.

Policies related to climate change mitigation and adaptation

Reference: page 97 ("Policies"), indexed at page 53.

Four policies govern climate. The Bioenergy Policy is set out in full (page 97):

• Accountability: Chief Pulp Officer, VP Operations and site directors
• Scope: Lenzing Group and upstream value chain
• Objective: "to provide guidance on biomass sourcing for Lenzing's energy production as well as for the biomass sourcing of third parties delivering bioenergy to members of the Lenzing Group"
• Key elements: "Lenzing aims to source biomass from non-controversial sources. For woody by-products and agricultural residues, Lenzing requires transparency about the sourcing region, legal harvesting and a low risk of deforestation. Compliance... is ensured through regular risk assessments... audits and on-site visits, as well as independent third-party certification"
• Against paragraph 25d: "Switching to renewable energy is a core objective of Lenzing's climate action plan."

Three further policies carry MDR-P detail elsewhere: the Sustainability Policy (page 61), which "promotes the continuous improvement of resource efficiency as well as decarbonization along the entire value chain" and under which "Lenzing continuously manages environmental risks, including risks related to climate change adaptation"; plus the HSE Policy and the Group Environmental Policy and Standard (pages 109-110).

Actions and resources in relation to climate change policies

Reference: pages 98-99 ("Actions"), indexed at page 53. Five levers, with 2025 actions and quantified effects.

Continuous improvement. Gas boilers replaced at Mobile (USA) in 2025, "estimated to avoid approximately 8,000 tons of Scope 1 GHG emissions annually at this site"; around EUR 12 mn invested (page 98).

Low-carbon fuels (page 98). At Nanjing (China) a new gas pipeline, boiler and turbine has been "operational since April 2025"; once fully established by 2027, "a reduction of 100,000 tons of GHG emissions as compared to 2021 is expected", on around EUR 30 mn. At Indianopolis (Brazil), LNG from 2026 is "expected to result in a reduction of around 38,000 tons in Scope 1". Prachinburi (Thailand) achieved 100 percent biomass "for only a few months during the reporting year"; about 64,000 tons of reductions are "expected to materialize by 2030 at the latest".

Renewable electricity. 100 percent renewable grid electricity at seven sites, "resulting in a mitigation of around 420,000 tons of GHG emissions"; a new 1.3 MWp photovoltaic plant lifted PV capacity to 8.3 MWp (pages 98-99).

Supplier engagement. Low-carbon sodium hydroxide from three suppliers "saved around 85,000 tons of GHG emissions compared with conventional NaOH" (page 99).

Nature-based solutions. Conservation projects that "do not lead to direct GHG emission reductions" within Lenzing's reporting boundary (page 99).

Targets related to climate change mitigation and adaptation

Reference: pages 100-101, with target-scope emissions on page 104. Indexed at page 53.

Near-term SBT: Scope 1 and 2 absolute emissions minus 42 percent and Scope 3 minus 25 percent by 2030 (baseline 2021) – On track. Long-term net-zero SBT: "at least a 90 percent reduction in absolute GHG emissions (Scopes 1, 2 and 3)" by 2050 – On track (page 100).

Values (page 100): near-term Scope 1+2 from 1.77 to 1.03 mn t CO2 eq. and Scope 3 from 1.82 to 1.37; long-term from 3.59 to 0.36. Scope 3 coverage is "around 97 percent of reported Scope 3 GHG emissions including Categories 1, 3, 4, and 9 and excluding Category 15".

Verification. Targets were revised in 2023 from a 2 degrees C intensity basis to absolute 1.5 degrees C alignment, and "The SBTi verified and approved these targets in 2024" (page 101).

Sub-targets (page 100): 100 percent green electricity at four sites (Achieved); coal phase-out at Nanjing; Prachinburi carbon neutrality by 2030; engagement of 20 key suppliers and of 80 percent of customers with approved SBTs by 2030.

Remuneration-linked intermediate target: "Lenzing reduces 50 percent of specific GHG emissions per ton of pulp and fiber produced (baseline 2017)" by 2027, On track (page 101).

Progress (page 104): Scope 1+2 index at 80 percent of the 2021 base (2024: 95) against a 58 percent 2030 target; Scope 3 index 77 percent against 75.

Energy consumption and mix

Reference: page 102 ("Energy and fuels"), indexed at page 53; paragraphs 37, 38 and 40-43 are SFDR/Benchmark datapoints (page 84).

Total energy consumption: 16.79 mn MWh (2024: 16.63), split 4.79 fossil (2024: 5.46) and 11.99 renewable (2024: 11.16). The renewable share rose to 71.44 percent from 67.20, and the fossil share fell to 28.56 percent from 32.80. Nuclear consumption is zero.

Fossil detail in mn MWh: coal and coal products 1.44 (2024: 1.89), crude oil and petroleum 0.46 (0.37), natural gas 1.59 (1.60), other fossil 0.52 (0.44), purchased electricity, heat, steam and cooling 0.79 (1.16). Renewable fuel including biomass 10.96 (10.14) and purchased renewable energy 1.03 (1.02).

Energy intensity from activities in high climate impact sectors: 0.0065 MWh/EUR (2024: 0.0063). Energy production: 12.27 mn MWh, of which 8.99 renewable.

"Lenzing's absolute consumption of fossil energy decreased by 12 percent, while the use of renewable energy increased by 7 percent. The total energy consumption at the Group level slightly increased compared to the previous year. This change is largely due to a decrease of production at the Lenzing site in Purwakarta (Indonesia) in 2025" (page 102).

Fuel sources are listed by site, with coal used at Lenzing (Austria), Nanjing (China), Purwakarta (Indonesia) and Prachinburi (Thailand). A 2024 unit error, mn MWh/EUR instead of MWh/EUR, is corrected (page 105).

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 103-106, indexed at page 53.

2025 absolute emissions, mn t CO2 eq. (page 104):

• Gross Scope 1: 1.15 (2024: 1.28, minus 11 percent); 28 percent under regulated emission trading schemes
• Scope 2 location-based 0.69 (0.80); market-based 0.27 (0.40, minus 32 percent)
• Scope 1 and 2 market-based: 1.42 (1.69, minus 16 percent)
• Scope 3: 1.45 (1.54, minus 6 percent) – C1 purchased goods 0.88, C3 fuel and energy-related 0.20, C4 upstream transport 0.12, C9 downstream transport 0.20, C15 investments 0.05
• Total market-based: 2.87 (3.23); location-based 3.29 (3.62)
• Biogenic CO2: Scope 1 1.74, Scope 2 0.20, Scope 3 0.88

Intensity (page 104): 0.00110 t CO2 eq./EUR market-based (2024: 0.00121). Specific emissions (page 105): 1.34 t CO2 eq. per ton of pulp and fiber, an index of 52 percent of the 2017 base (2024: 58).

Method (pages 105-106). GHG Protocol with IPCC AR6 GWP100. "Of the total purchased power (electricity and steam), 52 % is bundled with attributes and 4 % is unbundled." Scope 3 Category 1 is 43 percent supplier-specific. Categories 2, 5, 6, 7 and 8 are "relevant but not material" and excluded; Category 10 is excluded because "the company has no visibility into over the processing methods applied by downstream users".

Scope 1 for 2017 and 2021 was recalculated after the fossil share of externally burned waste at Lenzing (Austria) moved to measurement (page 106).

Policies related to pollution

Reference: pages 109-110, indexed at page 54. Three policies are set out in full, plus the Water Policy cross-referenced from E3.

Policy for Health, Safety and Environment (page 109). Accountability: VP Global HSE. Objective: "to protect people from harm and preserve the environment". Against E2-1 15a: "the HSE Policy states that Lenzing protects the environment in which it operates in by minimizing emissions, waste and pollution as well as by improving resource efficiency." Monitored under ISO 14001 and ISO 45001.

Group Environmental Policy and Standard (page 109). It "is designed to reflect the industry best practice and emission thresholds for the best available techniques for industrial pulp and fiber production (EU BAT). In addition, Lenzing adopted the Zero Discharge of Hazardous Chemicals (ZDHC) MMCF Guidelines." Against 15b: "Lenzing commits to eliminate hazardous chemicals (including Substances of Concern and Substances of very high concern) along the supply chain."

Chemical Management Group Standard (page 110). Objective: "to ensure that all risks associated with the handling, storage, transportation, use and disposal of chemicals are controlled and managed", through "comprehensive chemical inventories and approval processes as well as hazard and exposure assessment for each chemical". Emergency procedures, drills and Safety Data Sheets are described against 15c.

Actions and resources related to pollution

Reference: pages 110-111, indexed at page 54. Four key actions: ZDHC, Higg FEM, wastewater treatment plants, and sulfate and COD reduction.

ZDHC. "All Lenzing viscose sites (Lenzing (Austria), Purwakarta (Indonesia), Nanjing (China)) completed the Supplier to Zero Platform assessment and achieved an overall 'aspirational' performance level." For lyocell, testing under the updated ZDHC laboratory guidelines was completed at Mobile (USA) in 2025 (page 110).

Wastewater treatment plants (pages 110-111). The new Grimsby (UK) plant "became fully operational" in 2025; "COD and amine removal exceeded minimum requirements. The project has now moved into its second phase with further optimization underway to reach EU BAT limits in 2026. This strategic investment of EUR 24 mn, covering all project costs, represents a significant step in the site's sustainability roadmap." Upgrades at Mobile (USA) and Purwakarta (Indonesia) carry total investments of EUR 12 mn and EUR 26 mn. At Nanjing (China), "Enhanced wastewater degassing led to a substantial reduction of sulfur emissions to water".

Sulfate and COD reduction (page 111). An extraction agent purification plant at Lenzing (Austria), CapEx EUR 5 mn, was completed in 2025.

Lenzing states a limit plainly: "There is no action regarding the 'Potential negative impact of Lenzing's downstream textile value chain on water pollution'" (page 111).

Targets related to pollution

Reference: pages 111-112, indexed at page 54.

ZDHC viscose target. Aspirational MMCF level for ZDHC wastewater and air emission guidelines at viscose facilities by 2026 – On track. Base year 2020, from 0 to 3 sites. All three "successfully achieved the overall performance at 'aspirational' level" in the 2024/5 assessment (page 111).

ZDHC lyocell target. Aspirational level at lyocell facilities by 2028, On track, five sites from a 2022 base of zero. The 2025 sub-target is marked Delayed: "the facility in Lenzing (Austria) has achieved aspirational level for all parameters except one", and "Currently there are no ZDHC authorized testing laboratories available in the UK" (page 112). This target is relevant to Managing Board LTI remuneration.

Wastewater target. "To improve Lenzing Group's specific wastewater emissions (chemical oxygen demand (COD)) by 20 percent by 2024 (baseline 2014)" – Achieved, from 6,110 to 4,888 tons COD, with a 2025 status recording a "reduction of 24 percent from the baseline" (page 112).

FEM target. Site-level only: "There is no group-level aggregated FEM reduction target" (page 112).

Confidentiality omission, declared. "For confidentiality reasons, Lenzing has omitted information regarding: numbers for specific loads as this requires total fiber and pulp production volumes for Lenzing production sites (ESRS E2-3 23 a)" (page 56).

Pollution of air, water and soil

Reference: pages 113-115, indexed at page 54; paragraph 28 is a Benchmark datapoint (page 84).

Scope. Coverage includes pulp, viscose/modal and lyocell units plus the RVL joint venture, and "There are no material emissions to soil" (page 113). PRTR pollutants enter Group totals only above the EC 166/2006 Annex II threshold, except COD, sulfate, amines and sulfur.

Emissions to air, tons (page 113): sulfur as CS2 and H2S 7,086 (2024: 8,427; 2014: 34,787), SO2 2,148 (2,535), NOx 3,000 (3,351), PM10 148 (135). Specific indices against 2014: sulfur 14.4 percent (2024: 16.9), SO2 41.6 percent (46.8).

Emissions to water after treatment, tons (page 114): COD in target scope 4,381 (2024: 5,626; 2014: 6,110) and all sites 5,192 (6,230); sulfate 162,396 (189,298); amines 94 (183); total nitrogen 360 (138); phosphorus 63 (100); nonylphenol and ethoxylates 0 (0); zinc 5 (5); AOX 18 (24); chlorides 8,963 (8,234); fluorides 5 (4). Specific indices against 2014: COD 76.1 percent, sulfate 66.1, amines 33.6.

Explanations (pages 114-115). Amine and phosphorus falls follow the Grimsby WWTP start-up; the sulfate fall follows stabilized operation at Purwakarta; "The increase of total nitrogen emissions is a result of improved monitoring of water pollutants at the viscose fiber production site in Purwakarta (Indonesia), which was not tested for nitrogen emissions to water before 2025."

Substances of concern and substances of very high concern

Reference: pages 115-116, indexed at page 54.

Scope. "Lenzing discloses all substances of concern (SoCs) and substances of very high concern (SVHCs) across the Group's data inventory and production output. This includes purchased chemicals..., substances produced for on-site use as intermediates, chemical products placed on the market, and substances contained in articles sold" (page 115).

Both limbs of ESRS E2 paragraph 34 are answered. Totals in tons (page 116): SoCs input 70,979 and output 11,234 (2024: 73,985 and 8,769).

By hazard class, input / output in tons (page 115): skin sensitisation cat. 1 (H317) 1,471.05 / 51.92; respiratory sensitisation cat. 1 (H334) 0.03 / 0.03; reproductive toxicity cat. 2 (H361fd) 64,938.30 / 6,604.20; STOT repeated exposure cat. 1 (H372) 64,910.63 / 6,605.03; chronic aquatic hazard (H410, H411) 4,149.13 / 4,149.13; PBT or vPvB 2.17 / 2.17; suspected carcinogen (H351) 80.69 / 6.68.

SVHCs presented separately (page 116), per paragraph 35: respiratory sensitising properties (Article 57f) 0.022 / 0.022 tons; PBT and vPvB 2.172 / 2.172 tons.

Method. Chemicals are identified "by mapping the hazard classes in the production chemical inventories of all Lenzing sites"; mixture quantities come from supplier Safety Data Sheets. A 2024 input error in the skin sensitisation class, minus 53,406.54 tons, is disclosed and corrected (page 57).

Policies related to water and marine resources

Reference: page 119, indexed at page 54. Paragraphs 9 and 13 are SFDR datapoints mapped to this section; paragraph 14 "Sustainable oceans and seas" is marked "Not material" (page 84).

The Water Policy is set out in full (page 119):

• Accountability: VP Global HSE
• Scope and coverage: Lenzing Group and local communities
• Objective: "To ensure responsible water stewardship by managing and conserving water resources throughout Lenzing's operations and value chain, minimizing impacts on communities and ecosystems."
• Key elements: "Lenzing continuously monitors and manages its water use and water emissions, increasing efficiency and reuse while ensuring alignment with best practices and compliance with legal and environmental standards."
• Standards: EU Best Available Techniques, ZDHC, UN SDGs; published on the Lenzing website

Against the topic-specific requirements: 12ai, water use in own operations and products "is governed by a Group-wide Performance Standard"; 12aiii, "Lenzing aims to continuously reduce its water consumption and water-related emissions after wastewater treatment to levels that go beyond legal requirements"; 12c and 13, "Lenzing recognizes the growing global issue of water stress and quality... As part of its sustainability strategy, Lenzing has prioritized water stewardship" (page 119).

The Group Environmental Policy and Standard also applies (page 118).

Actions and resources related to water and marine resources

Reference: pages 119-120, indexed at page 54. Four key actions.

Global water assessment tools in risk management. "Lenzing uses tools such as the WRI Aqueduct Water Risk Atlas and WWF Water Risk Filter to evaluate current watersheds and identify location-specific risks, including regions with high water stress. The facility in Prachinburi (Thailand), which deploys water-efficient lyocell technology, is the Group's only site located in a region of high-water stress." The assessment "is an ongoing annual process and was carried out again in the reporting year" (page 119).

Water footprint assessment. LCA is "the primary tool for assessing cradle-to-gate impacts within direct and indirect operations", supported by growing supplier data: "While initial efforts focused on pulp suppliers, primary data is now also requested from important chemical suppliers" (pages 119-120).

Continuous and targeted measures (page 120). At Paskov (Czech Republic), "corrective measures after a leakage of process and drinking water systems was detected", plus a condensate reuse project running to 2026. At Nanjing (China), "Wastewater is purified by a reverse osmosis unit and reused in cooling towers, thereby reducing freshwater withdrawal."

Higg FEM. Annual self-assessment and third-party verification at all sites; it "requires production facilities to examine prospective water withdrawal and/or consumption".

Targets related to water and marine resources

Reference: page 120, indexed at page 54.

The only Group-level water target disclosed is the FEM target: "To implement and annually update the Facility Environmental Module (FEM) in all pulp and fiber production facilities and share verified modules with customers from 2024" – status Continuous / On track.

• Scope: all Lenzing production sites
• Geographical coverage: Grimsby (UK), Heiligenkreuz (Austria), Indianopolis (Brazil), Lenzing (Austria), Mobile (USA), Nanjing (China), Paskov (Czech Republic), Prachinburi (Thailand), Purwakarta (Indonesia)
• Base year 2017; baseline 0 sites; target value 9 sites
• Status 2025: "In 2025, Lenzing conducted FEM self-assessments and verifications for all sites. Therefore, the target is still on track."

The Higg FEM "provides a comprehensive assessment across key environmental impacts, including energy use, water consumption, air emissions and waste management", and the target was defined by the Group Environmental Management team with Corporate Sustainability, driven partly by customer requests.

Lenzing places consumption targets at site rather than Group level: "Each site has set individual water-use targets for specific baseline and target years." No Group-wide quantified water reduction target is disclosed. Targets for water pollution sit in the E2 chapter.

Water consumption

Reference: pages 121-122, indexed at page 54; paragraphs 28c and 29 are SFDR datapoints (page 84).

Water consumption, m3 (page 121): total 16,321,161 (2024: 13,520,862), of which 609,596 in areas of water stress (2024: 635,726). Total water recycled and reused: 593,519,966 (2024: 471,484,218).

Water withdrawal, m3: total 120,703,520 (2024: 125,792,211), all freshwater – surface water 97,764,520, groundwater 13,273,181, third-party water 9,665,818; 1,316,396 in areas of water stress. No seawater or produced water.

Water discharge, m3: total 104,382,359 (2024: 112,271,349), to surface water 46,150,257 and third-party water 58,232,102. No discharge to groundwater or seawater.

Water intensity: 6,272 m3 per EUR mn revenue (2024: 5,076).

Explanation (page 122). "Total water withdrawal and discharge volumes slightly decreased in 2025... However, water consumption significantly increased in group-wide operations mainly due to less water discharged at the pulp production facility in Brazil as an effect of both optimized operations and increase of recycled and reused water."

Stated limitation (page 122): "many complex recycling systems, such as the reuse of water in different fiber washing steps, are not yet represented and need further assessment... there is currently no established foundation or sufficient data to provide a reasonable estimate of missing water recycling and reuse flows."

Transition plan and consideration of biodiversity in strategy

Reference: pages 123-124, with the resilience assessment method on page 82. Indexed as "ESRS E4-1 Transition plan and consideration of biodiversity and ecosystems in strategy and business model / Strategy" (page 54).

"Lenzing focuses on three areas to reduce its impact on nature: responsible wood and pulp sourcing, its fiber production and products' end-of-use" (page 123). It joined the European Business Nature Commitment and the SBTN Corporate Engagement Program in 2023 and applies TNFD guidance.

The Biodiversity Approach and Action Plan (BAAP) covers the rationale, identification of ecosystem dependencies and impact drivers, locating and measuring them, impact materiality, resilience analysis, and an action plan (page 124). Lenzing states the limit explicitly: "the BAAP does not represent the full biodiversity strategy and transition plan required under the ESRS" (page 124).

Resilience assessment (page 82). Built on the 2024 LEAP analysis, using scenarios SSP1-1.9, SSP2-4.5 and SSP5-8.5 over 0-1, 1-5 and 5-30 year horizons, covering nine production sites and the Austrian and Czech wood supply chain, "about 70 to 80 percent of the wood used in Lenzing's European pulp mills". "Detailed ecosystem scenario modeling was not yet included due to limited data availability... No stakeholders participated in the assessment."

A site-level Biodiversity Action Plan is in place at LD Celulose in Brazil.

Policies related to biodiversity and ecosystems

Reference: page 125, indexed at page 54. Paragraphs 24b and 24d are SFDR datapoints mapped here; 24c "Sustainable oceans / seas practices or policies" is marked "Not material" (page 84).

Biodiversity Policy (page 125). Accountability: SVP Commercial Pulp, Biorefinery and Co-Products, Wood. Objective: "to maintain productive ecosystems healthy, especially forests, while protecting the related biodiversity and ensuring the preservation of ecosystem services." Standards: Kunming-Montreal, TNFD, SBTN, EBNC. Against 23a it "addresses climate change, land-use change, direct exploitation, pollution and invasive alien species"; against 23c, "Lenzing's business model depends on wood as a natural raw material, which results in a material dependency on natural resources, primarily forests".

Wood & Pulp Policy (page 125). Objective: "to source wood and pulp exclusively from non-controversial sources", using "a region-specific due diligence system... FSC and PEFC certifications... and science-based conservation planning". Controversial sources "also include wood obtained in violation of traditional, community and/or human rights... as well as the failure to respect Free, Prior and Informed Consent (FPIC)". Against 24b: "Lenzing does not procure wood from plantations established after 1994."

Social consequences of biodiversity loss "will be assessed as part of the biodiversity strategy" (23f), so are not yet reported.

Actions and resources related to biodiversity and ecosystems

Reference: pages 126-127, indexed at page 54. Actions use the SBTN AR3T framework.

Avoid. "All wood and dissolving wood pulp used by the Lenzing Group is either FSC or PEFC certified or controlled", ensured "through annual internal and external audits" (page 126).

Restore, Brazil. LD Celulose's eucalyptus plantation, "located approximately 800 km away from the Amazon region", applies minimum soil cultivation, plot-specific fertilization, ecological corridors and monitoring of riparian Permanent Preservation Areas; flora and fauna monitoring "covers the entire plantation area" (page 126).

Restore, Austria. With Osterreichische Bundesforste, peat bog restoration in the Ausseerland region completed in 2025, "resulting in the restoration of high-biodiversity wet meadows and ponds for amphibians" (page 126).

Transform. A doctoral project with Wood K Plus on biodiversity metrics produced a published review paper in 2025 (page 127).

Beyond the value chain (page 127): projects in DR Congo, Tanzania, Burundi and China (Fashion Forest, "approximately 35,000 Qinghai spruces across an area of 18 hectares").

"While Lenzing supports several restoration and regeneration projects worldwide... it does not engage in biodiversity offsetting", and "local and Indigenous knowledge on nature-based solutions... [has] not yet been integrated into internal processes" (page 126).

Targets related to biodiversity and ecosystems

Reference: page 128, indexed at page 54.

Conservation Area Brazil target. "To implement conservation solutions on 24,500 ha at the pulp mill in Indianopolis (Brazil) by 2030" – On track. Base year 2020, baseline 13,000 ha, target 24,500 ha. Status 2025: "Lenzing over-achieved its previous target of 20,000 ha in 2024. In 2025, the area was expanded to more than 23,000 ha, and therefore the target ambition and measure was increased to 24,500 ha."

Conservation Projects target. "To engage in further conservation, biodiversity protection and restoration activities in regions where forests are at risk or should be improved by 2025" – Achieved. Scope: own operations, value chain and beyond; geography Europe, Americas and Africa; baseline and target value "N/A". Status 2025 lists the Austrian moorland and peat bog project plus projects in China, DR Congo, Burundi and Tanzania.

Method caveats stated by the company (page 128). "In setting the targets for Lenzing, ecological thresholds, impact allocations and biodiversity offsets were not applied. These targets were set prior to the Kunming-Montreal Global Biodiversity Framework and the EU Biodiversity Strategy for 2030." Development of a new biodiversity strategy "is underway".

"The Conservation Projects target is not linked to a quantitative metric... Outcomes are primarily assessed through qualitative evaluation" (page 128).

Impact metrics related to biodiversity and ecosystems change

Reference: pages 129-131, indexed at page 54.

Stated limitation first. "Land use area alone is not a meaningful metric for impacts, and robust indicators for land-use intensity and biodiversity condition are still under development... As a consequence, no specific actions can yet be derived from existing metrics" (page 129).

LD Celulose land use, hectares (page 129): total area 99,438 (2024: 93,908), of which forest/plantation 71,089 (66,540), FSC-certified 55,012 (48,155), protected 23,563 (22,980), of which required by regulation 19,888 (18,782), and infrastructure 4,786 (4,388). "In 2025, however, 3,014 hectares (2024: 55 hectares) of degraded former agricultural grassland were converted to forest plantations", with no conversion of primary or naturally regenerating forest, savannah, grassland or freshwater ecosystems.

Biodiversity monitoring (page 130). "Biodiversity monitoring has identified around 300 plant species and 440 animal species (2024: around 200 plant species and 450 animal species) within the forest management units of LD Celulose... No significant reduction in species has been observed since monitoring began."

TNFD metrics (page 131) cover total disturbed area (0 ha), rehabilitated area, ecosystem use change and land conserved or restored. Estimation of European wood-sourcing land area began in 2023 but "no results are available at present" (page 129).

Policies related to resource use and circular economy

Reference: page 135, indexed at page 54.

E5 carries no policy of its own. "The topic of resource use and circularity is governed by two Lenzing policies. The minimum disclosure requirements and topic-specific requirements of these policies are described in other chapters: the Sustainability Policy - covering the topic-specific requirements transitioning away from use of virgin resources, sustainable sourcing and use of renewable resources - can be found in the 'Sustainability Strategy' section of the 'ESRS 2 General disclosures' chapter. The Wood and Pulp Policy can be found in the 'Policies' section of the 'E4 Biodiversity and ecosystems' chapter" (page 135).

The Sustainability Policy's E5-1 text reads: "Lenzing is committed to collaborate with stakeholders, including innovation partners, suppliers and NGOs to promote fibers that reduce potential environmental and social impacts. Lenzing supports the research and development of commercially viable cellulose fibers made from alternative sources such as agricultural residues and textile waste... Lenzing is dedicated to sourcing all raw materials responsibly (sustainable sourcing) and to continuously improving sustainability performance and resource efficiency" (page 61). Accountability sits with the Head of Corporate Sustainability.

The Wood & Pulp Policy commits Lenzing "to source wood and pulp exclusively from non-controversial sources" (page 125).

Actions and resources related to resource use and circular economy

Reference: pages 135-136, indexed at page 54. Three key actions.

Biorefinery for pulp production. "At Lenzing's pulp sites, this process is energy self-sufficient, uses raw materials efficiently and achieves high recovery rates for solvents and chemicals." Three biorefineries produce acetic acid, furfural, magnesium lignosulphonate, soda ash and xylose alongside bioenergy. Surplus energy is used on site at Lenzing and exported to the grid at Paskov and Indianopolis, illustrating "the cascading use of biomass and the 100 percent utilization of the raw material wood" (page 135).

Commercial-scale recycling (page 135). Chemical recycling through REFIBRA technology, which "converts pre- and post-consumer cellulosic textile waste from cotton or regenerated cellulose, together with virgin pulp, into new fibers"; ECOVERO viscose made with REFIBRA "contain[s] a minimum of 20 percent recycled content". Mechanical recycling uses Lenzing fibers as carrier material.

Collaboration and research (page 136). Group R&D expenditure of EUR 31.7 mn in 2025 (2024: EUR 30.4 mn), Frascati method. Named projects: Sodra (LIFE TREATS, "to recycle and process 50,000 tons of textile waste per year at Sodra's Morrum site by 2029"), CELLFIL, CISUTAC, ESCIB, and TreeToTextile, in which Lenzing "acquired a controlling majority" in February 2026.

Targets related to resource use and circular economy

Reference: page 137, indexed at page 54. Both targets are voluntary and relate "primarily... to the 'recycling' tier of the waste hierarchy".

Textile Recycling target – 2030, On track. Sub-targets: increasing the share and types of alternative feedstocks; "Increasing recycled content in viscose and lyocell fiber types from 20 percent to minimum 30 percent from post-consumer waste on a commercial scale by 2030"; and "Innovating the use of at least 5 alternative feedstocks providers... by 2030". Base year 2020. Status 2025: "A highlight in 2025 was production of a lyocell staple fiber with 30 percent recycled content from Circ Inc." but "lab tests were conducted on agricultural waste such as hemp, banana fibers and aquatic plants. However, none of these innovations reached pilot-plant scale in 2025."

Circular Business Model target – "To innovate a new circular business model by closing the loops for post-consumer materials and partner with 15 key supply chain companies by 2025" – Achieved. Base year 2020, from 0 to 15 partners. Status 2025 records a pilot to collect and sort textile waste via a social enterprise organisation, and work with Recyc Leather combining recycled leather fibers with TENCEL Lyocell.

Sodra "played a key role in defining these targets" (page 137).

Resource inflows

Reference: pages 138-139, indexed at page 54.

"Lenzing's main resource inflows are wood, dissolving wood pulp, chemicals, fuels and water" (page 138).

Quantified inflows (page 139):

• Overall total weight of products and technical and biological materials used: 4.35 mn t (2024: 4.85)
• Sustainably sourced biological materials: 81 percent of total (2024: 72 percent)
• Absolute weight of secondary reused or recycled components and materials: 1.84 mn t (2024: 2.33)
• Percentage secondary: 42 percent (2024: 48 percent)

"All (100 percent) biological materials are sustainably sourced, as all wood originates from well-managed forest operations certified or controlled according to the FSC and PEFC certification schemes", and "Chemicals and solvent recovery are reflected in the high percentage of secondary or reused materials (42 percent)" (page 139).

Named materials (page 138). Nominal dissolving wood pulp capacity is 320,000 t at Lenzing (Austria), 300,000 t at Paskov and 600,000 t at Indianopolis. The chemicals "accounting for around 85 percent of the total purchased volume" are carbon disulfide, NMMO, sodium hydroxide, sulfuric acid, sulfur, sulfur dioxide, spin finishings, titanium dioxide and zinc sulfate. "In lyocell manufacturing, up to 99.8 percent of the used NMMO can be recovered and reused."

Data comes from direct weighing of raw material input, adjusted for storage movements (page 139).

Resource outflows

Reference: pages 139-141, indexed at page 54.

"Lenzing's main product outflows are regenerated cellulose fibers, which are used in applications such as clothing, home textiles, personal care and hygiene products... Pulp and other biorefinery products as well as co-products from fiber production are sold to other industries" (page 139).

Durability and repairability (page 141). Lenzing declines to give a figure and explains why: "durability is not determined solely by the fiber itself but is heavily influenced by the subsequent textile processing steps and, ultimately, by the construction of the final product... For this reason, comparing industry averages for fiber materials does not yield significant insights."

Recyclable content (page 141). "As regenerated cellulose fibers can technically be recycled into new regenerated cellulose fibers, they consist of 100 percent recyclable content. The recyclable content rate in product packaging stands at around 90 percent", estimated Group-wide from Lenzing (Austria) figures.

Biodegradability (pages 139-140). LENZING Lyocell, Modal and Viscose Standard fibers are TUV Austria certified biodegradable and compostable, supported by Scripps Institution of Oceanography studies and a 2025 Hydra Institute study.

Net-benefit fibers. "In 2025 the net-benefit/speciality fiber share based on fiber revenue amounted to 92.0 percent (2024: 92.6 percent)", voluntary information (page 140).

Policies related to own workforce

Reference: pages 145-149, indexed at page 54. Paragraphs 20-23 are SFDR datapoints mapped to this section (page 84).

Policy on Human Rights and Labor Standards (pages 145-146). Accountability: SVP Corporate Human Resources. Scope: Lenzing Group, upstream value chain and downstream Tier 1, local communities. Objective: "Lenzing is fully committed to uphold the protection of human rights in its sphere of influence and to identify, prevent, mitigate and remediate adverse human rights impacts." Standards: UN Global Compact, UNGPs, OECD Guidelines, ILO Declaration and the UDHR. Against 20c, Lenzing "provides appropriate remedies for human rights impacts to affected individuals, employees and local communities, including indigenous peoples, through both judicial and non-judicial mechanisms".

Global Equity, Diversity & Inclusion Policy (page 146). Aims "at eliminating discrimination, including harassment and promoting equal opportunities". Against 24d, a stated gap: "There was no formalized procedure in place to prevent, mitigate and combat discrimination in the reporting year. Lenzing has actions in place to advance diversity and inclusion."

Four further policies are set out: the Communication Guideline, Life Saving Rules Guideline, Global Learning & Development Guideline and Global Performance Management Guideline (pages 147-148).

Processes for engaging with own workforce

Reference: page 148 ("Communication"), indexed at page 54.

"The Managing Board communicates regularly with employees and their representatives... Information is shared through multiple channels including onboarding sessions, townhall meetings, notice boards, internal email and internal news." Semi-annual global townhalls run for all Group companies, supplemented by site townhalls. "Responsibility for ensuring this engagement lies with the Senior Vice President Corporate Human Resources" (page 148).

Works council and social dialog (page 148). "Local works councils exist at both Austrian sites. At the Lenzing site, the council holds a seat and voting rights on the Supervisory Board of Lenzing AG... the works council meets with the CEO before Supervisory Board meetings and with the CFO on a monthly basis. With the exception of the site in Prachinburi (Thailand), trade union representatives... represent the interests of the employees at all other sites."

Health and safety committees operate at all sites (page 148).

Lenzing Climate Survey (page 148). "The latest survey from April 2025 showed significant improvements in all areas (+5 percentage points on average). The health climate index, for example, reached a value level of 76 percent. The participation rate was once again above 70 percent."

Three Employee Resource Groups exist: Women@Lenzing, Multicultural@Lenzing and PrideAlliance@Lenzing.

Processes to remediate negative impacts and channels to raise concerns

Reference: pages 148-149, indexed at page 54. Paragraph 32c is an SFDR datapoint mapped here (page 84).

Channels (page 148). Three routes are listed: the whistleblower system described in the G1 chapter; the works council at the Lenzing and Heiligenkreuz sites in Austria; and trade unions or employee interest groups at all sites "except Prachinburi (Thailand)".

Awareness and effectiveness. "A mandatory eLearning course entitled 'Our Whistleblower System' helps employees to understand and use available channels to raise concerns and grievances. The Compliance team also conducts an integrity scan through a survey to assess employees' knowledge" (page 148). The system runs in seven languages, allows anonymous reporting, and its "anonymity safeguards are certified by an independent body" (page 169).

Stated gap on remediation (page 149). "There is no formal process for remediation or assessing the effectiveness for remediation. Remediation is conducted on an individual, case-by-case basis." The one formalised procedure is the Global Child Labor Remediation Procedure, which "provides guidance for handling any instance of child labor within Lenzing. It outlines remediation steps for managers to ensure child safety, uphold rights, and act in the best interests of child."

Reports are handled under the Investigation Directive (page 169).

Taking action on material impacts on own workforce

Reference: pages 149-151, indexed at page 54. Six action areas are listed.

Learning and development (page 149). A global L&D catalog on Learn@Lenzing; "LinkedIn Learning was introduced in 2025"; "428 Learn@Lenzing courses have been assigned in the skill matrix IT tool".

Equity, diversity and inclusion (page 149). Three Employee Resource Groups; Pride Month marked at multiple sites; International Women's Day panels and "supported access to menstrual products at headquarters".

Social audits (pages 149-150). "In 2025, all production sites completed verification under the Higg Facility Social & Labor Module (FSLM)... The overall results were well above the median scores."

Work-life balance (page 150). Flexible hours, part-time roles and remote work "at most sites"; benefits for full-time employees "are generally extended to part-time staff".

Health and safety (page 150). Hazard identification across "six core categories: safety, biological, physical, ergonomic, chemical and psychosocial"; employees and contractors have "the right to stop unsafe work without reprisal".

Remediation in 2025 (page 149). "a tragic incident resulted in the death of a contractor working at the plant in Lenzing Biocel Paskov (Czech Republic)... the company collaborated closely with the contractor's employer to ensure the family received appropriate support, including access to counselling."

Targets related to own workforce

Reference: pages 150-152.

Social Standard target. A valid third-party audited social certificate for every production site – Continuous, On track. Base year 2020, 0 to 9 sites. "FSLM verification... was successfully completed by all nine Lenzing production sites in 2025" (page 151).

Equity, Diversity and Inclusion target – Continuous, On track, with three sub-targets (page 151):

• Training for 75 percent of the workforce on diversity, discrimination and human rights – Achieved (85 percent completed)
• 22.5 percent women in positions graded 5a and above by 2025 – Delayed: "In 2025, Lenzing's proportion of women in the target group was 21.9 percent (in 2024: 22.8 percent)."
• Inclusion Index score of 75 percent by 2026 – On track

Health target (page 152). "In January 2025, Lenzing set a Group-level target to reduce the Total Recordable Injury Frequency Rate (TRIFR) per 200,000 working hours from a baseline of 1.1 to 0.8 by year-end 2025. The target was achieved. The previous target of 0.3 by 2025 was revised".

Declared gaps (page 152). "At present, Lenzing has no target regarding... [a] lack of work-life balance; Positive impact... through various working time models; Risk and opportunity for being an attractive employer...; Negative impact on gender equality and equal pay for equal work. Lenzing's current resource constraints have made it challenging to fully address these important topics."

Characteristics of the undertaking's employees

Reference: pages 152-154, indexed as "Employees in numbers" (page 54). Figures are head count at 31 December 2025.

Headcount: 8,129 (2024: 8,228), 1,439 female and 6,690 male. "In 2025, Lenzing has no employees registered with the gender category 'other'" (page 153).

By country (page 153): Austria 3,418, Indonesia 1,322, Brazil 1,282, China 802, Czech Republic 528, Thailand 276, UK 227, USA 201, others 73.

By contract (page 153): permanent 7,819 (1,359 female, 6,460 male); temporary 310 (80 female, 230 male); non-guaranteed hours 0; full-time 7,535; part-time 594. "Only around 4.5 percent of the workforce (including external personnel) has a genuine fixed-term... contract that extends beyond the usual six-month fixed-term period." Apprentices number 243 (2024: 253).

Turnover (page 154): 875 employees left (2024: 888), 203 female and 672 male; by age, 211 under 30, 406 aged 30-50, 258 over 50; by country, Austria 384, Brazil 272, Indonesia 70, Czech Republic 42, USA 37, China 31. Group turnover rate 11 percent (unchanged), Austria 44 percent (2024: 33).

Context is given: "To strengthen long-term competitiveness, a structured job reduction program was initiated in 2025. Therefore, the main reasons for employees' departures during the reporting year were mutual or voluntary contract terminations, employer-initiated terminations and retirements" (page 152).

Characteristics of non-employee workers

Reference: page 154, indexed as "Employees in numbers" (page 54).

Total number of non-employees: 114 (2024: 149), in head count at 31 December 2025.

"The total number of non-employees does not include self-employed people as they are not recorded in the HR system. The largest group of non-employees consists of supervised workers employed indirectly through an employment agency. They are treated in the same way as Lenzing employees. Most supervised workers are employed in the production area (shift work), as determined by an evaluation of their job titles and description" (page 154).

Non-employees are within scope of several other S1 disclosures. Under S1 SBM-3, "Members of Lenzing's own workforce who could be materially impacted include employees and non-employees. Non-employees constitute a small fraction of leased personnel and self-employed individuals" (page 144). Under S1-14, "100 percent of Lenzing's employees, non-employees and contracted staff working on company premises are covered by the Occupational Health and Safety (OHS) Management system" (page 157), and separate injury statistics are published for non-employees, covering 7,008,265 hours worked and recording one fatality in 2025 (page 157).

No further breakdown of non-employee characteristics by type or gender is disclosed.

Diversity metrics

Reference: pages 155-156, indexed as "Diversity metrics" (page 54).

Lenzing defines the population: "Individuals within management roles are defined as people who directly oversee at least one other employee", split into white collar manager (category 1), blue collar manager (category 2) and supervised worker manager (category 3) (page 155).

Individuals in a managing role (page 155): 933 in total (2024: 912), of whom 162 female (17 percent) and 771 male (83 percent); by age, 30 under 30 (3 percent), 611 aged 30-50 (65 percent) and 292 over 50 (31 percent). The female share fell from 18 percent in 2024.

By category: category 1 white collar managers 736 (2024: 729), 147 female and 589 male, 20 percent female; category 2 blue collar managers 193 (181), 13 female and 180 male, 7 percent female; category 3 supervised worker managers 4 (2), 2 female and 2 male.

All employees by age and gender (page 156): 8,129 in total, of whom 1,392 under 30 (17 percent), 5,008 aged 30-50 (62 percent) and 1,729 over 50 (21 percent); 1,439 female (18 percent) and 6,690 male (82 percent), both shares unchanged from 2024.

The related EDI sub-target, 22.5 percent women in positions graded 5a and above by 2025, is recorded as Delayed at 21.9 percent, down from 22.8 percent in 2024 (page 151). The metrics in this chapter, other than health and safety, "are not validated by an external body other than the assurance provider" (page 152).

Social protection

Reference: page 156, indexed as "Social protection" (page 54).

"Social protection against income loss due to major life events, including sickness, unemployment (from the start of employment at Lenzing), work-related injury, acquired disability, parental leave and retirement, is provided to all employees through public programs in all countries where Lenzing operates. The only exception is the USA, where payments for sickness and parental leave are not provided. The information was obtained from official government sources and the International Labour Organization (ILO)" (page 156).

This covers the five ESRS events and identifies the single gap by country, together with the source used to establish coverage. Lenzing had 201 employees in the USA at 31 December 2025 (page 153).

The disclosure is short and gives no percentage of employees not covered, but the exception is named and the population is identifiable from the S1-6 country table. Social protection is listed in the S1 IRO table as a metric attached to the work-life balance positive impact (page 143).

Persons with disabilities

Reference: page 156, indexed as "People with disabilities" (page 54).

"In the reporting year, 1.6 percent of Lenzing's employees had a disability (2024: 2 percent). The category 'employees with disabilities' is based on the legal definitions in the respective country of operations. For example, the definition for Austria can be found here. At the Grimsby (UK) and Mobile (USA) sites, no formal recording takes place, as local legislation does not define disability status and employees are not required to disclose a potential disability to their employer. Therefore the reported numbers for both sites are an estimate" (page 156).

Lenzing flags the disclosure as voluntary information in the running head, and gives no gender breakdown.

The supplementary § 243b UGB annex for Lenzing Aktiengesellschaft separately reports employees with disabilities of 44 in 2025 (2024: 50) for the Austrian parent company alone (page 178).

Persons with disabilities appears as a metric against the diversity IROs in the S1 IRO table (page 144), which links it to the Equity, Diversity and Inclusion target and the EDI actions.

Training and skills development metrics

Reference: page 156, indexed as "Learning and development" (page 54).

Training volume (page 156). "Courses offered through Learn@Lenzing were completed approximately 93,996 times in the reporting year. This resulted in a total training time of 54,757.7 hours and an average training time of 6.7 hours per employee. The average training time was 7.7 hours for women and 6.5 hours for men (2024: average training time 6 hours, 7 hours for women, 6 hours for men)." Total expenditure on lifelong learning and personnel development, including the Bildungszentrum Lenzing, "stayed at EUR 6.70 million in 2025 compared with EUR 6.70 million in 2024", disclosed as voluntary information.

Performance reviews (page 156). "During the Performance Management cycle, 88.7 percent of the target group (68 percent male, 32 percent female) defined three to five individual goals in SuccessFactors. Furthermore, 80.6 percent... who had set goals in 2024 completed their annual goal review."

Talent management. "the Talent Management Process captured data for 70.2 percent of Lenzing's white-collar workforce (2024: 80.4 percent). Additionally, 1,008 out of 2,706 key positions already have at least one identified successor in place (2024: 973 out of 2,535)."

The performance-review figure covers a "target group" rather than all employees.

Health and safety metrics

Reference: pages 157-158, indexed as "Health and Safety" (page 54). Paragraphs 88b, 88c and 88e are SFDR datapoints (page 85).

Coverage. "100 percent of Lenzing's employees, non-employees and contracted staff working on company premises are covered by the Occupational Health and Safety (OHS) Management system. All manufacturing sites are certified to ISO 45001 with the current certification renewed in 2024 and valid until 2027" (page 157).

Employees, per 1,000,000 working hours (page 157): 15,656,014 hours worked; fatalities 0 (2024: 1); recordable work-related injuries 70 (86); TRIFR 4.5 (5.5); recordable work-related ill health 0 (0); work-related injuries and ill health 224 (312), a rate of 14 (20); days lost 1,256 (1,585).

Non-employees (page 157): 7,008,265 hours worked; fatalities 1 (2024: 0); recordable injuries 15 (21); TRIFR 2.1 (3.1); injuries and ill health 45 (93), rate 6.4 (13.8); days lost 532 (338).

The fatality is reported plainly (page 157): "in 2025, a tragic incident occurred, resulting in the loss of a contractor who was fatally injured following exposure to a hazardous substance."

"In 2025, the Group recorded no high-consequence work-related injury events involving employees" (page 157). Health and safety metrics are the one part of S1 subject to external verification beyond the assurance provider (page 152).

Work-life balance metrics

Reference: page 158, indexed as "Family-related leave" (page 54).

"All (100 percent) of Lenzing's employees are entitled to take family related leave such as paternity, maternity or parental leave. A total of 93 percent of Lenzing's employees are entitled to take carer's leave. Sites where employees are not entitled to take carers' leave are the production sites in Prachinburi (Thailand), Mobile (USA) and the offices in Coimbatore, Hong Kong and Singapore" (page 158).

"In 2025, 11 percent of employees took family related-leave, of which 27 percent were female and 73 percent were male (2024: 6 percent, 28 percent female, 72 percent male)" (page 158).

Take-up therefore nearly doubled year on year, with the gender split broadly unchanged. Lenzing names the locations where the carer's leave entitlement does not extend, so the 93 percent figure is traceable.

Related actions are described under S1-4: flexible hours, part-time roles and remote-work options "at most sites", with benefits granted to full-time employees "generally extended to part-time staff and, in many cases, to temporary employees" (page 150). Lenzing states under S1-5 that it has no target for the work-life balance impacts, citing resource constraints (page 152).

Compensation metrics (pay gap and total compensation)

Reference: page 158, indexed as "Annual total remuneration ratio; Gender pay gap" (page 54). Paragraphs 97a and 97b are SFDR datapoints (page 85).

Gender pay gap: 27.16 (2024: 25.30, "the adjusted value from 2024"). "The calculation method corresponds to the calculation method defined in the ESRS standard. The calculation was based in part on estimated working hours and annual pay. The accuracy of the estimates corresponds to level 2 (1 - exact figure, 2 - calculation/accurate estimate, 3 - rough estimate)." Lenzing explains the scale: "if a man's salary is double that of a woman, the pay gap ratio amounts to 50" (page 158).

Annual total remuneration ratio: 58.20 (2024: 51.87, adjusted). "The number includes the total remuneration before taxes and including boni" (page 158).

Prior-period error, disclosed (page 56). "When calculating the gender pay gap, the difference of average pay levels between female and male employees, was mistakenly expressed as the percentage of the average pay level of female employees instead of male employees. The difference between correct and incorrect number of 2024 is +1.4... When calculating the annual total remuneration ratio, the number of employees taken into account was incorrect. The difference... for 2024 is +10.87."

Both metrics moved against Lenzing year on year. The paragraph 98 breakdown is treated as not material and placed in the annex (pages 152, 184).

Incidents, complaints and severe human rights impacts

Reference: page 158, indexed as "Raised concerns and human rights incidents" (page 54).

"In the reporting year, 125 complaints were filed through the Lenzing Group whistleblower system and the whistleblower system of Lenzing's joint venture LD Celulose in Indianopolis (Brazil) (2024: 161 complaints filed).

No cases of discrimination or (severe) human right abuses, based on Discrimination ILO 111 Article 1, within Lenzing's own workforce were filed, reported or recorded within the reporting year (2024: no cases). Consequently, Lenzing did not receive any penalties and paid no fines or compensation for damages related to such cases or incidents" (page 158).

The same 125 figure is repeated in the G1 chapter under compliance monitoring, where "Lenzing's investigation team reviewed and processed any reported violations of its principles and, if necessary, imposed appropriate sanctions" (page 172).

The datapoints table marks "ESRS S1-17 103a Incidents of discrimination" and "104a Non-respect of UNGPs on Business and Human Rights and OECD guidelines" as "Not material (but can be found in S1 Own workforce: Raised concerns and human rights incidents)" (page 85), so the nil return is published even though those datapoints were not assessed as material.

No breakdown of the 125 complaints by type is disclosed.

Policies related to value chain workers

Reference: page 160, with the policy tables in the S1, E4 and G1 chapters. Indexed as "ESRS S2-1 Policies related to value chain workers / Policies" (page 55). Paragraphs 17, 18 and 19 are SFDR datapoints (page 85).

"Lenzing's approach to workers in the value chain is governed by four policies": the Global Code of Business Conduct and the Global Supplier Code of Conduct (G1 chapter), the Policy on Human Rights and Labor Standards (S1 chapter) and the Wood and Pulp Policy (E4 chapter) (page 160).

"The Policy on Human Rights and Labor Standards addresses all topic-specific requirements. The Global Supplier Code of Conduct addresses the coverage of specific groups, human trafficking, forced labor and child labor" (page 160).

Against S2-1 paragraph 17c, Lenzing states a gap plainly: "Lenzing's policy commitments do not include a general approach for its engagement with value chain workers" (page 146).

Against paragraph 19: "In the reporting year, no cases of non-compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines for Multinational Enterprises were reported in the upstream value chain" (page 146).

The Supplier Code prohibits child labour "under any circumstances" (page 167).

Processes for engaging with value chain workers

Reference: page 160, indexed as "Grievance mechanisms and remediation" (page 55).

Lenzing's S2-2 disclosure is a single, unambiguous statement of absence: "At present, Lenzing has not yet have established a standardized process for engaging with workers in its value chain" (page 160).

The surrounding disclosures set out what exists instead. Under S2 SBM-2, "In relation to workers in the value chain, Lenzing primarily relies on information from credible external sources, including NGOs, NPOs, trade unions, risk databases and governmental reports, which are supplemented by internal expertise, to identify and assess impacts. Lenzing's sphere of influence currently covers direct suppliers and to a lesser extent its downstream business partners... At present, Lenzing's influence is limited to reviewing working conditions through audits and relying on external ratings and standards such as the EcoVadis rating" (page 70).

Under S2-5, "there was no direct engagement with workers in the value chain, their legitimate representatives or external stakeholders, during the process of setting targets, tracking performance, or identifying improvements" (page 162).

Engagement therefore runs through supplier audits, EcoVadis and Together for Sustainability rather than through workers or their representatives (pages 161-163).

Processes to remediate negative impacts and channels for value chain workers

Reference: pages 160-161, indexed as "Grievance mechanisms and remediation" (page 55).

Grievance mechanism. "Lenzing's online whistleblower system 'Tell us' enables employees, customers, suppliers, workers in the value chain and other stakeholders worldwide, to report concerns confidentially and anonymously... In 2025 the system has been updated for further quality improvement" (page 160).

Supplier-side channels. The Global Supplier Code of Conduct requires that "Suppliers are required to provide means for their employees to report concerns or potentially unlawful activities in the workplace... Suppliers are required to investigate such reports and take corrective action if needed. It is expected that suppliers shall not retaliate against or harass any employee submitting a report in good faith" (page 160).

Two stated limits (page 161). "Lenzing is committed to providing appropriate remedies on a case-by-case basis. It has not yet been possible to assess the effectiveness of this process as no cases were reported during the year under review. While Lenzing conducts audits at supplier sites, these audits currently do not include verification of workers' awareness of, or trust in, Lenzing's whistleblower system."

In 2025 "no cases related to workers in the value chain and human rights were reported through Lenzing's whistleblower system (2024: No cases)" (page 163).

Taking action on material impacts on value chain workers

Reference: pages 161-163, indexed as "Actions" (page 55). Paragraph 36 is an SFDR datapoint (page 85).

Hotspot analysis (page 161). "After focusing on child and forced labor in the hotspot analysis in 2024, the analysis was extended in the reporting year to include... occupational health and safety, freedom of association and collective bargaining, discrimination, fair employment community impacts, and corruption/transparency. The analysis was finalized by the end of Q3... Consequently, the results have not yet been reflected in the current revision of the materiality assessment."

Supplier engagement (pages 161-162). Lenzing "expects a minimum EcoVadis score of 50 points. Suppliers falling below this threshold are required to submit a corrective action plan within three months in order to maintain the business relationship... No supplier relationships were terminated in 2025." Five Together for Sustainability audits were carried out in 2025 (2024: four), and they "did not detect any severe human rights issues" (page 163).

Human rights due diligence (page 161). "In the reporting year, Lenzing did not identify any incidents in its value chain and therefore did not provide remediation related to an actual material impact... At this stage, Lenzing cannot yet determine whether it does or does not cause or contribute to such impacts."

Targets related to value chain workers

Reference: pages 162-163, indexed as "Targets" (page 55).

Supplier Engagement target. "To engage key suppliers, covering more than 80 percent of spend, to improve sustainability performance" – Continuous, On track. Sub-target: "Lenzing assesses 95 percent of its top 200 suppliers via EcoVadis, the Together for Sustainability Audit or an internal assessment/audit by 2025" – Delayed (page 162).

Status 2025 (page 162). "More than 1000 of Lenzing's suppliers are assessed and monitored by EcoVadis... 68 percent of the global procurement spend, including wood and pulp was covered by these assessments. The sub-target of assessing 95 percent of 200 suppliers has achieved around 70 percent of these suppliers. There were challenges in the EU chemical industry and logistics due to geopolitical situation and events like the Red Sea crisis... [which] delayed the sub-target accomplishment."

Two stated gaps. "While there was no direct engagement with workers in the value chain, their legitimate representatives or external stakeholders, during the process of setting targets, tracking performance, or identifying improvements, several internal stakeholder groups played a crucial role" (page 162). And: "At present, no specific targets have been established for workers in the downstream value chain. Lenzing's current focus is on areas within its strongest sphere of influence, primarily upstream" (page 163).

Business conduct policies and corporate culture

Reference: pages 166-170, indexed as "Policies; Detective measures; Functions-at-risk" (page 55).

Culture. "Compliance at the Lenzing Group extends beyond adherence to statutory and regulatory requirements. It reflects a fundamental attitude and a culture of responsibility, respect and integrity" (page 166).

Policies (pages 167-169). Global Code of Business Conduct; Global Supplier Code of Conduct; Product Safety Policy; Wood and Pulp Policy by cross-reference. Directives: Anti-Bribery and Corruption, aligned "with the United Nations Convention against Corruption" (10b); Investigation; Anti Money Laundering; Whistleblower.

Whistleblower protection (10a, 10c, page 169). The online system has run "since 2017", is "available in all languages relevant to production sites (English, German, Czech, Chinese, Bahasa, Thai and Portuguese)", and "the system's anonymity safeguards are certified by an independent body". A caveat is disclosed: "Although the directive does not explicitly refer to monitoring activities, the effectiveness, accessibility and overall acceptance of the whistleblower system are evaluated through a regular Integrity Survey."

Functions-at-risk (10h, page 170). Twelve functions are named, including Global Legal IP and Compliance, Global HSE, Global Procurement, Corporate Treasury and Corporate HR. A Training Directive "is planned for the next fiscal year".

Management of relationships with suppliers

Reference: pages 173-176 ("Sourcing"), indexed at page 55.

Approach (page 173). "Lenzing aims to minimize purchasing risks, such as major price fluctuations and supply bottlenecks through reliable, long-term supply relationships and active supplier management. The most important materials procured are (in order of annual procurement volume): wood, dissolving wood pulp, sodium hydroxide, sulfuric acid, sulfur, carbon disulfide, sulfur dioxide and magnesium oxide."

Screening result (page 173). "In 2025 (and 2024), when screening for risk suppliers, no Lenzing suppliers were identified as having significant actual and potential negative environmental impacts. This statement is based on... EcoVadis, Together for Sustainability, FSC and PEFC."

EcoVadis coverage (page 173). Assessed suppliers rose to 1,025 in 2025 from 824 in 2024 and 608 in 2023. "Lenzing engages only with EcoVadis rated suppliers that achieve a minimum score of 50 points."

Regionality (page 173). "Regionally purchased" chemicals were 87 percent of volume (2024: 87 percent), and "80 percent of all purchased chemicals (in liquid metric tons) were delivered by 33 suppliers (2024: 36 suppliers)".

Wood and pulp (pages 174-175). "Lenzing does not source wood and dissolving wood from primary, natural or ancient and endangered forests." Regional wood was 98.8 percent for the Lenzing site (2024: 97.1 percent) and 100 percent for Paskov.

Prevention and detection of corruption and bribery

Reference: pages 169-172 ("Actions"), indexed at page 55.

Compliance Management System (page 171). Its objective is "to prevent, detect and respond to compliance violations against the interests of the company, as well as to avoid liability risks and damage to the company's reputation", on three pillars: prevention, detection and response.

Handling of reports (18b, 18c, page 169). "Reported incidents are assessed by lawyers... and forwarded to the Group Compliance Officer or to the Local Compliance Officer... Monthly reporting on the status of compliance as well as ongoing investigations are provided to the Managing Board. In addition, the Audit Committee... is informed about reported incidents on a quarterly basis."

Training (21a-21c, page 172). Mandatory annual eLearning for employees with IT access, requiring "at least 80 percent in the final assessment". In 2025, 87 percent of assigned employees completed the required eLearning based on 6,185 enrolled (2024: 89 percent). "All white-collar employees and the Managing Board (2,661 employees) were assigned the mandatory ABC Directive training, of whom 95 percent completed the course." Antitrust: 248 employees, 92 percent completion.

Compliance cockpit (page 172). Globally implemented in 2025. A global compliance risk assessment covering all legal entities is planned for the first half of 2026.

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 became a standalone DR only in the 2025/2026 ESRS.

Lenzing states directly that it has no business conduct targets for three of its four material G1 IROs. The G1 impacts, risks and opportunities table records "*No target" against the corporate culture risk, the whistleblower protection negative impact and the corruption and bribery incidents negative impact (page 165).

The one G1 IRO with a target is supplier-related: the Supplier Engagement target, connected with the CSDDD non-compliance risk, is reported in the S2 chapter (page 172). It is "To engage key suppliers, covering more than 80 percent of spend, to improve sustainability performance", Continuous and On track, with its 2025 sub-target Delayed at around 70 percent of the top 200 suppliers (page 162).

Consistent with MDR-T, effectiveness is tracked without targets: quarterly incident reporting to the Audit Committee and monthly reporting to the Managing Board (page 169); a regular Integrity Survey "supported by an independent scientific team" (page 170); training completion of 87 percent Group-wide and 95 percent for the ABC Directive; and a global compliance risk assessment "expected to be conducted and finalized in the first half of 2026" (page 172).

Incidents of corruption or bribery

Reference: page 172, indexed as "Metrics" (page 55). Paragraphs 24a and 24b are SFDR datapoints (page 85).

Convictions and fines (24a). "In 2025, there were no convictions or fines related to anti-bribery and anti-corruption laws (2024: No convictions or fines). No public complaints in connection with corruption incidents were brought against the company or its employees during the reporting period" (page 172).

Reports received (24b). "Concerns reported via the whistleblower system are recorded in the Legal, IP and Compliance department. A total of 125 cases were filed through the Lenzing Group whistleblower system and the whistleblower system of Lenzing's joint venture LD Celulose in Indianopolis (Brazil) (2024: 161 filed cases). Lenzing's investigation team reviewed and processed any reported violations of its principles and, if necessary, imposed appropriate sanctions" (page 172).

The 125 figure is the same total reported under S1-17 (page 158), and it is not broken down by category, so the number of cases specifically concerning corruption or bribery is not separable from the total.

An entity-specific product safety metric sits alongside: "In 2025, all products in scope were successfully re-certified... The outcome of the ISO 9001 audit was positive, with no major non-conformities being identified" (page 172).