MAXIMA GRUPĖ

(Section ESRS 2 GOV-1, pp 93-95, 194-196) MAXIMA GRUPĖ describes how its administrative, management and supervisory bodies oversee sustainability impacts, risks and opportunities through approval and monitoring. The Management Board reviews sustainability policies and goals, approves the annual sustainability statement and oversees strategy implementation through annual and ad hoc updates. A governance scheme sets out the roles of the Board, CEO, Audit Committee, Legal and Sustainability Department, Finance Department and Internal Audit, plus the responsibilities of Group companies. The Audit Committee oversees the reporting process and the independence of the assurance provider, while an independent provider performs limited assurance. Day-to-day governance of controls and procedures is delegated to the Legal and Sustainability Department, Finance Department and Internal Audit. The company states that sustainability-related responsibilities are not reflected in terms of reference, board mandates or other policies. It lists the areas of internal sustainability expertise mapped to topics G1, E1, E2, E3, E5, S1, S2 and S4, supported by training and external consultancy. Composition and diversity details are incorporated by reference to the Governance report.

(Section ESRS 2 GOV-2, p 96) The company explains how sustainability matters are addressed by management, with reporting lines structured to align with its operating and subordination principles so topics are handled in a timely manner. A table sets out the rapporteur, oversight body, frequency and topics. The Head of Sustainability reported to the Management Board annually (once in 2024) on the annual report, key metrics and progress towards science-based targets, and ad hoc (once in 2024) on setting goals, results of the double materiality assessment, updates to science-based targets and progress on group-wide goals. The Head of Sustainability reported to the Audit Committee ad hoc (three times in 2024) on developing internal controls and improving data traceability and reliability. The Head of Sustainability and Head of Legal reported to the CEO quarterly (four times in 2024) on priorities, action plans, compliance and stakeholder engagement results. Internal Audit reporting to the Audit Committee did not occur in 2024. The Management Board considers strategic decisions on sustainability through its risk-management approach and risk tolerance principles.

(Section ESRS 2 GOV-3, p 97) MAXIMA GRUPĖ discloses that the Group does not have any incentive schemes or remuneration policies linked to sustainability matters for members of the administrative, management and supervisory bodies. It states that climate-related considerations are not factored into the remuneration of these body members. As a result, the company reports that 0% of remuneration recognised in the current period is linked to climate-related considerations.

(Section ESRS 2 GOV-4, p 97) The company provides a statement on due diligence. It explains that Group companies followed the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct when establishing their sustainability due diligence processes. A table maps the core elements of due diligence to where they are addressed in the sustainability statement. Embedding due diligence in governance, strategy and business model is linked to GOV-1, GOV-2, GOV-3 and SBM-3. Engaging with affected stakeholders across the due diligence steps is linked to GOV-2, SBM-2 and IRO-1. Identifying and assessing adverse impacts is linked to IRO-1 and SBM-3. Tracking effectiveness and communicating is linked to topical actions including E1-3, E2-2, E4-3, E5-2, S1-4 and S4-4. Remaining elements are cross-referenced to topical targets and metrics such as E1-4, E5-3, S1-5, E1-6, E5-5, S1-14, S1-16, S1-17 and G1-4.

(Section ESRS 2 GOV-5, pp 98-99) MAXIMA GRUPĖ describes its risk management and internal controls over sustainability reporting. The framework uses standardised data-collection templates, validation rules and checks for manual and software-assisted verification, continuous training, audit trails documenting data sources and methodologies, and role-based access with segregation of duties. Risk assessment identifies issues through document reviews, stakeholder consultations, process mapping and external benchmarking, with each risk scored for severity and likelihood and prioritised as high, medium or low. The framework is reviewed annually using feedback from audits and stakeholders. In 2024 the main risks identified included inaccurate or incomplete data, insufficient controls against data manipulation and fraud, delayed data availability, technological failures, non-compliance with methodology and lack of an audit trail, with mitigation through audits, validation rules, clear policies, robust data systems and enhanced training. Findings are integrated through reviews, training and Audit Committee oversight. A Validation Protocol requires data owners to confirm reliability and ESG controllers to perform random checks. Reporting to the bodies includes presenting reports to the Board and regular Audit Committee oversight. Supporting procedures include the Sustainability Reporting Procedure, ESG Data Validation Protocol and six ESG Data Processing Procedures.

(Section ESRS 2 SBM-1, pp 99-102) The company describes its strategy and business model. Information on principal business activities, products, significant markets and employee headcount is provided by reference to the Business Overview chapter. Group companies are not active in fossil fuels, chemical production, controversial weapons, or tobacco cultivation and production, with no revenue from such activities, and none of their products are banned in the markets where they operate. The value chain is broken down into upstream inbound logistics, own operations (operations, outbound logistics, marketing and sales, and services) and a downstream chain of customers who are mainly natural persons shopping in physical and online stores. Key upstream actors are direct goods suppliers, with farmers at the Tier-N level. The company maps six capitals it relies on (human, intellectual, social and relationship, natural, manufactured and financial) to how it discloses and creates value for stakeholders. It sets out key sustainability goals, including a validated science-based target to cut absolute scope 1 and 2 GHG emissions 42.0% by 2030 from a 2021 base year, and a commitment that suppliers covering 78.3% of purchased goods and services emissions will have science-based targets by 2027. It reports alignment with 11 targets across 7 Sustainable Development Goals.

(Section ESRS 2 SBM-2, pp 103-107) MAXIMA GRUPĖ describes the interests and views of stakeholders. It defines stakeholders broadly and uses Mendelow's Matrix to categorise them by power and interest, splitting them into affected stakeholders and users of sustainability statements. A table maps stakeholder groups (shareholders and investors, suppliers and business partners, employees, customers and end-users, local communities, media, authorities and NGOs) to their areas of concern and the channels used to engage them. The company reports a 2024 online survey open for two weeks across all countries of operation, its first engagement since 2019, asking respondents to rate 15 sustainability topics on a scale of 1 to 5. A total of 2,289 respondents completed it, and scores were compared to category thresholds, with seven topics classified as primary focus areas (including reduction of waste, circular economy, appropriate working conditions, human rights, product safety and quality, food waste prevention, and business ethics and anti-corruption). Results were communicated to the CEO. The section also details the interests and views of own workforce, workers in the value chain, affected communities, and consumers and end-users, and states the survey did not contradict the business strategy.

(Section ESRS 2 SBM-3, pp 120, 130, 132, 135-136, 140-141, 145, 149-150, 161-162, 164-166, 169, 172, 179, 180) The disclosure on material impacts, risks and opportunities and their interaction with strategy is aggregated across the topical chapters. For each material matter the company presents a table of associated impacts, risks and opportunities coded to the topic, indicating whether they arise in own operations or the value chain, together with the impact on people and environment, link to strategy and business model, time horizon and nature of involvement. Topics covered include climate change management (E1), air and water pollution and chemicals of concern (E2), water and marine resources (E3), biodiversity and ecosystems (E4), circular economy and waste (E5), own workforce (S1), workers in the value chain (S2), consumers and end-users (S4), responsible business conduct (G1), and sector-specific and entity-specific matters such as food waste, affordability, food safety and quality, and digitalisation. The company notes a first-year phase-in was applied to data point ESRS 2 SBM-3 48(e), and that a detailed climate resilience and scenario analysis will begin in future reporting periods, so IROs were identified with less depth this year.

(Section ESRS 2 IRO-1, pp 108-112) This is the first time a double materiality assessment was used, referring to EFRAG conceptual guidance and following a process of peer review, preliminary assessment, stakeholder engagement, finalisation and presentation to the Management Board. The assessment focused on sector-agnostic topics, supplemented by SASB retail and e-commerce standards and peer reviews because ESRS sector-specific standards were unavailable. Impact materiality scored scale, scope and irremediable character from 0 to 5, with a topic material at a total score of 8 or higher, or automatically material if any dimension scored the maximum of 5; for potential negative human rights impacts severity outweighs likelihood. Environmental topics used elements of the TNFD LEAP approach with proxies from SBTN, ENCORE and the WWF Risk Filter Suite. Financial materiality was assessed for the first time using the IIRC concept of six capitals, scoring triggers from 0 to 4 with a threshold of 2. It also used the CSR Risk Check tool. It assessed 92 sector-agnostic matters plus 8 sector-specific and 6 entity-specific matters, and lists the resulting material matters (E1-E5, S1, S2, S4, G1, plus food waste, affordability, food safety and quality, digitalisation and access to green financing) by materiality type and value chain concentration. The assessment is reviewed in full at least every three years with annual partial reviews.

(Section ESRS 2 IRO-2, pp 184-191) The company provides an ESRS Disclosure Requirements Index listing each disclosure requirement covered in the sustainability statement, its title, the page location and reasons for omission where relevant. The index covers ESRS 2 general disclosures (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2, MDR-P and MDR-A) and the topical standards. It records incorporation by reference for certain GOV-1 and SBM-1 data points and notes that a first-year phase-in was applied to data point ESRS 2 SBM-3 48(e). The index also flags topical disclosure requirements and data points that were omitted or subject to phase-in, with reasons such as a sustainability matter not being material or the requirement being assessed in future periods. It shows page references for each item, for example GOV-1 on pages 93-95 and 194-196, GOV-4 on page 97, GOV-5 on pages 98-99, SBM-1 on pages 99-102, SBM-2 on pages 103-107 and IRO-1 on pages 108-112, providing a navigable map of where required information appears.

(Section ESRS E1-2, p 122) MAXIMA Grupe reports that it has not adopted policies relating to climate change mitigation and adaptation, energy efficiency, renewable energy deployment or other climate change-related topics. The Group states that the relevant policies are set to be developed no earlier than 2026. It explains that the delay relates to the complexity of implementing such policies across the Group, given the different contexts, markets and regulatory environments in the countries where it operates. No further policy detail is disclosed for the reporting year.

(Section ESRS E1-3, pp 122-123) Although the Group has no written climate policies yet, its companies are actively implementing measures addressing energy consumption, renewable energy generation and GHG emission reduction. Total GHG footprint was 5,167,645 tCO2e in 2024, with the largest share from the value chain for acquired goods. The Group monitors carbon-reduction investments through the EU Taxonomy framework: EUR 71.9 million in Capex and EUR 14.5 million in Opex were directed to reducing climate impacts in 2024 (up from EUR 58.1 million Capex and EUR 5.5 million Opex in 2023). MAXIMA Latvia finalised solar stations at two stores (100 kW and 150 kW); STOKROTKA deployed 35 solar stations totalling about 1,700 kW. Renewable generation rose above 5.4 GWh, 89% consumed on-site, avoiding 2,257 tCO2e. Refrigerant leakage emissions fell to 66,993 tCO2e, with 118 stores using natural refrigerants. Physical risk actions were limited to insurance.

(Section ESRS E1-4, p 124) In March 2023 the Group committed to near-term science-based targets validated by the Science Based Targets initiative (SBTi), aligned with the Paris Agreement goal of limiting warming to 1.5 degrees C. Approval was issued at the end of 2023, and SBTi classified the Scope 1 and 2 ambition as in line with a 1.5 degrees C trajectory. MAXIMA Grupe commits to reduce absolute Scope 1 and 2 GHG emissions 42.0% by 2030 from a 2021 base year, and that 78.3% of suppliers by emissions covering purchased goods and services will have science-based targets by 2027. The Scope 3 target is an engagement target covering two thirds of Scope 3 emissions. By the end of the reporting period a 13.2% reduction in Scope 1 and 2 had been achieved, and progress toward the engagement target was 16.0%. STOKROTKA targets no refrigerants above 2,500 GWP by end 2026; Baltic companies target none above 1,800 GWP by 2030.

(Section ESRS E1-5, p 126) The Group applies a conservative approach to reporting its renewable share, including only renewable energy backed by Guarantees of Origin and excluding unclaimed grid renewables, the renewable share of road transport fuel, and uncertified district heating. Total energy consumption was 663,009 MWh in 2024 (647,450 MWh in 2023). Fossil sources made up 491,028 MWh, or 74.1% of the total (73.8% in 2023), including 56,876 MWh from crude oil and petroleum products, 47,216 MWh from natural gas, and 386,935 MWh of purchased electricity, heat, steam and cooling from fossil sources. Nuclear sources contributed 30,904 MWh, or 4.7%. Renewable and low-carbon consumption totalled 141,078 MWh, a 21.3% share (21.7% in 2023). Energy intensity in high climate impact sectors was 109 MWh per million EUR, down 2% year on year.

(Section ESRS E1-6, pp 127-129) The Group calculates its GHG inventory under the GHG Protocol using an operational control approach matching its financial reporting boundaries. None of its emissions fall under the EU Emissions Trading System. Gross Scope 1 emissions were 91,793 tCO2e in 2024 (down 13.0% year on year). Gross location-based Scope 2 was 171,938 tCO2e and market-based Scope 2 was 151,368 tCO2e (down 13.4%). For market-based Scope 2, a zero emissions factor is applied to electricity with Guarantees of Origin, covering 28% of consumption. Total Scope 3 was 4,924,483 tCO2e, up 10.5%, dominated by Category 1 purchased goods and services at 4,358,712 tCO2e. Total GHG emissions were 5,188,215 tCO2e location-based and 5,167,645 tCO2e market-based. No Scope 3 categories were excluded, though 0% of Scope 3 used primary supplier data, so uncertainty is considered high. Scope 1 biogenic emissions were 48 tCO2e.

(Section ESRS E2-1, p 131) MAXIMA GRUPĖ reports that although air and water pollution were assessed as material within its own operations, the Group has not yet adopted dedicated policies to manage these impacts and risks. The primary sources of pollution are transport tailpipe emissions and refrigerant leakage. Refrigerant leakage is addressed under the Group's climate change mitigation efforts, while tailpipe emissions are managed by selecting the highest-available EURO standard whenever the fleet is renewed. Several pollution-related topics are also significant in the upstream value chain, but limited visibility into Tier-N suppliers has prevented the Group from prioritising dedicated policies there, since most impacts are expected to materialise beyond Tier-1 suppliers. To address some of these challenges, the revised Supplier Code of Conduct sets out expectations that upstream partners manage environmental issues with due care; embedding the code and enforcing compliance are the main planned actions. The Supplier Code of Conduct is detailed in chapter G1-2. Group companies also operate complaint mechanisms allowing stakeholders to report adverse environmental impacts in the upstream value chain.

(Section ESRS E2-2, pp 131-132) During the reporting year MAXIMA Lithuania undertook environmental management actions aligned with its ISO 14001 certification. The company conducted approximately 50 comprehensive internal audits across retail stores, distribution centres and administrative offices, focused on the use of chemical products, spill-prevention measures for oil-based materials, and other environmental protection controls. Outcomes included better ISO 14001 compliance and early identification of improvement opportunities. Staff training was delivered via an online platform to improve proficiency in chemical handling and spill prevention, reducing the likelihood of environmental incidents. MAXIMA Lithuania completed an ISO 14001 recertification process in March 2025 to extend the certification's validity and reinforce continuous improvement. Affected stakeholders include employees and environmental regulatory bodies. In the short term the Group will complete recertification in early 2025; in the longer term it anticipates ongoing audit cycles, continued staff development and adaptation to evolving regulations. On intentionally added substances of concern and very high concern, including microplastics under REACH, the Group includes compliance requirements in supply contracts and recalls products where contamination above permissible levels is identified. Customers can inquire about product composition via customer support and quality hotlines.

(Section ESRS E2-3, p 132) As the priority level for pollution is low, the Group set or implemented no measurable outcome-oriented targets during the reporting period, and it does not track the effectiveness of its policies and actions in managing pollution. On metrics, the Group measures pollution to air in its own operations through an entity-specific indicator: the EURO standard of the vehicles making up the operated fleet. It reports that 99.9% of the fleet meets the EURO 6 standard for tailpipe emissions. The Group did not gather information or evaluate any metrics for material pollution-related impacts concentrated in the value chain, having applied phased-in provisions for value-chain information. It notes that limitations on data gathering arising from the disclosure scope of the to-be-approved LSME and VSME standards further constrain the information accessible in the upstream value chain, and that once those standards are approved it will be able to identify what information can be gathered without placing an unreasonable burden on value-chain actors.

(Section ESRS E3-1, p 133) The Group has not adopted dedicated policies for managing material impacts, risks and opportunities related to water and marine resources. Group companies rely on municipal water supplies for both sourcing and discharging water at nearly all sites across their countries of operation. The Group states this approach ensures its water usage does not interfere with the needs of local communities and ecosystems in a way that deviates from established best practices in urban freshwater management. On that basis, it has determined that developing a dedicated water and marine resources policy for its own operations is not a high priority. The Group has also not adopted policies or practices related to sustainable oceans and seas. It acknowledges that this topic carries material impacts and risks arising from the upstream value chains, but reports it was unable to set a high priority level for developing such policies due to limited Tier-N visibility.

(Section ESRS E3-2, p 134) As the priority level for water and marine resources is low, the Group adopted no action plans during the reporting period in relation to water and marine resources. It did not implement any dedicated actions regarding areas at water risk, including areas of high water stress, for its own operations or in the value chain. The Group states that it plans to reevaluate the priority of the topic in no longer than three years' time.

(Section ESRS E3-3, p 134) As the priority level for water and marine resources is low, the Group has not set or implemented any measurable outcome-oriented targets during the reporting period. The Group also states that it does not track the effectiveness of its policies or actions in the management of water and marine resources.

(Section ESRS E3-4, p 134) The Group reports that it does not directly meter water consumption in its operations. In most stores it meters only water withdrawals, with separate metering of water effluents; where effluents are not metered, they are assumed to equal the amount of water withdrawal, and consumption is then estimated as the difference between withdrawals and effluents. A total of 99.9% of water withdrawal data was obtained from direct measurements or invoices, with the remainder estimated. For the reporting year 2024, total water consumption was 9,055 m3 (2023: 49,752 m3), with none reported in areas at water risk, including areas of high water stress, in either year. Water consumption intensity was 1.5 m3 per million EUR of net revenue in 2024 (2023: 8.5). Total water withdrawals were 850,334 m3 in 2024 (2023: 853,856 m3) and total water effluents were 841,278 m3 in 2024 (2023: 804,103 m3). Only data point E3-4 28(c through d) was deemed not material; the disclosure requirement itself is reported.

(Section ESRS E4-1, p 135) MAXIMA GRUPĖ reports that the resilience of its strategy and business model in relation to biodiversity and ecosystems was not assessed during the reporting period, and a value chain phase-in was applied. The Group postponed the assessment because its own operations are not dependent on ecosystem services and there are no material impacts from own operations apart from pollution, which is addressed in chapter E2 Pollution. Materiality of biodiversity- and ecosystem-related impacts was established in the upstream value chain. The Group states that limited availability of information means the assessment requires more detailed planning and will be considered in later reporting periods. It used the ENCORE tool and WWF Risk Filter Suite to assess dependencies and impacts on nature; for own operations ENCORE identified only a very low materiality level of dependencies, while pollution was identified as material.

(Section ESRS E4-2, pp 136-138) The Group reports that all biodiversity- and ecosystem-related topics apart from invasive alien species are highly material in the upstream value chain, while only pollution is material in own operations (addressed in chapter E2 Pollution). Because most impacts are expected to materialise beyond Tier-1 suppliers and Tier-N visibility is limited, the Group has been unable to prioritise dedicated biodiversity and ecosystem policies, citing limited value-chain data availability. It did not adopt biodiversity and ecosystem protection, sustainable land and agriculture, or sustainable oceans and seas policies. Its Supplier Code of Conduct conveys expectations that upstream partners manage environmental issues with due care, and complaint mechanisms allow stakeholders to report adverse impacts. Group companies have drafted or adopted a Deforestation-free policy (MAXIMA Lithuania in 2024; others planned for 2025), aligned with EU Regulation 2023/1115 and referencing the Accountability Framework Initiative, covering sourcing, supply chain management and risk assessment across the value chain.

(Section ESRS E4-3, p 138) The Group reports actions related to biodiversity and ecosystems, with a value chain phase-in applied. The main action is preparation for the EU Deforestation Regulation (EUDR), which targets seven commodities (cattle, cocoa, coffee, palm oil, soya, rubber and wood) and prohibits their placement on the market unless proven deforestation-free and legally produced; enforcement was postponed from December 2024 to December 2025. In 2024, Group companies allocated dedicated resources to identifying relevant assortment items, assessing inherent non-compliance risk by country of production, establishing due diligence procedures, and engaging suppliers to raise awareness. During 2025 they will develop and integrate tools for faster due diligence, building experience toward the Forced Labour Products Regulation and CSDDD. Pollution-related impacts in own operations are addressed in chapter E2 Pollution. The Group states that no biodiversity offsets were used during the reporting year.

(Section ESRS E4-4, p 138) The Group reports that no measurable, outcome-oriented targets related to biodiversity and ecosystems were set or implemented during the reporting period, and the effectiveness of policies and actions on biodiversity and ecosystem management was not tracked. It states that potential targets in this area will be assessed by Group companies during 2025 and 2026 as part of the implementation and continuous improvement of EUDR-related processes.

(Section ESRS E4-5, p 139) The Group reports impact metrics related to biodiversity and ecosystem change, identifying land-use change (LUC) associated with the food products it offers as the main metric representing impact on biodiversity and ecosystems, with impacts concentrated in the upstream value chain through business relationships with suppliers and agricultural producers. LUC is expressed in tCO2e emitted due to land-use change and measured indirectly using emission factors, applying SBTi and GHG Protocol methodologies, using statistical LUC and levelling deforestation emissions through linear discounting over a 20-year period following a deforestation event. LUC associated with food products sold totalled 355,696 tCO2e in 2024, with no comparative figures available because it was calculated for the first time; further details are in the Metrics sub-chapter of E1 Climate Change. Only data points E4-5 (35) and E4-5 (38) were deemed not applicable.

(Section ESRS E5-1, p 141) The Group reports that Group companies have not adopted policies relating to the circular economy. It identifies amendments to the Packaging and Packaging Waste Regulation (PPWR) as the key driver for future developments in packaging circularity, which it considers the main aspect for the retail sector. As the amended regulation was finally approved at the end of 2024, the Group plans to review the direction agreed by European policymakers and will then determine whether dedicated circular economy policies should be developed by Group companies.

(Section ESRS E5-2, pp 141-142) The Group reports actions related to resource use and circular economy. In Poland, STOKROTKA is preparing for the deposit-refund system (delayed to 1 October 2025), which will apply to retail outlets larger than 200 square metres covering aluminium cans and plastic bottles; it held consultations in 2024 with Baltic Group companies where deposit systems already operate and is selecting reverse vending machine suppliers and preparing an investment plan. The system stems from Directive 2019/904 (SUP Directive). Separately, in March 2024 MAXIMA Latvia launched an initiative to cut logistics plastic film use by nearly 50% through improved delivery processes and alternative goods-securing methods; as a result, plastic film used in 2024 was 41% lower than the previous year, reducing plastic waste and boosting operational efficiency. Results are tracked through plastic use reductions and cost savings, and MAXIMA Latvia plans to continue similar efforts.

(Section ESRS E5-3, p 142) The Group reports that, drawing from the draft PPWR renewal proposal, some Group companies set circular economy-related targets aligned with the draft regulation. The targets cover private-label "Master's Quality" ready-to-eat and ready-to-heat products and relate to the recycling layer of the waste hierarchy. In the Baltics, retail companies set a target to ensure 100% of "Master's Quality" packaging is recyclable by 2030. MAXIMA Lithuania and MAXIMA Latvia set a target for at least 30% recycled content in "Master's Quality" PET packaging and at least 10% recycled content in other plastic packaging by 2030. Both targets are measured annually and progress will be reported in Sustainability Statements. The Group states these targets support increased use of circular design for packaging to enable recyclability and use of circular materials.

(Section ESRS E5-5, pp 142-143) The Group reports resource outflows covering products, materials and waste. For products and materials, it considers packaging for "Master's Quality" products to be the key outflow, for which targets have been set; it plans to evaluate and track recyclable content rates for plastic and paper/cardboard packaging. As the targets were set at the end of the reporting period, relevant Group companies will establish data collection workflows to report on progress during 2025. The disclosure also covers waste outflows from own operations (see the waste-specific summary). Waste associated with packaging of sold products at the consumer and end-user level is reported through end-of-life GHG emissions, totalling 1,056 tCO2e in 2024 (Scope 3 Category 12). Only data point E5-5 36(a-c) was deemed not material; the disclosure requirement is otherwise reported.

(Section ESRS E5-5, pp 142-143) The Group reports waste outflows for its own operations only (value-chain waste is not included). A sizeable amount of non-food waste comes from packaging materials, plus operational waste such as cleaning-supply containers and paper waste; food waste consists mainly of expired, spoiled or trimmed items. No radioactive waste is created. The 2023 data was restated after internal control found incompleteness, and in 2024 about 5.5% of waste volume was estimated. Total waste generated (food and non-food) rose from 113,770 tons in 2023 to 123,507 tons in 2024 (+9%). Waste diverted from disposal rose to 91,132 tons (+20%), while non-recycled waste fell from 38,126 to 32,375 tons (-15%); the share of non-recycled waste dropped from 35.5% to 26.2%. Of 2024 diverted waste, non-hazardous recycling was 85,465 tons. Hazardous waste was 80 tons (-34%); radioactive waste was zero. Non-food waste generated was 95,293 tons in 2024, with about 81% of handling tracked directly and the remainder estimated using Eurostat data.

(Section ESRS S1-1, pp 150-152) In Group companies, human rights are respected through the Equal Opportunities and Diversity Policy and shareholder Vilniaus prekyba's Code of Business Ethics (covered further in the G1 chapters). The Group has not established dedicated policies explicitly addressing human trafficking, forced or compulsory labour, or child labour; trafficking and child labour are not material for own operations, while forced and compulsory labour in the form of modern slavery is addressed through the Code of Business Ethics via fair employment and non-discrimination clauses. The Equal Opportunities and Diversity Policy aims to eliminate discrimination including harassment, promote equal opportunities and diversity, and foster respect for human rights, but sets no commitments on inclusion or positive action for vulnerable groups. It has been adopted by MAXIMA International Sourcing, MAXIMA GRUPE, FRANMAX and all Group retail companies except MAXIMA Estonia, covers all employment aspects, references the UN Global Compact Ten Principles, and is implemented through internal procedures and training. Group companies have established workplace accident prevention management systems.

(Section ESRS S1-2, p 152) Across the Group, employee dialogue and engagement channels vary based on local and national circumstances. Where trade unions or workers' councils are present, the Group upholds employees' right to legal representation without fear of retaliation, and internal communication channels are available for employees to raise concerns and engage in dialogue. The Head of Human Resources or the company CEO are ultimately responsible for engagement throughout the Group. MAXIMA Latvia and STOKROTKA conduct annual engagement and satisfaction surveys, while MAXIMA Lithuania carries out an annual psychosocial risk assessment in which employees can anonymously express how they feel at work. HR departments conduct interviews and surveys to understand obstacles experienced by vulnerable employee groups and identify solutions. Ukrainian refugees working in Group companies are considered more vulnerable due to their personal circumstances, and companies ensure they receive work-related information in an understandable language to support integration. The effectiveness of engagement is assessed through surveys, feedback sessions and turnover trends.

(Section ESRS S1-3, p 152) Employees can raise concerns through several channels, including hotlines, email channels for reporting grievances, email addresses for whistleblowing, representatives of trade unions or works councils, and reporting to their direct supervisors. Responsible persons assess whether employees are aware of and trust these channels through ad hoc surveys, interviews and feedback. Investigating a complaint involves analysing its content, verifying information, interviewing current and former employees and department heads, checking video footage, identifying responsible parties, and setting up a complaints investigation committee if needed; for reports of possible violence or harassment, a committee of at least three people is always established. Where investigation identifies that a situation has caused or contributed to a material negative impact, the relevant unit manager should immediately arrange mediation and remediation, escalating to higher management where required, with appointed employees monitoring implementation. Employees may submit grievances anonymously, and whistleblower mechanisms and anti-retaliation processes are in place (detailed in chapter G1-1).

(Section ESRS S1-4, pp 153-154) Group companies identify actual or potential negative impacts requiring a response through employee surveys, consultations with stakeholders and employee representatives, grievance mechanisms and internal audits. Actions are developed by relevant departments, allocating human and financial resources, and are guided by the Vilniaus prekyba Code of Business Ethics. On training and skills development, Latvia introduced the Think-Act-Inspire programme for store managers in July 2024, with the initial phase concluding in November 2024 with 13 groups and 150 store managers participating. MAXIMA Lithuania runs the Maximanija initiative in which all head office employees train and work at the cash desk for three days each year; a similar initiative at MAXIMA GRUPE, UAB selected 13 proposals, with five approaching final implementation stages by end 2024. In Poland, the 13th edition of the five-month STOKROTKA Express Manager programme launched in 2024. On occupational health and safety, MAXIMA Lithuania started a project enabling regional directors to qualify as OHS specialists, to be finalised in 2025, contributing to the TRIR target.

(Section ESRS S1-5, p 154) In 2024, retail companies in the Baltics set targets for the number of accidents per hours worked over the 2024-2030 period. The indicator, equivalent to the total recordable incident rate (TRIR), is calculated as the total number of recordable incidents divided by total hours worked in 2024, multiplied by one million. During the stakeholder survey, employees highlighted occupational health and safety as a focus area, and targets were set based on actual performance in previous years. The goal for the 2024-2030 period is for the average number of accidents per one million hours worked not to exceed 6.7 at MAXIMA Lithuania, 4.5 at MAXIMA Latvia and 6.0 at MAXIMA Estonia. The 2024 rate of recordable work-related accidents (TRIR) was 8.1 at MAXIMA Lithuania, 5.6 at MAXIMA Latvia and 6.0 at MAXIMA Estonia. Progress is reported annually and made available to all stakeholders, with improvement measures set by each company and tracked by its OHS specialists.

(Section ESRS S1-6, pp 155-156) National laws in the countries of operation do not allow persons to identify as non-binary on identity documents, and GDPR limits data collection, so not all Group companies gather gender identity data; gender is reported based on legal identity documents. As of 31 December 2024 the Group had 36,412 total employees, comprising 7,363 male, 29,048 female, 1 other and 0 not reported. By country, employees numbered 12,392 in Lithuania, 6,139 in Latvia, 3,114 in Estonia, 12,272 in Poland and 2,495 in Bulgaria. By contract type there were 30,176 permanent, 6,236 temporary, 0 non-guaranteed hours, 29,851 full-time and 6,561 part-time employees. Total employee turnover was 48.7% (76.0% male, 41.7% female). Following the cessation of Barbora Polska Sp. z o.o. on 3 March 2024, which made turnover no longer comparable, an additional turnover figure excluding Barbora Polska was provided at 48.2% overall.

(Section ESRS S1-7, p 157) The Group reports non-employee workers in its own workforce as full-time equivalents. To calculate this, it adds up all hours worked by contractors from employment service companies (classified under NACE code 78) and self-employed workers, then divides the total by the number of working hours in a year for a standard employee working five days a week and eight hours per day. The calculation is adjusted for national holidays but does not account for annual vacation time. During the reporting year, the Group had an average of 2,120 FTE among non-employee workers.

(Section ESRS S1-8, p 157) At the end of the reporting period, 49.4% of total employees in the Group were covered by collective bargaining agreements. There were no agreements for employee representation by the European Works Council (EWC), Societas Europaea (SE) Works Council or Societas Cooperativa Europaea (SCE) Works Council during the reporting period. At the end of January 2024, a trade union was established at UAB Barbora. For collective bargaining coverage among EEA employees, Lithuania and Latvia fall in the 80-100% band while Estonia, Poland and Bulgaria fall in the 0-19% band. For workplace representation (EEA only), Lithuania, Latvia, Poland and Bulgaria fall in the 80-100% band while Estonia falls in the 0-19% band.

(Section ESRS S1-9, pp 157-158) Ensuring diversity and equal opportunities is an important part of the Group's business conduct, and its workforce includes people of various ages, gender identities and backgrounds. By age group, of the 36,412 total employees, 6,341 (17.4%) were under 30 years, 17,521 (48.1%) were 30-50 years and 12,550 (34.5%) were over 50 years. Within the under-30 group there were 2,123 male and 4,217 female employees plus 1 other; the 30-50 group had 3,430 male and 14,091 female; and the over-50 group had 1,810 male and 10,740 female. At the end of the reporting period, gender distribution within top management was 53% male and 47% female, which the Group considers to align with the 60/40 gender ratio good-practice benchmark. Top management, defined as individuals one and two levels below the administrative and supervisory bodies, totalled 131 persons: 69 male (52.7%) and 62 female (47.3%).

(Section ESRS S1-10, p 158) All of the Group's companies operate in countries with legally set minimum wages that meet the concept of adequate wages, and the Group ensures that 100% of its employees are compensated in line with the regulations. The EU Commission is updating the methodologies and approaches used to establish minimum salaries, ensuring that the actualisation of suitable pay is embedded in national laws. During the reporting year, the total average annual remuneration increased by 9.7% compared to the previous year, while the annual benefits package (excluding bonuses) reached EUR 58 million.

(Section ESRS S1-11, p 158) All of the Group's employees are covered by social protection through public programmes against loss of income due to major life events. This coverage includes sickness, unemployment, employment injury and acquired disability, parental leave and retirement.

(Section ESRS S1-14, pp 158-159) The Group's health and safety management systems are based on legal requirements in the countries of operation and cover 100% of employees in every Group company. Each company has appointed specialists or divisions responsible for maintaining and implementing OHS standards, with protocols set out in Internal Rules of Working Procedures handbooks; the three essential actions on detecting a risk are to STOP work, REMOVE oneself from danger and REPORT the incident. For the reporting year 2024 the Group recorded 0 work-related fatalities (0 in 2023), 16 high-consequence work-related injuries (4 in 2023), 457 recordable work-related accidents (433 in 2023), a TRIR of 7.01 (6.98 in 2023), 123 cases of recordable work-related ill health (27 in 2023) and a rate of high-consequence injuries of 0.25 (0.06 in 2023). New hires receive initial training before starting work, with refresher training at set intervals. A total of 24,648 employees received health and safety training during 2024. The data point on days lost to injuries, accidents, fatalities or illness (S1-14 88(e)) was deemed not material.

(Section ESRS S1-15, p 159) All of the Group's employees, irrespective of age or gender, are entitled to family-related leave, including maternity leave, paternity leave, parental leave and carers' leave, through national laws. In 2024, 2,599 employees took family-related leave (2,281 female and 318 male). Of the 1,630 employees due to return from family-related leave during the reporting period (1,337 female and 293 male), 1,221 returned to work after their leave ended during the reporting year (1,024 female and 197 male). The return-to-work rate was 74.9% overall, comprising 76.6% for female employees and 67.2% for male employees. The percentage of employees who took family-related leave was 7.1% overall, at 7.9% for female employees and 4.3% for male employees.

(Section ESRS S1-16, p 160) The unadjusted gender pay gap is calculated as the difference in average pay levels between female and male employees, expressed as a percentage of the average pay level of male employees. Figures are provided for the whole Group and for individual countries of operation, with the country breakdown given to help understand pay differences relating to purchasing power and local circumstances. The figures include only data for Group companies that had more than 150 employees on 31 December 2024. The unadjusted gender pay gap was 13.3% for the Group, 15.0% in Lithuania, 5.8% in Latvia, 11.3% in Estonia, 9.9% in Poland and 25.4% in Bulgaria. The annual total remuneration ratio (S1-16 97(b)) was omitted for confidentiality reasons.

(Section ESRS S1-17, p 160) During the reporting year there were no cases of severe human rights violations within the Group's workforce, meaning no fines, penalties or compensation for damages were incurred. The total number of incidents of discrimination, including harassment, was 7. There were 35 complaints filed through internal channels for the own workforce and 13 complaints filed through external channels. No complaints were filed with National Contact Points for OECD multinational enterprises. The total amount of fines, penalties and compensation for damages resulting from the incidents and complaints disclosed above was 0.

(Section ESRS S2-1, p 162) Group companies have implemented a Supplier Code of Conduct that embeds respect for human rights, including the labour rights of workers in the value chain. To apply the code in operations, they have established channels enabling reports of misconduct in the value chain, and all such reports are investigated with due care, with mediation initiated where needed to remediate adverse human rights impacts. In addition, MAXIMA Lithuania has adopted a Deforestation-free policy addressing human and labour rights at the level of sourcing raw commodities. The policies explicitly align with the UN Guiding Principles on Business and Human Rights and expect suppliers to implement human rights due diligence proportionate to the size and nature of their operations, focusing on preventing and addressing violations throughout the supply chain. The Group reports no instances of severe human rights violations or non-compliance with the UNGP, the ILO Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines for Multinational Enterprises involving value chain workers.

(Section ESRS S2-2, p 162) Group companies do not have processes for regular engagement with value chain workers. Instead, they rely on credible proxies, such as the CSR Risk Filter and the Business and Human Rights Resource Centre, to gain insight into situations involving value chain workers. Direct engagement occurs only in response to legal requirements or substantiated allegations. While the Group does not actively engage with value chain workers itself, through the Supplier Code of Conduct it encourages suppliers to implement their own grievance and due diligence mechanisms, proportionate to company size and scope of activities.

(Section ESRS S2-3, pp 162-163) Group companies provide external channels for stakeholders, including value chain workers, to raise concerns and submit grievances. These channels, also used for reporting misconduct (with further detail in the sub-chapters of G1 Business Conduct), are publicly accessible and regularly monitored to ensure effectiveness. Group companies maintain active communication with stakeholders, engaging through various channels and responding promptly to their interests and concerns. Although the Group does not actively engage with value chain workers, through the Supplier Code of Conduct it encourages suppliers to implement their own grievance and due diligence mechanisms, proportionate to company size and scope of activities.

(Section ESRS S2-4, p 163) During the reporting year, actions on workers in the value chain concentrated on pursuing compliance with the EU Deforestation Regulation (EUDR), which addresses actual adverse impacts and material risks related to non-respect of human and labour rights among value chain workers for relevant high-risk commodities. The Group treats products within the scope of the regulation as the primary near-term focus and foresees expanding coverage as legislation develops and its own processes mature. During the year there were no instances in which the Group identified itself as causing or contributing to actual adverse impacts on value chain workers requiring mediation or remediation; such instances are identified primarily through reports of misconduct filed via grievance and whistleblowing mechanisms. Where misconduct is reported, Group companies would engage in dialogue with the relevant supplier, dedicate appropriate resources, and evaluate responses to substantiated violations, reserving the right to terminate a contract if a supplier that breached the Supplier Code of Conduct is unwilling to provide remediation.

(Section ESRS S2-5, p 163) Group companies have not set specific targets or metrics for managing negative impacts, enhancing positive impacts, or addressing material risks and opportunities related to workers in the value chain. This is primarily because they are awaiting further guidance on newly introduced regulations, particularly the Forced Labour Products Regulation (FLPR), which is expected to provide a structured framework for addressing labour and human rights risks in upstream value chains. At this stage the Group is prioritising adherence to the EUDR for relevant commodities, seen as a solid foundation for a risk-based due diligence approach, focusing resources on the most critical commodities to strengthen labour and human rights protections. Group companies did not establish any specific metrics to track progress of targets or actions in this area.

(Section ESRS S4-1, pp 166-167) The main policy is the Privacy Policy, adopted by retail and e-commerce Group companies, MAXIMA International Sourcing and FRANMAX. It defines the procedures and purposes for collecting and processing personal data and its scope, and informs service users and website visitors of their rights, covering the privacy of all consumers and end-users. The policy focuses on Group companies' own operations and does not cover the upstream or downstream value chain; personal data is mainly processed within the EU, though some website-visit data may be processed or shared inside and outside the EEA, including the US, via services such as Google Analytics and Facebook ads. The CEO is accountable for implementation, and the policy is published on company websites. Group companies have no separate dedicated human rights policy for consumers, but grievance and whistleblower hotlines let customers report misconduct and help monitor alignment with the UNGP, the ILO Declaration and the OECD Guidelines. The Group respects the human rights of its customers and addresses substantiated non-compliance it has caused or contributed to.

(Section ESRS S4-2, p 167) The Group prioritises honesty, transparency and timeliness in all customer interactions. It disseminates information through a variety of channels, including newspapers, weekly flyers, customer magazines, television advertisements and official websites, and engages via social media platforms such as Facebook, LinkedIn and Instagram. While specific tools vary by country, customers across all regions can contact the company, ask questions and give feedback, generally by phone, email, in person at stores, through the loyalty app and via social networks. The Head of Customer Support or Director of the Retail Department is usually responsible for keeping engagement processes active. To understand particularly vulnerable groups, the Group engages with non-governmental organisations and monitors information reaching it through grievance and whistleblower channels. The effectiveness of engagement channels is assessed by relevant communications departments using indicators that differ by engagement tool, with results communicated to company management.

(Section ESRS S4-3, pp 167-168) Complaints and reports filed by customers and end-users through grievance and whistleblower channels, either directly or anonymously, are thoroughly investigated. This involves analysing the complaint's content, verifying facts, interviewing relevant employees, asking security staff to check video footage, and setting up a complaints investigation committee if deemed necessary. Where a Group company identifies that it has caused or contributed to a material negative impact on customers, the relevant unit manager, within their authorisation, immediately takes action to ensure timely mediation and remediation; higher management is informed and participates when needed, and appointed employees monitor implementation. Group companies do not have dedicated processes to assess whether customers are aware of and trust these channels, but internal evaluations based on how actively customers file reports suggest the channels have an appropriate level of visibility and accessibility.

(Section ESRS S4-4, p 168) Group companies identify particular actual or potential negative impacts requiring response through customer surveys, consultations with stakeholders and NGOs, and grievance mechanisms. Relevant departments then develop actions to address the negative impacts identified; where an adverse impact has occurred, remediation is provided and appointed responsible persons oversee implementation and effectiveness. When tensions arise between mitigating negative impacts and other business objectives, Group companies rely on established decision-making processes and ethical considerations, and are prepared to accept short-term limitations on sales or marketing strategies if these pose a credible risk to consumer interests. To ensure proper use of customer data, they rely on internal processes and privacy policies aligned with regulations and best practices. To improve access to information, the Group has introduced QR codes in non-prepacked-goods sections providing product details including allergens, and displays recall notices in stores in the event of a public recall so customers can return products for a refund.

(Section ESRS S4-5, pp 170-171) Group companies did not set specific long-term targets related to managing negative impacts, advancing positive impacts, or addressing material risks and opportunities in relation to customers and end-users. Instead, operational functions set quarterly targets that address the identified impacts, risks and opportunities through dedicated, relevant and timely actions. On consumer privacy, Group companies track the total number of breaches involving personally identifiable customer information to assess the effectiveness of internal data-safety processes, and carry out employee training, especially for higher-risk functions. During the reporting period, 2,084 employees performing functions at risk of personal data breaches received training on cybersecurity, GDPR, personal data handling and related fields. On affordability, MAXIMA Lithuania emphasised price reductions through weekly and monthly promotions and a campaign offering a 50% discount on non-food items when buying two or more, while STOKROTKA launched its "Cheap is here" and "Cheaper is not possible" campaigns and reduced regular prices on more than 600 products.

(Section ESRS G1-1, pp 173-174) Each Group entity operates under a conduct framework based on fairness, ethical practices and compliance with the laws of its operational jurisdictions. Three core policies anchor the approach: the Equal Opportunities and Diversity Policy, the Anti-Corruption Policy and the Supplier Code of Conduct, all aligned with shareholder Vilniaus prekyba's Code of Business Ethics. The Code, together with the Anti-Corruption Policy, sets a zero-political-contributions approach across Group operations. Policies apply to all employees and markets with no geographic exclusions, and are published on public websites and intranets. Annual training is provided across the Group, and new employees are introduced to the policies during onboarding, covering corruption, competition law, conflicts of interest, gifts, nepotism and related topics. The functions most at risk are purchasing, supply chain management and real estate management, monitored through internal, financial, compliance and internal audit controls, with senior management and the Audit Committee informed of fraud or corruption. A whistle-blowing mechanism protects and pseudonymises whistleblowers. Estonian companies adopted whistleblower policies in early 2025 after national law took effect on 1 September 2024.

(Section ESRS G1-2, pp 175-176) The Group expects suppliers to conduct business ethically and transparently, producing goods fairly and with minimal environmental impact. A Supplier Code of Conduct was introduced in 2020 and revised during the reporting period to highlight expectations to follow key international good-practice standards on human and labour rights; the revised version will be adopted by Group companies during the first half of 2025. Suppliers must comply with all relevant laws, treat employees fairly, provide a safe workplace, and take responsibility for their environmental footprint. The code sets minimum standards, applies to all suppliers and subcontractors across all geographies with no explicit exclusions, and the revised version explicitly addresses human trafficking, forced labour and child labour. It aligns with the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights, the ILO Declaration, the International Bill of Human Rights and the UN Global Compact. The code is available on the corporate website as a contract addendum, and Group companies may conduct assessments, inspections and audits. Most sourcing is handled locally, with the remainder centralised through MAXIMA International Sourcing. A separate Deforestation-Free Policy also applies to relevant suppliers.

(Section ESRS G1-3, pp 177-178) The fundamental principles for preventing and detecting corruption and bribery are set out in the Anti-Corruption Policy, implemented by Group companies through processes integrated into daily operations. The policy has been adopted by all retail Group companies, FRANMAX and MAXIMA GRUPE. It aims to establish principles to prevent corruption and promote integrity, transparency and accountability, and enforces a zero-tolerance approach to bribery, influence peddling and nepotism, while addressing conflicts of interest and unethical procurement practices. Its scope is broad, applying to all employees, including management, supervisory bodies and committees, and to individuals under civil contracts, across the upstream and downstream value chain and all geographies. The management of each Group company is accountable for implementation. The policy is published on Group companies' websites. Dedicated corruption-prevention training is carried out, and all current and newly joining employees are acquainted with the policy. The companies identified a total of 1,264 persons performing functions considered at risk from corruption or bribery, of which 485 employees received dedicated training on corruption and bribery prevention during 2024.

(Section ESRS G1-4, p 178) The Group actively monitors implementation of its anti-corruption policy at all levels and encourages the reporting of activities that may pose a risk of misconduct, guaranteeing protection and anonymity for those who come forward. During the reporting period, there was 1 case of abuse of rights confirmed through internal investigation, and the employment relationship with the employee concerned was terminated. The case did not result in fines for the Group companies. To mitigate risks, Group companies conduct security inspections when corruption concerns arise, with dedicated employees reviewing agreements to ensure consistency across contracts, invoices and procurement tenders. Regular training reinforces ethical standards, while internal audits and investigations help identify and address potential breaches, and violations are met with disciplinary actions ranging from warnings to termination or legal proceedings. Investigation outcomes are communicated to the management board at Group level and to the audit committee. During the reporting year, there were no convictions relating to violation of anti-corruption or anti-bribery laws that resulted in fines.

(Section ESRS G1-6, p 178) Group companies have established internal controls and procedures to prevent late payments. Their payment practices are in line with applicable national regulations that, among others, transpose and implement the Unfair Trading Practices Directive, and 100% of payments are aligned with standard payment terms, with further information on payment terms available in Note 18 of the financial statements. As of the end of the reporting period, there was 1 outstanding legal proceeding for late payments. One data point, the disclosure under ESRS G1-6 33(a) of the average number of days to pay an invoice, has been omitted because it is considered confidential business information that shall not be disclosed.