MAXIMA GRUPĖ

Governance roles

Reference: pages 41-43, 58-59. Composition, diversity, roles and sustainability expertise of the administrative, management and supervisory bodies are incorporated by reference to the Governance Report (pages 41-43); the gender ratio is given under S1-9 Diversity (page 88).

Allocation of responsibility (page 58):

• The Board (Management Board) approves Group-wide sustainability policies, approves the double materiality assessment outcomes, approves Group-wide sustainability targets, approves the annual report and oversees implementation of sustainability targets through semi-annual and annual reports.
• The Audit Committee oversees the sustainability reporting process and the independence of the assurance provider.
• The CEO ensures implementation of sustainability targets, policies and actions.
• The Legal and Sustainability Department develops Group-wide targets, conducts and periodically reviews the DMA, and prepares the annual consolidated sustainability statement; the Finance Department prepares the statement as part of the financial reporting package and the Head of Accounting and Financial Control prepares the Taxonomy Report; Internal Audit evaluates the effectiveness of internal controls relevant to sustainability reporting.

Responsibilities "are set out in the Sustainability Policy, established in 2025" (page 58; the policy itself is described under G1-1, page 93). Board members "can leverage sustainability-related expertise through the network of sustainability professionals, practitioners and subject-matter experts in their own workforce and dedicated training, as well as external consultancy when deemed necessary" (page 58). Internal expertise is mapped topic by topic: real estate departments and sustainability units for E1; sustainability units for E2, E3 and E5; HR, legal and sustainability units for S1; legal and sustainability units for S2; communications, legal and sustainability units for S4 (page 58).

Information provided to and matters addressed by the bodies

Reference: pages 59-60. The report tabulates each reporting line, its frequency and the decisions taken in 2025.

• Head of Sustainability to the Management Board - annually (once in 2025) on the annual sustainability statement, key metrics and progress towards goals including science-based targets; the Board "Approved the Annual Sustainability Statement 2024" and became acquainted with progress (no formal decision).
• Head of Sustainability to the Management Board - ad hoc (twice in 2025) on setting the Group Sustainability Policy and presenting the reviewed DMA results; the Board "Approved the Sustainability Policy" and "Approved the List of Material Topics resulting from the updated double materiality assessment".
• Head of Sustainability to the Audit Committee - at least three times per year (three times in 2025) to oversee the reporting process and the independence of the assurance provider; the Committee reviewed the final sustainability statement and the results of the limited assurance engagement (no formal decision made).
• Head of Sustainability to the Audit Committee - ad hoc (twice in 2025) on internal controls for sustainability reporting and data-collection traceability.
• Head of Sustainability to the CEO - quarterly (four times in 2025) on work priorities, action plans, quarterly goals and stakeholder engagement results.
• Head of Legal / Internal Audit team to the Audit Committee and Management Board - ad hoc, and this "did not take place in 2025".

The Management Board "takes into considers the broader implications of strategic decisions on sustainability matters through its approach to risk management. Risk tolerance is assessed in light of the principle that the company's financial stability or reputation is not exposed to intolerable threats" (page 59).

Sustainability performance in incentive schemes

Reference: page 60.

The Group discloses a nil return. "The Group does not have any incentive schemes or remuneration policies linked to sustainability matters among members of the administrative and management bodies. Climate-related considerations are not factored into the remuneration of members of the administrative, management and supervisory bodies. This means that 0% of remuneration recognised in the current period is linked to climate-related considerations as well as it was in 2024" (page 60).

The same disclosure is cross-referenced under E1 as E1.GOV-3 in the ESRS index (page 96), which points to page 60. Because there is no sustainability-linked remuneration, no further percentage breakdown, no description of performance benchmarks and no approval or update process is disclosed.

Statement on due diligence

Reference: page 60.

"Group companies followed the United Nations Guiding Principles on Business and Human Rights (UNGP) and the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises on Responsible Business Conduct in establishing the sustainability due diligence processes" (page 60).

The mapping table gives, for each core element of due diligence, the paragraphs of the statement where it is addressed:

• Embedding due diligence in governance, strategy and the business model - GOV-1, GOV-2, GOV-3, SBM-3
• Engaging with affected stakeholders in all key steps - GOV-2, SBM-2, IRO-1
• Identifying and assessing adverse impacts - IRO-1, SBM-3
• Taking actions to address adverse impacts - E1-3, E2-2, E3-2, E4-3, E5-2, S1-4, S2-4, S4-4
• Tracking effectiveness and communicating - targets E1-4, E5-3, S1-5; metrics E1-6, E2-3, E3-3, S1-14, S1-16, S1-17, E5-5, S2-5, S4-5, G1-4

The table is a signposting exercise: it names no due diligence outcomes of its own.

Risk management and internal controls over sustainability reporting

Reference: page 60.

The framework rests on "standardised data collection templates to ensure consistency and accuracy across subsidiaries", validation rules and checks for manual and software-assisted verification, continuous training, documentation of data sources and methodologies for traceability, and role-based access with segregation of duties (page 60).

Risks identified in 2025 "remained consistent with those identified in the previous year, including inaccurate or incomplete data, insufficient controls to prevent data manipulation and fraud, delayed data availability, technological failures, non-compliance with methodology, and the lack of an information trail" (page 60).

Three documented controls are described (page 60):

• Sustainability Reporting Procedure - a standardised procedure for preparing the annual statement, compliant with Directive (EU) 2022/2464, covering data consolidation, risk management, internal controls and the reporting cycle.
• ESG Data Validation Protocol - principles, checklists for minimum validation processes and methodological support for data quality assurance, including data ownership, source verification and completeness and accuracy checks.
• ESG Data Processing Procedures - "a set of six documented procedures" covering energy, the GHG inventory, water, waste, own workforce and governance disclosures.

"The Validation Protocol mandates data owners to confirm the reliability of their submissions and environmental, social, governance (ESG) data controllers to perform random checks" (page 60). Findings are reported to the Board and the Audit Committee.

Strategy, business model and value chain

Reference: pages 7-8, 60-62. Principal activities, products, major markets and headcount are incorporated by reference to the About MAXIMA Group chapter (pages 3-10).

MAXIMA GRUPE is a food retailer. In 2025 the Group operated across five countries, with revenue of EUR 6.35 billion, up 4.1%, and EBITDA profitability up 0.6 percentage points to 8.0% (page 3). At the end of the year the sole shareholder "Vilniaus prekyba" narrowed the Group's scope to the Baltic countries: STOKROTKA in Poland and T Market in Bulgaria were sold to PARETAS B.V. (page 3). Those markets contributed EUR 2.28 billion of 2025 revenue.

Exclusions (page 60): "Group companies are not active in the fossil fuel (coal, oil and gas) sector, chemical production, controversial weapons, nor cultivation and production of tobacco, with no revenues gained from such activities during the reporting period. None of the products and services provided by the Group's companies are banned in the markets in which they operate."

Value chain (pages 61-62). The upstream chain covers product and raw material suppliers (agricultural producers, food manufacturers and processors, non-food manufacturers, importers and distributors), packaging and materials suppliers, logistics and transportation providers, warehousing and infrastructure suppliers, and financial and professional services providers. Own operations cover inbound logistics and warehousing, quality and food safety, physical and online retail, customer-related activities and last-mile delivery. The downstream chain "primarily comprises individual consumers and business customers". Own operations "are mainly located in the Baltic States and other selected markets"; the upstream chain "is geographically diverse", and "Agricultural raw materials are sourced from multiple countries depending on product type and seasonality".

Interests and views of stakeholders

Reference: pages 62-63.

Stakeholders are identified using Mendelow's Matrix, segmenting them "based on two key dimensions: their level of power and their level of interest" (page 62), and are then sorted into two types: affected stakeholders and users of sustainability statements, with the report noting that "some stakeholder groups may be assigned to both categories".

The mapping table (page 62) sets out each group, its type, its areas of concern and the engagement channels:

• Shareholders and investors (users) - financial and sustainable performance, risk management, ethics and transparency.
• Suppliers and business partners / workers in the value chain (affected and users) - delivery terms, fair payment terms, fair treatment.
• Employees / own workforce (affected) - working conditions, wellbeing, benefits, development, equal opportunities, safety.
• Customers and end-users (affected) - product quality, availability, safety, assortment, affordable prices, shopping experience, claims handling, data protection.
• Local communities / affected communities (affected) - food waste, environmental impact, social initiatives, local suppliers.
• Media, authorities and public administration, NGOs - open dialogue, taxes, compliance, environmental and health impacts, animal welfare, anti-corruption.

Insights "are used by the relevant departments to refine processes, develop new offerings and prevent misconduct" (page 62). On affected communities specifically, the Group states they "are concentrated in Tier-N of the upstream supply chain, particularly in locations where raw materials are harvested" (page 63); ESRS S3 was nonetheless not assessed as material.

Material impacts, risks and opportunities

Reference: pages 65-67, with topic-level tables on pages 70, 76, 77, 78, 80, 84, 89-90, 90-91 and 93.

The DMA identified nine material sustainability matters, all sector-agnostic: climate change management (E1), control of air and water pollution and control over intentionally added chemicals (E2), water and marine resource management (E3), impacts and dependencies on biodiversity and ecosystems (E4), circular economy and waste (E5), own workforce (S1), workers in the value chain (S2), our customers (S4) and responsible business conduct (G1) (pages 64-65). Six entity-specific matters were assessed but "were not assessed as material for disclosure in the current reporting period" (page 65). ESRS S3 Affected communities is absent from the material list.

The consolidated table on pages 65-67 tags 31 individually coded impacts, risks and opportunities, each with its value chain location, whether it is actual or potential, its link to the business model, time horizon and nature of involvement. Examples: "Non-renewable energy consumption results in GHG emissions into the atmosphere that increase the pace of climate change [E1_MI-1]"; "Spikes in energy prices, carbon taxes on energy-inefficient assets, risk of stranded assets [E1_MR-2]"; "Food waste contributes to environmental impacts arising from waste handling and the production of goods [E5_MI-3]"; and the single opportunity, "Opportunities to reduce food waste in own operations through improved inventory management, handling and food donation practices [E5_MO-1]".

Financial effects (page 65): "At the reporting date, the current financial effects of the Group's material sustainability-related risks and opportunities are mainly reflected in operating costs, capital expenditure and compliance-related administrative expenses. No separate material effects on the carrying amounts of assets and liabilities were identified for the purposes of disclosure in this sustainability statement." A three-year phase-in is applied to datapoint ESRS 2 SBM-3 48(e) (page 96).

Climate-specific risk identification and scenario analysis is also presented under E1-2, and climate resilience under E1-3 (2025 ESRS numbering).

Process to identify and assess material impacts, risks and opportunities

Reference: pages 64-65.

The DMA was first conducted in 2024 and "was further refined in 2025 to enhance clarity on where material impacts, risks and opportunities arise and are significant across the value chain" (page 64). "The refinement did not materially alter the list of material sustainability matters identified in the 2024 assessment... Accordingly, the 2024 DMA outcome was not retrospectively revised." The assessment "is reviewed in full at least every three years" and results are approved by the Management Board.

Scope: "We assessed 92 sustainability matters that are universally applicable across sectors (sector-agnostic) and explicitly defined in the ESRS", plus "an additional six sustainability matters specific to our organisation (entity-specific)", which were not assessed as material (page 65). With no ESRS sector standard for retail, the Group turned to SASB retail and e-commerce standards and peer reviews.

Thresholds (page 64). Impact severity is scored 0-5 on scale, scope and irremediable character: "A topic was considered material if its total score was 8 or more", with an exception that "if any dimension... received the maximum score of 5, the impact was automatically classified as material". Positive impacts use a separate threshold of 4 or more. For financial materiality, triggers are scored 0-4 under the six IIRC capitals and "Financially material triggers were defined as those with a score of 2 or more and a probability of occurrence of more than 50%".

Tools and proxies: elements of the TNFD LEAP approach for pollution, water, circular economy and biodiversity; ENCORE, the WWF Risk Filter Suite and SBTN for environmental proxies; CSR Risk Check (MVO Nederland) and the Worldwide Governance Indicators for social and governance risk (pages 64-65). For the upstream chain "we did not have sufficient information to identify physical locations, nor were we able to consult affected communities due to limited visibility down to Tier N".

Disclosure requirements covered by the sustainability statement

Reference: pages 96-98.

The statement carries a full ESRS Disclosure Requirements Index at pages 96-98, listing each disclosure requirement with a page reference or, where none is given, a reason for omission. Sections cover ESRS 2 (BP-1 to MDR-T), E1, E2, E3, E4, E5, S1, S2, S4 and G1. No ESRS S3 section appears in the index, consistent with affected communities not being material.

Reasons recorded in the index include: "Disclosure requirement deemed not material" (E2-4, E2-5, E2-6, E3-5, E4-6, E5-4, S1-12, G1-5); "The Group applied a three-years transitional period for disclosure, following ESRS 1 Appendix C provisions" (E1-9, E5-6); "3 year phase-in applied to Disclosure Requirement following provisions of ESRS 1 Appendix C" (S1-13); "Value chain phase-in applied" (E4-1, E4-3); "The Group did not acquire GHG removal credits or finance any GHG mitigation projects" (E1-7); and "The Group did not apply any internal carbon pricing schemes" (E1-8). Datapoint-level exclusions are flagged for ESRS 2 SBM-3 48(e), E3-4 28(c-d), E4-5 (35) and (38), E5-5 36(a-c) and S1-14 88(e).

A separate list of datapoints derived from other EU legislation precedes the index (pages 95-96), giving the location of each datapoint or marking it "Not material", "Phase-in applied" or "Value chain phase-in".

BP-1 states that the statement "has been prepared on a voluntary basis. Notwithstanding its voluntary nature, the Group has prepared the statement in accordance with the European Sustainability Reporting Standards (ESRS)" (page 57).

Transition plan for climate change mitigation

Reference: page 71.

The plan does not yet exist in finished form. "The Group has begun developing a transition plan for climate change mitigation, with completion anticipated no earlier than 2026. The plan is being developed based on GHG emission reduction targets verified by the Science Based Targets initiative (SBTi) in alignment with the goal of the Paris Agreement to limit global warming to 1.5 degrees C" (page 71). The ESRS index records the same reason against E1-1 (page 96).

What is disclosed is a quantified decarbonisation waterfall for the Scope 1 and 2 science-based target, from a 2021 base year to -42.0% by 2030 (page 71): transition to lower climate impact refrigerants -15.7%, transition to renewable energy and further adaptation of energy efficiency measures -16.6%, solar panels for electricity production -4.3%, conversion to LED lighting -2.2%, smart automation of store energy systems -1.6% and energy efficiency measures -1.6%, with organic growth and the expected decarbonisation of national grids also shown. A "current knowledge wall" splits "actions already planned and future actions that we have not yet explicitly planned". No decarbonisation levers are presented for Scope 3, "as the Group has set Scope 3 engagement targets".

Investment. "In 2023, we assessed the preliminary investment needed to achieve our science-based targets pertaining to Scope 1 and 2 emissions. These investments are projected to amount to approximately EUR 100 million between 2023 and 2030." Cumulative Taxonomy-eligible Capex under the climate change mitigation objective for 2023-2025 "has amounted to EUR 59 million (excluding CCM7.1 and CCM 7.7 as these two activities do not contribute to investment's to achieve SBTi goals)". "At the time of publishing the sustainability statement, we had not conducted any estimations on the potential alignment of future Capex and Opex with the Taxonomy."

The Group "does not fall under the definition for exclusion from the EU Paris-aligned Benchmarks as laid down in Article 12 of Commission Delegated Regulation (EU) 2020/1818", and "made no significant Capex investments in coal-, oil- or gas-related economic activities" (page 71).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 as applied to climate (E1 IRO-1 Climate Risks), where this content is disclosed in the FY2025 report (page 70). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification of risks. The E1 SBM-3 table (page 70) names two climate risks: physical risk, "Risks of negative impacts from climate change on infrastructure that may disturb normal operations, including acute climate effects that prevent a building from being entered or cause damage to property, frost that impacts road infrastructure, and acute and chronic hazards that impact the agricultural sector [E1_MR-1]"; and transition risk, "Spikes in energy prices, carbon taxes on energy-inefficient assets, risk of stranded assets [E1_MR-2]".

Methodology and scope (page 70). "During the reporting period, the Group conducted a climate change resilience analysis covering its own operations (including stores, warehouses and logistics infrastructure) in Lithuania, Latvia, Estonia, Poland and Bulgaria... It primarily covered the Group's own operations, while transition risks were also considered in relation to upstream value chains through suppliers, logistics and packaging. The analysis did not extend to a detailed downstream value chain assessment or asset-specific analysis." Horizons are medium term to 2030 and long term to 2050.

Scenarios (page 70). "This was a qualitative scenario analysis conducted during the reporting period." Physical risk drew on the Eighth National Communications to the UNFCCC and Climate-ADAPT, and "applied a high-emissions climate scenario broadly aligned with the Intergovernmental Panel on Climate Change (IPCC) Representative Concentration Pathway (RCP) 8.5 assumptions". Transition risk used "two qualitative scenarios: an orderly transition scenario, aligned with EU climate-neutrality objectives by 2050, and a delayed transition scenario, reflecting limited and fragmented climate policy action (a 'hot world' pathway)".

Gap: no global average temperature projection is attached to either scenario, and no 1.5 degrees C-aligned scenario with no or limited overshoot is named for transition risk. "The resilience analysis was qualitative in nature and did not include a separate quantification of anticipated financial effects."

Resilience in relation to climate change

Back-filled from the E1 IRO-1 Climate Risks subsection and ESRS 2 SBM-3, where this content is disclosed in the FY2025 report (page 70). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Results (page 70). "The analysis identified exposure to a range of climate-related physical risks, including heatwaves, heavy precipitation, floods and temperature variability... These risks were assessed as manageable within existing operational controls, with no physical climate risks identified as having a high likelihood of causing material financial or operational disruption within the assessed time horizons." Because no physical risk scored both high likelihood and potentially material impact, "no further detailed impact assessment was performed at this stage".

"Transition risks were identified primarily in relation to energy costs, refrigeration systems, regulatory developments and upstream supply chains", expected to materialise over medium to long horizons. "No material climate-related transition risks were identified over a one-year time horizon."

Business model implications (page 70). "The climate resilience analysis did not identify any assets or business activities as incompatible with a transition to a climate-neutral economy. However, certain operational areas, including refrigeration, energy use, logistics and packaging, were identified as requiring continued transition efforts." The E1 SBM-3 narrative adds that "When deemed necessary, Group assets important to business activities are insured against climate-change-driven physical risks" and "Supply chains are diversified to build resilience against disruptions in the availability of agricultural products due to low harvests" (page 70).

Uncertainty (page 70). "The analysis is subject to uncertainty inherent in long-term climate projections and qualitative scenario analysis, particularly where the assessment of risks to own operations was based on national and, in some cases, subnational climate risk information rather than asset-specific analysis." It "did not identify any material climate-related risks that had not already been captured through the DMA".

No quantified capacity-to-adapt analysis (flexibility of financial resources, redeployment or decommissioning of assets) is presented.

Policies related to climate change mitigation and adaptation

Reference: page 72.

The Group discloses that it has no climate policies. "The Group has not adopted any policies relating to climate change mitigation and adaptation, energy efficiency, renewable energy deployment or other climate change-related topics, with the relevant policies set to be developed no earlier than 2026. The delay relates to the complexity of implementing such policies within the Group due to different contexts, markets and regulatory environments in the countries of operation" (page 72).

This is consistent with the general statement in GOV-1 that "If a given impact, risk or opportunity has no dedicated action, policy or target presented in the sustainability statement, it means that no actions, policy or target materials for reporting have been implemented during the reporting period" (page 58). A Sustainability Policy was nonetheless established in 2025 covering, among other things, "reducing CO2 emissions and waste", and is described under G1-1 (page 93).

Actions and resources in relation to climate change policies

Reference: page 72.

"Although there are no climate-related written policies at present, Group companies are actively implementing measures that address energy consumption, renewable energy generation and the reduction of GHG emissions" (page 72). Total GHG footprint was 5,120,815 tCO2e in 2025 against 5,167,645 tCO2e in 2024.

Renewable energy. MAXIMA Lithuania installed one new 50 kW solar station, raising installed capacity from 266 kW to 316 kW; STOKROTKA added 15 photovoltaic systems totalling 787.98 kW, reaching 122 installations and 5,807.33 kW. Renewable generation rose to "more than 7.1 GWh (compared to 5.4 GWh in the previous year), of which we consumed 95% directly on-site", avoiding 2,837 tCO2e (2,257 tCO2e in 2024).

Refrigerants. "GHG emissions arising from refrigerant leakage reached 45,893 tCO2e in 2025 (compared with 66,993 tCO2e in 2024)." Stores with water-loop or CO2-based systems rose to 145 (118 in 2024), of which 122 in the Baltic States; STOKROTKA installed its first CO2 systems in four stores.

Energy efficiency. Heat recovery from refrigeration was extended to 6 more MAXIMA Lithuania stores, reaching 70 sites and recovering 3,015 MWh of thermal energy, "approximately 510 tCO2e of avoided emissions". 99.7% of owned and operated vehicles meet EURO 6 (99.9% in 2024) and 79% of passenger cars are petrol or hybrid (69% in 2024). MAXIMA Latvia has run an ISO 50001-certified energy management system since 2016.

Resources. "A total of EUR 77.0 million in Taxonomy-eligible Capex and EUR 25.1 million in Taxonomy-eligible Opex was directed towards reduction of climate impacts throughout the whole Group in 2025 (compared with EUR 71.9 million in Taxonomy-eligible Capex and EUR 14.5 million in Taxonomy-eligible Opex in 2024)." The Group notes that measures outside hard investment are reflected in the GHG inventory but "the specific monetary values of these measures are not explicitly quantified". Physical-risk actions "focused primarily on insurance coverage".

Targets related to climate change mitigation and adaptation

Reference: pages 72-73.

"MAXIMA GRUPE is committed to reducing absolute Scope 1 and 2 GHG emissions 42.0% by 2030 from the 2021 base year. MAXIMA GRUPE also commits that 78.3% of its suppliers by emissions covering purchased goods and services, will have science-based targets by 2027" (page 72). The absolute reduction target value is 117,626 tCO2e.

Targets were validated by the SBTi, with "Official approval... granted at the end of 2023, with SBTi classifying our Scope 1 and 2 target ambitions as being in line with a 1.5 oC trajectory", set using "the SBTi cross-sector pathway and corporate near-term criteria and using an absolute contraction approach" (page 72). Scope 2 is calculated market-based. "Scope 1 and 2 targets cover 100% of Scope 1 and 2 emissions, while the Scope 3 engagement target covers two-thirds of Scope 3 emissions." Targets are reviewed and if necessary recalculated at least every five years, with a 5% significance threshold; "No reviews of the baseline were performed during the reporting year".

Progress (page 72). "At the end of the reporting period, a 24.5% reduction in Scope 1 and Scope 2 GHG emissions had been achieved compared to base year 2021." On the engagement target, "At the end of the reporting period 19.0% of our suppliers, by emissions covering purchased goods and services, had science-based targets according to publicly available information from the Science Based Targets initiative (SBTi) Target Dashboard" - against the 78.3% commitment for 2027.

Caveat: "Following the disposal of the Group's operations in Poland and Bulgaria in 2025, the suitability and feasibility of this Scope 3 engagement target will be reviewed in 2026" (page 72). The 2021 baseline was chosen because the 2022 inventory was incomplete at submission and 2020 was distorted by COVID-19 (page 73). No adaptation target is disclosed.

Energy consumption and mix

Reference: pages 73-74. Figures in MWh for own operations, with three columns: comparative 2024, reporting year 2025 and continuing operations 2025.

Fuel consumption from coal and coal products and from other fossil sources is nil in all periods. Energy intensity per net revenue for activities in high climate impact sectors (NACE sections G Wholesale and Retail Trade and L Real Estate Activities) fell 5% year on year, and is 89 MWh per EUR million for continuing operations (page 74).

Method (page 73). "We adopted a conservative approach to reporting the proportion of our energy use that comprised renewables... We included only renewable energy for which Guarantees of Origin were attributed." No renewable share is claimed from grid electricity without market instruments, from blended road-transport biofuel or from district heating without attribution certificates. Conversion factors are from DEFRA; nuclear is estimated from AIB residual-mix data for 2022 and 2023.

The higher renewable share in continuing operations is explained by the disposed Polish and Bulgarian operations being "predominantly composed of non-renewable energy sources" (page 74).

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 74-75. tCO2e, with a retrospective 2021 base year.

Categories 8, 9, 10 and 15 are reported as not occurring. For continuing operations, Scope 1 is 32,520, location-based Scope 2 is 52,834 and market-based Scope 2 is 37,070; Scope 3 "cannot be reliably separated between continuing and discontinued operations", though "the discontinued operations accounted for approximately 44% of Scope 3 Category 1" (page 75).

Method and uncertainty (pages 74-75). GHG Protocol Corporate Standard, operational control, boundary matching financial reporting. "None of our Group companies are subject to the EU Emissions Trading System." A zero-emission factor was applied to electricity with Guarantees of Origin, "representing 28% of our electricity consumption the same share as in 2024". Scope 1 and 2 uncertainty is "low to medium"; for Scope 3, "0% of our Scope 3 emissions inventory was calculated from primary data obtained directly from suppliers or other actors in our value chain, so we consider the results to have a high level of uncertainty". More than 2,000 emission factors were used from ADEME, Agribalyse, AIB, DEFRA, CarbonCloud, EXIOBASE and IEA. Biogenic Scope 1 emissions are 48 tCO2e; biogenic Scope 2 and 3 are "Not available". FLAG emissions are estimated for the second year, with land-use change accounting for "approximately 19% of emissions" of Category 1 food and non-food purchases (page 73).

Total GHG emissions per net revenue fell 4.9% on a location-based basis and 4.7% on a market-based basis, to 809 and 807 tCO2e per EUR million respectively (page 74).

Policies related to pollution

Reference: page 76.

No dedicated pollution policy exists. "Although air and water pollution were assessed as being material within our operations, the Group has not yet adopted dedicated policies to manage these impacts and risks. The primary sources of pollution in our operations are associated with transport (tailpipe emissions) and refrigerant leakage. The latter is addressed under our climate change mitigation efforts, while tailpipe emissions are managed by selecting the highest-available EURO standard when renewing our fleet" (page 76).

For the upstream chain, "due to limited visibility into Tier-N suppliers, we were unable to prioritise the development of dedicated policies in these areas. Most impacts are expected to materialise beyond our Tier-1 suppliers." The Supplier Code of Conduct "conveys our expectations that our upstream business partners will manage environmental issues with due care", and "Embedding the reviewed code and subsequent enforcement of compliance are the main actions to be taken to manage pollution-related matters in the value chain" (page 76; the code is described under G1-2, page 94). Complaint mechanisms allow stakeholders to report adverse environmental impacts in the upstream chain.

Actions and resources related to pollution

Reference: page 76.

"During the reporting period, there were no major developments in the field of pollution-related matters. Group companies, which continued pollution prevention and control activities, did not encounter any material pollution-related incidents requiring remedial action in 2025" (page 76).

Environmental management system. "MAXIMA Lithuania has maintained an ISO 14001 - certified environmental management system since 2009... In March 2025, the company successfully completed the ISO 14001 recertification process, extending the certification validity for an additional three-year period." During the year 64 internal environmental audits were carried out across retail stores, distribution centres and administrative offices, focused on "chemical management, spill-prevention measures related to technical oils and similar hazardous liquids, and the implementation of environmental protection controls". All new hires complete EMS e-learning training and existing employees repeat it every three years. Air emission measurements are performed periodically by accredited laboratories; wastewater and surface water discharges are monitored through regular laboratory testing.

Control over intentionally added chemicals. For substances of concern and very high concern including microplastics under REACH, "we include requirements in supply contracts to comply with the applicable regulations... If contamination above permissible levels is identified through active internal or external testing, the products concerned are recalled." For selected private-label textiles sourced through MAXIMA International Sourcing, OEKO-TEX certification is used as an additional control: "In 2025, 128 out of 870 textile stock keeping units (SKUs) traded during the reporting period (approximately 15%) were certified under OEKO-TEX" (page 76). Customers can query product composition through customer support or quality hotlines.

Oil traps at parking lots are maintained to prevent runoff contamination (page 76). No monetary resources are quantified for these actions.

Targets related to pollution

Reference: page 76.

No pollution targets are set. "As the priority level of this topic is low, no measurable outcome-oriented targets were set or implemented by the Group during the reporting period. While elements of pollution prevention and control are monitored locally through entity-level procedures and controls, including ISO 14001 where implemented and in accordance with applicable regulatory requirements, the effectiveness of policies and actions is not systematically measured or consolidated at the Group level through standardised performance indicators" (page 76).

One entity-specific proxy metric is reported in its place: "The Group assesses air pollution from its own operations, in particular from its transport fleet, with a focus on non-GHG air pollutants such as nitrogen oxides (NO2), sulphur oxides (SO2) and particulate matter (PM). As an entity-specific performance indicator, the Group uses the EURO emission standard of the vehicles that comprise the fleet as a proxy for the level of these pollutants. At the time of reporting, approximately 99.7% of the operated fleet complied with the EURO 6 standard for tailpipe emissions (99.9 % in previous year)" (page 76).

For the value chain, "The Group did not collect information or evaluate any metrics for material pollution-related impacts concentrated in the value chain. We applied phased-in provisions for value-chain information" (page 77).

Policies related to water and marine resources

Reference: page 77.

No water policy exists. "The Group has not adopted any dedicated policies for the management of material impacts, risks and opportunities related to water and marine resources. The Group's companies rely on municipal water supplies for both sourcing and discharging water at nearly all sites across its countries of operation. This approach ensures that our 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. Given this, we have determined that developing a dedicated water and marine resources policy for our operations is not a high priority" (page 77).

"The Group has not adopted policies or practices related to sustainable oceans and seas. The topic has material impacts and risks arising from upstream value chains, but we were unable to assign a high priority level to developing such policies due to limited Tier-N visibility" (page 77).

The corresponding datapoints derived from other EU legislation (ESRS E3-1 dedicated policy, ESRS E3-1 sustainable oceans and seas) are marked "Not material" in the datapoint list (pages 95-96). The material water impacts are "The withdrawal and inefficient use of water by our own operations in regions vulnerable to water stress, drought and quality-related challenges [E3_MI-1]" and "Food systems put pressure on water resources and marine capital through high levels of withdrawal and consumption, as well as overextraction [E3_VCMI-1]" (page 77).

Actions and resources related to water and marine resources

Reference: page 77.

A nil return. "No Group-wide action plans were adopted during the reporting period regarding water and marine resources. The Group did not implement any dedicated actions with regards to areas at water risk, including in areas of high-water stress, for its own operations or in the value chain. The Group plans to reevaluate the priority of this topic within no more than three years" (page 77).

The only management approach described is structural rather than an action: "The business strategy of primarily relying on municipal networks for water withdrawal and wastewater treatment enables a managed approach to this shared resource. Municipal water management enables a high level of control over impacts and risks in the region that may affect the local population and ecosystems" (page 77). No operational or capital expenditure is allocated to water, and no water-related actions are attributed to individual Group companies.

Targets related to water and marine resources

Reference: page 77.

A nil return, with no effectiveness tracking either. "No measurable outcome-oriented targets were set or implemented by the Group during the reporting period. The Group does not track the effectiveness of policies or actions in the management of water and marine resources" (page 77).

This is the second limb of MDR-T failing as well as the first: unlike business conduct, where monitoring substitutes for a target, the Group states plainly that no tracking takes place. Water metrics are nonetheless reported under E3-4 (pages 77-78), including consumption in areas at water risk, so a baseline exists against which a future target could be set.

Water consumption

Reference: pages 77-78. Cubic metres, own operations.

Method (page 77). "In our operations, we do not directly meter water consumption. In most of our stores, we only meter water withdrawals and have separate metering for water effluents. In stores where there is no metering of effluents, the volumes are assumed to be equal to the volume of water withdrawn. The water consumption is then estimated from the difference between withdrawals and effluents. A total of 99.9% of water withdrawal data was obtained from direct measurements or invoices, with the remaining amount estimated."

The ESRS index records that "Data point E3-4 28(c through d) is deemed not material" (page 97) - the water recycled and reused volume and the stored water datapoints. Water intensity is calculated on the revenue line from Notes 18 and 23 of the 2025 consolidated financial statements.

Transition plan and consideration of biodiversity and ecosystems in strategy and business model

Reference: page 78. The ESRS index notes "Value chain phase-in applied" against this requirement (page 97).

No comprehensive assessment was carried out. "The resilience of the strategy and business model regarding biodiversity and ecosystems was not comprehensively assessed during the reporting period. The decision to postpone a more detailed assessment was based on the fact that our own operations are not dependent on ecosystem services and that there are no material impacts from our own operations with regards to biodiversity and ecosystems, apart from pollution-related impacts that have already been addressed through sustainability matters in disclosures presented in chapter E2 Pollution" (page 78).

"At the same time, material biodiversity- and ecosystem-related impacts have been identified in the upstream value chain. Due to limited information availability, the assessment of how these upstream impacts and dependencies may affect the resilience of the Group's strategy and business model will require more detailed planning for execution and will be considered in later reporting periods."

The tool-based basis for this position is given under IRO-1: "With the assistance of benchmarks and proxies, we established that our own operations are not dependent on biodiversity and ecosystems, while our upstream value chains are highly dependent on the state of natural capital, especially at the level of raw agricultural materials" (page 64). ENCORE "identified only a very low materiality level of dependencies" for own operations (page 78). No biodiversity transition plan is disclosed, and no alignment with the Kunming-Montreal Global Biodiversity Framework is claimed.

The E4.SBM-3 row is recorded in the index as not applicable "because in terms of impacts on biodiversity and ecosystems, there were no sites of own operations identified that were negatively affecting biodiversity and ecosystems" (page 97).

Policies related to biodiversity and ecosystems

Reference: pages 78-79.

"We determined that all biodiversity- and ecosystem-related sustainability topics, apart from invasive alien species, were highly material in the upstream value chain... due to limited Tier-N visibility, we were unable to prioritise the development of dedicated policies for biodiversity and ecosystems" (page 78). Accordingly, "the Group did not adopt Biodiversity and Ecosystem Protection, Sustainable Land and Agriculture or Sustainable Oceans and Seas Policies. However, Group companies have drafted or already adopted a Deforestation-free Policy."

Deforestation-free Policy (page 79). Adopted by MAXIMA Lithuania in 2024, and by MAXIMA Latvia, MAXIMA Estonia, MAXIMA Bulgaria and MAXIMA International Sourcing in 2025.

• Objective: "to ensure that all products associated with deforestation and forest degradation made available on the market by the company are sourced sustainably and legally".
• Matters covered: deforestation-induced land-use change as a direct driver of biodiversity loss, land-use rights, environmental protection, third-party rights, human rights protected under international law, free, prior and informed consent with regard to Indigenous people, tax law adherence and anti-corruption.
• Scope: sourcing and procurement, supply chain management, risk assessment and mitigation for relevant commodities; the entire upstream value chain, own operations and the downstream chain to the extent the EUDR applies; all geographies.
• Accountability: senior management, defined as the CEO and individuals reporting directly to the CEO who manage others.
• Standards: aligned with Regulation (EU) 2023/1115 and referencing the Accountability Framework Initiative.
• Availability: published on the websites of relevant subsidiaries and communicated to suppliers.

The Supplier Code of Conduct also "conveys our expectations that our upstream business partners will manage environmental issues with due care" (page 78).

Actions and resources related to biodiversity and ecosystems

Reference: page 79. The ESRS index notes "Value chain phase-in applied" against this requirement (page 97).

EUDR implementation is the principal action. "During the reporting year, the Group focused on preparing for EUDR implementation by establishing core due diligence processes and implementing dedicated IT solutions to support traceability and risk assessment. In 2025, the Group deployed specialised software to support EUDR compliance, with total operational expenditures amounting to EUR 314 thousand, including software licences and internally allocated implementation costs. The system has been configured, key processes defined and supplier engagement initiated in a testing phase" (page 79).

The rollout was not completed: "To ensure a clear, proportionate and practically implementable approach, further supplier onboarding and operational rollout were temporarily paused pending additional regulatory clarifications following updates to implementation requirements." EUDR enforcement was "postponed until December 2026". The Group notes that EUDR work "also supports the development of broader due diligence capabilities... strengthening preparedness for upcoming regulatory frameworks such as the Forced Labour Products Regulation (FLPR) and Corporate Sustainability Due Diligence Directive (CSDDD)".

Certified sourcing in private label. "Within the confectionery category, 29 out of 126 stock keeping units (SKUs) were certified in 2025, including products containing Rainforest Alliance-certified cocoa (17 SKUs) and RSPO-certified palm oil (12 SKUs)" (page 79).

"It should be noted that no biodiversity offsets were used during the reporting year" (page 79). Pollution-related impacts in own operations are handled under E2.

Targets related to biodiversity and ecosystems

Reference: page 79.

A nil return. "No measurable outcome-oriented targets were set or implemented by the Group during the reporting period, and the effectiveness of polices and actions regarding biodiversity and ecosystem management was not tracked. Potential targets in this area will be assessed by Group companies in 2026 and 2027 as part of the implementation and continuous improvement of EUDR-related processes" (page 79).

No target is therefore ecologically thresholded, none is derived from the Kunming-Montreal Global Biodiversity Framework, and no stakeholder involvement in target setting is described. The certified-sourcing figures reported under E4-3 (29 of 126 confectionery SKUs certified) are presented as action outputs rather than as progress against a target.

Impact metrics related to biodiversity and ecosystems change

Reference: page 79.

Land-use change is the single metric. "We consider land-use change (LUC) associated with the food products we offer in our stores to be the primary metric for measuring the impact on biodiversity and ecosystems. Group companies are indirectly involved through business relationships with suppliers and producers of agricultural products, with the impacts concentrated in the upstream value chain" (page 79).

"LUC is expressed in tCO2e, which is emitted from land-use change and measured indirectly by applying emission factors. The same factors are used to estimate GHG FLAG emissions, applying SBTi and GHG Protocol methodologies, using statistical LUC and levelling deforestation emissions using linear discounting over a 20-year period following a deforestation event."

"LUC associated with food products sold totalled 344,697 tCO2e in 2025, compared with 355,696 tCO2e in 2024" (page 79). The E1 FLAG breakdown (page 73) shows the same figure within Category 1 purchased goods, alongside land management Category 1 emissions of 1,511,563 tCO2e for 2025, with "approximately 19% of emissions... related to land-use change". Uncertainty is described as "moderate to high due to the absence of supplier-specific emission factors" (page 73).

The ESRS index records that "Data point ESRS E4-5 (35) and Data point ESRS E4-5 (38) have been deemed not applicable due to the indirect nature of involvement with impacts on biodiversity and ecosystems through the upstream value chain" (page 97) - the metrics on land-use change or sea-use change and on threatened species. No hectares, no species metrics and no site-level indicators are reported.

Policies related to resource use and circular economy

Reference: page 81.

No circular economy policy exists. "Group companies have not adopted any policies relating to the circular economy. Amendments to the Packaging and Packaging Waste Regulation (PPWR) are key drivers of future developments in packaging circularity, which we consider to be the most important aspect for the retail sector. The amended regulation was approved at the end of 2024. Therefore, we now plan to review the direction agreed by European policymakers and will determine whether the Group's companies should develop dedicated circular economy policies" (page 81).

The absence of a policy sits against a set of material impacts that the Group does accept: non-recyclable packaging placed on the market [E5_MI-1], non-recyclable waste streams from own operations [E5_MI-2], depletion of natural resources through virgin packaging materials [E5_VCMI-1], pressure on consumer-side waste systems [E5_VCMI-2], food waste [E5_MI-3], a regulatory risk on waste-management taxation [E5_MR-1], and the one opportunity identified anywhere in the DMA, food waste reduction [E5_MO-1] (pages 79-80). Targets were nonetheless set in the absence of a policy (E5-3, page 81).

Actions and resources related to resource use and circular economy

Reference: page 81.

Deposit system development in Poland. "STOKROTKA continued the rollout of reverse vending machines and other preparations for the implementation of the deposit-refund system in Poland throughout 2025. During the year, 117 stores were equipped with reverse vending machines. In 2025, the Company incurred capital expenditure of EUR 2.4 million related to reverse vending machines" (page 81).

Food donations. "In 2025, 231 MAXIMA Lithuania stores participated in this process", with donations extended to the temperature-controlled distribution warehouse. MAXIMA Latvia's Best Before framework expanded beyond the 74 stores operating at the end of 2024, with four further agreements covering 31 more stores signed by the end of 2025, taking the total to 109 stores. Estonia continued donations to the Estonian Food Bank. Total donations fell from 4,207 tons in 2024 to 3,097 tons in 2025 (-26%), mainly "due to changes in the operational process, whereby products approaching the end of shelf life were identified and discounted for sale at an earlier stage". "the accounting value of food donations to food banks during the reporting year amounted to approximately EUR 6.3 million".

Responsible planning. "During 2025, the rollout of SAP UDF was completed across the Group's retail operations in Lithuania, Latvia, Estonia and Bulgaria", allowing more accurate estimation of promotions, seasonality and historical sales trends. "The implementation required total expenditures of approximately EUR 548 thousand during the reporting year, comprising EUR 459 thousand in capital expenditures (Capex) and EUR 89 thousand in operational expenditures (Opex)."

Packaging work in the reporting period was preparatory: "Implementation activities primarily related to preparing packaging-related data structures and aligning internal processes to enable consistent measurement of recyclability and recycled content indicators" (page 81).

Targets related to resource use and circular economy

Reference: page 81. E5 is the only environmental topic other than climate where the Group sets measurable targets.

Packaging targets, scoped to the private-label "Master's Quality" ready-to-eat and ready-to-heat range and derived from the draft PPWR:

• "In the Baltics, our retail companies in Lithuania, Latvia and Estonia have set a target of ensuring that 100% of 'Master's Quality' packaging is recyclable by 2030."
• "MAXIMA Lithuania and MAXIMA Latvia have set a target to have at least 30% recycled content in 'Master's Quality' PET packaging and at least 10% recycled content in other plastic packaging by 2030."

Both "relate to the recycling lever of the waste hierarchy".

Food waste target. "In Baltics our retail companies in Lithuania, Latvia and Estonia set a target to reduce food waste in own operations by 30% from a 2023 base year by 2030." This "relates to the prevention lever of the waste hierarchy".

Progress is negative. "To date, the food waste produced by the Group's retail companies in the Baltics has increased by 15% compared with the baseline" - 12,412 tons in the 2023 base year, 13,918 in 2024 and 14,227 in 2025. The Group attributes this to both data and behaviour: "The increase in reported food waste in 2025 primarily reflects expanded biowaste sorting practices and more comprehensive capture of waste streams within operations in Latvia, including waste flows that were not previously fully reflected in reporting. The increase also reflects, to some extent, higher food write-offs" (page 81).

Progress on the packaging targets is not yet quantified against a baseline: "measurable progress is expected to occur gradually over upcoming reporting periods".

Resource outflows

Reference: pages 82-83.

Products and materials. "We consider the packaging for 'Master's Quality' products to be the key outflow. We have set targets for this and will evaluate the recyclable content rate, which we plan to track for plastic and paper/cardboard packaging. As the targets were introduced recently, the relevant Group companies have started establishing and refining appropriate data collection workflows to enable consistent tracking and reporting of progress in future reporting periods" (page 82).

The one recyclability figure given is: "Based on currently applicable regulatory criteria, 98.5% of 'Master's Quality' plastic packaging and 98.8% of paper/carboard packaging are classified as recyclable, representing the primary packaging materials used within the product range" (page 82).

The Group qualifies the basis: "Assessment of packaging recyclability is currently based on applicable national regulatory requirements and established market practices in the countries of operation. As the detailed methodological criteria under the Packaging and Packaging Waste Regulation (PPWR) remain subject to the adoption of delegated acts, the definition and measurement of recyclability may evolve in future reporting periods."

The ESRS index records that "Data point ESRS E5-5 36 (a through c) deemed not material" (page 98) - the durability, reusability and repairability datapoints for products and materials. No rates of recyclable content in products or in packaging are given at Group level beyond the "Master's Quality" range, and no design-for-circularity metrics are reported for the wider assortment. Waste outflows are reported separately (see Waste, pages 82-83).

Waste

Reference: pages 82-83. Tonnes, own operations, with a continuing-operations column.

Of the 2025 total, 24,902 tonnes is food waste (28,213 in 2024) and 98,875 tonnes non-food (95,293 in 2024). Non-hazardous recycling was 89,995 tonnes and other recovery operations 12,570 tonnes.

Food waste handling (page 83). 735 tonnes were given to farmers, 21,678 tonnes sent for energy recovery (biogas, biofuels and energy) and 2,488 tonnes sent for disposal not for energy recovery. "A total of 7.8% of reported food waste quantities in 2025 was estimated due to a lack of data."

Non-food waste handling (page 83). "We currently have detailed information from waste management companies and tracking systems on how approximately 69% of total non-food waste is handled, while the remainder was estimated using Eurostat data for each country in which we operate." Beverage deposit packaging, reusable packaging such as EURO pallets and customer-returned electronic waste are excluded. "The estimated proportion of non-food waste in the reporting period amounted to 5.1% of the non-food total."

Comparability caveat (page 82). "The basis used to determine non-recycled waste changed in 2025. In 2024, non-recycled waste was presented on the basis of waste directed to disposal only. In 2025, following the EFRAG clarification of the ESRS methodology, the non-recycled waste figure was derived using a broader waste flow equation... Accordingly, the 2024 and 2025 figures for non-recycled waste are not fully comparable." Overall, "In 2025, 5.6 % of the waste volume was estimated to have been due to a lack of information about actual waste streams", and value chain waste is excluded.

Policies related to own workforce

Reference: pages 84-85.

"In Group companies, human rights are respected and ethical business conduct is established through our Equal Opportunities and Diversity Policy and our shareholders' 'Vilniaus prekyba' Code of Business Ethics" (page 84).

A stated gap. "The Group has not established any dedicated policies that explicitly address human trafficking, forced or compulsory labour, or child labour. Issues involving human trafficking and child labour are not material for our own operations, while issues of forced and compulsory labour that are material in the form of modern slavery are addressed in the 'Vilniaus prekyba' Code of Business Ethics... through fair employment practices and non-discrimination clauses" (page 84).

Equal Opportunities and Diversity Policy (page 85). Adopted by MAXIMA International Sourcing, MAXIMA GRUPE, FRANMAX and all Group retail companies. Objective: "to outline key principles for gender equality and non-discrimination, and promote high standards for responsible business conduct". It "applies to all activities within the Group's companies, including all aspects of employment such as hiring, working conditions, professional development, performance evaluation and dismissal", but "specifically focuses on the internal operations of Group companies, and does not cover the upstream or downstream value chain". Grounds for discrimination covered are listed explicitly, including racial and ethnic origin, colour, sex, sexual orientation, gender identity (indirectly), disability, age, religion, political opinion, national extraction or social origin, language, membership of associations and intention to have children. It references the Ten Principles of the UN Global Compact. Accountability sits with the CEO of each Group company. The policy "is available on the intranet and the corporate websites of some of the Group companies".

A second stated gap: "The policy does not make any commitments regarding inclusion or positive action for individuals who belong to groups at particular risk of vulnerability in our own workforce" (page 84). Grievance and whistleblower channels are used to monitor compliance with the UNGP, ILO Declaration and OECD Guidelines.

Processes for engaging with own workforce and workers' representatives

Reference: page 85.

"The Group engages with its own workforce at various stages of its management and decision-making processes. Engagement takes place at key moments such as updates to internal people-related policies and procedures (including ethics and conduct requirements), changes to working conditions and operational practices, and annual planning of workforce-related initiatives" (page 85).

"Where trade unions or workers' councils are present, the Group upholds employees' right to legal representation without fear of retaliation." Responsibility sits with the Head of Human Resources at each company.

Named instruments: "MAXIMA Latvia and STOKROTKA conduct annual engagement and satisfaction surveys to further strengthen engagement. Meanwhile, MAXIMA Lithuania conducts an annual psychosocial risk assessment in which employees can anonymously express how they feel at work" (page 85).

Vulnerable groups. "HR departments conduct interviews and surveys to better understand the obstacles experienced by vulnerable employee groups... For example, Ukrainian refugees employed by the Group's companies are considered more vulnerable due to their personal circumstances. To help them integrate more easily, the companies ensure these individuals receive work-related information in an understandable language."

Effectiveness "is assessed through surveys, feedback sessions and turnover trends, by monitoring indicators such as the number and nature of grievances raised and resolved" (page 85). No global framework agreement is reported and no engagement frequency is quantified at Group level.

Processes to remediate negative impacts and channels to raise concerns

Reference: page 85.

Channels available to employees are "hotlines, email channels for reporting grievances, email addresses for whistleblowing, representatives of trade unions or works councils, and reporting to their direct supervisors" (page 85). "Responsible individuals evaluate whether employees are aware of and trust the channels through ad hoc surveys, interviews and the feedback they receive."

Investigation process (page 85). "Investigating a complaint involves analysing its content, verifying the information it contains, interviewing employees who are still working at the company or have left or have been dismissed, interviewing heads of departments, asking security staff to check video footage to verify certain details, trying to identify the people responsible and setting up a complaints investigation committee if deemed necessary. If a report of possible violence and/or harassment is received, a committee of at least three people is established to examine the content of the report, investigate the circumstances of the incident and decide on the appropriate action to be taken."

Remediation. "In instances in which a Group company identifies through investigation that a situation has caused or contributed to a material negative impact on its own employees, the relevant unit manager, to the extent of their authorisation, should immediately take action to ensure the timely provision of mediation and remediation... appointed employees monitor the implementation of such remediation measures."

"When submitting grievances, employees may choose to stay anonymous. In addition, Group companies have implemented whistleblower mechanisms and processes to prevent retaliation against employees who raise concerns" (page 85); the mechanism is set out under G1-1 (page 94). Volumes of complaints are reported under S1-17 (page 89).

Taking action on material impacts on own workforce

Reference: pages 85-86.

Negative impacts requiring a response are identified "through employee surveys, consultations with stakeholders and employee representatives (such as workers' councils and trade unions), grievance mechanisms and internal audits" (page 85). "In response to labour market pressures, including minimum wage increases and risks related to employee attraction and retention, Group companies implement workforce-related measures such as remuneration reviews, employee engagement initiatives and actions aimed at maintaining attractive working conditions."

Training and skills development (page 85). Delivered "primarily via internal digital learning platforms", covering "operational procedures, workplace safety, compliance topics and professional skills development". "During the reporting year, total expenditures related to employee training and skills development at Group level amounted to approximately EUR 686 thousand." The Group notes it "continues to enhance its training data collection practices to further strengthen the consistency and comparability of training-related metrics in future reporting periods" - relevant because S1-13 training metrics are omitted under a phase-in.

Occupational health and safety (page 86). "During the reporting year, 2,827 workplace health and safety inspections, controls and internal audits were carried out across the Group's retail companies, including those operating in e-commerce... These included 61 inspections by state institutions, 270 reviews performed by independent health and safety experts or agencies, and 2,496 internal audits. The results of these inspections and audits are used to define corrective and preventive measures... they contribute to the implementation of the Group's target to reduce the Total Recordable Incident Rate (TRIR)."

Effectiveness is tracked "through a combination of employee surveys, grievance-related information, internal audits, health and safety monitoring, training participation data and other workforce-related indicators such as turnover trends and absenteeism" (page 85). No Group-wide action plan or dedicated budget beyond the training figure is disclosed.

Targets related to own workforce

Reference: page 86.

One target family is set, on safety. "In 2024, retail companies in the Baltics set annual targets for the number of accidents per hours worked for each year from 2024 to 2030. The indicator used to track the target, which is equivalent to the TRIR, is calculated as the total number of recordable incidents divided by the total number of hours worked in 2024 multiplied by 1 million" (page 86).

"The goal in the 2024-2030 period is for the average number of accidents per 1 million hours worked to not exceed 6.7 at MAXIMA Lithuania, 4.5 at MAXIMA Latvia and 6.0 at MAXIMA Estonia."

"During the stakeholder survey, employees highlighted occupational health and safety as a focus area. Targets were set based on actual performance in previous years." Progress "is reported annually, and this information is made available to all stakeholders. The improvement measures are established and adopted by each individual company based on the operational performance, which is tracked by each company's occupational health and safety specialists."

Group TRIR for 2025 was 7.88, above 7.01 in 2024 (S1-14, page 88), so the Group-level rate moved away from the company-level ceilings during the year. No targets are disclosed for diversity, pay equity, training, adequate wages or workforce reduction of any other material impact.

Characteristics of the undertaking's employees

Reference: pages 86-87. Head count as at 31 December, excluding Poland and Bulgaria for 2025 following their disposal in December 2025.

By country at 31 December 2025: Lithuania 12,411 (12,392 in 2024), Latvia 6,184 (6,139), Estonia 3,000 (3,114); Poland 12,272 and Bulgaria 2,495 appear in the 2024 column only. Total departures in 2025 for continuing operations were 6,457.

"The total number of employees in the table below matches that in the financial statements on page 18" (page 86). The Group cautions that "changes between 31 December 2024 and 31 December 2025 partly reflect the disposal of these operations and should not be interpreted solely as changes in the Group's workforce".

On gender reporting: "national laws do not allow individuals to identify as non-binary on their personal ID documents. Due to this and because the EU General Data Protection Regulation (GDPR) limits how we can collect personal data, not all Group companies collect information about employees' gender identities, instead they report gender based on what is stated in legal identity documents" (page 86). Temporary contracts "are most commonly used for seasonal or short-term increases in workload and, as an entry-stage employment arrangement before a permanent contract is offered, typically after a trial period of around three months" (page 87).

Characteristics of non-employee workers in own workforce

Reference: page 88.

"We report non-employee workers as full-time equivalents (FTEs). This metric is calculated by aggregating all the hours worked by contractors from employment service companies (classified under NACE code 78) and by self-employed workers, and dividing this total by the number of working hours in a year for a standard employee who works eight hours a day, five days a week. We adjusted this calculation for national holidays, but did not account for annual vacation time" (page 88).

"During the reporting year, we had an average of 1,766 FTE among non-employee workers on a consolidated basis (2,120 FTE in 2024)", presented as an annual average rather than a year-end position and including the Polish and Bulgarian operations disposed of in December 2025. "For comparability, the average number of non-employee workers in continuing operations in 2025 was 59 FTE" (page 88).

The gap between the consolidated and continuing-operations figures is large and is not explained beyond the disposal. "Fluctuations in the number of non-employee workers mainly reflect seasonal operational needs, temporary workload peaks and the use of agency workers in logistics, warehousing and store operations."

No split between self-employed people and people provided by employment agencies is given, and no health and safety metrics are collected for this group: "the Group does not collect work-related health and safety metrics for non-employees, including fatalities, high-consequence injuries, recordable accidents and occupational ill-health cases, or the related proportions" (page 88).

Collective bargaining coverage and social dialogue

Reference: page 88.

"At the end of the reporting period, 83.4% of the Group's employees were covered by collective bargaining agreements." The figure "reflects the Group structure as of 31 December 2025 and therefore excludes the operations in Poland and Bulgaria, which were disposed of in December 2025" (page 88).

The report also presents a coverage-rate table with bands (0-19%, 20-39%, 40-59%, 60-79%, 80-100%) split across collective bargaining coverage for EEA employees, an estimate for non-EEA regions, and workplace representation for EEA countries with more than 50 employees representing more than 10% of total employees, naming Estonia and the Lithuania/Latvia pairing.

"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" (page 88).

No non-EEA operations remain after the disposals, and no separate working-conditions coverage percentage is given for employees not covered by collective agreements.

Diversity metrics

Reference: page 88. Figures reflect the Group structure at 31 December 2025 and exclude Poland and Bulgaria.

Gender split of the workforce: 16,410 female and 5,185 male employees, with none recorded as other or not reported, out of 21,595.

Top management: "In the context of this report, top management is defined as comprising individuals who are one and two levels below the administrative and supervisory bodies of each Group company." The population is 84 individuals: 50 female and 34 male. "At the end of the reporting period, the gender distribution among our top management stood at 40% males and 60% females, reflecting a balanced gender composition" (page 88).

Age distribution: under 30 years 3,694 employees (17.1%), 30-50 years 8,751 (40.5%) and over 50 years 9,150 (42.4%).

"Ensuring diversity and equal opportunities is an important part of our business conduct. Throughout our companies, we have a diverse workforce that includes people of various ages, gender identities, backgrounds and other characteristics that we embrace and do our best to support" (page 88). The gender ratio of the administrative, management and supervisory bodies is cross-referenced here from GOV-1 (page 58).

Adequate wages

Reference: page 88.

"All our companies operate in countries with legally set minimum wages that meet the concept of adequate wages, and we ensure that 100% of our employees are compensated in line with the regulations. The EU Commission is updating the methodologies and approaches to establish minimum salaries, ensuring that actualisation of suitable pay is embedded in national laws" (page 88).

The disclosure is a compliance statement against national minimum wage law rather than a benchmark against an independently derived living wage, and no percentage of employees paid below an adequate wage benchmark is given because the Group asserts the figure is zero by construction.

Wage pressure is one of the Group's three material own-workforce IROs - "Minimum wage increases, and competitor actions impose risks to operational costs and, employee retention and attraction [S1_MR-1]" (page 84) - and the CEO's letter records that "The increase in the minimum monthly wage (MMW) in our countries of operation led to higher operating costs" (page 3). Remuneration reviews are listed among the actions taken in response (S1-4, page 85).

Social protection

Reference: page 88.

"All of our employees are covered by social protection through public programmes against loss of income due to major life events, including sickness, unemployment, employment injury and acquired disability, parental leave and retirement" (page 88).

The disclosure covers all five ESRS-listed major life events and rests entirely on statutory public schemes in Lithuania, Latvia and Estonia; no company-funded supplementary provision is described, and no country-level exceptions are identified. As the coverage is asserted as universal, no breakdown of employees not covered by type of event and country is given.

Family-related leave entitlement is reported separately under S1-15, where "100% of our employees, irrespective of age or gender, are entitled to family-related leave (maternity leave, paternity leave, parental leave and carers' leave) through national laws" (page 89).

Health and safety metrics

Reference: pages 88-89. Full-year 2025 data including the Polish and Bulgarian operations disposed of in December 2025.

"Our health and safety management systems are aligned with legal requirements in the countries of operation and cover 100% of our employees across all companies in our Group" (page 88). "A total of 28,962 employees received health and safety training during 2025."

Two stated limitations (page 88). "The Group is currently not able to reliably distinguish days lost due to work-related injuries from days lost due to other health-related absences, as the available source data do not specify the cause of incapacity. As a result, the disclosure of days lost due to work-related injuries would not be reliable." And "the Group does not collect work-related health and safety metrics for non-employees, including fatalities, high-consequence injuries, recordable accidents and occupational ill-health cases". The ESRS index records that "Data point S1-14 88 (e) is deemed not material" (page 98).

The TRIR rose 13% year on year against company-level ceilings of 6.7, 4.5 and 6.0 set under S1-5 (page 86).

Work-life balance metrics

Reference: page 89. Full-year 2025 data including the operations in Poland and Bulgaria disposed of in December 2025.

"100% of our employees, irrespective of age or gender, are entitled to family-related leave (maternity leave, paternity leave, parental leave and carers' leave) through national laws" (page 89).

Take-up is reported by gender and by country for 2024 and 2025, in both head count and percentage terms. The cleanest comparable figure the Group gives is for continuing operations: "in continuing operations in 2025, 674 female employees and 155 male employees took family-related leave, representing 4.1% and 3.0% of female and male employees, respectively (829 employees and 3.8% in total)" (page 89).

Because entitlement is asserted as universal, no split of employees without entitlement is given. The consolidated take-up tables cover Lithuania, Latvia, Estonia, Poland and Bulgaria, so the year-on-year movement is affected by the December 2025 disposals in the same way as the headcount disclosures under S1-6.

Compensation metrics (pay gap and total compensation)

Reference: page 89.

Gender pay gap. "The unadjusted gender pay gap was 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. The figures are provided for the entire Group, based on full-year 2025 data, and by country of operation. The country breakdown is provided to better understand differences in pay related to local labour market conditions, purchasing power and other country-specific circumstances. The figures include only data for Group companies with more than 20 employees that formed part of the Group during 2025" (page 89). The Group and country figures are charted for 2024 and 2025 across Lithuania, Latvia, Estonia, Poland and Bulgaria. A footnote records that "The 2024 comparative figures included data for Group companies with more than 150 employees as of 31 December 2024", so the two years are not compiled on the same population threshold.

The Group attributes the gap to structure rather than to rate: "The unadjusted gender pay gap is influenced by the overall workforce composition and the distribution of employees across different roles and functions within the Group."

Total compensation ratio. "The annual total remuneration ratio of the highest paid individual to the average annual total remuneration of the Group's employees (excluding the highest-paid individual) was 1:46 during the reporting period, based on consolidated full-year data. For the purposes of this disclosure, the ratio was calculated using annual gross pay as a consistent remuneration basis across the employee population and average annual FTE as the available population measure. Gross pay is based on payroll data and includes fixed and variable pay components reflected in payslips, including bonuses" (page 89).

Incidents, complaints and severe human rights impacts

Reference: page 89. Full-year 2025 data including the operations disposed of in December 2025.

"During the reporting year, there were no cases of severe human rights violations within our workforce, therefore no fines, penalties or compensation payments for damages were incurred" (page 89).

"No separate presentation for continuing operations is provided, as the disposed operations in Poland and Bulgaria had no such incidents or complaints during 2025."

A reporting threshold is stated: "Disclosure policy: we track and report the total amount of fines, penalties, and compensation payments for damages as a result of incidents and complaints that incur amounts of more than EUR 10,000" (page 89). The channels through which these complaints arrive, and the investigation and remediation process applied to them, are described under S1-3 (page 85).

Policies related to value chain workers

Reference: pages 90 and 94.

"The Group's companies have implemented a Supplier Code of Conduct that embeds respect for human rights, including worker's labour rights in the value chain. To implement the code in operations, the Group's companies have established channels for the reporting of instances of misconduct in the value chain" (page 90). The code was introduced in 2019 and "was revised during the reporting period and updated to highlight expectations to follow key international good-practice documents setting the standards for respect of human and labour rights"; the revised version "explicitly addresses human trafficking, forced labour and child labour" (page 94).

"Additionally, MAXIMA International Sourcing and all our retail companies in continuing operations have established a Deforestation-free Policy, that addresses human and labour rights associated with specified commodities at the raw commodities sourcing stage" (page 90).

"These policies are explicitly aligned with internationally recognised instruments relevant to value chain workers, including the United Nations Guiding Principles on Business and Human Rights (UNGP). The policies set out the expectation that suppliers implement human rights due diligence in line with the UNGP. Suppliers are encouraged to establish such processes proportionate to the size and nature of their operations" (page 90).

"There have been no reported 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 connected to the Group's companies" (page 90). Group companies "have reserved the right to withdraw from an agreement if the code is violated and the supplier is not willing to provide remediation to affected individuals".

Processes for engaging with value chain workers about impacts

Reference: page 90.

A stated gap, disclosed plainly. "The Group's companies lack processes for regular engagement with value chain workers. Credible proxies, such as the CSR Risk Filter and the Business and Human Rights Resource Centre are used to gain insights into the situations involving value chain workers. Direct engagement occurs in response to legal requirements or substantiated allegations" (page 90).

The company also records the limits of its visibility: "current visibility into the upstream value chain is limited, while the risks we identified could not be attributed to specific groups of value-chain workers rather than all value chain workers" (page 89). Workers at higher risk "are primarily those employed by entities in our upstream value chain, such as those involved in commodity harvesting and goods manufacturing. These risks are more prevalent in countries outside the EU."

Because there is no direct engagement process, the statement identifies no operational-level responsibility for engagement with value chain workers, no engagement frequency, and no assessment of engagement effectiveness. In their place the Group describes the EUDR due diligence system as the mechanism "currently being implemented" for a more detailed risk-based approach to the relevant commodities (page 89), and encourages suppliers to run their own grievance and due diligence mechanisms (S2-3, page 90).

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

Reference: page 90.

"The Group's companies provide external channels for stakeholders, including value chain employees, to raise concerns and submit grievances. These channels, which are also used for reporting misconduct (with more information available in the sub-chapters of G1 Business Conduct), are publicly accessible and regularly monitored to ensure effectiveness. The Group's companies maintain active communication with stakeholders, engaging through various channels and responding promptly to their interests and concerns" (page 90).

"While the Group's companies do not actively engage with value chain workers, they encourage suppliers to implement their own grievance and due diligence mechanisms, which are proportionate to the company's size and scope of activities through the Supplier Code of Conduct" (page 90).

The disclosure does not state whether value chain workers are aware of or trust these channels, nor whether any protection from retaliation is extended to them specifically; the whistleblower protections described under G1-1 apply to Group companies with more than 50 employees (page 94). No remediation was triggered in 2025: "there were no instances for which we would have identified ourselves as causing or contributing to actual adverse impact on value-chain employees that would require mediation or remediation actions" (page 90).

Taking action on material impacts on value chain workers

Reference: page 90.

EUDR compliance is the single named action. "During the reporting year, our actions with regard to workers in the value chain have concentrated around pursuing compliance with EUDR, which addresses actual adverse impact and material risks related to non-respect of human and labour rights among value-chain workers in the area of relevant high-risk commodities. We consider the set of products within the scope of the regulation as constituting the primary focus area for action in the near-term period and foresee expanding the coverage of products following legislative developments and increased maturity of our own processes" (page 90). The EUDR programme itself, including EUR 314 thousand of software Opex and the pause in supplier onboarding, is described under E4-3 (page 79).

"During the reporting year, there were no instances for which we would have identified ourselves as causing or contributing to actual adverse impact on value-chain employees that would require mediation or remediation actions. The identification of such instances is primarily based on the reports of misconduct filed through our grievance and whistleblowing mechanisms."

Where misconduct were reported, "Group companies would actively engage in dialogue with the relevant supplier, dedicating appropriate human resources to the process... In cases whereby the supplier has breached the Supplier Code of Conduct, Group companies reserve the right to terminate a contract, if the supplier is not willing to provide remediation."

Effectiveness "is currently tracked primarily through the review of reported misconduct cases, supplier follow-up and the implementation status of due diligence processes for high-risk commodities" (page 90). No supplier audit counts or coverage percentages are reported.

Targets related to value chain workers

Reference: page 90.

A nil return with a stated reason. "The Group's 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 our value chain. This is primarily due to the need to await further guidance on newly introduced regulations, particularly FLPR. These guidelines are expected to provide a structured framework for addressing labour and human rights risks in the upstream value chains" (page 90).

"At this stage, we are prioritising compliance with EUDR for relevant commodities, as we believe this will establish a solid foundation for a risk-based approach to due diligence. By focusing resources on implementing this regulation, we aim to address the most critical commodities and strengthen labour and human rights protections within our supply chain."

"The Group's companies have not established and do not monitor any specific metrics to track the progress of targets or actions related to workers in the value chain" (page 90). Unlike business conduct, where monitoring substitutes for a target, no effectiveness tracking mechanism is offered here beyond the qualitative review of misconduct reports and due diligence implementation status described under S2-4.

Policies related to consumers and end-users

Reference: page 91.

Privacy Policy (page 91). Adopted by the Group's retail and e-commerce companies, MAXIMA International Sourcing and FRANMAX. Objective: "The Privacy Policy defines the procedures and purposes for collecting and processing personal data and the scope of the data, as well as informing individuals who use the company's services or visit its website of their rights." Material matters covered: "Privacy of all consumers and end users." The policy "specifically focuses on the operations of Group companies, it does not cover the upstream or downstream value chain". On geography: "Personal data are mainly processed within the EU; however, some information from website visits may be processed or shared with companies inside or outside of the EEA - including the US - through services such as Google Analytics and Facebook ads." Accountability sits with the CEO of each Group company. "It does not explicitly reference third-party standards or initiatives."

A stated gap. "The Group's companies do not have a separate dedicated human rights policy that explicitly addresses consumers and end-users" (page 91). Instead, "The grievance and whistleblower channels, comprising hotlines established at the companies, are made available for customers and end users to report any instances of misconduct and enable us to monitor alignment with fundamental rights established under the UNGP, the ILO Declaration on Fundamental Principles and Rights at Work and the OECD Guidelines for Multinational Enterprises." The channels are accessible through company websites, in-store information desks and private-label product packaging.

"The Group's companies did not identify any severe or systematic instances of non-respect of the UNGP or the OECD Guidelines in relation to customers and end-users during the reporting period" (page 91).

Processes for engaging with consumers and end-users

Reference: pages 91-92.

"Within the Group, we prioritise ensuring that all our interactions with customers are characterised by honesty, transparency and timeliness. We use a variety of channels to disseminate information to our customers, including newspapers, weekly flyers, customer magazines, television advertisements and our official websites... we also engage with them through social media platforms such as Facebook, LinkedIn and Instagram" (page 91).

"In most countries, we offer several options for customers to reach out to us, including by phone and email, in person at our stores, through our loyalty app and via various social networks." Operational responsibility sits with "The Head of Customer Support or the Director of the Retail Department".

Vulnerable groups. "To better understand the specific circumstances of particularly vulnerable groups, we engage with various non-governmental organisations and monitor the information that reaches us through grievance and whistleblower channels" (page 91). The S4 SBM-3 narrative identifies three distinct customer groups considered in the DMA: general consumers purchasing food and consumer goods; customers using loyalty programmes or online platforms, where "Socially and financially vulnerable individuals may be more affected by targeted marketing and promotional offers"; and customers purchasing products for children, where "Products intended for children require special consideration due to children's vulnerability" (page 90).

"The effectiveness of engagement channels is assessed by relevant communications departments at the Group's companies, using selected indicators for evaluation that vary depending on the type of engagement tool used. The results are communicated to the company management" (page 91). The indicators themselves are not disclosed.

Processes to remediate negative impacts and channels for consumers to raise concerns

Reference: page 92.

"Complaints and reports filed by our customers and end users through the grievance and whistleblower channels available either directly or anonymously are thoroughly investigated. This process involves analysing the complaint, verifying its facts, interviewing relevant employees, asking security staff to review video footage to verify certain facts, and setting up a complaints investigation committee if deemed necessary" (page 92).

"In instances where a Group company establishes that it has caused or contributed to a material negative impact on customers or end users, the relevant unit manager, to the extent of their authorisation, will immediately take action to ensure timely mediation and remediation. If remediation actions require involvement of a higher level of company management, such individuals are informed and participate in the processes. Appointed employees monitor the implementation of such remediation measures."

A stated gap. "The Group's companies do not have dedicated processes to assess whether customers and end-users are aware of and trust processes through which complaints, grievances and reported instances of misconduct are submitted. Internal evaluations based on how actively our customers file reports suggest that the channels have an appropriate level of visibility and accessibility" (page 92).

Product recalls run through a parallel route: "In the event of a public recall, in line with our internal procedures we display recall notices in our stores, whereby customers can return the product for a refund" (page 92). Complaint volumes are reported under S4-5.

Taking action on material impacts on consumers and end-users

Reference: page 92.

Access to information. "To cater to these needs in our non-prepacked-goods sections, we have introduced QR codes that offer comprehensive details about the products, including information about allergens. Additionally, customers can obtain information they require directly from our staff or by calling the contact numbers provided on product labels" (page 92).

Product safety and quality. "Our entire Group adheres to the HACCP food safety management system." Suppliers must submit safety data sheets, organic or eco-certifications and other certifications; the Group runs "both scheduled and ad hoc laboratory tests" and supplier audits, and applies acceptance quality control at warehouses for fresh produce and meat, checking "cold-chain temperature violations and inconsistencies in product appearance and smell".

Reported outcomes for 2025 (page 92):

• 351 food safety recalls, against 264 in 2024; "The increase versus 2024 primarily reflects enhanced control procedures and a higher volume of product safety assessments."
• 3,072 samples analysed through product safety assessments, against 2,871 in 2024.
• The "Quality Checked by J. S. Hamilton" seal covered 104 stock keeping units at the end of 2025, with 387 laboratory tests carried out under quarterly testing plans.
• MAXIMA International Sourcing "maintained licences under Roundtable on Sustainable Palm Oil (RSPO), Ecolabel and Rainforest Alliance schemes".

"The actions described in this chapter did not require separately identified significant operational or capital expenditures during the reporting period. Related costs were managed within ordinary operational budgets of the relevant functions." "During the reporting period, no severe human rights issues or incidents connected to consumers and end-users were identified or reported" (page 92).

Targets and metrics related to consumers and end-users

Reference: page 92.

No long-term targets, but tracked effectiveness. "The Group's companies have not set specific long-term targets to manage negative impacts, advance positive impacts, or address material risks and opportunities in relation to customers and end-users. The Group's companies operate in such a manner that operational functions set quarterly targets to address the identified impacts, risks or opportunities through dedicated, relevant and timely actions. Although no specific long-term time-bound targets have been set for this matter, the Group tracks the effectiveness of relevant actions through quarterly operational targets and selected metrics, including confirmed incidents related to personal data safety, complaints related to discriminatory practices and related corrective actions" (page 92).

Consumer privacy. "During the reporting period, the Group identified a total of 22 confirmed incidents involving personal data safety. The majority of the incidents were of limited scope and impact and were addressed promptly through established internal procedures... The incidents were primarily related to unauthorised access to personal data, improper handling or disclosure of personal information, incidents affecting customer account security and deficiencies in access control or data deletion processes." "Of the 22 confirmed incidents, 5 were reported to the competent supervisory authorities." "During the reporting period, 587 employees considered to perform functions at risk of personal data breaches received training in cybersecurity, GDPR, personal data handling and other related fields" (page 92).

Equal treatment. "During the reporting period, the Group recorded a total of 8 complaints focused on alleged unequal treatment or accessibility issues affecting customers and end users. Of these, 7 complaints were resolved during the reporting period and 1 remained unresolved at year-end. The complaints primarily related to accessibility for persons with disabilities, including physical access to store premises, movement within stores and access to services" (page 92). The complaint figures cover the full year including Poland and Bulgaria.

Business conduct policies and corporate culture

Reference: pages 93-94.

"Central to our business conduct approach are four core policies: our Equal Opportunities and Diversity Policy, Anti-Corruption Policy, Supplier Code of Conduct and Sustainability Policy... aligned with the foundational principles of our shareholders' 'Vilniaus prekyba' Code of Business Ethics" (page 93).

Code of Business Ethics. It "establishes ethical standards for responsible and transparent business conduct... risks related to labour rights, fair employment, non-discrimination, anti-corruption, customer protection and environmental responsibility", and "applies to all employees and business operations across all markets, with no exclusions based on geography or business activities". Together with the Anti-Corruption Policy it "sets out a zero-political-contributions approach across the operations of the Group's companies".

Sustainability Policy (page 93). "In 2025, the Sustainability Policy was established to embed sustainability as a core value and strategic priority", adopted in 2025 by the Group's retail and e-commerce companies and MAXIMA International Sourcing, and in January 2026 by FRANMAX. It commits to the UN Global Compact, OECD Guidelines, UNGP, ILO Declaration, International Bill of Human Rights, Paris Agreement, European Green Deal and EU Taxonomy Regulation, but "does not explicitly cover the upstream or downstream value chain".

Corruption-exposed functions. "The functions most at risk of corruption and bribery are the purchasing, supply chain management and real estate management departments" (page 94). "Senior management is informed of all instances of fraud or corruption, alongside the Audit Committee."

Whistleblowing (page 94). "All companies in the Group that have more than 50 employees have established whistleblower mechanisms." The process is set out step by step: registering the submission, pseudonymising the whistleblower's personal data, a prima facie conformity assessment, notification of recognition within 3 days, processing within 2-3 days, progress notification within 2 months and a committee decision "no later than 3 months from the date of receipt of the submission". Annual training sessions are conducted across the Group.

Management of relationships with suppliers

Reference: page 94.

Supplier Code of Conduct. Introduced in 2019 and "revised during the reporting period and updated to highlight expectations to follow key international good-practice documents setting the standards for respect of human and labour rights" (page 94). The revised version has been adopted by all Group retail companies, FRANMAX and MAXIMA GRUPE; MAXIMA Bulgaria was still on the 2020 version. The code "applies to all suppliers and subcontractors within MAXIMA Group's value chain across all geographical locations where it operates. The policy covers a wide range of stakeholders, including suppliers, subcontractors and, indirectly, their employees, communities and local environments. There are no explicit exclusions stated within this policy." "The revised version of the policy explicitly addresses human trafficking, forced labour and child labour" and aligns with the OECD Guidelines, the UNGP, the ILO Declaration, the International Bill of Human Rights and the UN Global Compact. "The code is available on the corporate website as an addendum to the contracts." "Group companies reserve the right to conduct assessments, inspections and audits to confirm that suppliers adhere to the code."

Supply chain structure. "Most of our supply chain is managed by local the Group's retail companies, whereby product selection, negotiation and procurement processes are handled at the country level, with the aim of enhancing regional and local sourcing. The remaining products in the supply chain are managed by MAXIMA International Sourcing, which is responsible for centralised sourcing" and "develops private label brands" (page 94).

A stated gap. "The implementation of the Supplier Code of Conduct is supported through supplier onboarding processes, contractual requirements and ongoing supplier relationship management at both local and central sourcing levels. At this stage, the Group does not apply entity specific quantitative targets or metrics" (page 94). No supplier screening or audit coverage rate is disclosed, and social or environmental criteria for supplier selection are set out only through the code itself and the Deforestation-free Policy, which "establishes a mandatory requirement for suppliers of relevant products to support our commitment to due diligence of supply chains" (page 94).

Prevention and detection of corruption and bribery

Reference: page 95.

"The fundamental principles for the prevention and detection of corruption and bribery are laid down in the Anti-Corruption Policy", adopted by all Group retail companies, FRANMAX and MAXIMA GRUPE (page 95). Its objective is "to establish fundamental principles and guidelines to prevent corruption within Group companies, promoting integrity, transparency and accountability", enforcing "a zero-tolerance approach to bribery, influence peddling and nepotism". Scope is broad: "all employees within the Group's companies, including members of management teams, supervisory bodies and committees, as well as individuals engaged through civil contracts", and "The policy encompasses all activities and operations across the Group's upstream and downstream value chains". "It does not explicitly reference third-party standards or initiatives."

Training coverage, with a gap the Group flags itself (page 95). "The companies have identified a total of 4,414 individuals who perform functions considered at risk of corruption or bribery (2024 - 1,264). The increase compared with 2024 reflects an expanded scope of roles assessed as being exposed to corruption or bribery risks. In 2025, 448 of these individuals received dedicated training in preventing corruption and bribery (2024 - 485)... Given the expanded scope of roles newly identified as exposed to corruption or bribery risks in Q4 2025, training coverage did not yet increase proportionately during the reporting year. The Group's companies intend to further expand training coverage for these roles in the next reporting period."

"Members of management team are covered by the Anti-Corruption Policy and are informed of its requirements in line with their roles and responsibilities. Allegations or incidents of corruption or bribery are reviewed by designated internal functions. Investigations are conducted in a manner that seeks to avoid conflicts of interest, including, where feasible, separation from the management chain involved in the matter" (page 95).

Targets related to business conduct

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

MAXIMA GRUPE sets no business conduct targets and says so. "the Group's companies have not set any specific long-term targets to manage negative impacts, advance positive impacts, or address material risks and opportunities arising from incidents of Corruption or bribery" (G1-4, page 95). On suppliers, "At this stage, the Group does not apply entity specific quantitative targets or metrics" (G1-2, page 94). The general convention stated in GOV-1 applies: "If a given impact, risk or opportunity has no dedicated action, policy or target presented in the sustainability statement, it means that no actions, policy or target materials for reporting have been implemented during the reporting period" (page 58).

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

• "We actively monitor the implementation of our Anti-Corruption Policy at all levels", with "a security inspection whenever a corruption concern arises, 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" (page 95).
• Exposure is quantified and tracked year on year: 4,414 individuals in functions at risk of corruption or bribery (1,264 in 2024) and 448 trained in 2025 (485 in 2024), with the shortfall explained and a commitment to "further expand training coverage for these roles in the next reporting period" (page 95).
• "The outcomes of any investigations are communicated to the Management Board at the Group level and to the Audit Committee" (page 95).
• Payment practices are monitored through the average time to pay an invoice and the count of outstanding legal proceedings for late payments (page 95).

Incidents of corruption or bribery

Reference: page 95.

"During the reporting period, no incidents of corruption or bribery were confirmed. During 2025, two investigations were initiated by the company in response to suspected misconduct, however neither case was substantiated. By comparison, in 2024 one case of abuse of rights was confirmed following an internal investigation and employment relationships with the employee concerned were terminated. The case did not result in any fines for any of the Group's companies" (page 95).

"During the reporting year, there were no convictions relating to violations of anti-corruption or anti-bribery laws that resulted in fines" (page 95).

Mitigation measures reported alongside the incident count: "the Group's companies conduct a security inspection whenever a corruption concern arises, 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. Violations are met with appropriate disciplinary action, including warnings, termination and, if necessary, legal proceedings."

"The actions described in this chapter, including training, investigations, audits and supplier-related controls, were implemented within the ordinary operational budgets of the relevant Group functions and did not require separately identified significant operational expenditures (Opex) or capital expenditures (Capex) during the reporting period" (page 95).

Payment practices

Reference: page 95.

"The Group's companies have established internal controls and procedures to prevent late payments. Our payment practices are in line with applicable national regulations, including transposing and implementing the Unfair Trading Practices Directive. Further information on payment terms is available in Note 17 of the financial statements" (page 95).

Basis of preparation: "The information presented in the table below regarding the Group's payment practices is based on full-year 2025 data extracted from the accounting systems of Group entities and therefore includes all operations that formed part of the Group during the reporting year, including the operations in Poland and Bulgaria that were disposed of in December 2025. The average time to pay an invoice was calculated based on all supplier invoices. Given the nature of the Group's retail business, goods suppliers are the primary supplier category, therefore information on payments aligned with standard payment terms focuses on goods suppliers" (page 95).

"No dedicated policy has been developed, as no need was identified for one after evaluating current practices and confirming compliance with regulatory requirements" (page 95). Inappropriate payment practices are nonetheless a material impact in the DMA: "Inappropriate payment practices can have a substantial impact on the business continuity of suppliers, particularly SMEs, due to shortages in cashflows [G1_MI-2]" (page 93). No comparative 2024 figures are given.