Modern Times Group MTG

The Board of Directors and group management are responsible for MTG's strategic direction and ensuring that the business is conducted in a sustainable manner. The Board of Directors has overall responsibility for the organization and management of MTG's business and is responsible for ensuring that MTG's organization is structured in such a way that accounting, asset management and MTG's financial affairs are controlled in a satisfactory manner.

The Board consists of seven members elected by the Annual General Meeting, with no deputies. All Board members, with the exception of the CEO, are independent of the company and senior management. The Chairman of the Board, Natalie Tydeman, and Board member Dawn Airey are independent of major shareholders, while the other Board members are not independent of major shareholders.

The Board has established an Audit Committee and a Remuneration Committee. The Audit Committee consists of three members: Gerard Griffin (Chairman), Natalie Tydeman and Simon Duffy. The Remuneration Committee consists of three members: Dawn Airey (Chairman), Natalie Tydeman and Bert Klanderman.

Integration of sustainability-related performance in incentive schemes

Overview

MTG integrates sustainability-related performance into its incentive schemes for senior employees across the group. The company includes Environmental Social and Governance (ESG) metrics in its Long-Term Incentive Plans (LTIPs), covering approximately 45 key employees across MTG, InnoGames, and Hutch.

Roles Covered

Approximately 45 key employees in MTG, InnoGames and Hutch participate in the LTIP plans and are divided into tiers. This includes approximately 33 key employees in MTG and InnoGames in the 2023 plan, and approximately 11 key employees in MTG in the 2022 plan.

Sustainability KPIs Tied to Remuneration

The incentive schemes include the following sustainability-related KPIs:

Data Privacy and Security

MTG includes building and maintaining data privacy protection measures in each studio, against which all participants of the incentive scheme are measured (approximately 45 senior employees across the group). The company believes that comprehensive privacy protection measures create long-term value and help build a sustainable gaming business.

Gender Diversity

MTG includes a gender diversity target in the incentive schemes. The objective is to increase gender diversity year-over-year. The threshold level is a 1% improvement of the prior year-end ratio of female and non-binary employees in the group, and the maximum level is a 3% improvement of the same. Improvement is measured on an individual company level, each with equal weighting. All participants of the incentive scheme are measured against this target.

Weighting and Structure

Long-term incentive plan 2022

The performance criteria included:

• Financial measures: 60%
• Shareholder value creation TSR: 25%
• Environmental Social and Governance ESG: 15%

Long-term incentive plan 2023

The performance criteria include:

• Financial measures: 50%
• Strategic KPI: 20%
• Shareholder value creation TSR: 20%
• Environmental Social and Governance ESG: 10%

Long-term incentive plan 2024

The performance criteria include:

• Financial measures: 50%
• Strategic KPI: 20%
• Shareholder value creation TSR: 20%
• Environmental Social and Governance ESG: 10%

Performance Period and Structure

2022 Plan

• Performance Amount allotted in beginning of 2023
• Cash portion paid at end of performance period in Q1 2023
• Share rights: 50% vested in 2024 and 50% in 2025, after publication of year-end for 2023 and 2024, respectively
• Subject to continued employment at time of vesting

2023 Plan

• Performance Amount allotted in beginning of 2024
• Participants allotted cash bonus in Q1 2024
• Share rights based on volume-weighted average price paid for MTG's Class B Share during 60 days after publication of interim year-end report for 2023
• 50% vest in Q1 2025 and 50% in Q1 2026
• Subject to continued employment at time of vesting

2024 Plan

• Performance Amount allotted in beginning of 2025
• Cash portion paid at end of performance period in Q1 2025
• Share rights subject to 3-year vesting period
• 100% of share rights vest during single event after 3 years, after publication of year-end interim report for 2026
• Subject to continued employment at time of vesting

Performance Targets

For financial and ESG measures:

• Participants receive maximum Performance Amount if target level is reached for each performance condition
• If average weighted index is above 100, performance conditions based on financial measures and shareholder value return can contribute up to index 150
• In case of overperformance between target and maximum level, relative weighting may be linearly increased up to 50%
• Outcome may never exceed maximum Performance Amount

2024 Performance Outcomes

Parent Company Performance Outcome

Subsidiary InnoGames 2024 Performance Outcome

Subsidiary Hutch 2024 Performance Outcome

2023 Performance Outcomes

The 2023 plan delivered the following outcome: participants from the parent company achieved 93% payout of the corporate goals and the participants from InnoGames achieved 72% payout. Participants in the plan were allotted a cash bonus in Q1 2024.

TSR Performance

For the 2024 plan, the final TSR was determined based on an initial share price equivalent to the VWAP during the period from November 1, 2023 to December 31, 2023, and a final share price equivalent to the VWAP during the period from November 1, 2024 to December 31, 2024. As the TSR performance criteria was not met, no value has been assigned to the participants.

Business Model

MTG owns and operates six international gaming studios that develop and publish a wide range of popular titles, which are enjoyed by players all over the world. Our games are available on mobile and other platforms, and we generate revenues via in-app purchases, in-app advertising, and from third-party distribution.

Our studios are responsible for developing, launching, marketing, and operating the high-quality games that make up our portfolio. Many of our games are based on popular, international IPs, across a wide range of casual and mid-core genres.

Long-term value creation

Our business model is designed to generate long-term value for our shareholders through consistent profitable growth. The built-in operating leverage in our business model enables us to deliver stronger profits in periods of lower growth. Due to our financial discipline and operational efficiency, we are also highly cash generative.

Nearly all our games are available to consumers on a free-to-play (F2P) basis and we generate a majority of our revenues from in-app purchases and in-app advertising. Our group's main focus is on mobile gaming, which accounts for 76% of total group revenues. An important part of our revenues also comes from games that are available via browser and on third-party platforms like Steam, Apple Arcade, and Netflix.

A synergetic common layer

In order to accelerate further growth by driving synergies and encouraging our studios to share knowledge and best practices with each other, we are building out a synergetic common layer, the "Flow Platform". It is focused on providing our companies with commercial technology, skills and tools that can help them accelerate growth. The acquisition of Plarium is expected to strengthen this part of our strategy.

Accretive & strategic M&A

The recent acquisition of Plarium positioned us as a top 10 mobile games developer in the West and the #1 listed mobile gaming company in Europe. We remain committed to accretive and strategic acquisitions of gaming studios all over the world and it will continue to contribute to our future growth.

Venture Capital Fund

To complement and support our strategy, we also operate a venture capital fund that has invested a total of USD 40 million in a total of 26 companies, ranging from start-up game developers across several genres to MMO (massively multiplayer online games) and game creation platforms in the USA and Europe.

Interests and views of stakeholders

Stakeholder engagement approach

At MTG, engaging actively with our stakeholders is a core component of our ESG activities. These interactions help us to understand our material issues and support the development of our ESG commitments and goals. Our engagement efforts involve collaboration across various teams, including People and Culture, Marketing, Product Development, Finance and Investor Relations, among others.

Stakeholder engagement overview

The table below highlights our primary stakeholders, the methods we use to engage with them, and the objectives of these interactions.

Integration into double materiality assessment

In 2024, our engagement strategy was particularly focused on assessing double materiality, ensuring that we not only address financial implications but also understand the broader impact of our operations on the communities and the environment.

Distinction between affected stakeholders and users of sustainability information

The stakeholder engagement overview distinguishes between:

• Affected stakeholders who are impacted by the business: own workforce, consumers and end-users (gamers), suppliers, workers in the value chain, and the natural environment
• Users of sustainability information: shareholders & investors, executive management, and lenders & banks

Engagement in materiality assessment process

The double materiality analysis was conducted in five key steps and involved stakeholder engagement through:

• Examination of relevant documents
• Interviews with key internal stakeholders
• A dedicated workshop
• Consultations with affected stakeholders and external experts to understand the potential impacts on relevant groups

The individuals involved in these activities included representatives from MTG and all its studios. Studio representatives conducted the initial scoring of identified IRO's, which was then reviewed by senior management.

MTG's corporate sustainability strategy reflects our vision of a Gaming Village where entrepreneurs, and the studios they have created, can grow and thrive, supported by clear targets and collaboration. To support our strategy, we have established three pillars that reflect our sustainability-related impacts, risks and opportunities (IROs) within the areas of environment, social and governance.

During 2025 the sustainability strategy, including objectives and targets, will be reviewed following the results of the double materiality assessment (DMA) that were conducted in 2024. The result of the DMA will inform the future sustainability strategy.

During 2025 the sustainability strategy, including objectives and targets, will be reviewed following the results of the double materiality assessment (DMA) that were conducted in 2024. The result of the DMA will inform the future sustainability strategy. These are based on identified sustainability topics as a result of the DMA, industry and globally recognized standards.

Transition plan for climate change mitigation

Target year and alignment

50% reduction by 2032 in line with the Paris Agreement (to limit global warming to 1.5°C). Base year of target is 2022.

SBTi validation status

MTG is working with portfolio companies PlaySimple, Hutch, InnoGames, Ninja Kiwi and Snowprint to:

• Conduct a GHG screening to map our material emission sources,
• Set science-based emissions reduction targets in line with SBTi,
• Set a concrete action and transition plan thereafter.

Key decarbonization actions (2024)

• Expanded our carbon accounting by including hotspot categories.
• Conducted training for HQ and studios on climate change, carbon accounting and ESRS reporting.
• Optimization of energy use through smart systems and measures.
• Use of solar panels for sustainable electricity supply.
• Responsible waste and e-waste management through authorized operators.
• Sustainability themes in games, to raise environmental awareness and promote positive messages.

Emissions performance (2024 status)

Total value chain emissions; Scope 1, Scope 2 (market-based) and Scope 3 for 2024 was 4,592.3 tCO2e. We are unable to draw meaningful conclusions due to changes in the methodologies and expansion of the reporting scope.

Total value chain emissions increased by 124.6% compared to baseline. Our total emissions consumption (location-based) increased by 118.2% from 2,156.6 tCO2e to 4,705.2 tCO2e. Our total emissions consumption (market-based) increased by 124.6% from 2,044.8 tCO2e to 4,592.3 tCO2e. This increase was primarily a result of changes in the methodologies and expansion of the reporting scope. Consequently, we cannot draw any conclusions or deeper analysis.

Policies related to climate change mitigation and adaptation

MTG addresses climate change mitigation through existing governance documents and is in the process of adopting a dedicated environmental policy.

Code of Conduct (CoC)

Policy name: Code of Conduct (CoC)

Scope: MTG's entire policy framework, covering all geographies where MTG operates

Key content:

• Expresses MTG's values and helps navigate ethical and legal issues
• Stands as the governing document within MTG's entire policy framework
• Describes the approach to managing environmental performance and driving sustainability efforts across the organization
• Includes tracking emissions, mapping energy consumption, and recycling waste whenever possible

Public availability: Accessible to all employees via MTG's policy management system

Supplier Code of Conduct (SCoC)

Policy name: Supplier Code of Conduct (SCoC)

Scope: All suppliers globally, covering all geographies where MTG operates or engages with suppliers

Key content:

• Requires suppliers to adhere to international environmental principles and standards
• Suppliers expected to monitor, manage, and minimize greenhouse gas emissions from their operations
• Requires actively monitoring and managing emissions to air, water, and soil
• Working to reduce waste generation
• Encourages prioritizing reuse and recycling of byproducts
• Suppliers providing cloud and data services expected to prioritize sustainability-conscious energy sources and efficiency measures

Public availability: Accessible to all employees via MTG's policy management system

Environmental Policy (planned)

Policy name: Environmental Policy

Status: To be adopted in 2025

Scope:

• Will be adopted at MTG group level
• Covers both upstream and downstream value chains
• Includes all geographies MTG operates in
• Studios will develop company-specific climate activities while adopting minimum requirements for the group

Governance: The CFO will be accountable for implementing the policy

Key content:

• Will serve as a framework and guide sustainability efforts
• Will address Scope 1-3 emissions, climate change mitigation, energy efficiency, and renewable energy
• Will cover sustainability matters
• MTG adheres to the precautionary principle

Public availability: Not yet disclosed (policy not yet adopted)

Actions and resources in relation to climate change policies

MTG acknowledges its environmental impact and has committed to reducing emissions across the value chain (Scope 1, 2, and 3) by 50% by 2032, with 2022 as the base year, in line with the Paris Agreement to limit global warming to 1.5°C.

Overall Approach

Scope: Own operations, upstream and downstream value chain

Key commitments:

• Monitor carbon footprint and map energy consumption
• Promote reuse of equipment whenever possible
• Transition to renewable energy sources
• Implement energy efficiency measures
• Promote circularity of equipment

Value chain coverage:

• Own operations and upstream: Energy usage in offices and studios, fugitive emissions, company vehicles
• Downstream: Business travel, IT equipment, employee commuting, external and on-site cloud servers, energy consumption by players during gameplay

Actions taken in 2024

MTG Group level:

• Expanded carbon accounting by including hotspot categories
• Conducted training for HQ and studios on climate change, carbon accounting and ESRS reporting
• Set reporting structures and quality assurance

Studio-level actions:

Hutch:

• Sourced renewable electricity
• Implemented energy-saving measures: overnight and weekend powerdowns
• Optimized air conditioning schedules

InnoGames:

• Used 100% renewable electricity
• Implemented sensors to optimize office energy use
• Approved installation of over 80 solar panels for 2025

Ninja Kiwi:

• Utilized existing solar panels
• Ensured ongoing reliance on renewable electricity

PlaySimple:

• Reduced emissions and achieved energy savings despite increase in headcount

Planned actions for 2025

Time horizon: Short term (2025)

Scope: MTG HQ and studios (PlaySimple, Hutch, InnoGames, Ninja Kiwi, Snowprint)

MTG aims to:

• Conduct a GHG screening to map material emission sources
• Set science-based emissions reduction targets in line with SBTi
• Set a concrete action and transition plan thereafter
• Adopt a new Environmental Policy at MTG group level

Long-term action plan

Time horizon: Long term (towards 2032)

Actions planned:

• Switch to renewable energy sources
• Install new on-site renewable energy production
• Monitor and match supply and consumption of renewable energy in both geography and time
• Shift to data storage providers with stronger commitment to energy efficiency

Policy framework

Environmental Policy: To be adopted at MTG group level in 2025. Studios will develop company-specific climate activities while adopting minimum requirements for the group.

Supplier Code of Conduct: Requires suppliers to:

• Monitor, manage, and minimize greenhouse gas emissions
• Actively monitor and manage emissions to air, water, and soil
• Reduce waste generation
• Prioritize reuse and recycling of byproducts
• For cloud and data service providers: prioritize sustainability-conscious energy sources and efficiency measures

Resources

Non-financial resources:

• Training programmes delivered to HQ and studios on climate topics
• Quality assurance and reporting structures established
• Solar panel installations (InnoGames: 80+ panels approved for 2025; Ninja Kiwi: existing panels in operation)

Financial resources: Not quantified in the disclosure

Link to targets

All actions link to MTG's overarching climate target: 50% reduction in value chain emissions (Scope 1, 2, 3) by 2032 (base year 2022), aligned with the Paris Agreement 1.5°C pathway.

Targets related to climate change mitigation and adaptation

MTG has a clearly defined target: MTG is to reduce emissions in the value chain (Scope 1, 2, and 3) by 50% by 2032, with 2022 as the base year.

Our commitment is in line with the Paris Agreement to limit global warming to 1.5 degrees.

Target details

Planned actions for 2025

In 2025, MTG aims together with HQ and the studios PlaySimple, Hutch, InnoGames, Ninja Kiwi and Snowprint to:

• Conduct a GHG screening to map material emission sources
• Set science-based emissions reduction targets in line with SBTi
• Set a concrete action and transition plan thereafter

Energy consumption and mix

E1-5 Energy consumption and mix

MTG's overall energy consumption increased by 29.5% from 913.9 MWh in 2023 to 1,183.3 MWh in 2024. This increase was primarily a result of changes in methodologies and expansion of the reporting scope. Consequently, the company notes that conclusions or deeper analysis cannot be drawn. For 2024, MTG incorporated consumption from fossil, nuclear, or renewable sources, in contrast to 2023 where reporting only distinguished between "green" energy and non-green energy.

Methodology note: Lines 1-4 (fuel consumption from coal, crude oil, natural gas, and other fossil sources) are not relevant for MTG. For more information on methodologies and emission factors used, please refer to the accounting policies, section 4, on pages 151-153.

Gross Scopes 1, 2, 3 and Total GHG emissions

Total GHG emissions summary

Scope 1 emissions breakdown

Scope 1 emissions primarily consist of:

• Fuel for company vehicles
• Leaking refrigerants
• Natural gas

No detailed sub-breakdown by stationary combustion, mobile combustion, process emissions, or fugitive emissions was provided in the report.

Scope 2 emissions breakdown

Scope 2 emissions are primarily from electricity consumption in offices.

Scope 3 emissions by category

Main Scope 3 sources (2024): Use of sold products (66.8% of Scope 3), business travel, and capital goods.

GHG intensity

Biogenic emissions

Biogenic CO₂ emissions are not separately disclosed in the report.

Regulated emissions

No regulated emissions under the EU ETS or similar schemes were disclosed.

Methodology and scope notes

• Reporting standard: The GHG inventory follows the GHG Protocol Corporate Accounting and Reporting Standard.
• Organizational boundary: The reporting covers MTG's operational control approach for 2024, including InnoGames, Hutch, Ninja Kiwi, PlaySimple, and Snowprint. Kongregate was deconsolidated in Q1 2024. Plarium was acquired in February 2025 and is not included in the 2024 figures.
• Comparability: The company notes that year-over-year comparisons are affected by changes in methodologies and expansion of the reporting scope. Scope 3 emissions increased by 134.4% compared to 2023, but the company states it is "unable to draw meaningful conclusions due to changes in the methodologies and expansion of the reporting scope."
• Scope 3 category 11 (Use of sold products): Represents the largest source of Scope 3 emissions, calculated based on player usage of games.
• Emission factors: Market-based Scope 2 calculations use supplier-specific emission factors where available; otherwise, residual mix factors are applied. Location-based calculations use IEA country-specific grid factors.
• Data quality: Some Scope 3 data points rely on estimates and assumptions, particularly for categories where direct data is not available.
• Category 15 (Investments): Not disclosed for 2024.
• Base year: The company references 2022 as a base year for its 50% reduction target by 2032, but detailed 2022 baseline figures are not reproduced in this section of the report.

Less waste

We consistently strive to minimize waste production and promote circularity through recycling and taking advantage of opportunities for reuse. Responsible waste and e-waste management through authorized operators.

Responsible waste and e-waste management through authorized operators.

MTG have clear requirements for basic pay to align with universal labor rights standards, applicable laws, and agreements on working hours and wages. Each portfolio company is responsible for ensuring correct pay grades and remuneration based on local laws, regulations, and standards.

Each portfolio company is responsible for ensuring the well-being of their employees, based on their working methodologies and regional laws and regulations.

Each of our portfolio companies has a workers' council, or a comparable entity, tasked with addressing work-related injuries and health concerns, and proposing improvements. The frequency and format of these meetings vary, based on the structure and needs of each company.

Training and awareness

Training and awareness are one way to increase equality and inclusion. For example, training is carried out for most employees in the areas of unconscious bias and diversity, equality and inclusion (DE&I) as well as training on the responsible use of AI.

Action 2024: Annual training on unconscious bias and diversity, equity, and inclusion (DE&I). Training in responsible AI usage to enhance operations and creativity. Trainee programs to attract young talents from diverse backgrounds. A fair recruitment process to minimize bias.

Targets related to own workforce

Gender Diversity Target

Target metric: Percentage of workforce represented by female or non-binary employees

Target value: 40% of the workforce to be represented by female or non-binary employees

Baseline year: 2020

Baseline value: Not disclosed

Target year: Not disclosed (ongoing annual target)

Annual interim target: Increase gender diversity by 1% year-over-year

Scope: MTG's operations globally, including direct employees and those employed through third-party agencies within its workforce

Type: Absolute target (percentage of workforce)

Validation: Informed by industry benchmarking data and the global gaming industry's gender diversity statistics, using employee demographic surveys and local gender equality indexes. Engagement with employee resource groups, senior management, and external DEI consultants. Not externally validated or science-based.

Progress tracking: Progress is tracked annually and reviewed by the group's P&C executive, who provides yearly updates to the Board or applicable Board committee.

Stability: No changes to the original target or methodology have been made since its introduction in 2020. Adjustments to measurement practices will be disclosed in future reports, if applicable.

Incentive scheme: MTG includes a gender diversity target in incentive schemes. The threshold level is a 1% improvement of the prior year-end ratio of female and male employees.

Current status (2024):

• Female employees: 297 (27.1% of 1,097 total)
• Male employees: 791 (72.1% of 1,097 total)
• Other (non-binary): 9 (0.8% of 1,097 total)
• Combined female and non-binary: 306 (27.9% of 1,097 total)

In 2024, women and non-binary employees accounted for 28% of the workforce. In 2024, the MTG village decreased by 4.7% in terms of new employees.

Status in 2024: 28% of employees identified as female or non-binary in 2023. ~20% of top and middle management is represented by female or non-binary employees.

Characteristics of non-employees in the undertaking's own workforce

Disclosure

MTG's Code of Conduct (CoC) applies to all MTG employees, as well as temporary workers, such as contractors, freelancers, and consultants.

Freelancers and contractors are excluded from employee headcount calculations (as noted in S1-6 and S1-8 disclosures).

Quantitative metrics

No quantitative data on the number, breakdown by type (contractor, agency, self-employed), or FTE/headcount methodology for non-employee workers is disclosed in the ESRS S1-7 context.

Multi-year comparison data for non-employee workers is not provided.

Collective bargaining coverage and social dialogue

S1-8: Collective Bargaining coverage and social dialogue

None of the entities had a collective bargaining agreement in 2024. The company aims to provides working conditions above the minimum requirements of CBAs. Only those entities with more than 50 employees and representing at least 10% of the total workforce are reflected in the table.

Engagement with workers' representatives

Currently, MTG engages directly with the workforce, as there are no formal worker representatives or unions within the organization. Engagement is facilitated through standard management procedures such as one-on-one meetings, surveys, and whistleblowing mechanisms.

Scope

Germany, India, and the UK are the only locations where employee count reaches 50 or more, with each of these countries accounting for at least 10% of overall workforce.

Diversity metrics

Gender distribution at top management level

Board of Directors and Senior Executives (Group)

Board of Directors and Senior Executives (Parent company)

Employees in top management by gender (headcount)

Methodology note: Top management is defined as the two levels below the administrative management and supervisory bodies. Gender distribution is assessed by counting the total number of men and women in these leadership positions, excluding freelancers and contractors from the calculation.

Age band distribution of total workforce

Methodology note: Freelancers and contractors are not included in this calculation.

Adequate wages

S1-10 Disclosure

All employees paid adequate wage: Yes (2024)

Statement: MTG states: "We ensure that all our employees in Europe receive fair compensation in accordance with Directive (EU) 2022/2041. Likewise, every employee in our non-European locations is paid a sufficient wage based on relevant national standards. To maintain fair pay across all regions, we align employee wages with established national benchmarks."

Benchmark methodology

National benchmarks: MTG uses "established national benchmarks" across all regions. The company states:

• Employee wages are "determined based on industry standards, market comparisons, and legal requirements, including compliance with the National Minimum Wage and National Living Wage where applicable."
• MTG "assess[es] local market conditions and cost-of-living standards across all operational locations."
• "When necessary, compensation is adjusted to remain competitive and exceed livable wage thresholds."
• The company subscribes to external workforce benchmarking data via Willis Tower Watson and conducts regular compensation benchmarks in all jurisdictions.

Studio-level practices:

• InnoGames publishes pay ranges publicly
• NinjaKiwi has implemented above-industry-standard increases to address inflation
• PlaySimple employs a pay-for-performance model with competitive base salaries

Coverage

All employees across all operational locations (Europe, non-European locations). No percentage breakdown provided.

Geographic scope

Global - covers all MTG locations including Germany, India, UK, Canada, Sweden, Croatia, USA, New Zealand, Chile, Norway, and Singapore.

Targets

No specific targets disclosed.

Methodology details

• Frequency: Regular compensation benchmarks conducted in all jurisdictions
• External data source: Willis Tower Watson
• Assessment: Local market conditions and cost-of-living standards
• Commitment: Wages remain "above the local living wage" and adjusted to "exceed livable wage thresholds"

Historical note: This metric was not included in 2023 sustainability reporting.

Social protection

Coverage of social protection

Disclosure statement

At MTG, we prioritize the well-being of our employees by offering comprehensive social protection benefits. These include healthcare, retirement plans, disability insurance, paid leave, and workplace safety measures. Each benefit is tailored to align with local regulations and market conditions, ensuring that all employees receive support during significant life events.

Methodology and scope

Employee compensation and social protection vary by country and region, depending on local regulations and the availability of public programs. Where necessary, additional benefits are provided, with each studio designing its own approach. These benefits may include pensions, healthcare and insurance plans, wellness programs, various leave options, and more.

In 2023, this metric was not included in the sustainability reporting, and therefore, the data is not available for comparison.

Training stands out as a crucial tool for enhancing expertise. Each of our portfolio companies provides a diverse range of training programs for their employees.

For both MTG and our employees, career development is of high interest. To be able to provide individualized career growth, each of our portfolio companies conducts annual reviews. This ensures that career development remains a focal point. In 2024, 91.9% of employees participated in at least one review.

Each of our portfolio companies has a workers' council, or a comparable entity, tasked with addressing work-related injuries and health concerns, and proposing improvements. The frequency and format of these meetings vary, based on the structure and needs of each company.

Our approach centers on creating workplaces that facilitate physical and mental well-being through a healthy work-life balance. We also aim to provide development opportunities and flexibility, allowing individuals to navigate new life situations while contributing to our Gaming Village.

In recent years, we have sustained a high return-to-work rate, with a majority of employees choosing to stay at MTG after taking parental leave. This is a positive indication that our workplaces are sustainable and flexible in addressing new life situations.

Compensation metrics

Pay gap

Not disclosed.

Remuneration ratio

Not disclosed.

Methodology

No methodology for S1-16 metrics was provided in the excerpts. The report includes detailed executive remuneration disclosures in Note 21, including breakdowns of base salary, variable remuneration, other benefits, pension costs, and extraordinary costs for the Board of Directors, CEO, and senior executives. However, no gender pay gap statistics or CEO-to-median employee remuneration ratio were disclosed.

Incidents, complaints and severe human rights impacts

S1-17 Work-related grievances, incidents and complaints

Methodology note

2024 was the first year MTG reported this metric and cannot therefore draw any conclusions or deeper analysis. In 2023 the company reported on Work-related ill health and injuries as described in GRI. In 2024 they reported on S1-17 as described in ESRS and these two methods are not comparable due to different response options.

Total number of confirmed work-related cases of incidents, complaints, discrimination and harassment, social and human rights incidents are identified and registered by local HR functions at MTG and the studios during the reporting period. The reported cases cover the entire workforce.

Remediation actions taken in 2024

During 2024, whistleblower reports related to workplace discrimination were addressed through corrective action plans, including mediation, employee reassignment, and additional manager training. In cases of severe harm, external mediation and compensation mechanisms were used to resolve disputes.

Age classification of games

Games developed by MTG's companies are classified by either the International Age Rating Coalition (IARC) or the age rating systems on platforms such as Google Play and the Apple App Store. However, country or region-specific age limits may vary depending on the markets where the games are published.

Protecting minors' data

All MTG's companies continuously improve their data protection processes in accordance with the framework developed and governed by our Head of Data Protection. Tailoring these processes to individual games, their respective mechanics, and the data collected, each company has developed its own approach to ensure the safeguarding of all data, with a particular focus on protecting the data of minors.

Action 2024: Responsible gaming, with a focus on age classification and protection of minors' data. Strict data protection measures, including limited collection of personal data and compliance with global regulations. Adherence to age restrictions, ensuring games are rated according to international guidelines.

Our games engage passionate player communities across the world. Our studios actively nurture and engage these communities on different digital platforms. They focus on streamers and other content creators and manages both proprietary and public forums where players can engage with our brands and IPs.

We want our gaming environments to be safe and respectful. To achieve this, our gaming companies have implemented policies, guidelines, and tools to address any unacceptable behavior.

We want everyone to be able to play and enjoy our games, including neurodivergent players. This is why our game studios are continuously developing and implementing different settings and mechanics which allow players with, for example, color blindness, visual impairments, or sensory sensitivity to play our games.

In promoting gaming for all, we also include the significance of maintaining a healthy balance between engaging with our games and life outside of our games, particularly for our younger players.

To implement MTG's sustainability strategy all studios must adhere to our policy framework and ensure that all employees participate in training courses for our core policies: the Code of Conduct, Anti-Corruption Policy and Whistleblower Policy.

Policy Framework: Anti-Corruption Policy, Code of Conduct, Whistleblower Policy

During 2025, we will adopt and roll out a Responsible Marketing Policy for the group to address the identified risks and opportunities in connection to our players.

We expect our suppliers and stakeholders to share this commitment. Our ambition is to establish appropriate guidelines and internal structures to ensure that everyone in the group acts responsibly within the scope of their role. We believe that collaborating with our partners and suppliers, and clearly articulating our expectations and future targets will enable us to achieve a more environmentally responsible approach.

To implement MTG's sustainability strategy all studios must adhere to our policy framework and ensure that all employees participate in training courses for our core policies: the Code of Conduct, Anti-Corruption Policy and Whistleblower Policy.

Our target within "respectful" is to improve our sustainability governance by reducing our ESG risk rating to 10 by 2025. Base year of target is 2022.

Status in 2024: 15.9 is our ESG risk rating, in December 2024.

Incidents of corruption or bribery

Confirmed incidents and convictions

MTG reports zero confirmed incidents of corruption or bribery during the 2024 reporting period:

The company explicitly states: "In 2024, no incidents of fraud, corruption, bribery, or violations of antitrust or competition laws were reported. Additionally, MTG did not face any convictions or fines for violations of anti-corruption or anti-bribery laws during the year and were not subject to any related legal actions."

Investigation and speak-up procedures

MTG maintains a comprehensive whistleblower system accessible to employees, customers, suppliers, and business associates for reporting concerns regarding breaches of the Governance Framework. Reports submitted through MTG's whistleblower channel are managed by a specially appointed, impartial group, with the option to report incidents anonymously. The company ensures whistleblowers are protected from retaliation, discriminatory actions, or disciplinary measures in accordance with EU law.

Employees who encounter suspected instances of corruption—whether within MTG or by any third party affiliated with MTG—are encouraged to report these concerns to the company's management or contact the Group General Counsel. Additionally, suspected acts of corruption can be reported anonymously through MTG's whistleblower channel.

If a case were to be reported, it would be assessed by an independent internal committee or a third party to ensure impartiality and accountability. Investigation outcomes would be escalated to the Audit Committee.

Anti-corruption training is mandatory for all employees, including the Board and senior management team. The training covers the Code of Conduct, Anti-Corruption Policy, and Whistleblower Policy.

Risk assessment

MTG assesses the risk of corruption or bribery within its workforce or supply chain as minimal due to a transparent and relatively short supply chain in the gaming industry. The company's operational model significantly reduces inherent risks, including operations across countries with varying cultural norms and reliance on major platforms like Apple App Store and Google Play. The company has processes in place to assess potential risks associated with specific jurisdictions in relation to M&A activities.