Modern Times Group MTG

Governance roles

Reference: pages 62-65 (the ESRS content index lists GOV-1 and GOV-2 together at pp.62-65).

The Board comprises 7 members, 0 executive and 7 non-executive, 29% women and 71% men; "Among the non-executive board members, 5 are independent" (p.62). Executive Management has four members - CEO, CFO, EVP Gaming and General Counsel - and "represented 25% women and 75% men" (p.62).

Allocation of responsibility:

• "The Board's oversight of sustainability rests with the Audit Committee (AC), which also serves as MTG's ESG Committee." The AC receives quarterly updates from the Sustainability Specialist covering material IROs, regulatory compliance, assurance readiness and data quality; the Board receives an annual update (p.62).
• "At the executive level, the CFO has ultimate accountability for sustainability" (p.63).
• The policy framework "is reviewed by department leads and approved annually by the Board" (p.63).

The Board, ESG Committee and Management took structured training in 2025 on the CSRD and ESRS, internal controls, and investor expectations (p.63).

A self-declared gap: "As of the 2025 reporting year, MTG has not yet formally incorporated material impacts, risks, and opportunities (IROs) into strategic oversight, major transaction decisions, or the enterprise risk management framework" (p.63).

Information provided to and matters addressed by the bodies

Reference: pages 62-65 (the content index treats GOV-1 and GOV-2 as one disclosure at pp.62-65, p.113).

The Audit Committee, acting as the ESG Committee, "receives quarterly updates from the Sustainability Specialist. These cover material impacts, risks and opportunities (IROs), progress on regulatory compliance, assurance readiness, and the quality of reported sustainability data. The Board receives an annual update summarizing these topics" (p.62).

MTG names the three material topics its administrative, management and supervisory bodies addressed in 2025 (p.63):

• Resilience assessment and climate scenario - "The Board reviewed and approved MTG's resilience assessment and climate scenario analysis of IROs"
• Environmental management - "The Board reviewed and approved MTG's new Environmental Policy"
• Climate change and energy transition - "The Board approved the group's Science Based Target initiative (SBTi) and the transition plan"

Forward-looking commitment: "Starting in 2026, the Board and the AC will conduct an annual formal review of the group's sustainability strategy, our progress against defined targets, and the results of limited assurance on reported disclosures" (p.63). MTG describes 2025-2027 as "a transition phase, during which MTG will establish the mechanisms needed to embed IROs into strategic and risk management practices" following the Plarium acquisition (p.63).

Sustainability performance in incentive schemes

Reference: page 65.

Responsibility sits with the Board's Remuneration Committee, "which is composed of independent Directors" (p.65).

Climate is explicitly excluded: "MTG does not currently have incentive schemes in place that link the remuneration to climate-related targets but will consider it going forward" (p.65).

The single sustainability measure in the 2025 incentive plan is data privacy (p.65):

• Measure: Data privacy compliance
• Weighting: 5% of total payout
• Threshold: "Maintain 85% completion rate for all mandatory data protection training across the group"
• Weighting by company: based on 2025 revenue contribution

Coverage is partial: the measures "apply to all senior executives at group level, as well as to the senior leadership teams at three of MTG's gaming studios. Senior leaders in other studios are not yet included but may be integrated into future incentive cycles" (p.65). Financial indicators - revenue, adjusted EBITDA and Total Shareholder Return - "remain the primary focus of the program" (p.65). The Remuneration Committee sets the KPIs annually and "confirms achievement levels before payouts are approved". Detail on remuneration is cross-referenced to Note 20.

Statement on due diligence

Reference: page 66.

MTG presents the required mapping table linking the core elements of sustainability due diligence to paragraphs of the statement (p.66):

The wider due diligence framing sits in IRO-1: the DMA "was guided by the sustainability due diligence principles set out in the OECD Guidelines and the UN Guiding Principles on Business and Human Rights (UNGPs)" and "is viewed as an integral component of our due diligence framework" (p.75). Note that in the S4 chapter MTG states it "has not formally aligned its processes with the UN Guiding Principles on Business and Human Rights or the OECD Guidelines for Multinational Enterprises" for consumers and end-users (p.101).

Risk management and internal controls over sustainability reporting

Reference: page 66.

The internal control environment is founded but not complete: "the foundational components of the internal control environment have been established for sustainability reporting... While core components are in place, MTG is continuing during 2026 to further define, operationalize and test control activities, with full implementation targeted by year-end" (p.66).

Principal risks: "The principal risks identified relate to sustainability data and reporting and include data incompleteness and inaccuracies" (p.66). Risk assessment covers completeness, over- or under-reporting, entity-level accuracy and "verifying reported reductions".

MTG concedes the methodology is immature: "Current efforts focus on mapping areas assessed as high-risk by the Sustainability team, however, the risk assessment methodology and its linkage to control design will be further refined to ensure systematic coverage across environmental, social and governance data" (p.66).

Remediation planned for 2026: "completing process mapping including risk and controls and establishing a testing environment" (p.66). The Sustainability Specialist owns the reporting process and gives an annual update to the Board and Audit Committee; the environment is built with the Governance Risk and Compliance Director. GHG metrics follow the GHG Protocol on a group-wide reporting system.

Strategy, business model and value chain

Reference: pages 67-69.

MTG "owns and actively manages a portfolio of international gaming studios", organised into two clusters, the Midcore District and the Casual District (p.67). "Nearly all our games are made available to consumers on a free-to-play (F2P) basis, and we generate most of our revenues from in-app purchases and in-app advertising" (p.67). Headcount at end-2025: "676 in Ukraine, 395 in India, 393 in Germany, 289 in Poland, 191 in United Kingdom and 430 in other regions" (p.67).

Value chain (pp.68-69): upstream is cloud storage and IT equipment; own operations are game development, mergers and acquisitions, and marketing and distribution; downstream is sales and distribution, end-user experience, external content in games, and product end-of-life, where "MTG has not evaluated the end-of-life management of products in 2025".

The sustainability strategy rests on three pillars: "Inclusive and welcoming", "Climate action", and "Proud and respectful" (p.67). Stated goals include cutting scope 1 and 2 emissions 46.2% and scope 3 emissions 27.5% by 2031 (base year 2024), and raising the S&P Global CSA rating by 20 points by 2027. "During 2026, MTG will develop a new sustainability strategy... implemented from 2027 onwards" (p.67).

All four SBM-1 paragraph 40(d) datapoints - fossil fuel, chemical production, controversial weapons and tobacco - are marked "Not material" (p.108).

Interests and views of stakeholders

Reference: page 70.

"In 2025, MTG assessed stakeholder views as a part of the Double Materiality Assessment (DMA), ensuring the interests and expectations of our key stakeholders were considered when shaping MTG's sustainability roadmap" (p.70).

The stakeholder table names six groups plus one silent stakeholder (p.70):

• Own workforce - annual engagement surveys, pulse surveys, appraisals, questionnaires, online whistleblower system
• Consumers and end-users (gamers) - forum moderation, surveys on gaming experience, user feedback mechanisms, with the purpose of "Protecting young adults and children" and "Promoting online safety"
• Shareholders and investors - calls, annual and quarterly reports, AGMs, investor conferences and roadshows
• Executive Management - ESG updates
• Lenders and banks - regular updates and reports
• Suppliers - annual ESG reports, Supplier Code of Conduct
• Silent stakeholders: natural environment - "Track emissions"

Outcomes are traced to decisions: "Engagement with investors improves the clarity and timeliness of sustainability communication and informed our target to improve our S&P Global Corporate Sustainability Assessment (CSA) rating by 20 points by 2027" (p.70). MTG states plainly that "MTG has not scheduled any amendments to our strategy or business model in this area" (p.70).

Material impacts, risks and opportunities

Reference: pages 71-74, restated per topic at pp.79, 90, 99 and 105.

The DMA produced 15 material IROs across four topics (pp.72-73). "All identified IROs are covered by topical ESRS standards, except for cybersecurity, which is considered an entity-specific disclosure under G1 (Business Conduct)" (p.71).

"No material risks or opportunities have been identified that would give rise to a significant risk of material adjustment within the next annual reporting period to the carrying amounts of assets and liabilities" (p.71).

"2025 marks MTG's first year of reporting in accordance with the CSRD... No comparative changes to previously reported material IROs are therefore presented" (p.74).

Processes to identify and assess material IROs

Reference: pages 75-77, with climate and governance processes at pp.77-78.

"During 2025, MTG conducted a double materiality assessment (DMA) review to identify and validate the group's material impacts, risks, and opportunities (IROs). All IROs identified in the 2024 DMA were systematically reviewed, re-scored, and validated. The DMA was carried out in collaboration with an independent consultancy" (p.75). Plarium was included after its acquisition.

Five steps (p.75): identification; process and stakeholder review; impact assessment; consolidation and mapping; DMA validation. "The outcome of this initial assessment was a preliminary list of 38 impact IROs and 32 financial IROs" (p.75).

Impact scoring (p.76): "for negative impacts, the score is calculated by multiplying likelihood by the average of scale, scope, and irremediability; for positive impacts, likelihood is multiplied by the average of scale and scope." A five-by-five matrix with a sloping threshold is used; "Any impact with a severity score of four or above is automatically deemed material."

Financial scoring (p.77): magnitude is measured against EBITDA on a minor-to-major scale against likelihood, again on a five-by-five matrix.

"MTG will review the DMA every two to three years, or earlier if major acquisitions or significant operational changes occur" (p.77).

Disclosure requirements covered

Reference: pages 108-114.

MTG prints a genuine two-part ESRS index. Pages 108-112 carry the datapoints derived from other EU legislation (SFDR, Pillar 3, Benchmark Regulation, EU Climate Law), each flagged Material or Not material with a page number. Pages 113-114 carry the "Content index of ESRS disclosure requirements", listing every disclosure requirement covered with a page reference.

Covered per the index (pp.113-114):

• ESRS 2 - BP-1, BP-2 (p.62), GOV-1 and GOV-2 (pp.62-65), GOV-3 (p.65), GOV-4 (p.66), GOV-5 (p.66), SBM-1 (pp.67-69), SBM-2 (p.70), SBM-3 (pp.71-74), IRO-1 (pp.75-77), IRO-2 (pp.108-114)
• E1 - SBM-3 (pp.79-80), IRO-1 E1 (pp.77-78), E1-1 (pp.80-81), E1-2 (pp.81-82), E1-3 (p.82), E1-4 (pp.82-83), E1-5 (pp.83-84), E1-6 (pp.84-87)
• S1 - SBM-3 (pp.90-91), S1-1 to S1-6, S1-8, S1-9, S1-10, S1-13, S1-16, S1-17 (pp.91-98)
• S4 - SBM-3 (pp.99-100), S4-1 to S4-5 (pp.100-104)
• G1 - SBM-3 (p.105), IRO-1 G1 (p.78), G1-1 (pp.105-106), plus two entity-specific entries, "G1 Policies related to cybersecurity" (p.106) and "G1 Actions taken to manage cybersecurity risks and opportunities" (p.107)

E2, E3, E4, E5, S2 and S3 have no entries at all. Within E1, S1 and G1 the index omits E1-7, E1-8, E1-9, S1-7, S1-11, S1-12, S1-14, S1-15 and G1-2 to G1-6.

Transition plan for climate change mitigation

Reference: pages 80-81.

"During 2025, MTG developed and approved our first climate transition plan. The plan operationalizes our commitment to the Paris Agreement by addressing the group's material GHG emissions sources and setting out actions across both own operations and the value chain" (p.80).

Decarbonisation levers (p.81): scope 1 - lower-GWP refrigerants and leak monitoring; scope 2 - "switch to LED lighting, optimize AC schedules, reduce idle times" and "purchase Regional Energy Certificates (REC), adopt green heating"; scope 3 - "green server procurement, low-carbon user acquisition practices, performance-efficient ads" and circular equipment principles.

Locked-in emissions: "As MTG does not own GHG-intensive infrastructure, there are no material locked-in emissions associated with direct operations. However, the company is reliant on upstream digital services, where market readiness, such as the availability of green hosting or low-carbon ad delivery infrastructure, poses a risk to target achievement" (p.81).

Funding: the CapEx and OpEx needed "are currently being evaluated. There are no significant new CapEx investments required" (p.81).

Integration is incomplete and MTG says so: "the transition plan is not yet fully integrated with MTG's overall business strategy and financial planning", with integration planned "during 2026" (p.81). It is approved by Executive Management and the Board.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 E1 (pages 77-78) and the E1 climate scenario section (page 80). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"In 2025, MTG completed its first climate scenario analysis, aligned with... ESRS and TCFD recommendations" (p.77).

Scenarios (¶17(a)): three were applied - "Net Zero Emissions by 2050 (1.5°C), IEA Stated Policies (~3°C), and IPCC SSP3-7.0" (p.80). A 1.5°C-aligned transition scenario and a higher-emission physical pathway are both present; a temperature projection is given only for Stated Policies. Horizons: 2030, 2035, 2050.

Methodology (¶16): "Regional climate data and geospatial tools, including the IPCC Interactive Atlas and WRI Water Aqueduct, were used to assess the exposure and sensitivity of MTG's assets and value chain to physical climate hazards such as extreme heat, water stress, and flooding" (p.78).

Findings (¶15): "by 2050, offices in India, Israel, and Spain are projected to be most exposed to severe temperature increases and prolonged droughts. Stockholm and parts of Europe are expected to face heightened risks of flooding, saltwater intrusion, and water scarcity" (p.78). Transition risks cover carbon pricing and energy decarbonization. The analysis "relied primarily on regional climate data and did not fully cover all asset types or non-European markets" (p.78).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 (page 74) and the E1 resilience assessment (page 80). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"The resilience of MTG's strategy and business model to climate change was assessed as part of our scenario analysis in 2025. This analysis included all major business units, operational sites, and critical supply chain partners" (p.80).

Results (¶19(a)): "MTG's business model is moderately exposed to physical climate risks in regions experiencing rising temperatures and water scarcity, while European hubs face increased flood risk... MTG's diversified portfolio, digital-first operating model, and reliance on leased infrastructure support a relatively high level of resilience to climate-related risks in the short- to medium-term" (p.80).

Asset compatibility: the analysis "did not identify any assets or core activities that are incompatible with a climate-neutral transition... no significant stranded asset risk has been identified under a 1.5°C-aligned scenario" (p.78).

Uncertainty (¶19(b)): the assessment "is primarily based on regional data and does not fully capture all asset types or non-European markets" (p.80), and "has not been explicitly integrated into MTG's impairment testing or cash flow forecasts" (p.78). The group-level assessment rates MTG "moderate to high" short term and "low to moderate" long term (p.74).

Policies related to climate change mitigation and adaptation

Reference: pages 81-82.

"MTG's Environmental Policy was adopted in 2025 and sets the framework for Climate change mitigation and energy management across group operations and the value chain" (p.81). Adopting it was one of three sustainability matters the Board addressed in 2025 (p.63).

Scope: "The policy covers emissions from office energy use and on-site cooling (scope 1 and 2), as well as significant indirect emissions from business travel, capital goods, cloud services, and the use of MTG's digital products (scope 3)" (p.81).

Accountability: "MTG's CFO is accountable for group-wide implementation of the policy" (p.81), with monitoring by "Annual data collection; Audit Committee review; studio check-ins" (p.64).

Content: the policy "commits MTG to supporting decarbonization across the value chain, prioritizing energy efficiency, renewable energy sourcing, and circular procurement for IT equipment. Supplier engagement is guided by the Supplier Code of Conduct" (p.81).

Availability: it "is reviewed annually and updated in line with advances in climate science, regulatory requirements, and stakeholder expectations. It is publicly available on MTG's website" (p.82).

Two acknowledged gaps: embedding efficiency into game design and strengthening engagement with data centre partners "are areas for future development" (p.81). No separate adaptation policy is described.

Actions and resources in relation to climate change policies

Reference: page 82.

This disclosure is a documented nil return. "As of the reporting date, MTG has not adopted specific, time-bound climate action plans with allocated resources under the transition plan. During the reporting year, the group has focused on establishing and refining emissions measurement, improving scope 1, scope 2 and relevant scope 3 data coverage, and assessing potential decarbonization pathways" (p.82).

"Accordingly, MTG does not disclose detailed information on implemented climate actions under this section, as such actions have not been formally adopted during the reporting period" (p.82).

Resources: "MTG has not calculated or allocated significant capital expenditure (CapEx) or operating expenditure (OpEx) specifically to climate-related actions during the reporting year. The funding requirements for implementing future transition measures are currently being assessed" (p.82).

What is disclosed instead are the decarbonisation levers under E1-1 (p.81) and interim milestones: "Interim milestones have been established for 2030, reflecting a 40% reduction in scope 1 and 2 emissions and a 25% reduction in scope 3 emissions compared with the 2024 baseline" (p.82). The EU Taxonomy tables corroborate the absence of climate capex, with turnover, CapEx and OpEx all 0% aligned (pp.88-89).

Targets related to climate change mitigation and adaptation

Reference: pages 82-83.

"MTG has committed to reducing absolute scope 1 and 2 GHG emissions by 46.2% by 2031, with 2024 being the base year. MTG has also committed to reduce absolute scope 3 GHG emissions by 27.5% by 2031" (p.82).

"Scope 1 and 2 targets follow a 1.5°C science-based pathway, consistent with the IPCC Special Report on Global Warming of 1.5°C." The scope 3 target "is aligned with a well-below 2°C scenario", covering categories 1 and 2, which "represent approximately 81% of scope 3 emissions included in the SBTi boundary" (p.82). MTG quantifies the shortfall: 27.5% by 2031 "compared with a 46.2% reduction that would be required for a fully 1.5°C-aligned trajectory".

"MTG does not currently rely on GHG removals, carbon offsets or avoided emissions" (p.82). "The reference pathway will be disclosed after SBTi validation", and the targets "are not yet externally assured" (p.83). They "apply to MTG's studios prior to the acquisition of Plarium" (p.82), and "As Plarium's emissions have not yet been incorporated into the base year, MTG cannot currently assess performance against the disclosed targets" (p.83).

Energy consumption and mix

Reference: pages 83-84.

The renewable share fell from 47.6% to 32.0% while total consumption more than doubled. MTG attributes the shift to acquisition and geography rather than sourcing: "The reported energy mix is therefore largely influenced by geographic location rather than specific sourcing decisions made by MTG" (p.83), and "The acquisition of Plarium in 2025 impacts both absolute energy consumption and the distribution of energy sources" (p.84).

"Most of the energy, 68%, used within MTG was in the form of electricity" (p.83). Self-generation totalled 83.1 MWh, of which 51.4 MWh renewable from "solar panels at offices in New Zealand and Germany" (p.84).

Data quality: "The majority of the reported energy consumption is based on invoices and meter readings, of which 28% was partly or fully estimated" (p.84).

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 84-87.

Scope 3 by category (2025): purchased goods and services 46,679.4 (cloud services and data centers 626); capital goods 421.8; fuel and energy related activities 251.3; waste 5.7; business travel 1,060.2; employee commuting 497.2; use of sold products 10,985.4 (p.84).

"Given MTG's business model, data centers represent a structurally significant emission source" (p.85). The increase is attributed to the Plarium acquisition, emission-factor updates and an extended reporting scope. Intensity rose to 5.3 tCO2e per SEK million location-based, from 4.2 (p.85).

Data quality is weak and disclosed as such: "Scope 3 emissions were calculated using mostly secondary data, less than 1% was primary data" (p.85); the spend-based method covered 85% of total emissions (p.86). Eight scope 3 categories (4, 8, 9, 10, 12-15) are excluded as "not material" (p.86). The totals are labelled "not subject to limited assurance" in the table itself (p.84).

Policies related to own workforce

Reference: pages 91-92.

The framework "comprises the Code of Conduct (CoC), Whistleblower Policy, Anti-corruption Policy, Anti-discrimination & Harassment Policy, and Modern Slavery Act Statement" and applies "to the entire workforce and relevant contractors" (p.91).

"The CoC aligns with international initiatives and standards including the OECD Guidelines for Multinational Enterprises, UN Guiding Principles on Business and Human Rights, the ILO Fundamental Conventions, and the UN Universal Declaration of Human Rights. MTG explicitly prohibits human trafficking and forced labor in all operations" (p.91). The datapoint table marks the S1-1 ILO due diligence datapoint Material at p.91 (p.111).

A stated gap: "MTG does not have a group-wide workplace accident prevention policy or management system in place. Each of our studios operate in compliance with applicable local occupational health and safety (EHS) regulations" (p.92). Studios in higher-risk areas add "conflict-response planning in Israel and Ukraine and natural disaster preparedness in New Zealand".

The Chief People Officer is "The most senior individual accountable for the implementation of MTG's workforce-related policies" (p.92).

Engaging with own workforce and workers' representatives

Reference: pages 92-93.

Engagement is decentralised: "As part of a centralized feedback process, in all but one studio, HR teams and/or studio leadership conduct anonymous engagement surveys" (p.93), supplemented by "all-hands meetings, townhalls, roundtables, and feedback sessions".

No formal representation structures exist. "MTG does not have a Global Framework Agreement or other agreements currently with workers' representatives in relation to the respect of human rights of our own workforce, as the group does not have formal works councils or worker representative structures in place" (p.92). Some studios have "informal employee representatives who regularly share workforce perspectives with management".

Operational responsibility: "It is the responsibility of each studio's leadership to ensure that meaningful engagement with employees takes place" (p.93). Effectiveness is monitored "through survey participation, follow-up implementation, and workforce indicators such as voluntary turnover".

Vulnerable groups: "MTG does not currently have a formalized process specifically designed to identify and gather insights from workers who may be particularly vulnerable to impacts and/or marginalized groups" (p.93).

Remediation and channels to raise concerns

Reference: page 93. The datapoint table marks "ESRS S1-3 Grievance/complaints handling mechanisms paragraph 32 (c)" as Material at p.93 (p.111).

"Within MTG, primary responsibility for managing negative impacts on the own workforce rests with each studio's leadership team and HR function. They are accountable for receiving, logging, and addressing concerns raised locally" (p.93). Local channels are the anonymous engagement survey, direct discussions with managers or HR, and informal employee representatives in some studios.

Group channel: "MTG maintains a group-wide whistleblowing channel, enabling all employees to report concerns confidentially and securely, including anonymously where legally permissible... the grievance is directed to MTG's Chief People Officer, who oversees the investigation" (p.93).

Retaliation: "MTG has policies in place that explicitly prohibit retaliation against anyone using grievance channels, including workers' representatives. These protections are embedded in the Code of Conduct and Whistleblower Policy" (p.93).

Effectiveness is not yet formally reviewed, and MTG says so twice: "While a formal, systematic effectiveness review has not yet been implemented, MTG monitors participation levels, types of issues raised, and feedback to evaluate trust in these processes", and "A formal and systematic evaluation of their effectiveness has not yet been established" for remedies (p.93).

Taking action on material impacts on own workforce

Reference: pages 93-94.

"In 2025, MTG strengthened our approach to managing workforce-related impacts, risks, and opportunities (IROs) by formalizing the role of the group Chief People Officer (CPO) in overseeing people-related strategy and initiatives across the portfolio" (p.93). The annual engagement survey, run "across most studios", is the primary instrument.

Actions listed are studio-level and illustrative rather than plan-based (p.94): well-being and work-life balance initiatives; diversity and inclusion programmes including "mentoring for underrepresented groups, and bias awareness training for hiring managers"; health and safety measures such as "ergonomic workstation upgrades"; and skills and career development.

The central admission: "MTG has not adopted a single, formalized group-wide action plan structured around each identified material workforce-related IROs. Actions are currently embedded within local studio processes and people practices" (p.94).

Resources: "MTG has not yet tracked the total financial spend for specific areas across the portfolio for 2025 on actions relating to workforce engagement, well-being, and diversity" (p.94).

Timelines given: a new group-wide onboarding process by Q4 2026, and expansion of the annual employee survey to 100% coverage during 2027 (p.94).

Targets related to own workforce

Reference: pages 94-95.

This is a disclosed nil return, and an unusual one because a target was withdrawn during the year. "Following the materiality assessment conducted during the reporting year, MTG reviewed its targets related to the own workforce and decided to remove the target of 40% female or non-binary representation across the workforce. While this target supported earlier efforts to increase gender representation, it is no longer considered an appropriate or effective measure for managing the identified impacts, risks, and opportunities (IROs), as MTG's diversity, equity, inclusion, and well-being (DEI&W) approach has evolved beyond a single quantitative metric" (p.94).

"Consequently, MTG does not have any workforce-related targets applicable for the reporting year" (p.94).

What replaces it: "Going forward, MTG will focus on a more comprehensive and impact-driven approach to DEI&W. This includes embedding equity and inclusion principles across people processes, strengthening inclusive leadership and workplace culture, and supporting employee well-being across the group" (p.94).

Timetable: "Actions and any future group-wide targets linked to material IROs for the own workforce will be integrated into the Group Risk Management System from 2026. The definition of baseline data and potential future targets is expected to be completed in 2027" (p.95). No interim measure sits between the withdrawal and 2027.

Characteristics of the undertaking's employees

Reference: pages 95-96.

By country (2025): Ukraine 676, India 395, Germany 393, Poland 289, United Kingdom 191, Israel 187, Sweden 58, Finland 55, Other 130 (p.95). "The category 'Other' includes countries where the number of employees does not exceed 50 employees" (p.96).

Turnover: 11.0% in 2025 (2024: 10.9%), with 262 leavers against 119 the year before (p.95). The rate is calculated as exits during the period divided by closing headcount, including both voluntary and involuntary departures (p.96).

The near-doubling of headcount follows the Plarium acquisition: "Reported changes in number of headcount should be assessed in light of the expanded group with the acquisition of Plarium" (p.95).

Data quality: "The disclosed numbers are compiled at the studio or subsidiary level, as MTG does not yet have a single, fully integrated HR information system across the Group. Depending on the size and systems maturity of each company, data may be collected manually or through local HR or payroll platforms" (p.95). The headcount is reconciled to note 19 of the financial statements (p.96).

Collective bargaining coverage and social dialogue

Reference: page 96.

"None of the studios had a collective bargaining agreement in 2025. 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" (p.96).

The table reports a 0-19% coverage ratio for both EEA employees (Germany, Poland) and non-EEA employees (India, Ukraine), the lowest band available, with no workplace representation reported for the EEA (p.96).

This is consistent with the S1-2 disclosure that "the group does not have formal works councils or worker representative structures in place" (p.92), and that only "informal employee representatives" exist in some studios (pp.92, 94). Social dialogue therefore runs through anonymous engagement surveys, all-hands meetings, townhalls, roundtables and feedback sessions rather than through recognised representative bodies (p.93). MTG offers no target or plan to raise collective bargaining coverage.

Diversity metrics

Reference: pages 96-97.

Age distribution:

"Age distribution was calculated based on headcount at the end of the reporting period. Employees aged 30 and 50 are included in the middle age category (30-50 years)" (p.97).

Top management (4 people, being MTG's Executive Management): 1 woman (25.0%), 3 men (75.0%), 0 non-binary (0%) (p.96). "Employees in top management consists of the Executive Management at MTG group. See note 19 for reference" (p.97).

The 2024 comparatives sum to 712 rather than the 1,097 headcount reported under S1-6 for the same year, so the year-on-year age shares are not directly comparable; MTG does not comment on the difference. Board-level diversity is reported separately under GOV-1: 29% women and 71% men across seven directors (p.62). Note that MTG withdrew its 40% female or non-binary representation target during 2025 (p.94), so these metrics are now reported without a target attached.

Adequate wages

Reference: page 97.

"MTG is a service company employing primarily high-skilled professionals. The company benchmarks employee total compensation against external market data provided by Willis Towers Watson, Mercer, Korn Ferry and other official third-party benchmarking services, covering relevant roles within the media, technology and gaming sectors across MTG's core employment markets. Based on this benchmarking, MTG considers that its employees are paid at least an adequate wage in line with applicable benchmarks" (p.97).

This is a qualitative assertion supported by named benchmark providers rather than by a percentage of employees paid at or above an adequate wage reference level. MTG does not identify the applicable adequate wage benchmarks country by country, does not state the reference used for non-EEA markets such as Ukraine, India and Israel, which together account for 1,258 of its 2,374 employees (p.95), and reports no percentage of employees below any benchmark.

The disclosure appears in the ESRS content index at p.97 (p.114), so it is claimed as covered, but the substantive datapoint under ESRS S1-10 is not quantified.

Training and skills development metrics

Reference: page 97.

Average training hours fell by roughly two thirds year on year, from 12.6 to 4.3 hours. MTG does not explain the fall, though headcount more than doubled with the Plarium acquisition (p.95) and "In cases where training hours were not systematically tracked, average training hours have been estimated based on the average duration of the training activity" (p.97).

Training hours cover "in-person sessions, online courses, workshops, certification programmes, short-term educational initiatives, and compliance training" (p.97). The high per-head figures for non-binary employees (35.9 hours) and undisclosed-gender employees (22.7 hours) rest on populations of 7 and 12 people respectively (p.95).

Compensation metrics (pay gap and total compensation)

Reference: page 97. The datapoint table marks both S1-16 rows, the unadjusted gender pay gap (¶97(a)) and the excessive CEO pay ratio (¶97(b)), as Material at p.97 (p.111).

Pay gap: "The unadjusted gender pay gap was 24.4% for 2025, with the CEO excluded. This can be explained by differences in senior roles with men concentrated in the senior roles" (p.97).

Remuneration ratio: "For 2025, MTG reports a remuneration ratio of 56.8. The ratio is influenced by the company's pay structure, including a limited number of senior executive roles with remuneration levels significantly above the workforce median" (p.97).

Methodology (p.97): the ratio is "annual total remuneration for the CEO divided by the average employee annual total remuneration, excluding the CEO", where remuneration includes "base salary, benefits, long-term incentive (LTI) value, bonuses and pensions". The pay gap uses consolidated gross hourly pay, all currencies converted to SEK, and "Pay for non-binary employees and employees not disclosed is excluded from the pay gap calculation."

No comparative for either metric is given, and MTG sets no pay gap target, having withdrawn its only workforce target during the year (p.94).

Incidents, complaints and severe human rights impacts

Reference: page 98. The datapoint table marks "ESRS S1-17 Incidents of discrimination paragraph 103 (a)" as Material at p.98 (p.111).

"Total number of confirmed work-related cases of incidents, complaints, discrimination and harassment, social as well as human rights incidents are recorded by local HR functions at MTG during the reporting period. The reported cases cover the entire workforce" (p.98).

The most notable movement is the two complaints filed with OECD National Contact Points, against none in 2024. MTG reports no narrative on their subject matter or status, and reports zero cases of non-respect of the OECD Guidelines in the same table. Separately, the G1 chapter reports that "There were 3 cases reported to the Whistleblower channel in 2025" (p.106).

Policies related to consumers and end-users

Reference: pages 100-101. The datapoint table marks "ESRS S4-1 Policies related to consumers and end-users paragraph 16" as Material at pp.100-101 (p.112).

"MTG's approach to personal data protection is governed by a comprehensive policy framework that ensures compliance with applicable data protection legislation, including the EU General Data Protection Regulation (GDPR). Oversight rests with the Head of Data Protection and the Director of Governance, Risk & Compliance, supported by local Data Protection Managers in each studio" (p.100).

Internal policies: General Data Protection Policy, Intra-Group Data Protection Policy, Group Data Breach Policy, Employee Privacy Policy and Group AI Policy; they "are not published externally in order to safeguard confidentiality and maintain cybersecurity integrity" (p.100). External: Privacy Policy and Cookie Policy.

Responsible gaming: "In 2025, MTG adopted a Statement on Responsible Gaming and Advertising"; it "is publicly available on our website. A formal Responsible Marketing Policy will follow within the next few years" (p.101).

A stated shortfall: "Although MTG has not formally aligned its processes with the UN Guiding Principles on Business and Human Rights or the OECD Guidelines for Multinational Enterprises, we are progressively integrating elements of human-rights-based due diligence" (p.101).

Engaging with consumers and end-users

Reference: pages 101-102.

"MTG's engagement with consumers and end-users is primarily managed at the studio level, where teams interact directly with player communities through in-game channels, social media platforms, and customer-support functions" (p.101).

No group-wide channel exists: "While MTG does not maintain group-wide direct engagement channels for gamers, individual studios occasionally conduct targeted initiatives to collect feedback related to privacy and data protection practices" (p.101). These are "User focus groups, convened to test and evaluate privacy-related communications, consent mechanisms, and interface design" and "A/B testing of privacy features, allowing studios to assess user comprehension and comfort levels with privacy settings".

Timing is ad hoc, occurring "at any stage of the user lifecycle, including during the design and testing of features involving the processing of personal data, at product launch, during live operations, and when material changes are made to data processing practices" (p.101).

Escalation: feedback is "escalated, where material, to the Head of Data Protection and Director of Governance, Risk & Compliance" (p.101).

Vulnerable users: "At present MTG does not operate additional group-wide formalized processes specifically dedicated to collecting insights from vulnerable or marginalized consumers" (p.102).

Remediation and channels for consumers and end-users

Reference: pages 102-103.

"MTG and our studios follow a documented General Data Protection Regulation (GDPR)-compliant data breach process ensuring timely response, transparency, and accountability. When a breach is identified, the team assesses impact... takes immediate mitigation actions and reports to authorities and affected individuals within 72 hours when required" (p.102).

Four channels are named (p.102): the designated privacy email serving as the contact point for the DPO; direct contact options at each studio; the whistleblowing portal, allowing anonymous reporting; and contact details for IMY, the Swedish Data Protection Authority.

Protection of minors: "Age classifications are determined through the International Age Rating Coalition (IARC) and platform-specific frameworks used by Google Play and the Apple App Store" (p.102). Studios are exploring "Apple's Declared Age Range API and Google's Age Signals API", but "MTG has not yet introduced additional group-wide measures or formal processes to assess the effectiveness of age restrictions". Where titles include "paid random items (PRI), such as card packs, chests or crates", studios disclose "the odds of receiving specific items" (p.103).

Awareness is not measured: "MTG does not measure user's awareness of or trust in the reporting channels" (p.102).

Taking action on material impacts on consumers and end-users

Reference: pages 103-104.

"Material actual or potential negative impacts on consumers and end-users are identified through the double materiality assessment, incident reporting, user feedback, moderation data and monitoring of regulatory developments" (p.103).

Data protection actions are the structured half: a framework complying with the GDPR and UK GDPR, with "Data Protection Impact Assessment (DPIAs) and Legitimate Interest Assessments (LIAs) and embedding Privacy by Design into our product development, marketing and other processing activities" (p.103). Where risks arise, "actions may include changes to consent flows, minimization of data collection, strengthened access controls, updates to privacy notices, or technical safeguards".

The other three material S4 impacts have no action plans, and MTG states this plainly: "At this stage, MTG has not adopted separate formalised action plans specifically linked to the material impacts related to player well-being, chat safety or advertising exposure beyond the operational safeguards described above and in S4-3" (p.103).

Resources: "These actions are financed through ordinary operating budgets and are not linked to specific sustainable finance instruments" (p.104). "No severe human-rights violations or data breaches were reported during the reporting period" (p.104).

Targets related to consumers and end-users

Reference: page 104.

MTG discloses one group-wide S4 target, and it is a training input measure rather than an outcome measure for any of the four material S4 IROs (p.104):

The same measure carries a 5% weighting in the executive incentive plan (p.65), which makes it the only sustainability measure linked to remuneration anywhere in the group.

Stakeholder involvement is absent: "Consumers and end-users are not currently involved in setting targets, tracking performance, or identifying improvements" (p.104). No target addresses player exposure to advertisement, player well-being and game design, or player safety in chat forums.

Business conduct policies and corporate culture

Reference: pages 105-106. The datapoint table marks "ESRS G1-1 United Nations Convention against Corruption paragraph 10 (b)" Material at p.105 and "Protection of whistle-blowers paragraph 10 (d)" Material at p.106 (p.112).

"MTG have a robust Governance Framework that sets clear expectations for ethical behavior and responsible business practices. This framework includes our Anti-Corruption Policy, Code of Conduct, and Whistleblower Policy" (p.105).

On the UN Convention against Corruption, MTG declines to go further: "Following our materiality assessment, we do not consider a broader framework aligned with the UN Convention against Corruption to be relevant for our operations and have no plans to implement one" (p.105).

The Anti-Corruption Policy "covers eight different areas of corruption, including bribery, conflict of interest and nepotism. It is publicly available", and the General Counsel owns it (p.105).

Whistleblowing: reports "are managed by a specially appointed, impartial group, and individuals have the option to report incidents anonymously" (p.106). "There were 3 cases reported to the Whistleblower channel in 2025", and "Material cases are escalated to the Audit Committee".

Training coverage is incomplete: anti-corruption training "was provided to selected studios in 2025 and will be rolled out group-wide from 2026, with integrated onboarding and trackable completion rates" (p.106).

Targets related to business conduct

Back-filled from the ESRS 2 governance section and the G1 chapter, where targets and effectiveness tracking 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.

One quantified governance target is disclosed, under the heading "Sustainability governance targets": "Our goal is to ensure strong sustainability governance throughout MTG's various companies and operations. To get further towards this objective, our target is to increase our S&P Global Corporate Sustainability Assessment (CSA) by 20 points by 2027. At the end of 2025, our rating was 32" (p.65). The target originated in investor dialogue (p.70).

No target attaches to corruption, bribery or corporate culture. Consistent with the other limb of MDR-T, effectiveness is tracked in the absence of one: whistleblower cases are counted, at "3 cases reported to the Whistleblower channel in 2025", with material cases escalated to the Audit Committee (p.106); anti-corruption training moves to a measurable basis in 2026 "with integrated onboarding and trackable completion rates" (p.106); and for cybersecurity, "Annual cybersecurity maturity assessments are conducted across all studios to evaluate capabilities, identify gaps, and benchmark progress" (p.107).