Neste

Governance roles

Reference: pages 87-88 (content index page 141).

The Board of Directors "is in charge of sustainability matters of major significance to the Neste Group including ... the approval of the long-term ambition and targets, adoption of Neste's statutory sustainability reports and reviewing the sustainability performance" and "has the ultimate responsibility for sustainability matters and risk oversight of Neste" (page 87). The Audit Committee "monitors and supervises the statutory sustainability reporting process including the related controls, the assurance of the sustainability report and risk management" (page 87). Sustainability is represented on the Neste Leadership Team through the EVP, People & Culture (page 88).

The Shareholders' Nomination Board "pays attention to achieving a good and balanced gender distribution and diversity", taking account of the Finnish Companies Act goal of at least 40% of the under-represented gender. "Neste's Board does not include employee representatives" (page 87).

Information provided to the administrative bodies

Reference: page 88 (content index page 141).

"Neste's Board of Directors reviews the sustainability performance at least once a year. Other sustainability topics are also regularly reviewed by the Board. Risks are reported to the Board of Directors at least two times a year as a part of strategy and performance planning processes." Material sustainability risks are presented to the Audit Committee in connection with the risk reviews, and "The Audit Committee supervised the statutory sustainability reporting process throughout the year" (page 88).

Matters actually addressed in 2025 (page 88):

• April 2025 - the Board reviewed the results of Neste's double materiality assessment.
• February 2025 - the Board decided to revise the timeline for the transformation of the Porvoo refinery from crude oil refining into a renewable and circular solutions refining hub; short-term focus moves to energy efficiency and renewable hydrogen "while other components of the plan are considered to be delayed".
• December 2025 - the Board "decided to revise some of Neste's climate targets ... to reflect current financial position and the phased transformation of the Porvoo refinery".
• The annual strategy meeting covered "the impact of climate and ESG-related regulation on Neste's business".
• "Safety is addressed by the Board at every meeting."
• The Board "reviewed and approved the Modern Slavery Statement 2025".

Sustainability performance in incentive schemes

Reference: page 88 (content index page 141).

"Neste's Remuneration Policy aligns remuneration with the successful delivery of its long-term strategic and sustainability goals." The Board decides the remuneration of the President and CEO and the Neste Leadership Team and the long- and short-term incentive plans; the Personnel and Remuneration Committee drafts remuneration proposals (page 88).

Climate metrics in long-term incentives (LTIs):

• "In 2025, the main performance metric is renewable fuels sales volume with the weight of 60% of the total plan. It is linked to Neste's climate targets related to carbon handprint, with customers replacing fossil fuel with renewable fuels produced by Neste."
• "Combined Greenhouse Impact represents 20% of LTI in the Performance Share Plan 2023-2025 and 2024-2026 and includes greenhouse gas emission reductions achieved with Neste renewable products by customers and GHG emissions from Neste production."

Safety metrics in short-term incentives (STIs): "measures related to the improvement in both process and personnel safety constitute at least 10% of the short-term incentives' measures in 2025."

The report does not disclose the proportion of variable remuneration that is sustainability-linked at individual executive level.

Statement on due diligence

Reference: page 140 (content index page 141; Appendix B page 143 maps ESRS 2 GOV-4 paragraph 30 to page 140).

The statement is presented in the Appendixes as a mapping table of the five core elements of due diligence to the sections where each is disclosed (page 140):

The table cross-refers rather than restating the due diligence process. The substantive process is set out under S2 ("Neste conducts ongoing human rights due diligence across its operations and value chains to identify, prevent, mitigate, and, where necessary, remediate risks of forced and child labour", page 131) and under G1 supplier due diligence (pages 137-138).

Risk management and internal controls over sustainability reporting

Reference: pages 88-89 (content index page 141).

Risks identified and mitigations (page 89):

• Risks are prioritised "based on their potential impact on the reliability of its reporting, considering factors such as data materiality, process complexity and potential for human error".
• Neste discloses a live weakness: "The company continues to mature in its sustainability reporting processes and systems, however some data collection and input still rely on manual processes. Risks identified include accuracy and completeness of the data."
• Mitigations are "clearly defined roles and responsibilities for data collection and reporting, and a common reporting guideline provided in Neste manual for CSRD reporting", plus "reconciliation controls and review controls for quantitative and qualitative sustainability data".
• "Internal Control function monitors the control performance and assesses control adequacy. Deficiencies are promptly reported to responsible parties for corrective action, with appropriate escalation to management and the Audit Committee."

The report does not state the periodicity of Board reporting on internal control findings specific to sustainability data.

Strategy, business model and value chain

Reference: pages 89-90 (content index page 141).

Three business areas: Renewable Products, Oil Products and Marketing & Services, providing "renewable and fossil fuels for transportation, aviation, marine and other industrial uses, as well as renewable and circular solutions for the polymers and chemicals industries" (page 89). Renewable fuels are made in Finland, the Netherlands and Singapore plus the Martinez, California joint operation; oil products at Porvoo. In 2025 "the company's major crude oil and fossil raw material sources were Norway, the US and the Netherlands".

"Neste has no revenue from coal and taxonomy-aligned economic activities related to fossil gas." Significant CapEx for oil-related activities was 97 MEUR (2024: 387) and for gas-related activities 0 (page 90).

Interests and views of stakeholders

Reference: pages 94-95 (content index page 141).

"Neste aims for continuous dialog with its stakeholders and regularly seeks external views on its activities across the value chain. The company's key stakeholders include those who the business can influence as well as those that have the opportunity to influence Neste" (page 94).

Ten groups are tabulated with purpose, engagement mechanism and how outcomes are used (pages 94-95), from suppliers and value chain workers to employees, customers, consumers, local communities, NGOs, capital markets, media, universities, policymakers and industry associations. Examples:

• Suppliers and value chain workers - "Monitoring and auditing supplier sustainability, incl. worker interviews, worker voice surveys" and site-level grievance channels for contracted and subcontracted workers, feeding into readiness for the Corporate Sustainability Due Diligence Directive (page 94).
• Employees - engagement surveys, works councils and wellbeing discussions, with "Follow-up actions agreed based on employee engagement surveys" (page 94).

A Stakeholder Advisory Panel, including members of the Parliament of Finland, "ensures that the management and supervisory bodies are kept informed about stakeholders' views" (page 94). In the DMA, "Stakeholders' views were indirectly taken into account" (page 93).

Material impacts, risks and opportunities

Reference: pages 90-92 (content index page 141; also cited under E1, E4, S1 and S2).

By standard: E1 climate 10 (1 positive impact, 2 negative impacts, 3 risks, 4 opportunities); E2 pollution 1 (substances of concern); E4 biodiversity 4; E5 resource use 3; S1 own workforce 3 (health and safety only); S2 value chain workers 1 (forced labour); G1 business conduct 3.

Interaction with strategy (page 90): "Neste believes that by executing its strategy and acting in line with its Sustainability and Safety visions and its Code of Conduct, the company's strategy and business model have resilience towards identified material impacts, risks and opportunities."

Financial effects in 2025 (page 91): "Of the regulatory changes that materially impacted Neste in 2025, a key one was the change in US federal fuel incentive tax credits to support local producers, replacing the previous incentive to support local blenders. The change narrowed eligibility only to Neste's joint operation in the US and affected Neste's financial performance in 2025. None of the other environmental risks and opportunities alone are considered to have had a material impact on 2025 financial position, financial performance and cash flows."

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

Processes to identify and assess material IROs

Reference: pages 92-93 (content index page 141).

"The disclosed sustainability information is based on Neste's double materiality assessment which is reviewed annually ... The phases ... are the same as in 2024 and the assessment built on the previous year's results" (page 92).

Four phases (pages 92-93): value chain mapping ("There have not been material changes in the value chain mapping since 2024"); impact assessment, with each impact characterised and linked to ESRS sub-topics using Neste's internal horizons of "short 1 year, medium 1-3 years, and long 3+ years"; financial assessment, where "Magnitude was considered as estimated annual impact on operating profit; for risks, worst case annual impact while for opportunities a best case approach was applied"; and scoring, determination and validation, where "Threshold for impacts considers that both severity and likelihood need to be high for impact to be deemed material".

An override is disclosed: "Topics, which did not exceed the set materiality threshold but are seen as central for Neste's strategy and core values, or hold importance due to external stakeholder interest and strong industry relevance, are deemed material based on a separate management decision" (page 93).

The Leadership Team and Board reviewed the outcomes, and Neste "has defined internal controls to ensure the fulfillment of relevant requirements" in the assessment (page 93).

Disclosure requirements covered

Reference: pages 141-145 (index itself listed at pages 141-145).

Neste prints a full ESRS content index headed "Disclosure Requirements in ESRS covered by Neste's Sustainability statement" (page 141), plus the Appendix B list of datapoints deriving from other EU legislation (pages 143-145).

Indexed disclosure requirements: ESRS 2 BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2; E1-1 to E1-6 and E1-8; E2-1, E2-2, E2-3, E2-5; E4-1 to E4-5; E5-1 to E5-4; S1-1 to S1-6, S1-8, S1-9, S1-10, S1-11, S1-14, S1-17; S2-1 to S2-5; G1-1, G1-2 (pages 141-142).

Not indexed: E1-7, E1-9, E2-4, E2-6, E4-6, E5-5, E5-6, S1-7, S1-12, S1-13, S1-15, S1-16, G1-3, G1-4, G1-5, G1-6 and all of E3, S3 and S4.

The Appendix B legend explains the three exclusion labels used there: "i) 'Not material' based on the results of the double materiality assessment, ii) 'Not disclosed', if the disclosure requirement is phased in based on the provision in Appendix C of ESRS 1, or iii) 'Not applicable' if the disclosure requirement is not relevant for Neste's business" (page 143).

Transition plan for climate change mitigation

Reference: pages 89-90, 104, 106-109 (content index page 141).

Neste states plainly that it has no ESRS transition plan: "Neste does not have a separate climate transition plan as detailed in the ESRS but its targets, actions, resource plans and internal carbon price are intended to support the transition and climate change mitigation. Neste will evaluate developing a dedicated climate transition plan in line with emerging sustainability and due diligence regulations and evolving regulatory expectations" (page 106).

Governance: "All Neste's strategic plans are governed by the Board of Directors, including actions and related investments needed to meet Neste's climate targets" (page 106). The Board revised the climate targets in December 2025 (page 88).

Paris-aligned benchmarks: "Neste is excluded from the EU Paris-aligned Benchmarks (PABs), as the company derives revenue from the refining of fossil fuels" (page 106).

1.5C alignment is expressly not claimed: "While Neste's current near-term targets are not aligned with the 1.5°C pathways, Neste believes they remain broadly consistent with the Paris Agreement's goal to limit global warming to well below 2°C ... In the near term, reductions will be made at a financially viable pace" (page 107).

No locked-in emissions assessment is disclosed anywhere in the statement.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 climate DMA section, where this content is disclosed in the FY2025 report (pages 104-105). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risk classification (page 104): "Neste has identified three material transition risks related to climate change mitigation ... No material physical climate risks were identified in the double materiality assessment." Physical risks were screened in the TCFD work but none were deemed material.

The scenario analysis was conducted in 2024, focused on transition risks, and was not refreshed in 2025 (page 104).

Scenarios and indicative financial impact (pages 104-105):

• Net Zero World 2050, "in line with the 1.5°C pathways", on the IEA Net Zero 2050 Scenario - positive
• Net Zero EU and North America by 2050, "consistent with a 2°C trajectory", on the IEA Announced Pledges Scenario - base case
• Compromised Climate Targets, "global warming of 2.5°C to 3°C or more by the end of the century", partly on IEA Stated Policies - slightly negative

"These pathways cover concentration pathways similar to RCP 6.0, RCP 4.5 and RCP 2.6" (page 104). No high-emission physical-risk scenario such as RCP8.5 is named. Assets at risk: the Porvoo refinery and oil refining business in Finland (page 104).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the E1 resilience subsection, where this content is disclosed in the FY2025 report (pages 90, 104-105). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Neste states that it has performed no ESRS-defined climate resilience analysis. "Neste does not conduct a separate climate resilience analysis" (page 104), and again under the heading Resilience analysis: "While Neste does not conduct a separate climate resilience analysis as defined in ESRS E1, the identified climate-related impacts, risks and opportunities are indirectly considered in strategic planning" (page 105).

Uncertainty (page 104): "Uncertainties related to the scenario analysis include the pace and scope of regulatory changes, technological advancements, market dynamics, the varying impacts of climate change across geographies and industries, as well as the use of national or regional data."

The scenario table's indicative financial impacts (positive under Net Zero World 2050, base case under the 2°C scenario, slightly negative under Compromised Climate Targets, page 105) are the closest the statement comes to a quantified resilience result. No financial resilience quantification, no dated analysis and no time-horizon-by-horizon adjustment capacity are given.

Policies related to climate change mitigation and adaptation

Reference: pages 96, 105-106 (content index page 141).

Neste addresses material climate IROs through the Sustainability Policy, Sustainability Principle, Environmental Management Principle, Supplier Code of Conduct and Operations Excellence Policy, plus the Code of Conduct, which "sets out the company's commitment to reduce its GHG emissions, reach its climate targets and use energy-efficient solutions in its operations" (page 105). The policy-to-topic mapping table on page 96 confirms which instruments cover E1.

Sustainability Principle (page 105): "It covers Neste's approach to climate change mitigation and climate change adaptation and sets out Neste's ambition in relation to renewable energy and energy efficiency."

Value chain reach: "The Supplier Code of Conduct defines the minimum climate requirements for the company's suppliers and business partners. Neste's suppliers are expected to, at a minimum, consider the climate impact of their operations and undertake greenhouse gas reduction measures where reasonable" (pages 105-106).

Energy efficiency: "Ensuring the energy efficiency of investment projects is included in the Environmental Compliance Analysis, which is executed for all major investment projects when building new production capacity or increasing current capacity" (page 106).

Actions and resources in relation to climate change policies

Reference: pages 108-109 (content index page 141).

Actions are presented as a lever table with implementation status and the target each serves (page 108):

Expected outcome: "reduced scope 1 and 2 GHG emissions (reduction potential estimated to be ~2.8 MtCO2e from 2019 by 2040)" (page 108).

Resources (page 109): actions "are expected to require significant (>50 MEUR) operational and/or capital expenditures", with 2025 amounts folded into EU taxonomy CapEx-plan reporting. Taxonomy-aligned CapEx was 786 MEUR, 63% of the 1,253 MEUR total (page 100). No lever-by-lever tonnage is given.

Targets related to climate change mitigation and adaptation

Reference: pages 106-107 (content index page 141).

The Scope 1 and 2 target was revised in 2025: Neste set "a greenhouse gas emission reduction target of 80% by 2040 compared to 2019, replacing the target of reaching carbon neutral production by 2035. The interim targets ... are 24% reduction by 2030 and 50% reduction by 2035. With this revision Neste ... removes the option of using emission compensation from its climate target setting" (page 106).

Progress against the 2019 baseline halved because "scope 1 and 2 emissions were temporarily lower in 2024 due to a turnaround at Neste's Porvoo refinery" (page 107). No SBTi validation is claimed. "Neste does not have separate measurable, time-bound and outcome-oriented targets in place for IROs related to climate change adaptation nor upstream IROs related to climate change mitigation" (page 107).

Energy consumption and mix

Reference: pages 110, 112 (content index page 141).

Coal and other fossil fuel consumption were both zero. Energy intensity in high-climate-impact sectors was 713 MWh/MEUR of net revenue (2024: 595). The renewable share fell from 20% to 15% while nuclear rose to 5% and total consumption rose 10.5%, consistent with Porvoo returning to normal operation after the 2024 turnaround (pages 107, 110).

"Data coverage is estimated to be > 99 %" (page 112).

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 111-113 (content index page 141).

Scope 3 by category (page 111): 1 purchased goods and services 5,070,000; 3 fuel and energy-related activities 90,000; 4 upstream transportation 670,000; 5 waste generated in operations 30,000; 9 downstream transportation 590,000; 11 use of sold products 42,240,000; 12 end-of-life treatment of sold products 1,110,000; 15 investments 1,790,000. Use of sold products is 82% of Scope 3 and 77% of the total footprint.

Intensity (page 111): total GHG per net revenue 2,878 tCO2eq/MEUR location-based and 2,875 market-based (2024: 2,871 and 2,868). Absolute emissions fell 7.6% year on year but intensity was flat, because revenue fell in step.

"Energy and climate metrics described above have not been validated separately by an external third party" beyond certification and emissions-trading validation of some underlying data (page 113).

Internal carbon pricing

Reference: page 109 (content index page 141).

"Neste applies an internal carbon price for its scope 1 and 2 GHG emissions in investment calculations, business case evaluations and in strategic planning. The internal shadow price for carbon is utilized globally, across Neste's business areas and functions" (page 109).

Price and type: "Neste's internal carbon price is 100 EUR/tCO2e and remains unchanged compared to 2024." It is explicitly a shadow price, not an internal fee or trading scheme.

Stated limitation: "Neste internal carbon price does not cover scope 3 GHG emissions" (page 109). That is a material boundary, since Scope 3 was 51,590,000 tCO2eq, roughly 94% of Neste's total footprint in 2025 (page 111).

The carbon price is also named as one of the instruments standing in for a formal transition plan: targets, actions, resource plans "and internal carbon price are intended to support the transition and climate change mitigation" (page 106), and climate targets are "considered in financial planning and resource allocation, for example, through the use of internal carbon price" (page 107). The volume or share of emissions covered by the price, and the resulting effect on investment decisions, are not quantified.

Policies related to pollution

Reference: pages 96, 114-115 (content index page 141).

Legal basis (page 114): "The requirements of the Principle are based on legal requirements applicable to Neste's operations, including the REACH and CLP Regulations in the EU, the TSCA in the US, the Workplace Safety and Health Act in Singapore, and international agreements like the ILO Chemical Convention." Availability is internal only, via the Neste Management System, monitored through OEMS audit procedures.

Environmental Management Principle (pages 114-115): it "concerns the management of material impacts related to substances of concern by requiring that production sites evaluate presence and current or earlier use of substances of very high concern (SVHCs) and establish a program for risk management, control or removal and proper handling." It applies to all Neste owned and operated production sites and terminals, Neste operated logistics, Marketing & Services and other operations. "The implementation of the Principle is done through a dedicated program during 2025-2027 and furthermore, monitored through internal audits and monthly environmental compliance reporting" (page 115). A description of key contents is public; the Principle itself is internal.

Actions and resources related to pollution

Reference: page 115 (content index page 141).

Two action areas are tabulated with 2025 activity and planned activity (page 115):

Environmental management and compliance - "Neste follows up environmental compliance utilizing site-specific leading and lagging environmental indicators." In 2025 "key actions focused on implementing the updated Environmental Management Principle. Implementation actions were determined through a detailed site-specific gap analysis." Planned: "The implementation of the Environmental Management Principle continues until 2027."

Expected outcomes (page 115): "Neste expects its products to continue complying with product and chemical safety requirements, while also minimizing chemical compliance or safety incidents", tracked "through continuous monitoring of incidents of non-compliance concerning the health and safety requirements of products".

Resources (page 115): "Implementation of actions related to substances of concern are covered by e.g., process safety investments under prioritized maintenance operational or capital expenditures ... Actions related to compliance with regulatory requirements for product and chemical safety are business-as-usual activities that did not require dedicated significant (> 50 MEUR) financial resources during the reporting year, and are not expected to require such resources in the future."

No separate pollution CapEx or OpEx figure is disclosed.

Targets related to pollution

Reference: page 115 (content index page 141).

This is the MDR-T alternative limb: effectiveness tracking in the absence of a target.

The entity-specific KPI (page 115):

How the KPI is defined (page 116): "Incident of non-compliance concerning the health and safety requirements of products (entity-specific KPI) is an incident involving non-compliance with regulations resulting in a fine, penalty or warning ... The metric is based on the definitions in GRI indicator 416-2. The KPI has not been validated separately by an external third party."

The policy anchor is compliance-based rather than reduction-based: "Neste complies with requirements for product and chemical safety, as described in the Operations Excellency Policy and Product and Chemical Safety principle, to address impacts associated with substances of concern in its supply chain and products" (page 115). No substitution target, no reduction trajectory for substances of concern volumes, and no target year are given.

Substances of concern and substances of very high concern

Reference: page 116 (content index page 141).

Neste answers both limbs of ESRS E2 paragraph 34 (page 116):

Substances of very high concern are a nil return: "None of the chemicals Neste supplies as feedstock or manufactures is listed in the SVHC list by ECHA." Many petroleum products are in CLP Annex VI for health effects such as carcinogenicity, which is why the environmental column is near zero (page 116).

Emissions: "reported pollutants are carbon monoxide (over 95% of total reported SoC emissions), benzene, hydrogen cyanide and vinyl chloride". Neste discloses a limitation: "The total NMVOC of oil refineries is calculated as total carbon and the exact composition has not been reported" (page 116).

Transition plan on biodiversity and ecosystems

Reference: pages 117-118 (content index page 141).

Neste's material biodiversity IROs sit entirely upstream: "Neste's material biodiversity-related impacts arise from activities in the upstream value chain. No material biodiversity-related impacts on biodiversity-sensitive areas have been identified for Neste sites" (page 117).

Strategic direction disclosed in place of a formal ESRS transition plan (page 117): "The key strategic choices by Neste that address material impacts, risks and opportunities related to biodiversity are the focus on renewable and circular solutions and reducing reliance on fossil fuels. Neste continues to work toward increasing the availability of renewable and recycled raw materials, while developing technologies to diversify its current portfolio with new scalable raw materials. These actions support the company's resilience to biodiversity and ecosystems-related risks. Neste is also addressing its material biodiversity risks and impacts through landscape initiatives. These projects aim, among other things, to prevent deforestation, develop sustainability awareness and drive structural change to promote forest conservation in Neste's renewable raw material supply chain."

The vision target is "to drive a positive impact on biodiversity and achieve a nature positive value chain by 2040" (page 90), but it carries no interim milestones or dated plan.

Policies related to biodiversity and ecosystems

Reference: pages 96, 118 (content index page 141; Appendix B maps paragraphs 24(b), 24(c) and 24(d) to page 118).

Deforestation (paragraph 24(d)): "The Responsible Sourcing Principle prohibits sourcing from areas where feedstock production has adversely affected land use and habitat conversion of forested areas, wetlands, grasslands, and other natural ecosystems. Neste encourages any future development of biomass production to take place on degraded lands, or lands where cultivation increases the carbon stock of those areas" (page 118). The Principle "also contains requirements on community land rights and food security, sustainable land practices, direct impact drivers of biodiversity and impacts on ecosystem services, the extent and condition of ecosystems and the state of species".

Sustainable oceans and seas (paragraph 24(c)) - a stated gap: "Neste does not have a specific policy covering sustainable oceans practices in its value chain, but the Supplier Code of Conduct addresses environmental impacts, including impacts on oceans" (page 118).

All renewable raw material suppliers "are approved in accordance with the Supplier Sustainability Approval Principle, which outlines requirements relevant for the protection of biodiversity, such as the traceability of renewable raw materials" (page 118).

Actions and resources related to biodiversity and ecosystems

Reference: page 119 (content index page 141).

Scope (page 119): "Scope of actions is in the upstream value chain, especially focusing on sourcing of renewable raw materials. Thus far, Neste's actions for biodiversity have predominantly concentrated on avoiding impacts on land, water, and pollution, which have not necessitated the incorporation of local or indigenous knowledge, nor the encompassing of nature-based solutions."

Action areas tabulated (page 119):

Supplier route (page 119): "Neste conducts a sustainability review of all new crude oil suppliers with the aim to reduce impacts to the environment and ensure suppliers have sufficient environmental policies and practices in place, with a focus on crude oil production-specific issues."

Resources (page 119): "Implementation of the actions reported above did not require significant (> 50 MEUR) financial resources during the reporting year, and is not expected to require such resources in the future."

The Siak and Pelalawan Landscape Programme in Indonesia is described under the processes section, where "Participatory community consultations to map remaining forests strengthened community-led forest protection and initiated community-based mangrove protection at selected villages" (page 118).

Targets related to biodiversity and ecosystems

Reference: page 118 (content index page 141).

Neste discloses no measurable biodiversity target and states so: "Neste does not have separate measurable, time-bound and outcome-oriented targets specific to upstream material biodiversity impacts, risks and opportunities. Neste tracks the effectiveness of policies and actions through other relevant metrics and key performance indicators. These include for example, KPIs under the E1 Climate change and G1 Business conduct sections of this report, which focus on the reduced reliance on fossil resources and implementing environmental requirements within the supply chain, respectively" (page 118).

This is the MDR-T alternative limb: effectiveness tracked through proxy indicators rather than a biodiversity target. The proxies named are the E1 carbon handprint and Scope 1, 2 and 3 targets (pages 106-107) and the G1 Supplier Code of Conduct coverage KPI, which reached 100% of renewable and recycled raw material volumes and 93% of crude oil and fossil raw material volumes in 2025 (page 137).

The corporate sustainability vision states an aim "to drive a positive impact on biodiversity and achieve a nature positive value chain by 2040" (page 90), but that ambition is not carried into the E4 targets section as a measurable, baselined target, and no base year, interim milestone or unit of measure is given for it.

Impact metrics related to biodiversity and ecosystems change

Reference: page 119 (content index page 141).

No quantitative biodiversity impact metric is given: no land-use change figure, no hectares under conservation or restoration beyond the descriptive site facts, and no species or ecosystem condition indicator.

The quantitative and locational facts that are disclosed sit under E4-1 (page 117): a 3-hectare protected forest area out of 300 hectares of Neste land at Naantali; biodiversity baseline inventories at Porvoo and Naantali between 2022 and 2023 that identified "some vulnerable species and habitats"; and, from the 2025 assessment of biodiversity-sensitive areas, "three nature conservation areas or protected sites located within 2 km from Neste's production sites in Finland (Porvoo) and in The Netherlands (Rotterdam and Sluiskil)". Neste also states that "Material negative impacts in Neste's value chain are not related to land degradation, desertification and soil sealing" (page 117).

Appendix B position (page 144): the E4-related datapoint "ESRS 2- IRO 1 - E4 paragraph 16 (a) i" is marked "Not material", while paragraphs 16(b) and 16(c) are mapped to page 117.

The forward plan is stated under E4-3: Neste "plans to further assess prioritized raw materials critical for biodiversity and natural ecosystems, and continue to develop metrics and indicators to monitor biodiversity mitigation actions" (page 119).

Policies related to resource use and circular economy

Reference: pages 96, 120 (content index page 142).

The material E5 IROs are all upstream: the negative impact that "Use of virgin raw materials leads to depletion of finite resources", a raw material availability and price volatility risk, and a circular economy opportunity (page 120).

Responsible Sourcing Principle (page 120): "Neste expects its suppliers to have the same commitment to promote positive impacts and to prevent habitat conversion throughout its supply chain. Neste works to prevent deforestation, habitat conversion, and other social and environment negative impacts. The Responsible Sourcing Principle is aligned with relevant regulatory requirements, such as the EU RED and the US Renewable Fuels Standard (RFS), and the UN Guiding Principles on Business and Human Rights."

Own-operations waste (page 120): "All sites operated by Neste are responsible for understanding and managing their environmental impacts and aspects, including issues related to waste generation. Waste in Neste's own operations is handled by contracted third parties locally. Neste follows the local waste legislation in its operations and continuously seeks new opportunities to minimize the waste sent to landfill and find new waste recovery solutions."

Monitoring runs through the sustainability due diligence described under G1 (page 120). No circular-economy policy targeting resource outflows or product design is disclosed.

Actions and resources related to resource use and circular economy

Reference: page 121 (content index page 142).

Scope (page 121): "To align with the material impacts, risks and opportunities identified, the scope of the actions is especially focused on the company's upstream value chain and the use of renewable, particularly waste and residue, and recycled raw materials."

Continuous development in supplier relationships (page 121): "Neste works to eliminate deforestation, habitat conversion, and other social and environmental negative impacts", with the detail cross-referred to S2 and G1. Planned: "Neste will continue developing its supplier due diligence in accordance with upcoming regulations, such as the Corporate Sustainability Due Diligence Directive."

Resources (page 121): "Implementation of the actions listed above as well as the related actions under E1 Climate Change section are expected to require significant (>50 MEUR) financial resources. Implementation of these actions may be subject to individual investment decisions and depend on various factors, including external drivers such as market development and supportive policy environment."

Note the year-on-year direction: technology and innovation expenditure fell from EUR 86 million in 2024 to EUR 63 million in 2025 (page 121).

Targets related to resource use and circular economy

Reference: page 121 (content index page 142).

Neste discloses no measurable circular economy target and states so: "Neste does not have separate measurable, time-bound and outcome-oriented targets in place for the material impacts, risks and opportunities related to resource use and circular economy. Neste tracks the effectiveness of policies and actions through other relevant metrics and key performance indicators, which include for example, the Supplier Code of Conduct KPI as introduced under the G1 Business conduct section of this report" (page 121).

Direction of travel without a target (page 121): "To address the material impacts, risks and opportunities related to resource use and circular economy, Neste continues to strengthen and expand its raw materials portfolio and global sourcing capabilities."

No target is set for the share of renewable or recycled feedstock, for secondary material content, for waste diverted from landfill, or for resource intensity, even though the E5 metrics table reports biological materials at 24% of total inflows in 2025 (down from 25% in 2024) and secondary reused or recycled materials at 5,000 tonnes, rounding to 0% of the 17,190,000 tonne total (page 122). The absence of a target sits against a material negative impact that Neste itself describes as "Use of virgin raw materials leads to depletion of finite resources" and marks as new in 2025 (pages 92, 120).

Resource inflows

Reference: page 122 (content index page 142).

What the metric covers (page 122): "Total weight of renewable and fossil raw materials used in production, including co-processed volumes; Purchased hydrogen used in production; Natural gas used in production; Recycled (liquefied waste plastic) raw materials used for production; Ethanol used in production; Purchased propane used in production; Raw materials used for blending."

Total inflows rose 12.5% year on year while the biological share fell one percentage point to 24%, so absolute fossil inflows grew. Secondary materials more than doubled in absolute terms, from 2,000 to 5,000 tonnes, but remain below 0.03% of the total and round to 0%.

Neste does not disaggregate inflows by the ESRS categories of biological materials sustainably sourced, and does not report the share of reused or recycled components separately from secondary intermediary products.

Policies related to own workforce

Reference: pages 96, 123-124 (content index page 142; Appendix B maps paragraphs 20, 21, 22 to page 124 and paragraph 23 to page 123).

Human rights commitments (paragraphs 20-22, page 124): the Human Rights Principle commits Neste to "implementing, and acting in accordance with, the United Nations Guiding Principles on Business and Human Rights (UNGPs) and OECD Guidelines for Multinational Enterprises", and to the International Bill of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work. It "explicitly addresses trafficking in human beings, forced labour or compulsory labour and child labour. It also specifically addresses discrimination and harassment ... The Human Rights Principle prohibits discrimination on the basis of any grounds, including for example, gender, race, color, ethnic origin, nationality, age, pregnancy, sexual orientation, gender identity, disability, religion or political opinion."

Consultation (page 124): "Major updates to the Human Rights Principle typically include consultation with both internal and external stakeholders ... Neste seeks recommendations for improvements for example from recognized topic experts, such as human rights NGOs, government representatives and trade union experts."

The People Policy is available as a public summary; the Human Rights Principle is publicly available in full; OEMS Principles and Standards are internal (pages 123-124).

Processes for engaging with own workers

Reference: page 124 (content index page 142).

"Continuous engagement and communication ensure that employees at Neste are informed and consulted. Neste conducts global employee engagement surveys annually to understand how the company's operations impact its employees and to identify expectations for improvement. These surveys gather direct input from employees on topics such as engagement, strategy, leadership, wellbeing and safety" (page 124).

How outputs are used: "Employee surveys are used to integrate feedback into decision-making and concrete action plans at every team level. Agreed actions are communicated and monitored across the organization to develop engagement and ways of working. The effectiveness of these actions is assessed, for example, through the employee engagement scores in the next survey cycles" (page 124).

Worker representation: "At the local level, employee cooperation follows the specific legal and collective-agreement requirements in each country of operation ... Neste maintains established cooperation bodies in its main operating countries, including Finland, the Netherlands and Singapore. In 2025, a European Works Council (EWC) was established following collaborative negotiations with employee representatives from European countries. The agreement will become effective in March 2026" (page 124).

The report does not disclose engagement survey participation rates or scores.

Processes to remediate negative impacts and channels to raise concerns

Reference: page 125 (content index page 142; Appendix B maps paragraph 32(c) to pages 125 and 134-135).

Grievance channel (page 125): "Neste provides mechanisms for employees to raise concerns or grievances without fear of retaliation and is committed to handling issues fairly, confidentially and promptly ... Adverse impacts are remediated by providing and promoting access to grievance mechanisms and complaints channels, and by cooperating in the remediation of the adverse impacts that Neste has caused or contributed to." The mechanism itself is Ethics Online, described under G1: externally operated, available 24/7 in multiple languages, usable anonymously by phone or web, with reports handled by the Neste Investigation Group (pages 132, 135). "Neste has a strict non-retaliation policy for concerns reported in good faith", and the internal Misconduct Investigation Standard "is aligned with the Directive (EU) on the protection of persons who report breaches of Union law (2019/1937)" (page 135).

Awareness and trust of the channel is assessed indirectly: "To assess the effectiveness of Neste's reporting channels, the number of reports submitted through the channels is followed regularly. Neste may seek feedback from its employees on the channels, for example, through employee engagement surveys" (page 135).

Taking action on material impacts on own workforce

Reference: page 126 (content index page 142).

Three action areas are tabulated with 2025 activity (page 126):

Continual improvement of OEMS maturity - "In 2025, Neste initiated a five-year Process Safety Improvement Program to make impactful and sustainable improvements in process safety group-wide." Planned: "executing Process Safety Improvement Program according to workstream goals and objectives."

Investments prioritized to improve safety and reduce risk - "Incorporating safety into projects such as investments, change initiatives, and turnarounds remained Neste's focus in 2025 ... strengthening safety protocols, improving hazard identification and risk assessment processes are part of these actions." These are continuous.

Scope and effectiveness (page 126): "The initiatives are focused on Neste's own workforce, with some additional initiatives aimed at contractors and value chain workers. The effectiveness of the safety processes at Neste is followed through regular monitoring of the safety performance in the organization and OEMS audits in Neste's own operations." Neste also states that "it is ensured that the practices do not cause or contribute to any further impacts on Neste's own workforce".

The safety vision was updated in 2025 to "Creating safety together", emphasising "the actions, skills, expertise and safeguards needed to maintain safe and reliable operations every day" (page 123).

Targets related to own workforce

Reference: page 125 (content index page 142).

Governance of the targets: "Neste's safety performance and performance in targets is monitored monthly, including at Neste Leadership Team and at every Board of Directors meeting. Process and personnel safety targets are part of Neste's short-term incentives" (page 125).

Worker involvement: "Neste engages in a dialog with its employees to share the safety vision through, for example, 'I Act Safe' workshops. Neste incorporates changes, including changing safety targets, tracking performance and identifying lessons or improvements as a result of performance" (page 125).

TRIF and PSER are entity-specific in part: "Key performance indicators on total fatalities and total recordable injuries (TRIF) are in accordance with ESRS metrics, while Process Safety Event (PSER) is an entity-specific KPI" (page 125). No target is set for any non-safety S1 sub-topic, since none was found material.

Characteristics of Neste's employees

Reference: pages 127, 129 (content index page 142).

By region (2025): Europe 3,719, Americas 778, Asia-Pacific 439. By main country (2025): Finland 2,947 (2024: 3,439), United States 771 (870), the Netherlands 555 (511), Singapore 406 (451), others 257 (303) (page 127).

Turnover: 1,125 employees left in 2025 (2024: 1,184), a turnover rate of 22.8% (2024: 21.2%) (page 127).

Headcount fell 11.4% year on year. Neste attributes it directly: "The total headcount compared to previous year has decreased due to organizational change and related change negotiations" (page 129), and notes that "Organizational restructuring in 2025 impacts comparability of headcount" (page 128).

One US footnote qualifies the non-guaranteed hours category: "Based on local legislation, no contractual obligation exists to offer the employees specified under this group a minimum or fixed number of working hours ... However, in practice, employees specified under this group have typically worked full-time hours in 2025" (page 127).

Collective bargaining coverage and social dialogue

Reference: pages 127, 129 (content index page 142).

"Neste recognizes and respects the employees' rights to organize freely and bargain collectively. In 2025, 71% (2024: 65%) of Neste employees globally were covered by collective bargaining agreements" (page 127). The 2024 figure carries a caveat: "2024 figure not fully comparable as reporting approach was updated to align with the ESRS in 2025" (page 127).

Coverage bands disclosed (page 127):

Social dialogue mechanisms: cooperation bodies exist in Finland, the Netherlands and Singapore, and "In 2025, a European Works Council (EWC) was established following collaborative negotiations with employee representatives from European countries. The agreement will become effective in March 2026" (page 124).

Neste also commits "to respecting the internationally recognized human and labor rights and ensuring fair terms of employment for all employees, as set out in Neste's Code of Conduct and Human Rights Principle" (page 127). The report does not disclose whether non-EEA employees not covered by collective agreements are covered by workers' representatives instead.

Diversity metrics

Reference: pages 128, 129 (content index page 142).

Female representation in top management fell from 33.3% to 28.3%, and the top management population itself fell from 93 to 46 people. Neste flags the comparability issue: "Organizational restructuring in 2025 impacts comparability of headcount" (page 128).

Definition (page 129): "Top management at Neste includes members of the Neste Leadership Team, members of the Business Area or Function Leadership Teams and the President and CEO of Neste's subsidiary Mahoney Environmental Solutions."

For the workforce as a whole, women were 1,476 of 4,936 employees, 29.9%, against 1,744 of 5,574, 31.3%, in 2024 (page 127, ratio not printed by Neste). At Board level, female representation rose to 36.1% from 30.7% (page 88).

The metrics were not separately assured: "The metrics related to the own workforce described above have not been validated separately by an external third party" (page 129). No diversity target is set, since diversity is not among Neste's material S1 sub-topics; the only material own-workforce sub-topic is health and safety (page 123).

Adequate wages

Reference: page 128 (content index page 142).

The method is therefore a lowest-pay-category comparison against three permitted benchmark sources, covering all employees rather than a sample.

Corroborating work in the same year: among the four major human rights assessments completed in 2025, Neste lists "Living wage gap assessments completed for Neste's own employees globally" (page 133). The same exercise was run in 2024, so this is the second consecutive year of a global living wage gap assessment.

Value chain reach: adequate wages for own employees does not extend to value chain workers, but living wages are among the topics that Neste's audiovisual worker voice surveys cover: the surveys "provide direct insights from value chain workers on a range of topics including but not limited to indicators of forced labor, recruitment fees, children's rights, living wages, inequality, living standards, and issues impacting vulnerable groups" (page 131). Neste's sustainability vision includes 2030 goals "on responsible recruitment, living wages, children's rights, and reducing inequality" (page 133).

The report does not state the number of employees in the lowest pay category, the size of any margin above benchmark, or which countries were closest to the benchmark. Adequate wages is not one of Neste's material S1 sub-topics; the disclosure appears because the datapoint is required, and no target is attached to it.

Social protection

Reference: page 128 (content index page 142).

"Neste's commitment to social protection is included in its Human Rights Principle. Employees in all Neste operating countries are covered by social protection for sickness, unemployment, injury, disability, parental leave and retirement, through public programs or benefits offered by Neste" (page 128).

Year-on-year change: "Compared to 2024, employees in Singapore are now covered by social protection for unemployment through a public program" (page 128), which closes a gap that existed in the prior year.

Review cadence: "The coverage of social protection is assessed annually, if any changes occur in the countries where Neste has employees or in the applicable public programs and employee benefits providing social protection" (page 128).

The disclosure covers all six ESRS-listed major life events and identifies both the source of coverage (public programmes or Neste benefits) and the sole partial exception by country. It does not state how many employees are affected by the Indian unemployment qualifying period, and it does not break coverage down by country beyond the India and Singapore points. Social protection is not among Neste's material S1 sub-topics, which cover working conditions: health and safety only (page 123), so no target or action is attached to this metric.

Health and safety metrics

Reference: pages 128, 129 (content index page 142; Appendix B maps paragraph 88(b) and (c) to page 128).

One datapoint is phased in: the Appendix B table marks "ESRS S1-14 Number of days lost to injuries, accidents, fatalities or illness paragraph 88 (e)" as "Not disclosed", the label the legend reserves for a "disclosure requirement ... phased in based on the provision in Appendix C of ESRS 1" (pages 143-144). No days-lost figure is therefore given.

Contractor hours are partly estimated: "When recording the working hours of contractors, an estimate (e.g. accounting hours) can be used if the accurate number of hours is not known" (page 129). "The metrics related to the own workforce described above have not been validated separately by an external third party" (page 129).

Incidents, complaints and severe human rights impacts

Reference: pages 128, 129 (content index page 142; Appendix B maps paragraph 103(a) and 104(a) to page 128).

Fines and remediation (page 128): "Neste has not paid significant fines, penalties or compensation for damages related to the remediation of the reported incidents or complaints related to its own workforce in 2025."

Channel and process: reports reach the Investigation Group in person or through Ethics Online, the externally operated system available 24/7 and anonymously (pages 128, 132, 135). Across all categories, 25 suspected misconducts were reported group-wide in 2025 (2024: 57), of which misconduct was confirmed in 4 cases relating to conflict of interest, misuse of sensitive information, breach of internal rules or inappropriate behaviour, with one investigation pending (page 136).

Comparability caveat (page 129): "Neste reports the number of suspected misconducts reported in person or via the available reporting channels including Ethics Online to the Investigation Group ... As the reporting approach for the disclosure has been defined during the reporting year, comparative information is not presented."

The disclosure reports incidents raised and confirmed rather than the number of complaints resolved or the outcomes for complainants, and it does not state whether any of the four discrimination reports resulted in process changes.

Policies related to value chain workers

Reference: pages 96, 130 (content index page 142; Appendix B maps paragraphs 17, 18 and 19 to pages 130-131).

The single material S2 impact is forced labour: "Workers in Neste's upstream supply chains for wastes and residues and third-party workers at Neste refineries may face risks of forced labor ... Based on the assessments, these forced labor risks are systemic, pre-existing structural issues, and not caused through Neste's business model or strategy" (page 130).

Responsible Sourcing Principle (page 130): it "sets out additional requirements for all Neste's renewable raw material suppliers ... includes Neste's commitment to respect the human rights of all workers and communities in its supply base."

Communication (page 130): policies are made "available on Neste's public website in various languages, implementing mandatory e-learnings on policies for Neste employees, and providing training workshops for contractors, suppliers and sub-suppliers."

Neste names its highest-risk contexts explicitly: "the palm oil sector in Southeast Asia is identified as being particularly high risk", and "construction and maintenance projects at its refineries in Singapore, Rotterdam and Porvoo" (page 130).

Processes for engaging with value chain workers

Reference: page 131 (content index page 142).

"Neste seeks to engage with potentially affected groups early on and before decisions are made, not only when a decision is imminent or a situation is already escalating. When assessing human rights risks, the company pays special attention to vulnerable groups such as women, children, migrant workers and Indigenous peoples" (page 131).

Four named channels (page 131):

• Audiovisual worker voice technology - anonymous mobile surveys "easily accessible for illiterate workers", in mother-tongue languages, functioning "even in remote regions without internet access", covering "indicators of forced labor, recruitment fees, children's rights, living wages, inequality, living standards".
• Sustainability audits - "one-on-one interviews with different employee groups, including management, workers with different job profiles, third-party employees and, when possible, union or worker's committee representatives".
• Engagement with third-party workers on Neste sites - "site-entry-permit inductions and social toolbox meetings", with materials in the languages most spoken by migrant workers.

Effectiveness "is primarily assessed through direct worker feedback and ongoing monitoring of the number and quality of responses" (page 131). No number of workers reached is given.

Processes to remediate negative impacts and channels for value chain workers

Reference: pages 131-132 (content index page 142).

"Neste has established a comprehensive grievance ecosystem ... designed to facilitate the raising, assessment, and resolution of grievances across all its operations and value chains, in accordance with the UN Guiding Principles on Business and Human Rights" (page 132).

Channels open to value chain workers (page 132):

• Ethics Online - "available 24/7 and is accessible in multiple languages. Reports can be made anonymously via phone or web service, and can be made by anyone, including value chain workers."
• Site-level complaints channels at refineries - "accessible via both suggestion boxes and QR codes on posters discreetly placed around the sites", managed by local committees.
• A public grievance log for renewable raw materials supply chains, "updated on a monthly basis to include new grievances, provide status updates on the remediation of existing grievances, and track the effectiveness of the remedial actions taken".

Remediation steps run from impartial investigation and immediate action, through "Requiring a detailed plan with a timeline for corrective actions from the supplier", to "Ending purchases if Neste does not see adequate progress" (page 132). Neste explains why exit is last: "ending purchases does not resolve problems or provide access to remedy for affected rights holders".

Taking action on material impacts on value chain workers

Reference: page 133 (content index page 142; Appendix B maps paragraph 36 to page 132).

Two action areas are tabulated with 2025 activity (page 133):

Human rights saliency assessment - "Annual saliency assessment to evaluate actual and potential human rights impacts along the value chain, based on severity and likelihood. As part of the assessment, Neste also evaluates the effectiveness of current prevention and mitigation actions." In 2025 it was "reviewed and updated ... based on information gathered through discussions with internal and external experts, findings from sustainability audits, third-party human rights and labor assessments in Neste's supply chains, topics raised through Neste's grievance channels, and other ongoing human rights due diligence activities."

Resources (page 133): "Implementation of the actions reported above did not require significant (> 50 MEUR) financial resources during the reporting year, and is not expected to require such resources in the future."

Related supplier-side actions sit under G1: 36 sustainability audits conducted in 2025, 100% of new renewable raw material suppliers and 100% of new fossil raw material suppliers evaluated using sustainability criteria, and 83% of new recycled raw material suppliers (page 138). No number of identified forced labour cases or remediated workers is reported in the statement.

Targets related to value chain workers

Reference: page 133 (content index page 142).

Neste discloses no measurable, time-bound target and says so: "Neste does not have a separate measurable, time-bound target related to human rights-related issues in the value chain but does track the effectiveness of its policies and actions with e.g., an entity-specific Key Performance Indicator (KPI) of Human Rights Due Diligence carried out for key business areas/functions. The scope of the KPI is focused on Neste's upstream and own activities. The KPI has not been validated by an external third party" (page 133).

The KPI for 2025 - four major assessments (page 133):

• "Corporate-wide assessment to review Neste's salient human rights issues and mitigation actions."
• "Collaboration with third-party experts to conduct three on-the-ground human rights risk assessments, focused on salient issues in Neste's high risk supply chains."
• "Human rights due diligence maturity assessments completed for Neste's offices, owned pre-treatment facilities, and ground transportation."
• "Living wage gap assessments completed for Neste's own employees globally."

The ambition is that people across the value chain "work with dignity, guided by 2030 goals on responsible recruitment, living wages, children's rights, and reducing inequality" (page 133), but those goals carry no baseline or interim milestone, and the KPI counts assessments rather than outcomes for workers.

Business conduct policies and corporate culture

Reference: pages 96, 134-135 (content index page 142).

Code of Conduct (page 134): it "sets the framework for the company's global business operations. The Code of Conduct is approved by the Board and applies to the entire Neste Group." It references the UN Guiding Principles, the International Bill of Human Rights, the ILO Declaration and "the ten principles of the UN Global Compact". "All members of Neste Board of Directors have also completed the Code of Conduct e-learning."

Anti-Corruption Principle (page 134): "Neste has zero tolerance of corruption and bribery of any kind ... whether committed by Neste employees or third parties acting on behalf of Neste ... The principle is consistent with the United Nations Convention against Corruption."

Governance (page 134): the Compliance Function, headed by the Chief Compliance Officer, reports on compliance activities to the Leadership Team and Audit Committee.

Whistleblower protection (page 135): a strict "non-retaliation policy for concerns reported in good faith", with the Misconduct Investigation Standard "aligned with the Directive (EU) on the protection of persons who report breaches of Union law (2019/1937)".

Worth checking: Appendix B marks the G1-1 datapoints on the UN Convention against Corruption (10(b)) and protection of whistle-blowers (10(d)) as "Not applicable" (page 145), although pages 134-135 address both.

Management of relationships with suppliers

Reference: pages 136-139 (content index page 142).

Coverage KPI (page 137):

2025 activity (page 138): new renewable raw material suppliers evaluated using sustainability criteria 100%; new recycled raw material suppliers 83%; new fossil raw material suppliers 100%; 36 sustainability audits conducted. Neste "updated its country risk categorization" and "completed Sedex self-assessment questionnaires for its refineries in Porvoo, Rotterdam and Singapore".

Escalation (page 138): "If the sustainability criteria or contractual requirements included in contracts have been verifiably breached, their nature is considered serious, and progress to resolve those issues is not made in a reasonable time, Neste will terminate its contract with the supplier or contractor in question."

Resources (page 139): implementation "did not require significant (> 50 MEUR) financial resources during the reporting year". The KPIs and metrics "have not been validated by an external third party", and comparatives for the new-supplier evaluation metrics are not presented because the definitions changed (page 139).

Targets related to business conduct

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

Effectiveness indicators reported instead (pages 135, 137):

The supplier-side target statement carries the same shape: "Neste is committed to implement and sustain comprehensive sustainability due diligence across Neste's own operations and supply chains in line with Corporate Sustainability Due Diligence Directive (CSDDD) requirements. Specific targets in line with the European Sustainability Reporting Standard and the CSDDD requirements may be developed where relevant" (page 137).

The e-learning KPI is not comparable year on year: "As the topic of the e-learning varies annually, comparative information for the completion rate is not provided" (page 139).