Nokian Renkaat

The role of the administrative, management and supervisory bodies

Reference: pages 40-42 (ESRS content index, page 130).

Board composition. "At the end of 2025, there were seven non-executive members in the Board of Directors. There was no employee representation on the Board of Directors. The President and CEO was an executive director" (page 40). "At the end of 2025, the Board of Directors had four male (57.1%) and three female members (42.8%) and two different nationalities. The age range was between 49-64 years. The President and CEO was male and held Italian citizenship" (page 40). Counting the Board plus the President and CEO, the diversity table gives 37.5% female / 62.5% male, nationality Finnish 62.5% / German 25% / Italian 12.5%, and age over 50 years 87.5% (page 40).

Oversight structure. The People and Sustainability Committee (PSC) is "the highest body overseeing sustainability, including material impacts, risks and opportunities", approves the key sustainability targets and the group's key policies, and prepares sustainability topics for the Board (page 41). Below it sit the Group Management Team, a Sustainability Steering Group, a Greenhouse Gas Steering Group that "supervises and monitors the progress in reducing greenhouse gas emissions according to the climate transition plan", the SVP, Operations who "leads sustainability work", and the VP, Quality and Sustainability with five working groups (sustainability, safety management, environmental, energy efficiency, sustainable purchasing) (page 41).

Expertise. Board members bring "CEO experience, international experience especially in the Nordic, Central European and North American markets, tire industry, consumer goods industry, financing, corporate risk management, and corporate governance" (page 40).

Information provided to and sustainability matters addressed by the administrative, management and supervisory bodies

Reference: page 42 (ESRS content index, page 130).

The PSC's key responsibilities "include reviewing and preparing sustainability plans and results, monitoring the company's double materiality assessment, and ensuring the integrity of sustainability reporting through assurance processes". It also tracks regulatory developments, reviews relevant policies, and monitors "the effectiveness of the company's internal control and risk management systems regarding sustainability reporting" (page 42).

Frequency. "The Vice President, Quality and Sustainability reports sustainability matters to the PSC two to four times a year or as needed" (page 42).

What the Board addressed in 2025. "In 2025, the Board of Directors approved the results of the double materiality analysis and reviewed key impacts, risks, and opportunities. Updates of the planned and ongoing key sustainability actions were presented to them as well." "After the end of the reporting period, the Board of Directors approved Nokian Tyres' climate transition plan to address greenhouse gas emissions" (page 42).

Risk integration. "The Board of Directors and its Committees discuss the most significant sustainability risks and opportunities, risk appetite, and related measures in connection with the strategy process and decisions related to business objectives and major investments. Material sustainability-related risks presented to the Board of Directors during the 2025 strategy process were in line with the double materiality assessment results" (page 42).

Integration of sustainability-related performance in incentive schemes

Reference: page 42; supporting detail page 109 (ESRS content index, page 130).

The Remuneration Policy, approved at the 2024 Annual General Meeting, "outlines the compensation framework for both the Board of Directors and the President and CEO" and "links sustainability-related performance measurements with the company's incentive schemes" (page 42). The Board approves remuneration for the President and CEO and the Management Team.

The metric and its weight. "The company's main long-term incentive plan, the Performance Share Plan, uses performance criteria that include a sustainability-related goal. The reduction of Scope 1 and 2 carbon dioxide equivalent (CO2e) emissions carries 10 percent weight of the total of 100 percent target setting within long-term incentives" (page 42). Page 109 states the plan's three criteria as "average earnings per share (EPS), average return on capital employed (ROCE%), and reduction of Scope 1 and 2 CO2e emissions intensity", again at 10 percent weight.

Both share plans "were resumed in 2025, with the Performance Share Plan adjusted to a two-year performance period plus a one-year retention phase". A Restricted Share Plan is used for retention of the President and CEO, Management Team and selected key employees, and short-term incentives are "available to all employees" (page 109). No sustainability metric is disclosed as attaching to the short-term incentive.

Statement on due diligence

Reference: page 43 (ESRS content index, page 130; datapoint index page 134 marks ESRS 2 GOV-4 paragraph 30 as Material, page 43).

"Nokian Tyres' due diligence processes cover environmental and social responsibility as well as business conduct matters. The due diligence processes are aligned with regulations and the company's commitments to international frameworks, such as the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises" (page 43).

The mapping table on page 43 places each core element of due diligence:

The table adds that "Nokian Tyres' human rights and environmental experts have defined the company's due diligence process and oversee its integration across the company's operations", and that the company "engages with value chain workers during sustainability audits and through industry associations" (page 43).

Risk management and internal controls over sustainability reporting

Reference: page 43 (ESRS content index, page 130).

"Nokian Tyres' Enterprise Risk Management Policy provides a structured framework for managing risks related to sustainability reporting. At Nokian Tyres, a risk is defined as an uncertain event and its consequences, caused by an external or internal factors, which may be either a threat or an opportunity" (page 43).

Work done in 2025. "To ensure that Nokian Tyres' risk management and internal control framework is effective for sustainability reporting, the evaluation of the processes for all material areas of sustainability reporting continued in 2025. This included reassessment of existing controls and identification of additional controls within the processes. Based on the outcomes of the evaluation, data-owning functions improved internal processes and reporting practices" (page 43).

Main risk identified. "The main risks identified in sustainability reporting relate to the accuracy and completeness of certain metrics as the reporting is based on multiple data sources, including manual inputs and calculations" (page 43).

Mitigations. "Clearly defined roles and responsibilities, systematic data collection and reconciliations at critical reporting stages, segregation of duties, and both quantitative and qualitative data reviews by data owning functions, the Vice President, Quality and Sustainability, Sustainability Steering Group, and the People and Sustainability Committee" (page 43).

Two reporting errors from the prior year are disclosed and restated - hazard-class allocation under E2-5 and the count of recordable work-related ill health cases under S1-14 (page 39).

Strategy, business model and value chain

Reference: pages 44-46 (ESRS content index, page 130).

Business. Nokian Tyres makes winter, summer, all-weather and all-season passenger car tires plus "special tires, wheels and retreading materials for heavy-duty machinery, trucks and buses"; the Vianor chain provides tire and car services. "In 2025, Nokian Tyres' products were sold in 47 countries" and the company "employed 3,959 people, of which 2,659 in the Nordic countries, 579 in North America, and 721 in Central Europe" (page 44). Three business units: Passenger Car Tyres (more than half of net sales), Heavy Tyres, and Vianor.

Sites. Tire factories in Nokia (Finland), Oradea (Romania) and Dayton (US), a wheel factory in Nastola (Finland), test centres in Finland and Spain, and five Vianor retreading plants. "The factory in Romania is the world's first full-scale zero-CO2-emissions (Scope 1 & 2) tire factory" (page 45). "All factories are ISO 14001 and ISO 9001 certified, and the tire factories in Finland and the US are ISO 45001 certified" (page 45).

Value chain (page 45). Upstream: "over 3,700 suppliers worldwide, including more than 200 different raw material suppliers"; main raw material groups are synthetic rubber, fillers, chemicals, reinforcing materials and natural rubber. Downstream: distribution to the Nordics, Central Europe and North America, then end-of-life, where "the majority of a Nokian Tyres tire's carbon footprint is generated during its use".

Sustainability-related goals for significant product groups are listed on page 44, with 2025 outcomes: no SVHC in tires (achieved); renewable and recycled raw materials 28.3 percent against a 50 percent by 2030 target; 13 products in rolling resistance class A against at least 60 by 2028; LTIF 3.7 against a 1.5 target (not achieved).

Phase-in. Information on ESRS sectors (SBM-1 40 b and c) is omitted under the phase-in provisions (page 40).

Interests and views of stakeholders

Reference: pages 46-49 (ESRS content index, page 130).

"Nokian Tyres is committed to minimizing its negative impacts and maximizing its positive impacts on the economy, environment, and people... This is done by engaging stakeholders when conducting double materiality assessments. The feedback from stakeholders is taken into account in operational development and decision-making" (page 46).

Five stakeholder groups are tabulated on pages 46-48 with engagement channels, purpose, the topics each group prioritised in the DMA, and the connection to strategy:

• Employees - Drive! engagement survey, pulse surveys, safety and environmental observation systems, cooperation with employee representatives, whistleblowing channel. Top priorities: tire safety and quality, safety of employees, emission-reducing tire design (page 46).
• Customers (B2B) - day-to-day cooperation, customer experience surveys, materiality assessments. Priorities include "ethical and responsible company culture" and "respect for human rights in the supply chain" (page 47).
• Suppliers, business partners and subcontractors - supplier due diligence, assessments and audits, subcontractor cooperation on occupational safety. Priorities include "reduction and elimination of harmful chemicals" and "measures to prevent corruption, bribery and misconduct" (page 47).
• Investors, shareholders and Board members - investor meetings, stock exchange releases, General Meetings, Board meetings (page 48).
• Authorities, media, NGOs and industry associations - project cooperation, public consultations. Priorities include "minimization of tire and road wear particles", "traceability and transparency of raw materials" and "protection of biodiversity in the supply chain" (page 48).

"The prioritization of sustainability topics in different stakeholder groups was presented to the Management Team and to the Board of Directors in February 2024 together with the results of the double materiality analysis" (page 49). Consumers and end users "can also participate in materiality assessments through public links shared on the company's social media channels" (page 49).

Material impacts, risks and opportunities and their interaction with strategy and business model

Reference: pages 49-58; topic tables pages 50-57 (ESRS content index, page 130).

The IRO tables on pages 50-57 list 32 material IROs across eight topical standards, each with an explicit type label and value chain position:

"There were no changes to material IROs compared to the previous reporting period" (page 58).

Resilience. "Nokian Tyres' strategy implementation and business model are not critically dependent on individual customers or suppliers, and the company regularly maintains business continuity plans... As a conclusion, Nokian Tyres' strategy and business model are expected to adapt in relation to the material sustainability impacts and risks identified... For these reasons, Nokian Tyres has not conducted a more detailed analysis on the resilience of its strategy and business model in addressing individual material sustainability topics" (page 58).

Sustainability-linked funding. Part of external financing is sustainability-linked, with two KPIs on GHG emissions intensity (Scope 1 and 2, and Scope 3 from product use, both per production ton). "Failure to meet these KPIs would result in additional interest expenses to Nokian Tyres" (page 58).

Phase-in. Anticipated financial effects (SBM-3 48 e) are omitted under the phase-in provisions (page 40).

Description of the processes to identify and assess material impacts, risks and opportunities

Reference: pages 58-61 (ESRS content index, page 130).

"Nokian Tyres carried out a sustainability double materiality assessment according to the European Sustainability Reporting Standards' requirements for the first time during September 2023-February 2024. The assessment process consisted of a contextual analysis based on public and internal sources, stakeholder survey, internal assessment and working group meetings. The results were reviewed and validated by Nokian Tyres' Management Team, the Audit Committee, the People and Sustainability Committee, as well as the Board of Directors" (page 58).

Scoring. "The severity of the negative and positive effects (considering the scale, scope and, in the case of negative effects, also the irremediable character of the impact), the magnitude of the financial impact of the risks and opportunities, as well as the likelihood of their occurrence were each assessed on a scale of 1 to 5." "The median value of all the materiality scores was employed as the initial quantitative threshold", followed by qualitative adjustments in 2024 (pages 58-59).

2025 review. "In 2025, Nokian Tyres reviewed the double materiality analysis results. The review was based both on the criteria presented in EFRAG IG 1 Materiality Assessment Implementation Guidance and internal discussions... The review found that there were no changes to Nokian Tyres' material topics in 2025... The next review of material topics will take place in spring 2026, and a comprehensive assessment is planned for late 2026 to early 2027" (page 59).

Topic-specific screening limits, stated plainly. For pollution, "the assessment did not include screenings of site locations concerning Nokian Tyres' own operations and upstream and downstream value chain" (page 60). For biodiversity, "the assessment did not include the screening of site locations pertaining to Nokian Tyres' operations" (page 60). Same for resource use (page 61).

Water. "The topic of water and marine resources was assessed but not considered material. Water risk assessments for all current Nokian Tyres' production sites were conducted in 2023 using the WWF's water risks filters, and they are updated every three years... Nokian Tyres' water-related risks are minor and... the company does not operate in water-stressed areas" (page 60).

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

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Reference: page 61; the index itself on pages 130-133; EU-legislation datapoint index pages 134-139.

"The ESRS Disclosure Requirements covered by this Sustainability Statement are presented in the ESRS Content Index on pages 130-133. An index of datapoints deriving from other EU legislation is presented on pages 134-139" (page 61).

What the index lists. ESRS 2 in full (BP-1, BP-2, GOV-1 to GOV-5, SBM-1, SBM-2, SBM-3, IRO-1, IRO-2); E1 E1-1 to E1-6; E2 E2-1 to E2-5; E4 E4-1 to E4-4; E5 E5-1 to E5-5; S1 S1-1 to S1-11 and S1-13 to S1-17; S2 S2-1 to S2-5; S4 S4-1 to S4-5; G1 G1-1, G1-2, G1-5 and G1-6. E3 carries only a cross-reference to ESRS 2 IRO-1 (page 131). S3 does not appear.

Not listed, and why. E1-7 and the E5-5 waste datapoints are marked "Not material" in the EU-legislation index (pages 136-137). E1-9, E2-6, E4-6, E5-6 and S1-12 are omitted under phase-in (page 40); the datapoint index shows E1-9 as "Material / Phase-in" (page 136). G1-4's anti-corruption datapoints are marked "Not material" (page 139), consistent with the DMA finding that "business conduct was mainly evaluated through the risk of potentially occurring misconduct or violations and therefore, received a fairly low materiality score" (page 61).

Judgment applied. "When disclosing information related to material topics, experts used their judgment to decide on which information is necessary to provide the needed understanding to stakeholders... Actions that were deemed not to provide material information regarding the material topics were not disclosed" (page 61).

Additional non-material information (GRI, S&P Global CSA and local legislation) is flagged visually with a plus mark and gathered in a separate section on pages 140-141 (page 39).

Transition plan for climate change mitigation

Reference: pages 70-71; targets pages 73-75 (ESRS content index, page 130).

Timing. "Nokian Tyres adopted a transition plan for climate change mitigation in early 2026, after the end of the reporting period. The foundation of the plan was laid out in 2024 when the company's updated greenhouse gas emission reduction targets were approved by the Science Based Targets initiative and confirmed by Nokian Tyres' Board of Directors" (page 70). "The transition plan was approved by the Board of Directors in early 2026, and its implementation is ongoing" (page 71).

Levers (page 70). Operational process decarbonization at all factories, Vianor service centers and other relevant units; R&D and procurement efforts to decrease emissions from raw materials and tire use; supply chain and logistics decarbonization; switching to low-emission company vehicles. "In the long term, Nokian Tyres might also utilize high-quality carbon offsets for residual emissions."

Near-term actions (page 70). "In 2025, all energy used at the Romania factory was wind energy and thus from zero-CO2-emissions sources"; maximising zero-CO2 energy through self-generated solar, zero-CO2 electricity certificates and power purchase agreements; continued energy efficiency projects; "increasingly requiring suppliers to lower the CO2 footprint of their processes and products"; and the 50 percent renewable and recycled materials target by 2030.

Cost. "The plan does not include cost estimates, as there is significant uncertainty of expenses related to actions, in particular for those aimed at reducing Scope 3 emissions. As for Scope 1 and 2, additional expenses during the next five years are expected to be mostly related to reducing emissions from natural gas used at the factory in the US." "During 2025, direct investments and expenditures related to greenhouse gas emission reduction were not considered financially material in terms of overall investment and expenses" (page 70).

Locked-in emissions. "Nokian Tyres assesses that there are solutions available in the short or medium term for GHG emissions linked to the company assets. Hence there are no locked-in GHG emissions from the assets." For use of sold products, "the emissions from tire use are not included in the value chain emissions reduction targets scope, as the emissions are already accounted for in the overall emissions balance of vehicles" (page 70).

Paris-aligned benchmarks. "Nokian Tyres is not excluded from the EU Paris-aligned Benchmarks, as the Group is not involved in environmentally harmful practices as specified in Article 12 of the Commission delegated regulation (EU) 2020/1818" (page 71).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 (pages 58-60) and E1 SBM-3 (page 71), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification (adopted ESRS paragraph 15). The E1 IRO table (page 50) types "Increasing costs related to tire raw materials" and "Further environmental fees" as transition risks. Physical risk is addressed but not carried as a material IRO: "Extreme weather events disrupting the production and logistics supply chain were identified as an important physical risk. However, in the double materiality analysis it was identified as non-material" (page 59).

Methodology (paragraph 16). A four-step climate-related risk process runs over pages 59-60: mapping and identification integrated into enterprise risk management; strategic evaluation at group level covering "physical and transition risks... strategic risks, market effects, reputation risks, potential for goodwill, and strategic opportunities"; determining impact using "a ranking system that considers severity, likelihood of the risk occurring, and existing controls"; and responding. "The process for identifying and evaluating climate risk is the task of the specialized environmental and sustainability unit" (page 60).

Scenarios used (paragraph 17).

• Physical risk - "In the analysis of physical risks, the SSP scenarios SSP1-2.6 and SSP5-8.5 were used" (page 59), so at least one high-emission scenario is included.
• Transition risk - "two of the International Energy Agency's (IEA) climate related scenarios were used: The Announced Pledges Scenario (APS)... The Net Zero Emissions by 2050 (NZE) Scenario aims to limit global warming to 1.5 °C and assumes aggressive gains in energy efficiency and consumer behaviour changes" (page 59), so a 1.5 °C-aligned scenario is included.
• Time horizons - "short (< 2030), medium (2030-2040), and long term (2040-2050)" (page 59).
• Scope - the 2023 analysis covered specific assets: "flooding at the production facility in Romania and the warehouse in Germany, and tropical cyclones at the US locations" (page 59); the transition-side analysis "examined the resilience of the entire Nokian Tyres organization" (page 71).
• Results - "the financial impact of a single flood is low or medium. Only if several floods occurred at the same time, their combined financial impact would be high in the medium and long term... For cyclones, the financial impact is considered low during the short term and medium in the medium and long term" (page 59).
• When - "Nokian Tyres also conducted a scenario analysis in 2023"; the transition scenario work ran "between December 2023 and February 2024" (pages 59, 71). "As part of the process, risk assessments were conducted in 2025 to support the evaluation and to ensure that the IROs remain up to date. The assessment included a climate-related risk review" (page 59).

Gap. No global average temperature projection per scenario (paragraph 17 a iii) is stated for the SSP or IEA scenarios beyond the NZE 1.5 °C reference.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 (page 58) and E1 SBM-3 (page 71), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The company states it did not run a topic-level resilience analysis. "As a conclusion, Nokian Tyres' strategy and business model are expected to adapt in relation to the material sustainability impacts and risks identified, and the company is prepared to take advantage of material opportunities both in the short and long term. For these reasons, Nokian Tyres has not conducted a more detailed analysis on the resilience of its strategy and business model in addressing individual material sustainability topics" (page 58).

What was done instead. The 2023-2024 climate scenario analysis was framed as a resilience exercise: Nokian Tyres "carried out a scenario analysis between December 2023 and February 2024 to increase understanding of the resiliency of the company and how certain scenarios in the short (< 2030), medium (2030-2040), and long term (2040-2050) may impact the company financially moving forward. The scenario analysis examined the resilience of the entire Nokian Tyres organization" (page 71).

Results feeding the response (paragraph 19 a). "The results of the analysis of material transition risks showed that both price and availability of more renewable materials can be expected to be vulnerable... the likelihood of this risk affecting Nokian Tyres in the short term can be expected to be high, and medium in the medium and long term... the potential financial risk is considered high in the short term and medium in the medium and long term. To mitigate these risks, Nokian Tyres plans to keep investing in R&D regarding both natural rubber and other alternatives to fossil-based materials" (page 71). "The results also showed that carbon taxes are expected to rise significantly... the likelihood of carbon prices affecting the company in the short, medium and long term is considered high and thus has the potential to cause a medium financial impact. Nokian Tyres increases the use of non-fossil materials, which decreases the risk" (page 71).

Capacity to adjust (paragraph 19 c). "Nokian Tyres' strategy implementation and business model are not critically dependent on individual customers or suppliers, and the company regularly maintains business continuity plans. The Group has adopted a risk management policy, approved by the Board of Directors, which supports the achievement of strategic goals and ensures business continuity" (page 58). For physical risk, "Nokian Tyres has also invested in building design and insurances to mitigate such risks" (page 59).

Uncertainty (paragraph 19 b) is not disclosed as a discrete item.

Policies related to climate change mitigation and adaptation

Reference: page 72 (ESRS content index, page 130).

Four instruments carry the climate commitments:

• Code of Conduct - "Nokian Tyres' Code of Conduct states that the company is committed to reducing greenhouse gas emissions" (page 72).
• Environmental, Safety, and Quality Guideline - describes "Nokian Tyres' commitment to environmental responsibility, which includes but is not limited to reducing greenhouse gas emissions, improving energy efficiency, and preferring renewable energy. The guideline also pledges to set targets to reduce environmental impacts. The President and CEO is accountable for its implementation." It "received minor updates in 2025 based on customer needs" (page 72).
• Supplier Code of Conduct - "the supplier shall identify, monitor, manage, and reduce emissions to air from its operations. The supplier shall seek low carbon solutions, when possible" (page 72).
• Guideline for Sustainable Natural Rubber, Biodiversity and Deforestation (formerly the Sustainable Natural Rubber Policy) - natural rubber suppliers "are, for example, expected to manage their operations in a manner that minimizes and mitigates greenhouse gas emissions (including carbon emissions) and to actively seek for low carbon solutions". Updated in 2025 "to include more topics related to biodiversity, deforestation, and the EUDR" (page 72).

"The Senior Vice President of Operations in the Management Team is the most senior executive accountable for the implementation of the Supplier Code of Conduct and the Guideline for Sustainable Natural Rubber, Biodiversity and Deforestation. Both policies are available on the corporate website" (page 72).

SBTi history. "In May 2018, the company joined the Science Based Targets initiative (SBTi)... The company's science-based greenhouse gas emission reduction targets were published in May 2020, and Nokian Tyres was the first company in the tire industry to have its targets officially approved by the Science Based Targets initiative. In 2023 Nokian Tyres committed to setting targets to reach science-based net-zero greenhouse gas emissions by 2050. The SBTi approved Nokian Tyres' new and more ambitious emission reduction targets in 2024" (page 72).

No separate climate adaptation policy is disclosed; adaptation is handled through the risk process described under IRO-1 (pages 59-60).

Actions and resources in relation to climate change policies

Reference: page 72; supporting detail pages 70, 73 (ESRS content index, page 130).

Scope 2 certificates. "Nokian Tyres purchases zero-CO2e and renewable energy certificates for the factories in Finland and in the US and for Vianor. This approach will cover Scope 2 emissions for both the reporting year and future periods. The company estimates electricity use for both factories and assesses how these certificates reduce GHG emissions both now and in the future" (page 72).

Romania. "The factory in Romania is critical for achieving the GHG emission reduction targets, since it is a zero-CO2e-emissions (Scope 1 & 2) factory. Thus, emission reductions are significant when producing tires at the Romanian factory compared to production in Finland or in the US" (page 72). The 2025 factory table confirms the outcome: Romania Scope 1 = 0 tCO2e and Scope 2 market-based = 0 tCO2e (page 78).

Product-side action - rolling resistance. "When a tire rolls against the road surface, energy is lost mainly due to heat build-up; this is referred to as rolling resistance. The higher the rolling resistance is, the higher the fuel consumption and CO2 emissions will be... Tires with low rolling resistance may save more than 0.5 liters of fuel per 100 kilometers" (page 72). "The share of lower rolling resistance tires (class A, B, and C tires) manufactured by Nokian Tyres is over 90 percent... At the moment, class C is the most common fuel economy rating for Nokian Tyres' passenger car tires" (page 73). Three new products entered rolling resistance class A in 2025, taking the total to 13 (page 73).

Forward look. "In the coming years, Nokian Tyres will concentrate on actions that are defined in the transition plan" (page 72). Resources are not quantified: "During 2025, direct investments and expenditures related to greenhouse gas emission reduction were not considered financially material in terms of overall investment and expenses. The actions in 2025 were business-as-usual activities" (page 70).

Targets related to climate change mitigation and adaptation

Reference: pages 73-75; base-year data page 77 (ESRS content index, page 130).

"Nokian Tyres has four science-based emission reduction targets that are in line with the Paris Agreement. The Scope 1 and 2 targets are in line with the 1.5 degree pathway. The base year for the targets is 2022... The Science Based Targets initiative (SBTi) has validated the targets, and Nokian Tyres Board of Directors has confirmed them" (page 73).

Near-term, by 2030 (page 73):

• Absolute Scope 1 and 2 GHG emissions: reduce by 42 percent from the 2022 base year.
• Scope 3: reduce by 51.6 percent per ton of product purchased, covering "purchased goods and services (excluding emissions calculated by spend), and upstream transportation and distribution".

Long-term, by 2050 (page 73):

• Absolute Scope 1 and 2: reduce by 90 percent from 2022.
• Scope 3: reduce by 97 percent per ton of product purchased, covering purchased goods and services, capital goods, and upstream transportation and distribution.

Progress against base year (page 73):

The near-term Scope 3 intensity therefore remains above the 2022 base year.

Decarbonisation bridge charts (pages 74-75). For Scope 1 and 2 the chart runs from a 2022 baseline of 32,368 tCO2e, adds output growth to 2030, and applies three named levers - reducing emissions from natural gas used in the US, zero-CO2 energy sources and heating for Vianor, and zero-CO2 fuels instead of steam production in Finland - reaching 17,968 tCO2e of emissions after actions against a 2030 target of 18,773 tCO2e. For Scope 3 the chart runs from 3,840 kg CO2e per ton purchased to 1,857 after actions against a 1,859 target, with levers named as suppliers' actions for reducing CO2e, selecting materials with a smaller CO2 footprint, new innovations together with suppliers, improved resource use efficiency, and CO2 reduction from transportation.

"Nokian Tyres does not yet publish estimates of quantitative contributions of different actions for the years 2030 to 2050, as technologies evolve and are likely to affect selected actions from 2030 onward" (page 73).

Product target. "To reduce emissions from traffic, the company aims to have at least 60 products in the best rolling resistance A class by 2028"; 13 were in class A at the end of 2025, up from 10 in 2024 (page 73).

Energy consumption and mix

Reference: page 76 (ESRS content index, page 130).

"In 2025, 80.5 percent (66.3% in 2024) of all energy used in the tire factories was produced from renewable energy sources" (page 76).

Group energy consumption and mix, MWh (page 76):

By site, 2025 (page 76): tire factory Finland 202,450 MWh (98.1 percent renewable); tire factory Romania 47,063 MWh (100 percent renewable); tire factory US 109,914 MWh (60.4 percent fossil, driven by 66,376 MWh of natural gas); wheel factory Finland 10,277 MWh (46.5 percent nuclear); other 63,728 MWh.

Energy intensity (page 76). "Total energy consumption from activities in high climate impact sectors per net sales from activities in high climate impact sectors" was 315.5 MWh / EUR million in 2025 (294.6 in 2024), on net sales of EUR 1,373.6 million (1,289.8). All net sales fall in high climate impact sectors: NACE C22.11 "Manufacture of rubber and plastic products" for Nokian Tyres and G45.3 "Sale of motor vehicle parts and accessories" for Vianor.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 77-80 (ESRS content index, page 130).

"In 2025, GHG emissions from Nokian Tyres' factories represented 54 percent of its total GHG emissions... The tire factories' Scope 1 and 2 emissions intensity per ton of tires produced was 114 kg CO2e / ton of product" (page 77).

Emissions, tCO2e (page 77):

Scope 3 category 11, use of sold products, is 7,089,665 tCO2e, or roughly 89 percent of the total footprint; purchased goods and services is 682,506 and upstream transportation and distribution 72,538 (page 77). Total market-based emissions rose 4 percent year on year.

Restatement. "In 2025, the calculation of Scope 1 and 2 emissions improved, as some estimates were more precise due to better data availability. Therefore, the figures from 2022 and 2024 marked with an asterisk (*) have been restated. In the company's Sustainability Statement 2024 they were reported as follows (tCO2eq): Scope 1: 10,978 and 15,195 for 2022 and 2024, respectively; Scope 2 (location-based): 26,562 and 28,840; Scope 2 (market-based): 21,390 and 7,803" (page 77).

Methods. Scope 1 uses Defra factors and fleet management data; Scope 2 location-based uses IEA grid factors; market-based uses supplier factors where available, otherwise AIB residual mix, with Defra factors for district heating (page 77). Scope 3 primary-data shares are disclosed per category (pages 78-80): category 1 purchased goods and services 80 percent primary; category 3 and category 5 100 percent primary; category 4 upstream transport 40 percent; categories 2, 7, 11 and 12 fully secondary. Categories 6, 10, 13, 14 and 15 are excluded or not applicable with reasons given.

Intensity per net sales (page 78): 5,790.9 tCO2e / EUR million market-based (5,942.5 in 2024).

Biogenic emissions. "Biogenic emissions data is generally not available from suppliers, so Nokian Tyres is unable to report them comprehensively. The amount of biogenic emissions from the Finnish tire factory in Scope 2 was 43,388 tons CO2e (40,506 tons CO2e in 2024). Scope 2 data is not available from other sites or operations. For Scope 1 and 3, data is not available" (page 80).

Policies related to pollution

Reference: page 82 (ESRS content index, page 131).

Four instruments cover pollution:

• Code of Conduct - reflects "the company's commitment to continuously enhancing its products, functions, and production facilities to minimize environmental impact. This includes preventing pollution of the air, water, and soil and addressing environmental effects throughout Nokian Tyres' supply chain" (page 82).
• Environmental, Safety, and Quality Guideline - "the company aims for efficiency, zero errors, and zero accidents across all operations". "Responsible chemical management is a key part of this commitment, with efforts to reduce or phase out hazardous substances. Moreover, Nokian Tyres has emergency plans in place to control and mitigate impacts on people and the environment during unexpected situations. The President and CEO is the most senior executive accountable for the implementation of both the Code of Conduct and the Environmental, Safety, and Quality Guideline." Received "minor updates in 2025, consisting of small additions and wording adjustments based on customer needs" (page 82).
• Supplier Code of Conduct - suppliers must "minimize negative impacts on local and surrounding communities, adopt a precautionary approach to environmental challenges, and proactively prevent environmental incidents", comply with all relevant environmental laws and permits, and ensure "proper handling, storage, and disposal of chemicals". Suppliers "are required to prepare for and respond to emergencies such as fires, natural disasters, and chemical spills, with appropriate emergency plans, evacuation procedures, hazard detection equipment, training, and drills" (page 82).
• Guideline for Sustainable Natural Rubber, Biodiversity and Deforestation - "addresses pollution by committing to prevent air, water, and soil contamination", aligned with the GPSNR framework; updated in 2025 for biodiversity, deforestation and the EUDR (page 82).

"The Senior Vice President of Operations in the Management Team is the most senior executive accountable for the implementation of the Supplier Code of Conduct and the Guideline for Sustainable Natural Rubber, Biodiversity and Deforestation" (page 82).

Standards. "Nokian Tyres' Environmental, Safety, and Quality Guideline states that Nokian Tyres' operations are based on and fulfill the requirements of the ISO 14001 standard", and the three policies together carry the company's commitment to the ten principles of the UN Global Compact (page 82).

Actions and resources related to pollution

Reference: pages 82-84 (ESRS content index, page 131).

Governance of the work. "Environmental representatives and local working groups are dedicated to enhancing daily sustainability practices. Environmental experts handle practical coordination and training at the factories, covering areas such as chemical safety, emissions control, and waste management" (page 82). "Nokian Tyres documents the annual environmental impacts of its tire factories and reports them to local authorities, as required in each country. Feedback from, for example, affected communities and own workforce is recorded in the company's internal register, and corrective actions are taken when necessary" (pages 82-83).

Annual environmental programs. "The primary document guiding environmental protection efforts at Nokian Tyres is the Integrated Management System Manual. In collaboration with environmental experts, the Senior Manager of Sustainability prepares an annual environmental program that sets targets for the entire company. In addition, the program includes specific targets for each tire factory with regard to pollutants, such as volatile organic compounds (VOCs)" (page 83).

Dust, odour and VOC control. "The mixing equipment is equipped with effective ventilation and dust collection systems, and water cleaners achieve separation rates exceeding 99 percent." Dust emissions were "approximately 1.5 tons (1.5 tons in 2024) in the tire factory in Finland, 57.3 tons (58.5) in the tire factory in the US, and 23.5 kilograms in the tire factory in Romania" (page 83).

Chemical audits. "The target is that each year, two audits are conducted by chemical specialists at each tire factory, focusing on the use and storage of chemicals... The inspection is used to verify compliance with legislation... A report is drawn up on the inspection and the production departments define corrective actions for the deficiencies found" (page 83). "No auxiliary chemicals are used in Nokian Tyres' factories without a department-specific usage permit issued by the company's chemical control team" (page 83).

TRWP work. "The United Nations Economic Commission for Europe (UNECE) is developing a test method to measure tire abrasion. Nokian Tyres, as a full member of the European Tyre and Rim Technical Organisation (ETRTO), is actively involved in global standardization efforts... Tyres Europe (formerly ETRMA) launched the multi-sectorial TRWP Platform in July 2018 to build scientific knowledge and develop practical solutions for reducing environmental particle levels. Nokian Tyres actively contributes to this initiative" (page 83).

Supplier requirements. "Nokian Tyres requires all chemical suppliers to provide safety data sheets (SDS) that comply with current legislation before chemicals are purchased. These SDSs are registered in a database that is accessible to all employees" (page 84).

Targets related to pollution

Reference: pages 84-85 (ESRS content index, page 131).

Chemicals. "Nokian Tyres aims to avoid the use of carcinogenic or toxic chemicals or Substances of Very High Concern (SVHC) as defined by the EU's REACH regulation in tire production. The target is voluntary but monitored monthly and when approving new chemicals to be taken into use. In 2025, Nokian Tyres' tires once again did not contain any carcinogenic or SVHC chemicals" (page 84). "There is no specific target for other substances of concern" (page 84).

Chemical audits. "The ongoing target is to conduct two audits per year by chemical specialists at Nokian Tyres' tire factories... In 2025, these audits were completed in the factories in Finland and Romania, but not in the US" - recorded elsewhere in the report as "Partly achieved" (pages 38, 84).

Microplastics. "While no specific target exists for microplastics, the EU aims to reduce microplastic releases by 30 percent by 2030. Euro 7, a new emission standard implemented in July 2025, sets additional limits for particulate emissions from brakes and tire wear... Nokian Tyres is closely monitoring regulatory developments" (page 84).

VOC. "Nokian Tyres' ongoing air pollution target at its Finnish tire factory is to fulfill the requirements of the environmental permit. The target is mandatory, as the emissions of volatile organic compounds from the exhaust gases after the incineration plant may not exceed 20 mg C / m3... In 2025, the volume of VOC emissions was 1.5 mg C / m3 (1.5 in 2024) after the incinerator... Thus, the VOC-related goal was achieved" (page 84).

Two US enforcement events are disclosed. "In 2024, Nokian Tyres discovered that all VOCs were not accounted for in the established emissions factors and self-reported this error to the authorities. Recalculations showed that because of this error, the air permit limit had been exceeded since 2021, and in spring 2025, the company received a penalty of $5,700 for the violation." A separate Tennessee Department of Environment and Conservation inspection "resulted in a notice of violation and an associated civil penalty of $15,750" (pages 84-85). "In 2025, VOC emissions from the US factory were 37.5 tons, remaining under the permit limit" (page 84).

Particles and discharges. "For particle emissions from the Finnish factory, the target is a maximum of 5 mg/m3 after filters and droplet separators. At the US factory, the goal is that particle emissions are within the limits set by air permits. At the factory in Romania, the target is that particle emissions are within the environmental permit limits. All targets were achieved" (page 85). "In 2025, no such incidents occurred, and the ongoing goal is to prevent any accidental discharges from Nokian Tyres' factories into water or soil" (page 85).

Pollution of air, water and soil

Reference: page 85 (ESRS content index, page 131; datapoint index page 136 marks E2-4 paragraph 28 as Material, page 85).

Tire and road wear particles. "The friction between tires and the road, essential for driver safety, causes the abrasion of both surfaces. This friction generates particles, a combination of tire tread fragments and road surface elements, commonly classified as microplastics due to their size and composition. While it is not possible to measure microplastics directly, tire and road wear particles (TRWP) are a significant concern" (page 85).

The company states plainly why no abrasion figure is given: "Currently, it is not possible to report tire abrasion for new type-approved tires until 2028, as there is no valid and official method in place. However, measurement methods are under development at both the United Nations Economic Commission for Europe (UNECE) and ISO standardization levels" (page 85). The expected UNECE unit is "mg / km/t, which indicates the amount of tire emissions (in milligrams) per kilometer, per tire, normalized by the mass of the vehicle", applying to new C1 type approvals in 2028, all C1 tires by 2030, C2 in 2030 and 2032, and C3 in 2032 and 2034 (page 85).

Quantified emissions, 2025 (page 85):

E-PRTR. "Some of the HAPs may be on the Annex II of Regulation (EC) No 166/2006 list, but this has not been analyzed in detail" (page 85).

Water and soil. "Under normal operations, Nokian Tyres' production does not cause emissions to water or soil. However, emissions could occur during incidents, such as chemical spills... In 2025, no such incidents occurred" (page 85). NOx and SOx from the US factory are disclosed as additional, non-material information: NOx 3.6 t and SOx 0.1 t in 2025 (page 140).

Substances of concern and substances of very high concern

Reference: page 86 (ESRS content index, page 131).

Substances of very high concern. "Nokian Tyres does not use carcinogenic chemicals or Substances of Very High Concern (SVHC) as per the EU's REACH regulation as such in tire production. All Nokian Tyres' products also meet the EU REACH requirements concerning Polycyclic aromatic hydrocarbons (PAH). Nokian Tyres' products do not contain any conflict minerals" (page 86). This is a nil return for the SVHC limb, corroborated under SBM-1: "In 2025, Nokian Tyres' tires did not contain Substances of Very High Concern" (page 44).

Substances of concern - both limbs quantified (page 86), tonnes:

Both the inflow limb (generated, used or procured) and the outflow limb (leaving facilities, split by main hazard class) are reported.

Restatement. "There was a human error in 2024 reporting, as the amounts of chemicals were reported under wrong hazard classes, and one column in the table also had a wrong header. During 2025, the calculation method has also been improved to be more precise, as Nokian Tyres' chemical experts confirmed that due to the chemical reactions that take place during the vulcanization of tires, 100 percent of certain substances of concern turn into other substances. Thus, all data from 2024 has been restated" (page 86; see also page 39).

Transition plan on biodiversity and ecosystems

Reference: page 88 (ESRS content index, page 131).

Nokian Tyres does not present a biodiversity transition plan in the ESRS sense; it presents the dependency and the state of preparedness.

"As a tire manufacturer, Nokian Tyres purchases significant amounts of natural rubber, which is one of the main ingredients in tires and thus an integral part of the company's business. Nokian Tyres material biodiversity impacts are indirect, as they occur in the beginning of the value chain. There are biodiversity risks caused by deforestation and land use change that mainly come from cultivation of natural rubber" (page 88).

"Nokian Tyres is generally well prepared to address sustainability-related material impacts, risks, and opportunities, including those related to biodiversity. The company is preparing for the EU Regulation on Deforestation-free Products. A separate assessment of the resilience of the current business model and strategy to biodiversity and ecosystems-related physical, transition and systemic risks has not been conducted. Local and indigenous knowledge and nature-based solutions have been incorporated into the EUDR framework" (page 88).

The wider point is made under SBM-3 for the group as a whole: "Nokian Tyres has not conducted a more detailed analysis on the resilience of its strategy and business model in addressing individual material sustainability topics" (page 58).

Policies related to biodiversity and ecosystems

Reference: pages 88-89 (ESRS content index, page 131).

• Code of Conduct - commits the company "to continuously enhancing its products, functions, and production facilities to minimize environmental impact. This includes addressing environmental effects throughout Nokian Tyres' supply chain" (page 88).
• Environmental, Safety, and Quality Guideline - "Nokian Tyres is committed to preserving biodiversity as well as air and soil quality and to causing no deforestation in its own operations, and to setting targets to reduce environmental impacts." The President and CEO is accountable for its implementation (page 88).
• Supplier Code of Conduct - suppliers must show "continuous improvement in environmental performance, including understanding its impacts on biodiversity and, as relevant, act to safeguard biodiversity and surrounding ecosystems" (page 88).
• Guideline for Sustainable Natural Rubber, Biodiversity and Deforestation - aligned with the GPSNR policy framework, with eight components: "Commitment to legal compliance; Healthy functioning ecosystems; Respecting human rights; Community livelihoods; Increased production efficiency; Supply chain assessment and traceability; Monitoring and reporting, and Driving effective implementation of all these components" (page 89). Updated in 2025 "to include more topics related to biodiversity, deforestation, and the EUDR".

Scope and a stated gap. "Together these policies cover the biodiversity and ecosystem protection at operational sites owned, leased, or managed, and sustainable land practices. They also address deforestation, but they do not address the social consequences of biodiversity and ecosystems-related impacts" (page 89).

The EU-legislation datapoint index marks E4-2 sustainable land or agriculture practices (24 b) and policies to address deforestation (24 d) as Material at page 88, and sustainable oceans or seas practices (24 c) as Not material (page 137).

The SVP Operations "is the most senior executive accountable for the implementation of the Supplier Code of Conduct and the Guideline for Sustainable Natural Rubber, Biodiversity and Deforestation" (page 89).

Actions and resources related to biodiversity and ecosystems

Reference: page 89 (ESRS content index, page 131).

EUDR compliance is the principal action. "The EU regulation 2023/1115, also known as the 'Deforestation regulation' or 'EUDR', intends to stop deforestation linked to certain commodities... of which natural rubber is very relevant for Nokian Tyres as it is one of main ingredients of tires." Tires may not be placed on the market unless "they are deforestation-free; they have been produced in accordance with the relevant legislation of the country of production; and they are covered by a due diligence statement" (page 89).

"During the year, Nokian Tyres continued the work to ensure compliance with the EUDR regulation. The company communicated regularly with authorities, suppliers and customers and nominated an EUDR compliance officer. The regulation's application will start on December 30, 2026" (page 89).

"No biodiversity offsets were used in Nokian Tyres' action plans. Local and indigenous knowledge and nature-based solutions have been incorporated into the EUDR framework" (page 89).

Guayule research. "Guayule-based natural rubber is one of the active initiatives that Nokian Tyres has been working on for several years, targeting to find an alternative for the natural rubber that the company uses. As guayule originates from the desert, it can survive in very dry and poor soil conditions. It is a plant that does not exploit areas of any other vegetation or food production; on the contrary, it makes use of wastelands. Currently Nokian Tyres participates in the MIDAS research project that is related to the topic" (page 89).

Marine action. "To reduce the environmental burden of sea transport in its supply chain, Nokian Tyres gave the Baltic Sea Action Group (BSAG) a Baltic Sea commitment for the years 2023-2026... Nokian Tyres requires that the cargo ships under direct shipping company contracts discharge wastewaters in the reception facilities in Finnish ports... Ship Waste Action is one of the criteria influencing the selection of freight carriers in freight tenders" (page 89).

Supplier audits. "Nokian Tyres performs sustainability on-site audits at high sustainability risk suppliers' sites. During the audits it is evaluated, among other topics, whether the suppliers have performed biodiversity assessments in their own operations and in their supply chains. If any shortcomings are identified, Nokian Tyres requests mitigation actions from the suppliers" (page 88). No resources are quantified.

Targets related to biodiversity and ecosystems

Reference: pages 89-90 (ESRS content index, page 131).

The target. "Nokian Tyres mitigates and prevents negative impacts on biodiversity with the target that 100 percent of its natural rubber processor suppliers are either GPSNR members or signed Nokian Tyres sustainability commitment. This target serves as a mitigation and prevention measure for negative biodiversity impacts, because the GPSNR membership and signing Nokian Tyres sustainability commitment both mean that the natural rubber processor is committed to preserving biodiversity and operates in alignment with Nokian Tyres' policies" (page 89).

Its limits, stated by the company. "The target is not based on scientific evidence but instead focuses on confirming that suppliers follow the policies related to biodiversity impacts" (page 89). "No ecological thresholds were applied when setting the target, and Nokian Tyres did not use biodiversity offsets. Stakeholders were not directly involved in setting the target, but the GPSNR members comprise several different natural rubber stakeholders... Nokian Tyres has screened the EU's Biodiversity Strategy to inform its targets" (page 90).

2025 result. "In 2025, the target was achieved as the company maintained the level of 100 percent of the natural rubber processor suppliers either being GPSNR members or having signed Nokian Tyres sustainability commitment" (page 90). "As for impacts on nature, the primary step in Nokian Tyres' mitigation hierarchy is avoidance" (page 90).

Tracking effectiveness. "Nokian Tyres' sustainability audit model evaluates the suppliers' alignment with Nokian Tyres Guideline for Sustainable Natural Rubber, Biodiversity and Deforestation. The follow-up audits are performed every third year at high sustainability risk suppliers' sites. The audit model tracks the effectiveness of the company's Guideline" (page 90).

Traceability caveat. "Supply chain traceability remains a challenging topic in natural rubber supply chains globally. As Nokian Tyres does not own any plantations, the company needs to rely on its suppliers to trace the origins of the rubber" (page 90).

Policies related to resource use and circular economy

Reference: page 92 (ESRS content index, page 131).

Environmental, Safety, and Quality Guideline. It "states the company's promise to continuously improve the quality, safety and environmental sustainability of its products, services, and processes, considering the products' entire life cycle. To fulfill that promise, Nokian Tyres commits to environmental responsibility, which among other things includes consuming and managing resources sustainably and reducing waste. The company's President and CEO has approved the Environmental, Safety, and Quality Guideline and is accountable for its implementation" (page 92).

Waste hierarchy - a stated gap and a stated practice. "Even though waste is not a material topic, waste management is part of circular economy. Effective waste utilization reduces the need for virgin raw materials. Although Nokian Tyres' policies do not explicitly mention the waste hierarchy, the company's production processes adhere to it, supported by comprehensive training materials and a detailed waste flow diagram" (page 92).

The anchoring commitment. "Nokian Tyres is committed to increasing the share of renewable or recycled raw materials in its tires to 50 percent by 2030. Nokian Tyres' internal principles for environmental stewardship, safety, and quality - including chemical safety - are aligned with this target." "Furthermore, the company has introduced sustainability-related goal setting in the product lifecycle process, which covers work instructions for the new product development process" (page 92).

Other instruments. The Procurement Guideline, Supplier Code of Conduct and the Guideline for Sustainable Natural Rubber, Biodiversity and Deforestation apply, the last aligned with the GPSNR policy framework and updated in 2025. "In Nokian Tyres Management Team, the Senior Vice President, Operations is accountable for the implementation of the policy" (page 92).

Materials map (page 92). The policy section tabulates tire composition and named substitutes: synthetic rubber 23 percent (polymers from renewable sources, mass-balance approach, recycled rubber crumbs); natural rubber 22 percent (guayule); fillers 28 percent (recycled carbon black, renewable silica, forest industry side streams); reinforcement materials 15 percent (recycled steel, renewable or recycled textiles); chemicals 12 percent (renewable or recycled oil and resin).

Actions and resources related to resource use and circular economy

Reference: pages 93-94 (ESRS content index, page 131).

ISCC PLUS certification. "The factory in Finland obtained the International Sustainability and Carbon Certification (ISCC) PLUS in 2024 and the factory in Romania in 2025... Through the certification, Nokian Tyres is able to utilize ISCC PLUS-certified raw materials in its tires, which is an important step in reaching the long-term target of increasing the share of renewable or recycled raw materials in tires to 50 percent by 2030." "Nokian Tyres introduced the ISCC PLUS-certified raw materials in spring 2025 when new flagship products were launched. Nokian Tyres Seasonproof 2 contains up to 38 percent recycled and renewable raw materials, of which 2 percent are ISCC PLUS mass balance approach certified from bio-based, bio-circular and/or circular feedstock" (page 93).

Named material research programmes (page 93). Recycled carbon black - "Nokian Tyres has extensively researched the use of recycled carbon black in tire production. While securing and researching various grades of recycled carbon black has been challenging, more raw material providers have entered the market." Rice husk silica - "This bio-based silica offers a sustainable substitute for conventional, fossil-based silica, with comparable performance characteristics". UPM BioMotion RFF, and Reselo Rubber, "a completely renewable material made from birch bark sourced from the residue of the global pulp, paper, and plywood industry".

FUTUREPROOF. "Nokian Tyres launched the FUTUREPROOF research, development and innovation program in March 2025... funded by Business Finland. The program consists of four streams with the Sustainable Tire Lifecycle stream focusing on sustainable materials" (page 93). The company also participates in MIDAS, a Horizon Europe Innovation Action, and the VTT-led Bioboost co-innovation project.

Retreading. "A quality tire carcass can be retreaded two to four times, reducing tire costs by around 30 percent... producing a new truck tire generates approximately 220 kilograms of CO2e emissions, while retreading produces only about 40 kilograms. Furthermore, each retread saves 40 kilograms of rubber and 70 liters of oil per tire" (page 94).

Recycling. "In 2025, Nokian Tyres achieved a 94 percent (92% in 2024) recycling rate for the passenger car tires it sold." "Tire recycling in Finland has reached 100 percent... In mainland Europe, the recycling rate has been over 90 percent in recent years and in the US around 80 percent." "In Romania, Nokian Tyres joined Eco Anvelope S.A. in the beginning of 2026" (page 94).

Targets related to resource use and circular economy

Reference: page 94 (ESRS content index, page 131).

Materials target. "Nokian Tyres is committed to a voluntary target of increasing the share of renewable or recycled raw materials used in its tires to 50 percent by 2030. The company has systematically followed its roadmap toward these targets through monthly reporting. Key sustainability KPIs are reported to the Management Team" (page 94).

Progress at the end of 2025 is 28.3 percent (page 38), split under E5-4 into "the share of recycled materials was 2.9 percent (0.8%) and the share of renewable raw materials was 25.4 percent (24.2%) in the company's own-produced tires" (page 94).

Waste diversion target. "To further support circular economy, Nokian Tyres aims to ensure that 100 percent of tire production waste continues to be utilized, with zero production waste sent to landfill. This means that as a voluntary target that exceeds legal requirements, the company strives to divert all tire production waste away from landfills either through prevention, reuse, recycling, or recovery. In 2025, the target was again achieved" (page 94).

Supporting context: "The utilization rate of Nokian Tyres' production waste has been growing for years, and 2022 was the first year when 100 percent of the tire factories' production waste was utilized and thus there was no waste to landfill from tire production" (page 94). "Nokian Tyres' production units have action plans to reduce the amount of non-vulcanised scrap rubber and scrap tire generation. As the amounts of production waste are monitored daily, the action plans are updated when needed" (page 94).

No target is set for absolute resource inflows or outflows, and no target relates to circular product design beyond the materials share.

Resource inflows

Reference: page 94 (ESRS content index, page 131).

Total inflows. "In 2025, Nokian Tyres used a total of 158,979 tons (145,835 tons in 2024) of technical and biological materials. When reporting biological materials, Nokian Tyres refers to them as renewable materials" (page 94).

Recycled and renewable share. "Nokian Tyres' target of increasing the share of renewable and recycled raw materials to 50 percent by 2030 focuses on external renewable or recycled feedstock, and not internal waste. In 2025, the share of recycled materials was 2.9 percent (0.8%) and the share of renewable raw materials was 25.4 percent (24.2%) in the company's own-produced tires" (page 94), giving the 28.3 percent combined figure reported against the target (page 38).

Named material groups (page 92). Tires are approximately 23 percent synthetic rubber (from crude oil), 22 percent natural rubber, 28 percent fillers (silica, carbon black), 15 percent reinforcement materials (steel, textile) and 12 percent chemicals. "Tires are made from approximately a hundred different raw materials" (page 93).

Method. "Nokian Tyres uses direct measurements of the raw materials used in product manufacturing to accurately calculate data on resource inflows. Double counting is avoided by specified coding of each material" (page 94).

Declared omission. "Nokian Tyres has exercised the option to omit sensitive information concerning its manufacturing partners and specific datapoints 31 a and 31 c of the disclosure requirement E5-4" (BP-1, page 39).

Resource outflows

Reference: page 95 (ESRS content index, page 131).

Method and scope. "Nokian Tyres closely monitors resource outflows in order to calculate precise data on the key products and materials resulting from its production processes. Monitoring includes actively tracking production volumes by factory, in addition to any waste resulting from manufacturing processes. As a result, all outflow data has been sourced from direct measurements from the production units. All Nokian Tyres products - tires and retreading materials, disc wheel rims, and steel structures - are recyclable" (page 95).

Durability - why no comparison is given. "There is no source for industry average values related to mileage and other factors related to expected durability of products. A test method for measuring tire abrasion is currently being developed at both the United Nations Economic Commission for Europe (UNECE) and ISO standardization levels... Because it is not possible to compare the expected durability of Nokian Tyres products to the industry average for each product group, such comparisons are not reported" (page 95).

Repairability. "Punctures in tires' tread can be repaired under certain conditions, depending on damage location, its size, and the overall condition of the tire. However, tire safety must remain top priority... At the moment, a common rating system for assessing tire repairability does not exist" (page 95).

Remanufacturability. "With carefully developed and optimized tire retreading processes and materials, bus and truck tires can be given a second, a third, or even a fourth lease on life. Retreaded tires are also a safe alternative for buying new tires, as the whole process is strictly controlled by regulations and standards. Therefore, a retreaded tire is comparable to a brand-new one... By retreading the same tire several times, it can be driven up to a million kilometers" (page 95). "In Nordic countries, the majority of truck and bus tires are retreaded after they have been worn in use" (page 95).

Waste volumes are not disclosed here because waste was assessed non-material; they appear in the additional, non-material section on page 141.

Policies related to own workforce

Reference: pages 99-101 (ESRS content index, page 132).

Commitments. "In addition to honoring the ethical principles presented in Nokian Tyres Code of Conduct, the company is committed to acting in the manner required by the UN's Guiding Principles for Business and Human Rights, and to following the International Labour Organization's (ILO) Declaration on Fundamental Principles and Rights at Work. Nokian Tyres is a member of the UN's Global Compact initiative" (page 99). "The essential standards of the company include ISO 45001, the UN Global Compact, Nokian Tyres' policies and procedures related to safety, well-being, hiring, traveling, induction, people reviews and competence development, rewards, human rights, and equality" (page 101).

Human rights due diligence. "In 2023, Nokian Tyres carried out a human rights impact assessment covering the company's whole value chain, however the main focus was on its own personnel. The company also planned measures to minimize risks and impacts. Nokian Tyres has also defined a human rights due diligence (HRDD) process. If any impacts are identified, they are measured and needed actions are taken. In 2025 the human rights impact assessment was updated" (pages 99-100).

Code of Conduct content (page 100). Equality - "We do not tolerate harassment, bullying or discrimination on the basis of any characteristics such as race, ethnicity, color, sexual orientation, gender, gender identity, disability, age, religion, political opinion, union membership, national or social origin". Working conditions - "Our goal is to ensure a safe working environment and create working conditions that preserve physical and mental health". Participation and terms - "We have zero tolerance for forced labor, human trafficking, or child labor... Nokian Tyres will never pay anyone less than the minimum wage defined in the local legislation."

"The company provides mandatory training on the Code of Conduct for all personnel, which is included in the induction of new employees. At the end of 2025, 80 percent of personnel had completed the training" (page 100). "Every employee must adhere to the Code of Conduct, and Nokian Tyres' President and CEO is accountable for its implementation" (page 100).

Other instruments. The Environmental, Safety, and Quality Guideline ("Every employee is responsible for identifying dangers in the working environment and minimizing risks"), the Safety Management Model, which "provides tools across 16 areas of safety for continuous improvement", the Total Rewards Philosophy and Guideline, and the People Review instruction (pages 100-101).

Processes for engaging with own workforce and workers' representatives about impacts

Reference: pages 101-102 (ESRS content index, page 132).

Surveys. "Employee engagement at Nokian Tyres is assessed annually through the Drive! personnel engagement survey, which measures well-being, equality, inclusion, and overall engagement within the organization. Drive! engagement survey results are reviewed within teams, and action plans are collaboratively developed. Training resources for managers on facilitating these discussions are available globally" (page 101). In 2025 the company "started to conduct regular global pulse surveys, and several townhall meetings were organized to increase dialog between employees and management" (page 102).

Channels. "Multiple channels, such as Nokian Tyres' intranet, Microsoft Teams and Outlook, digital signage, and both virtual and in-person meetings, are used to ensure that employees stay well informed... The channels also provide opportunities for feedback and engagement" (page 101).

Safety reporting tool. "Nokian Tyres' global safety reporting tool can be accessed by all own employees, rental workers, partners and contractors, and it enables them to participate in safety initiatives. The tool is used to evaluate work-related risks, report accidents, incidents, and safety observations, as well as to investigate and manage safety-related corrective actions" (page 101).

Representatives, with the gap stated. "In the Nordic countries, local management and HR hold regular meetings with workers' representatives. The frequency of those meetings varies based on the country and legal company. No formal employee representatives are enacted in Central Europe due to the small size of operations, with a low number of employees in each country, the setup of the regional operations, and local legislations. Nokian Tyres also works directly with its own workforce in North America" (pages 101-102).

Accountability. "Nokian Tyres' Senior Vice President of Human Resources has operational responsibility for ensuring that engagement takes place" (page 102). "All employees participate in People Review discussions, which focus on managing performance and employees' personal development" (page 102).

Processes to remediate negative impacts and channels for own workforce to raise concerns

Reference: page 102 (ESRS content index, page 132; datapoint index page 138 marks S1-3 grievance handling paragraph 32 c as Material, page 102).

"Nokian Tyres has processes in place to provide for or cooperate in the remediation of negative impacts on people in its own workforce, as well as channels available to its own workforce to raise concerns and have them addressed. Examples of these are one-on-one discussions and the company's healthcare system, which help to prevent and remediate negative impacts" (page 102).

Whistleblowing. "If an employee discovers or suspects conduct that violates the company's business principles, including the Code of Conduct or Privacy Policy, they should report their concerns through Nokian Tyres' whistleblowing channel. Alternatively, they may report it directly to the General Counsel, CFO, and/or Head of HR. Every employee has direct access to the channel through the company website or intranet, and information about the channel is also available as part of Nokian Tyres' Code of Conduct and Whistleblowing Policy" (page 102).

Protection from retaliation. "Policies protecting individuals who use channels to raise concerns or needs against retaliation are in place as part of Nokian Tyres' Code of Conduct." "All whistleblowers are protected against any form of retaliation. Anonymous reports are treated with the same level or importance as named reports" (page 102).

Oversight. "Legal function coordinates the whistleblowing process and related investigations... All material findings and general statistics are reported to the Audit Committee and the People and Sustainability Committee of the Board of Directors" (page 102).

Effectiveness measure. "According to the internal communications survey in 2024, 74 percent of Nokian Tyres' employees feel that they can talk openly about the development of work or related concerns, as well as possible mistakes or failures" (page 102). Code of Conduct training completion in 2025 was 80 percent (page 102).

Taking action on material impacts on own workforce

Reference: pages 102-103 (ESRS content index, page 132).

Ownership. "The management of material impacts on Nokian Tyres' workforce is led by the HR and safety functions, and all supervisors are responsible for managing the impacts and implementing actions that are relevant for their teams" (page 102).

Development actions. "In 2025, the 360 tool was further developed for leaders to get feedback on their leadership skills and development needs." The development programme "follows the 70-20-10 principle: 70 percent of growth comes from on-the-job experience, 20 percent from learning from others, and 10 percent from formal training". "In 2025, the [eLearning] platform was upgraded to serve users even more efficiently, for example by sending notifications about mandatory eLearning courses" (page 102). Nokian Tyres "continued Leadership Growth Track, a training program for managers... This is an example of an initiative which aims to prevent adverse impacts on employee motivation, but primarily delivers positive impact through improved motivation, skills, and career development opportunities" (page 102).

Rewards. "In 2025, the focus was on reward training during the last quarter, and it will continue during 2026 to enhance understanding across the organization, further contributing to equitable and fair working conditions" (page 103).

Health and safety. "The company continually refines its Safety Management Model procedures to avoid and mitigate any adverse impacts on employee safety. Additionally, through partner companies in the health care sector, Nokian Tyres provides comprehensive occupational health services to all employees." "All accidents and incidents must be reported in the common safety reporting tool. Every accident requires a thorough investigation... Major accidents are communicated internally across locations, production units, and functions." "Employees are encouraged to make safety observations and carry out safety actions with the goal of five safety actions per employee on average." Development is "guided by a safety roadmap, which defines the key development targets for the next few years... regularly monitored by the Management Team" (page 103).

Well-being. "In 2025, caring was highlighted as a main theme for events, activities and communications as 'We care' is one of the company's values and leadership principles" (page 103). "In 2025, the survey included 19 questions, with two questions focusing on well-being, as well as one open-ended question" (page 103).

Targets related to own workforce

Reference: pages 103-104 (ESRS content index, page 132).

How targets are set. "Nokian Tyres engages directly with its own workforce in sustainability target setting by involving employees and workforce representatives in active dialogue. Other channels for involving employees in target setting and monitoring progress include the Drive! Engagement Survey, Sustainability Steering Group, and Occupational Safety Committees in Finland and Romania" (page 103). "Nokian Tyres' own workforce and workforce representatives were engaged directly in setting safety-related targets, tracking performance against them, and identifying lessons or improvements" (page 104).

The 2025 targets and their results (page 104):

Explanation given for the safety miss. "After setting the target, there have been significant changes in operations, which affected the realization" (page 104).

Two of the four are therefore missed and one is a newly established baseline. "Nokian Tyres will evaluate its non-financial targets in 2026" (page 38). Information flow on performance runs through "yearly sustainability info sessions and quarterly employee info sessions... management and team meetings, sustainability steering groups, and other follow-up mechanisms" (page 103).

Characteristics of the undertaking's employees

Reference: pages 104-105 (ESRS content index, page 132).

"Employee figures in both the Sustainability Statement and the Financial Statements are based on the official headcount at the end of the reporting period on December 31, 2025. In Financial Statements the figures are shown in the note 8: Personnel expenses" (page 104).

Headcount by gender (page 104): male 3,175 (2024: 3,080); female 784 (730); other 0; not reported 0; total 3,959 (3,810).

Countries with at least 50 employees representing at least 10 percent of the total (page 104): Finland 1,716 (1,770); US 567 (606); Romania 527 (new in 2025); Norway 525 (526); Sweden 418 (426).

Contract type by gender, 2025 (page 105): permanent 3,800 (760 female / 3,040 male); temporary 159 (24 / 135); non-guaranteed hours 23 (1 / 22); full-time 3,832 (742 / 3,090); part-time 127 (42 / 85).

By region, 2025 (page 105): Nordics 2,659; Other Europe 721; North America 579.

Turnover (page 105): 582 terminated employees in 2025 (426 in 2024) - Nordics 227, Other Europe 178, North America 177 - a turnover rate of 15 percent (11 percent in 2024). "In calculating the turnover rate, the denominator used is the number of headcount at the end of the reporting period."

Collar split (page 104): 1,694 white collar and 2,265 blue collar; "Among the blue collars, 86 percent were male, and 14 percent were female. Of the white collars, 73 percent were male, and 27 percent were female."

Seasonal workers. "There are two tire changing seasons each year when the headcount increases temporarily by approximately 500-700 employees. During 2025, Nokian Tyres employed a total of 1,388 seasonal employees in the Nordics at Nokian Tyres' Vianor tire and car service chain" (page 104).

Context. Personnel negotiations in the last quarter of 2025 "lead to termination of 35 permanent white-collar positions in Finland", plus "temporary layoffs of approximately 650 blue-collar and white-collar employees in passenger car and heavy tire production in Nokia, Finland for a maximum period of 90 days per person by the end of 2026" (page 99).

Characteristics of non-employee workers

Reference: page 106 (ESRS content index, page 132).

"Nokian Tyres refers to non-employees as workers who do not have a direct employment relationship with the company, but whose work is controlled and led by Nokian Tyres" (page 106).

"In 2025, there were 306 (342 in 2024) non-employees, most of them private employment agency workers (249), working in the Finnish factory production. Non-employee figures are reported in headcount at the end of the reporting period on December 31, 2025" (page 106).

The same figures are given under SBM-3, which adds that "the term non-employees refers to individuals who are not direct employees of the organization but whose work is managed and overseen by the company" (page 99), and that positive impacts such as "secure employment, fair working conditions, improved employee health and motivation, skills development, career growth, and a strong company culture - primarily benefit its own employees but may also positively affect non-employees" (page 99).

Non-employees are covered by the safety framework and are reported separately in the injury metrics: "The entire Nokian Tyres workforce, including non-employees, is covered by the company's Safety Management Model" and can use the safety reporting tool (page 108). The Finnish site's total recordable injury frequency for non-employees was 16.6 in 2025 (10.6 in 2024) against 4.6 for own employees, with 8 recordable injuries among non-employees (page 108).

No breakdown of non-employees by type beyond agency workers, and no gender or contract split, is disclosed.

Collective bargaining coverage and social dialogue

Reference: page 106 (ESRS content index, page 132).

"63 percent (67% in 2024) percent of Nokian Tyres' employees were covered by collective bargaining in 2025" (page 106).

Coverage and social dialogue table (page 106). For EEA countries with more than 50 employees representing more than 10 percent of the total workforce, collective bargaining coverage is banded: Finland and Sweden in the 80-100 percent band, Norway in the 60-79 percent band, Romania in the 0-19 percent band. For non-EEA regions, North America is in the 0-19 percent band. Workplace representation, reported for the EEA only, places Finland, Sweden and Norway in the 80-100 percent band. "Romania was added in 2025, as there are more than 50 employees representing > 10% of all employees. There haven't been any other changes compared to the data reported from 2024" (page 106).

European works councils. "There are no agreements with employees for representation by a European Works Council (EWC), a Societas Europaea (SE) Works Council, or a Societas Cooperativa Europaea (SCE) Works Council in Central Europe due to the small size of operations, with a low number of employees in each country, the setup of the regional operations, and local legislations" (page 106).

Where no agreement applies. "When there is no collective labor agreement, the company follows the employment regulations that are available. Nokian Tyres complies with the country-level legislation and regulation in each country" (page 106).

The decline from 67 to 63 percent coverage is not explained in the text, but tracks the addition of Romania (527 employees, 0-19 percent band) to the workforce (pages 104, 106).

Diversity metrics

Reference: page 106 (ESRS content index, page 132).

"Nokian Tyres' top management consists of the President and CEO and the Management Team. The figures are based on the official headcount on December 31, 2025" (page 106).

Gender distribution at top management level (page 106):

Female representation in top management therefore halved year on year, from 44 percent to 22 percent. No explanation is given in the disclosure.

Distribution of employees by age group (page 106):

For context, the group workforce as a whole is 784 female and 3,175 male (page 104), and the Board of Directors had "four male (57.1%) and three female members (42.8%)" at the end of 2025 (page 40).

Adequate wages

Reference: page 107 (ESRS content index, page 132).

"Nokian Tyres will never pay anyone less than the minimum wage defined in local legislation. Additionally, the company follows the local market practice as well as collective agreements when applicable" (page 107).

The same commitment appears in the Code of Conduct as a group-wide principle: "We have zero tolerance for forced labor, human trafficking, or child labor. Employment contracts are drawn up in writing and in adherence with the local legislation. We comply with local legislation and regulations relating to working hours and overtime work. Nokian Tyres will never pay anyone less than the minimum wage defined in the local legislation" (page 100), and again under the S1 chapter's policy table (page 98).

Pay-setting practice is described under S1-16: "At Nokian Tyres, base salary setting follows collective agreements as well as local market practices based on defined job architecture. All employees belong in the short-term incentive program" (page 109). The Total Rewards Philosophy and Guideline "provides globally consistent guidelines designed to ensure fair and equal treatment of employees while allowing local adjustments to remain competitive and attract top talent. They are based on performance, position evaluation, consistent goal setting, and benchmarking of rewarding practices in relevant markets as well as applicable laws and collective agreements" (page 101).

The disclosure is a statement of compliance rather than a quantified adequate-wage benchmark: no percentage of employees paid at or above an applicable adequate wage benchmark is given, and no country-level exceptions are identified.

Social protection

Reference: page 107 (ESRS content index, page 132).

"All Nokian Tyres employees are covered by social protection through either public programs or company-provided benefits. This coverage safeguards against income loss due to major life events such as sickness, unemployment, work-related injuries, acquired disabilities, parental leave, and retirement. Coverage begins as soon as employees start working for the company" (page 107).

This is a complete nil-exception return against the ESRS S1-11 requirement: every major life event listed in the standard - sickness, unemployment from the point the employee is working, employment injury and acquired disability, parental leave, and retirement - is named, and no country or employee group is excepted.

Supporting arrangements are described elsewhere in the chapter. Occupational health services are provided "through partner companies in the health care sector... to all employees. This enables the company to proactively prevent and mitigate risks, while providing remedies if issues arise" (page 103). "All employees are entitled to family-related leave through social policy and/or collective bargaining agreements" (pages 97, 108), and "Nokian Tyres adheres to local laws regarding flexible hours, part-time options, and paid parental and family leave" (page 103). "Occupational health care is based on local legislation and the company's Environmental, Safety, and Quality Guideline" (page 54).

No numbers are given for the share of employees relying on public rather than company-provided schemes.

Training and skills development metrics

Reference: page 107 (ESRS content index, page 132).

People review participation, percent of employees (page 107):

Average training hours per employee (page 107):

Average training hours rose 37 percent year on year, with the largest gain among blue-collar employees (3.7 to 6.1 hours).

Context. "People Review discussions are targeted to all employees, and they focus on managing performance and employees' personal development. The company's employee development program emphasizes internal job rotation, on-the-job learning, and diverse development solutions. It follows the 70-20-10 principle: 70 percent of growth comes from on-the-job experience, 20 percent from learning from others, and 10 percent from formal training" (page 107).

Health and safety metrics

Reference: page 108 (ESRS content index, page 132; datapoint index page 138 marks S1-14 paragraphs 88 b, c and e as Material, page 108).

Coverage. "The entire Nokian Tyres workforce, including non-employees, is covered by the company's Safety Management Model, which is based on legal requirements and recognized standards. The entire workforce can also utilize the safety reporting tool. The tire factories in Finland and in the US are certified according to the international ISO 45001 occupational health and safety standard. Safety management at Vianor follows the ISO 45001 standard but it is not externally certified" (page 108).

Total recordable injury frequency, per 1,000,000 hours worked (page 108): Finland 6.6 (2024: 8.0), of which own employees 4.6 (7.5) and non-employees 16.6 (10.6); US 12.9 (13.4); Romania 8.2 (3.9); Vianor 11.4 (15.4); Group 9.2 (11.3).

Number of recordable injuries (page 108): Finland 19 (23), of which own employees 11 (18) and non-employees 8 (5); US 16 (16); Romania 7 (1); Vianor 38 (52); Group 80 (92).

Lost-time incident frequency (page 108): Finland 1.8 (1.0); US 2.4 (2.5); Romania 5.9 (3.9); Vianor 5.7 (8.9); Group 3.7 (4.6) against a 2025 target of 1.5, not achieved (page 104).

Ill health and fatalities (page 108): occupational illness frequency 1 (0.8) per 1,000,000 hours worked; 8 cases of recordable work-related ill health (6 in 2024); zero fatalities for the group and for subcontractors working on Nokian Tyres' sites in both years; 647 days lost to work-related injuries and ill health (450 in 2024).

Restatement. "Due to a human error, the number of cases of recordable work-related ill health of employees was reported to be 17 in the Sustainability Statement 2024. The correct number of cases was 6" (page 108; see also page 39).

Group injury frequency improved, but Romania deteriorated on both TRIF (3.9 to 8.2) and LTIF (3.9 to 5.9) during the factory ramp-up, and days lost rose 44 percent.

Work-life balance metrics

Reference: page 108 (ESRS content index, page 132).

"All employees are entitled to family-related leave through social policy and/or collective bargaining agreements" (page 108). The same entitlement is recorded in the S1 policy table: "All employees are entitled to family-related leave through social policy and/or collective bargaining agreements" (page 97).

The entitlement is therefore reported at 100 percent of employees, with no country or group exceptions identified.

The take-up datapoint is omitted under a declared phase-in provision. "Nokian Tyres has used phase-in provisions regarding... datapoint S1-15 93 b" (page 40) - that is, the percentage of entitled employees who actually took family-related leave, and its gender split. No such percentage appears in the statement.

Supporting practice is described under S1-4: "Nokian Tyres adheres to local laws regarding flexible hours, part-time options, and paid parental and family leave. A modern work environment equipped with digital tools enables teams to organize work flexibly and supports employee well-being. Teams have also collaborated to establish the best working practices" (page 103). The E1-adjacent S1 IRO notes "a potential long-term negative impact that work-life imbalance and excessive working hours can lead to, e.g., employee burnout or otherwise poor working environment for employees" (page 54).

Compensation metrics (pay gap and total compensation)

Reference: pages 108-109 (ESRS content index, page 132; datapoint index page 138 marks S1-16 paragraphs 97 a and b as Material, page 108).

Remuneration metrics (page 109):

Definitions given. "Gender pay gap is defined as the difference of average gross hourly pay levels between female and male employees, expressed as percentage of the average pay level of male employees." "Total remuneration ratio is defined as annual total remuneration ratio of the highest paid individual to the median annual total remuneration for all employees (excluding the highest-paid individual). Calculation includes compensation elements stored in Nokian Tyres Global HR system: employees' base salary, main allowances and bonuses on target opportunity level (defined in bonus programs or as actually paid on median level). Ratio is impacted by the high volume of blue-collar workers in the workforce" (page 109).

The gender pay gap widened by more than tenfold, from 0.6 to 6.2 percent. No explanation of the movement is given in the disclosure.

Data source. "All reported data is sourced from the global HR system and is calculated in euros for consistency across all employees" (page 109).

Framework. "Nokian Tyres' Total Rewards Philosophy and Guideline forms a consistent framework for retaining, recognizing, and rewarding employees... Rewards offer competitive packages, including both monetary and non-monetary elements... The monetary elements include a base salary, benefits, and different types of incentives" (page 108). "At Nokian Tyres, base salary setting follows collective agreements as well as local market practices based on defined job architecture. All employees belong in the short-term incentive program" (page 109).

Incidents, complaints and severe human rights impacts

Reference: page 109 (ESRS content index, page 132; datapoint index page 138 marks S1-17 paragraphs 103 a and 104 a as Material, page 109).

A complete nil return for 2025, with 2024 comparatives:

"During 2025, no work-related incidents of discrimination were confirmed to have occurred on the grounds of gender, racial or ethnic origin, nationality, religion or belief, disability, age, sexual orientation, or other relevant forms of discrimination involving internal and/or external stakeholders across operations (0 in 2024). This includes incidents of harassment as a specific form of discrimination. Zero (0) complaints concerning misconduct referred to above were reported to the whistleblowing channel" (page 109).

"In addition, no severe human rights issues and incidents connected to own workforce were reported during the year, and there were zero cases of non-respect of UN Guiding Principles and OECD Guidelines for Multinational Enterprises (0)" (page 109).

"There were no fines, penalties, and compensation for damages as result of such incidents during 2025 or 2024" (page 109).

The corresponding channel and oversight arrangements are set out under S1-3: reports go through the whistleblowing channel or directly to the General Counsel, CFO or Head of HR; the Legal function coordinates investigations; "All material findings and general statistics are reported to the Audit Committee and the People and Sustainability Committee of the Board of Directors" (page 102). Under G1-1 the company adds that "In 2025, no compliance breaches were found (0 in 2024) relating to corruption or bribery, conflict of interest, money laundering or insider trading, or any subjects referred to in the EU Whistleblowing Directive" (page 127).

Policies related to value chain workers

Reference: pages 111-115 (ESRS content index, page 132).

Instruments. "The Group's Procurement Guideline establishes the general principles of sustainable procurement and guides Nokian Tyres' Procurement function's work... The company requires that all the suppliers that it has identified to be sustainability critical adhere to Nokian Tyres Supplier Code of Conduct that is publicly available on the corporate website." A Guideline for Sustainable Natural Rubber, Biodiversity and Deforestation also applies. "In Nokian Tyres Management Team, the Senior Vice President, Operations is accountable for the implementation of these supply chain-related policies" (page 111).

Content of the commitments (page 111). Suppliers are expected to "actively prevent child labor; provide employees at least with the minimum wage as required by local laws; provide employees with a safe working environment; respect the rights of migrant and foreign workers and promote ethical recruitment practice and take reasonable steps to ensure that recruitment fees and other associated costs are not born by employees; provide decent living conditions (e.g., adequate housing, access to drinking water, and the right to food and food security) for employees working and living on site... [and] ensure that labor rights-related safeguards apply to all employees, with no distinction being made on discriminatory grounds or employment status."

"The Supplier Code of Conduct expects the suppliers to commit to respecting human rights, including labor rights, and prohibits discrimination and the use of child labor or forced labor, among other things. Suppliers must not participate in, or benefit from, any form of modern slavery" (page 111).

International alignment. Nokian Tyres commits to respect "at a minimum, those [rights] expressed in the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labour Organization's Declaration on Fundamental Principles and Rights at Work. Nokian Tyres expects the same commitment from its suppliers" (page 111).

Grievance commitment. The company is "committed to maintaining a group-level grievance mechanism (in line with UN Guiding Principles effectiveness criteria) that is appropriate for receiving complaints and to providing an opportunity to enable remedy for adverse human rights impacts caused through production or sourcing/procurement. The company expects the same from its suppliers" (page 111).

Supplier risk model. Assessment covers four categories - "quality, sustainability (environmental, social and governance), business/strategic criticality, and safety at work" - with actions for all new suppliers classified critical or medium critical (page 112). The GPSNR-aligned guideline has eight components including "Respecting human rights" and "Community livelihoods" (page 115).

Processes for engaging with value chain workers about impacts

Reference: page 115 (ESRS content index, page 132).

"During the on-site audits conducted by Nokian Tyres, a certain percentage of employees at different levels of the workforce are confidentially interviewed to gather the views of the value chain workers and to gain insight into the perspectives of workers who may be particularly vulnerable to impacts. Follow-up audits are performed every three years, which includes assessing the effectiveness of the engagement" (page 115).

Accountability. "The Sustainability Manager from the sustainability department and the Category Manager from Procurement function are responsible for coordinating the audits and ensuring that the engagement happens" (page 115).

Indirect engagement. "In addition, the collaboration enabled by the GPSNR provides an opportunity to hear the perspectives of value chain workers" (page 115). Under SBM-3 the company explains that "Nokian Tyres is also a member of the Global Platform for Sustainable Natural Rubber (GPSNR), a platform in which different natural rubber stakeholders participate and where the views of value chain workers are presented as well" (page 111).

Who is engaged. "The smallholders, dealers, and processors are not employed by Nokian Tyres but work in the complex and fragmented natural rubber supply chain... In Malaysia, migrant workers have been identified as a particularly vulnerable group" (page 111). "More than 85 percent of the world's natural rubber is produced on farms smaller than two hectares in size... There are approximately three to six million farmers of natural rubber" (page 114).

A stated limit on reach. "This practice can disrupt the traceability chain: for example, the processing facilities may not be aware of the origins of the rubber they purchase. In such cases, there is no direct contact between the processor and the farmer, and a tire manufacturer's visibility to the livelihood of the farmer is very limited or non-existent" (page 114).

In 2025, five sustainability audits of natural rubber processing plant suppliers were conducted (page 115), which bounds the number of workers actually interviewed.

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

Reference: page 115 (ESRS content index, page 132).

Direct channels. "The interviews conducted during audits provide an opportunity for value chain workers to bring any issues to Nokian Tyres' attention. Additionally, in case value chain workers have concerns or suspect infringements, they have the possibility to contact Nokian Tyres through the company's whistleblowing channel" (page 115).

Third-party channel. "As the natural rubber supply chain is fragmented, all value chain workers do not know which company will eventually utilize the commodities they produce. To provide redress and remedy to any party that has suffered negative impacts from the actions of the GPSNR members, the GPSNR Grievance Mechanism (sustainablenaturalrubber.org/grievance-procedure/) offers an opportunity for stakeholders to express concerns... Grievances can be submitted by email to info@gpsnr.org or through an online form. If any cases linked to Nokian Tyres are reported through the channel and considered valid by the GPSNR Compliance Panel, Nokian Tyres will receive a corrective action request. No requests were received in 2025" (page 115).

Effectiveness - the limitation is stated plainly. "Assessing the effectiveness of the channels and value chain workers' awareness of the channels is challenging due to the fragmented natural rubber supply chain" (page 115).

Protection. "All whistleblowers are protected against any form of retaliation. Anonymous reports are treated with the same level of importance as named reports. The topic 'Business conduct' contains detailed information about the whistleblowing channel and the related processes" (page 115). The purpose of the process is "to encourage interest groups to report any activities that infringe upon the legislation, the Code of Conduct, or other provided guidelines" (page 115).

Taking action on material impacts on value chain workers

Reference: pages 115-116 (ESRS content index, page 132; datapoint index page 139 marks S2-4 human rights issues and incidents paragraph 36 as Material, page 115).

The audit programme. "Nokian Tyres started a partnership with an external auditor in 2016 to improve sustainability in its natural rubber value chain. The natural rubber sustainability auditing process has been developed together with a consulting company, and it is based on Nokian Tyres Supplier Code of Conduct and principles that comply with the UN Global Compact goals. In 2022, the audit model was updated so that it also evaluates the suppliers' alignment with Nokian Tyres Guideline for Sustainable Natural Rubber, Biodiversity and Deforestation" (page 115).

"Nokian Tyres exclusively purchases rubber processed in the plants that the company has approved. In 2025, Nokian Tyres conducted five sustainability audits of natural rubber processing plant suppliers. Nokian Tyres has conducted sustainability audits for 100 percent of its sustainability critical-rated suppliers on a three-year cycle" (pages 115-116).

Findings, stated frankly. "Over the years, a common issue identified during the audits has been the language and content of the employment contracts. The contract is not necessarily available in the employees' mother tongue, or the translated content differs from the original. In several cases, the records of working hours, rest times and holidays were missing or incomplete. In some audits it has also been identified that rest times and holidays are not always granted in accordance with the local law" (page 116).

"In some countries, the recruitment of foreign workers has been a problematic topic. Foreign workers are recruited through a recruitment agency network, and the amount of recruitment costs to the employee can be as much as a year's salary. As the agencies are often approved by local governments, it is difficult to improve the process. However, Nokian Tyres requires its suppliers to improve also on this issue. The suppliers have requested support from the local officials, but the progress is slow" (page 116).

"Nokian Tyres did not identify severe labor rights issues during 2025" (page 116).

Follow-up. "Nokian Tyres requires the suppliers to provide corrective action plans... Many suppliers have, for example, introduced employment contracts in several different language versions... If the supplier does not provide the corrective action plan or perform the corrective actions, the supplier can be put on hold status to prevent further business with the supplier until the requested actions are completed." "Currently, Nokian Tyres has mitigation plans from eight audited supplier sites and is monitoring the closing of the corrective actions until the next follow-up audits" (page 116).

Manufacturing partners. All relevant manufacturing partners "have also been audited by a respected third-party auditing agency", covering ISO 9001, ISO 14001 and SA 8000; "Only minor remarks on sustainability matters have been noted" (page 116).

Targets related to value chain workers

Reference: page 116 (ESRS content index, page 132).

"Nokian Tyres drives sustainable development in the supply chain. The aim is to maintain the status that 100 percent of sustainability high-risk suppliers in the company's value chain have been audited. This target is supported by setting yearly key performance indicators related to the audits and other topics related to the sustainability of the supply chain" (page 116).

The 2025 KPIs and results (page 116):

• "At least five sustainability audits performed"
• "100 percent of natural rubber processor suppliers are either GPSNR members or signed Nokian Tyres sustainability commitment"

"Both KPIs were achieved. Nokian Tyres performed five sustainability audits in total."

2026. "In 2026, Nokian Tyres aims to uphold the status of 100 percent of natural rubber processor suppliers either being GPSNR members or having signed Nokian Tyres sustainability commitment" (page 116).

Worker involvement - the gap is stated. "Value chain workers do not directly participate in the setting of the yearly KPIs or in tracking the company's performance against them. However, the insight gained from interviews with the value chain workers during the audits and through the GPSNR informs the decisions that are made to improve the company's performance. The KPIs also support the objectives of the policies related to supply chain sustainability" (page 116).

The targets are process and coverage measures rather than outcome measures for workers: none of them tracks wage levels, working hours, recruitment fees or grievance resolution in the supply chain, which are the substance of the findings reported under S2-4.

Policies related to consumers and end-users

Reference: pages 119-120 (ESRS content index, page 133; datapoint index page 139 marks S4-1 paragraphs 16 and 17 as Material, page 119).

Human rights framing. "Nokian Tyres operates in alignment with the UN Guiding Principles for Business and Human Rights and its own Code of Conduct, which reflects these principles. The company avoids any actions that could cause or contribute to human rights violations. If such impacts do occur, Nokian Tyres takes prompt action to address them. Additionally, Nokian Tyres aims to prevent or mitigate human rights risks directly linked to its operations, products, or services. For consumers and end users, these risks may involve issues related to security and privacy rights" (page 119).

Product safety instruments. The Environmental, Safety, and Quality Guideline "affirms the company's commitment to developing and manufacturing high-quality premium products and services that provide users with safe, economical, and comfortable driving experiences"; it received minor updates in 2025. The Product Lifecycle Process "guides internal procedures for developing new products while ensuring quality and safety standards are maintained throughout the entire product lifecycle" (page 120). "The company adheres to various regulations covering noise, studs, chemicals, testing, and tire markings... Tires in scope of EU Tyre Labelling regulation comply with the requirements and the related information is available in European Product Registry of Energy Labelling (EPREL)" (page 120).

Data protection instruments (page 120). The Data Protection Policy "lays down the requirements for personal data processing" and "was revised in spring 2025 to include clarifications regarding roles and responsibilities in relation to data protection"; alongside it sit the Data Subject Rights Guideline, Data Breach Guideline, Data Retention Guideline and an Information Security Policy (page 118).

Accountability. "Regarding the Data Protection Policy, the Board of Directors is accountable for the data protection governance and the management capabilities and their effectiveness. The President and CEO oversees application and monitors the performance of the data protection governance model. The heads of commercial organizations and heads of functions are accountable for implementation of data protection principles within their area of responsibility." The President and CEO is also responsible for the Environmental, Safety, and Quality Guideline and the Code of Conduct, and "the Product Lifecycle Process has been approved by a member of Nokian Tyres' Management Team" (page 120).

Marketing. The Code of Conduct "promotes reliable, balanced, and timely communication, ethical marketing practices, and the provision of truthful information" (page 120).

Processes for engaging with consumers and end-users about impacts

Reference: pages 120-121 (ESRS content index, page 133).

Indirect route. "Nokian Tyres' primary customers are tire dealers and other intermediaries who sell the tires to end users. Nokian Tyres has direct engagement with customers, gaining insight from end users through them" (page 120).

Product development input. "When developing new products, consumer and end user needs are researched and taken into account to guide the development work. During the new product development phase, consumers' needs are collected in cooperation with business areas through different types of surveys, such as dealer surveys. This kind of feedback guides the focus and needs of development in product development processes" (page 121).

Heavy tyres. "Nokian Heavy Tyres (NHT) personnel trains customers on products and product safety. End users of heavy tires can also give feedback, request materials, and ask for technical information via NHT's web page... The most senior role responsible for this engagement is the Management Team member responsible for Heavy Tyres" (page 121).

Materiality assessment. "Consumers and end users materially affected by Nokian Tyres were included in the company's double materiality assessment (DMA). The stakeholder survey was made available via social media, and an internal DMA workshop involved representatives from all three business units - Passenger Car Tyres, Heavy Tyres, and Vianor - along with survey participation from their respective customers" (page 119). "Additionally, during its double materiality analysis, Nokian Tyres included retailers among the survey respondent groups. The insights gathered from retailers are considered when managing sustainability impacts" (page 121).

Vulnerable groups. "Regarding B2B customers, Nokian Tyres has not identified any groups as particularly vulnerable to impacts. However, in the B2C context, Nokian Tyres has noted that some minors may be among Vianor's customers buying services" (page 121). Data Protection Impact Assessments "evaluate whether certain consumer groups, such as minors, may be more vulnerable than the average consumer. For example, some minors - like moped drivers - may visit Vianor service centers... However, no other consumer groups have been identified as being at higher risk than average consumers" (page 119).

Processes to remediate negative impacts and channels for consumers and end-users to raise concerns

Reference: page 121 (ESRS content index, page 133).

Data breach remediation. "If Nokian Tyres identifies a material negative impact on consumers and end users due to compromised customer privacy from inadequate cybersecurity measures, the company will notify local supervisory authorities and all individuals whose personal data may have been compromised, in accordance with applicable laws" (page 121).

Channels. "If a consumer or end user suspects a data protection issue, they can contact Nokian Tyres directly via email at privacy@nokiantyres.com. The number of incoming data subject requests is monitored internally, and response times are tracked to ensure compliance with legal requirements. The Privacy Statement, available on Nokian Tyres websites, includes instructions on how to contact the company" (page 121).

"End users are encouraged to share feedback or concerns through their local website or, for product-related issues, by contacting the dealer where the tires were purchased. If these channels do not fully resolve the issue, end users can reach out to Nokian Tyres' main offices via various channels, including info@nokiantyres.com. For unresolved concerns or significant issues, such as suspected infringements, reports can be made through the whistleblowing channel, also anonymously" (page 121).

Protection. "Nokian Tyres' policies protect individuals from retaliation when raising concerns about a misconduct, as outlined in the Code of Conduct." "Nokian Tyres plc manages personal data related to the company's group-level whistleblowing process. All grievances are handled confidentially and with respect to privacy and data protection rights" (page 121).

The effectiveness gap, stated by the company. "While the number of whistleblowing cases is monitored internally, there are currently no processes in place to track the effectiveness of these reporting channels or the consumers' and end users' awareness and trust toward these structures and processes" (page 121).

Taking action on material impacts on consumers and end-users

Reference: pages 121-124 (ESRS content index, page 133; datapoint index page 139 marks S4-4 human rights issues and incidents paragraph 35 as Material, page 121).

"In 2025, Nokian Tyres did not identify any severe human rights issues or incidents involving consumers or end users" (page 121).

Resourcing. "To proactively manage potential material impacts, the company has allocated resources across key functions. Data protection responsibilities are clearly defined within the Data Protection Policy... For the development of passenger car tires' safety properties, the Products and Innovations unit takes the lead in managing impacts. Additionally, the Nokian Heavy Tyres business unit oversees heavy tire safety" (page 121).

Data protection actions in 2025. "Nokian Tyres renewed its data protection governance model and conducted a review of the data subject rights process. As part of these initiatives, the revised processes were communicated, and relevant employees were provided with targeted training." "In 2025, Nokian Tyres took measures to increase the completion rate of mandatory data protection eLearning course among employees whose work may include processing of personal data. The mandatory eLearning course must be renewed at two-year intervals, and managers are responsible that their team members complete the course" (page 121).

Safety actions. "Nokian Tyres actively participates in the continued development of EU Tyre Labelling test methods for regulatory purposes, including wet grip and ice grip testing." "Process controls are implemented throughout production to guarantee quality, with every tire undergoing production quality control. This includes testing for force variations, roundness, and unbalance measurements, as well as a thorough visual inspection." Testing runs at test centres in Nokia and Ivalo, Finland, and Santa Cruz de la Zarza, Spain (page 122). Nokian Heavy Tyres "promotes safety and sustainability through innovations such as Intuitu smart tire technology, which provides real-time data on tractor tire pressure and temperature" (page 122).

Education actions. Vianor checks tyre condition at service and "if necessary, the customer also receives a recommendation to replace the tires to ensure road safety"; stored tyres are checked and customers informed "prior to the next tire change" (page 123). "In 2025, Nokian Tyres also launched a new sustainability communication concept and campaign under the theme 'About Time'" (page 123).

Track record. "The company has maintained a 24-year track record without significant product recalls" (page 120).

Targets related to consumers and end-users

Reference: page 124 (ESRS content index, page 133).

Wet grip. "For wet grip, Nokian Tyres aimed for 100 percent of its selected premium passenger car tires to achieve an A or B class rating in the EU Tyre Labeling system by 2025. By the end of 2023, the company had already met this target, with all premium tires in the selected scope rated A or B. The selected scope comprises the latest generation tires that are in price category A and included in the EU Tyre Labelling. The scope does not include Nordic winter tires, for which ice grip is crucial" (page 124).

Ice grip. "In terms of ice grip, ensuring the safety of winter tires is a top priority for Nokian Tyres. The target was that all of Nokian Tyres Hakkapeliitta products meet the EU ice grip requirements by 2025, which was achieved in 2022" (page 124).

Maintenance target. "The company targets to ensure that 100 percent of its premium passenger car tires in the selected scope achieve an A or B class wet grip rating in the EU Tyre Labeling system and that all of the Nokian Tyres Hakkapeliitta products meet the EU ice grip requirements also in the future. This target was achieved in 2025" (page 124), and is recorded as "Achieved" in the group target table (page 38).

How targets are set and tracked. "The EU Tyre Label classification is used in Nokian Tyres' Product Lifecycle Process to establish specific product performance targets, as achieving certain labeling classifications or fulfilling the criteria for labeling markings provide a means to assess product performance reliably and transparently" (page 124).

Consumer involvement - the gap is stated. "Although consumers and end users were not involved in setting or tracking these targets, the EU Tyre Label's classification criteria for wet grip, rolling resistance, noise, fuel efficiency, snow grip, and ice grip help simplify and guide consumers' and end users' purchase decisions." The company "actively collects user feedback and ratings on its website, allowing consumers to provide insights and suggestions for improvements" (page 124).

No target is set for the privacy and cybersecurity IRO, which is the only negative impact in the S4 IRO table (page 56).

Business conduct policies and corporate culture

Reference: pages 127-128 (ESRS content index, page 133; datapoint index page 139 marks G1-1 UN Convention against Corruption paragraph 10 b and protection of whistleblowers paragraph 10 d as Not material and Material respectively).

Framework. "Nokian Tyres' operations are guided by ethical principles defined in the company's Code of Conduct, approved by the Board of Directors... At the core of Nokian Tyres' corporate culture is a comprehensive compliance framework, which consists of key policies reviewed in regular intervals by the Board of Directors and the Management Team. These include ethical policies such as the Code of Conduct, Anti-Bribery and Conflict of Interest Code of Conduct, Data Protection Policy, and Supplier Code of Conduct as well as financial policies such as Tax Policy and Enterprise Risk Management Policy" (page 127).

Whistleblowing. "Nokian Tyres has a Whistleblowing Policy in place, approved by the Board of Directors. The company has had a whistleblowing channel since 2011, and it is also available to external stakeholders on the corporate website. The company utilizes whistleblowing service provided by an external third party." "To ensure anonymity of individuals submitting whistleblower reports, the external service provider automatically deletes all metadata, including IP addresses." "Access to messages received through the whistleblowing channel is restricted to members of the whistleblowing team... Their actions are logged, and handling is confidential" (page 127). "Nokian Tyres is subject to legal requirements under national law transposing Directive (EU) 2019/1937" (page 128).

Investigation and oversight. "Nokian Tyres is committed to investigating business conduct incidents promptly, independently and objectively. If an investigation reveals that an employee has acted contrary to Nokian Tyres business conduct policies, it may lead to corrective or disciplinary actions, termination of employment, and if necessary, to a report to the relevant authorities. Nokian Tyres' Whistleblowing Committee was formed in 2019... All material issues will be reported to the Audit Committee and People and Sustainability Committee at least once a year" (page 127).

Result for 2025. "In 2025, no compliance breaches were found (0 in 2024) relating to corruption or bribery, conflict of interest, money laundering or insider trading, or any subjects referred to in the EU Whistleblowing Directive" (page 127).

Two legal matters are disclosed. "Nokian Tyres informed on January 30, 2024 that the European Commission had at the same day initiated an unannounced inspection at Nokian Tyres plc's headquarters in Nokia, Finland. The European Commission has expressed its concerns that the inspected tire manufacturing companies may have violated EU antitrust rules that prohibit cartels and restrictive business practices. Nokian Tyres does not have information on the outcome of the inspection... Nokian Tyres is fully co-operating with the authorities." "On April 10, 2025, the Helsinki Court of Appeal issued a judgment in securities market information offence of Nokian Tyres plc and its former President and CEO" (page 127).

Training. "The Code of Conduct eLearning includes training on the whistleblowing channel" (page 127); Code of Conduct training completion was 80 percent at the end of 2025 (page 100). Internal Audit, outsourced in 2024, reports administratively to the CFO and functionally to the Audit Committee (page 128).

Management of relationships with suppliers

Reference: page 128 (ESRS content index, page 133).

"Requiring a commitment to ethical business and sustainability from suppliers promotes both environmental and social responsibility in the supply chain. The most important policies that drive this development are Nokian Tyres Supplier Code of Conduct and Nokian Tyres Guideline for Sustainable Natural Rubber, Biodiversity and Deforestation. They are discussed in more detail under the topic 'Workers in the value chain'. The Senior Vice President of Operations is accountable for the implementation of these supply chain related policies" (page 128).

Payment terms toward suppliers. "Nokian Tyres has standard payment terms, and there is no separate policy to prevent late payments. However, the basis of the procurement process is that justified invoices are paid on time" (page 128). The standard term is "90 days net. The payment terms are reconsidered when necessary in the case of, e.g., smaller suppliers" (page 126) - a point that matters for smaller and more vulnerable suppliers.

Due diligence on new suppliers. "Nokian Tyres checks the backgrounds of all new suppliers according to the Due Diligence process and assesses the possible risks attached to the suppliers before supplier approval. The assessment model has four different categories: quality, sustainability (covering environmental, social and governance criteria), business/strategic criticality, and safety at work. Actions are taken with all new suppliers that are classified as critical or medium critical in any of the four categories in the classification model. The actions are, for example, sustainability on-site audits, desk assessments and requesting a management system certification in terms of quality, environment, or safety. Potential risks identified with desk assessments are additionally confirmed and verified through on-site audits" (page 128).

Scale. "Nokian Tyres' supply chain consists of over 3,700 suppliers, including more than 200 raw material suppliers" (page 112). Supplier screening figures published as additional, non-material information record 3,868 unique suppliers in 2025, 47 significant suppliers, 13 assessed via desk or on-site assessment, 13 assessed with substantial actual or potential negative impacts, 6 with an agreed corrective action plan and none terminated (page 114).

Social considerations in supplier selection. The material IRO in the G1 table is the positive impact from "ethical and sustainable sourcing practices", with the accompanying opportunity of being a "preferred partner for suppliers through good and fair relationship management" (page 57).

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS; Nokian Tyres' FY2025 statement was prepared under the 2023 ESRS.

Nokian Tyres sets no measurable business conduct target. The group target table on page 38 lists targets under E1, E2, E4, E5, S1, S2 and S4 only; there is no G1 row, and no target appears in the business conduct chapter (pages 126-129).

Effectiveness is tracked in the absence of a target, which is MDR-T's other limb:

• Incident review. "In 2025, no compliance breaches were found (0 in 2024) relating to corruption or bribery, conflict of interest, money laundering or insider trading, or any subjects referred to in the EU Whistleblowing Directive" (page 127).
• Periodic governance reporting. Whistleblowing "material issues will be reported to the Audit Committee and People and Sustainability Committee at least once a year" (page 127), and under S1-3 "All material findings and general statistics are reported to the Audit Committee and the People and Sustainability Committee of the Board of Directors" (page 102).
• Internal Audit. "Nokian Tyres' Internal Audit systematically carries out assessments and audits on the efficiency of risk management, internal control, and corporate governance processes... Each year, the Audit Committee approves the focus areas for Internal Audit. The audit findings, recommendations and management action plans are presented to the Audit Committee, followed by ongoing monitoring and follow-up on the implementation of the management action plans" (page 128).
• Training coverage. Code of Conduct training is mandatory for all personnel and included in induction; "At the end of 2025, 80 percent of personnel had completed the training" (page 100).
• Payment practices measures. "In 2025, 93 percent (85% in 2024) of the invoices were paid aligned with the standard terms", and average payment time was 49 days (46) (page 129).
• Policy review cadence. The compliance framework policies are "reviewed in regular intervals by the Board of Directors and the Management Team" (page 127).

Nokian Tyres also states that it "will evaluate its non-financial targets in 2026" (page 38), which may bring business conduct into scope.

Political influence and lobbying activities

Reference: pages 128-129 (ESRS content index, page 133).

No political funding. "Nokian Tyres' business is guided by the ethical principles presented in the Code of Conduct, which states that Nokian Tyres does not provide monetary or in-kind support to political parties or groups or individual politicians" (page 128). The table on page 129 confirms EUR 0 in 2025 and EUR 0 in 2024 for "Political funding and in-kind giving provided to parties and politicians, and spending related to ballot measures or referendums".

Transparency register. "Nokian Tyres is registered with the European Transparency Register (registration number 604107415108-75)" (page 128).

Principles. "Lobbying work is transparent and characterized by accurate contribution of the company's technical expertise and knowledge concerning the tire industry and other related sectors, with a focus on products, safe and sustainable mobility, and innovation" (page 128).

Spend (page 129). "In 2025, the company's membership fees for trade associations and contributions to lobbying activities totaled 1,304,960 euros (1,271,640 in 2024) globally."

Main topic. "The biggest contribution for a specific topic was related to tire abrasion. The tire abrasion validation project is related to Nokian Tyres' material impact regarding pollution, as the project aims for reducing road transport emissions by setting global tire abrasion limits that are based on a reliable tire test method. There were no other significant topic-specific contributions in 2025" (page 129).

A concrete outcome is cited in the IRO table: "Nokian Tyres' advocacy led to the addition of the ice grip marking and snow grip marking in the EU Tyre Label to help drivers choose safe winter tires for winter conditions" (page 57).

No disclosure is made of Management Team or Board members who held a comparable position in public administration in the two years before appointment.

Payment practices

Reference: page 129 (ESRS content index, page 133).

Standard terms. "The standard payment term in Nokian Tyres' general terms and conditions for purchases is 90 days net. In the case of smaller suppliers, for example, the payment terms are reconsidered when necessary" (page 129; see also page 126).

Compliance with own terms. "In 2025, 93 percent (85% in 2024) of the invoices were paid aligned with the standard terms" (page 129).

Average payment time. "In 2025, the average time it takes to pay an invoice, starting from the date when the contractual or statutory payment term begins, was 49 (46) days. The payment term has been calculated as a weighted average based on the supplier invoices paid during the review period" (page 129).

Legal proceedings. "At the end of 2025, there were no outstanding legal proceedings for late payments" (page 129).

Payment practices sit within the G1 material topic "Management of relationships with suppliers including payment practices" (page 126). The related policy position is stated under G1-2: "Nokian Tyres has standard payment terms, and there is no separate policy to prevent late payments. However, the basis of the procurement process is that justified invoices are paid on time" (page 128).

On-time payment improved by 8 percentage points year on year while the average payment time lengthened by 3 days. The 90-day standard term is long relative to the EU Late Payment Directive's 60-day default for business-to-business contracts, and no breakdown is given of how many suppliers, or which categories, are on shorter negotiated terms.