Nordic Semiconductor

The role of the administrative, management and supervisory bodies

Reference: pages 39-41 (ESRS content index, page 67).

Two bodies: the Board of Directors (BoD), "acting as the supervisory body with overall accountability for sustainability governance, risk oversight, and approval of the Sustainability Statement", and the Executive Management Team (EMT) (page 40).

Composition (page 40). The BoD has eight members: five shareholder-elected independent directors (62.5%, all independent) and three employee-elected directors (37.5%). Gender split five female (62.5%) and three male (37.5%). The EMT has eleven members, one female (9%) and ten male (91%) at 31 December 2025.

Committees. Sustainability IROs and reporting sit with the Audit Committee (AC); workforce matters with the People & Compensation Committee (PCC). The report flags a change: "During 2024, sustainability matters were overseen by a dedicated Sustainability Committee of the Board. In 2025, oversight of sustainability reporting and related governance was integrated into the mandate of the Audit Committee" (page 40). The AC "Meets at least six times per year and receives scheduled semiannual updates"; the PCC meets quarterly. The EMT oversees sustainability through an ESG Committee of all EMT members meeting at least quarterly. The former Board-level Sustainability Committee "was dissolved in 2024".

Information provided to and sustainability matters addressed

Reference: page 41 (content index, page 67).

Information reaches the Board through defined channels: "Semiannual AC updates covering sustainability reporting, assurance readiness, and business-conduct risks", "Quarterly PCC meetings addressing workforce, diversity, and human-capital IROs", and an "Annual BoD review of the sustainability strategy, climate-transition plan, and approval of the Sustainability Statement" (page 41). At management level the ESG Committee is chaired by the CEO. Functional reporting flows "from the Quality, Supply Chain, and People & Culture departments on environmental, supplier, and workforce metrics".

Material IROs addressed during 2025 are listed as climate change, resource efficiency, worker safety, cybersecurity, diversity and inclusion, and ethics/business conduct (page 41).

External specialists, "including Position Green, support updates to the Double Materiality Assessment and the development of climate-transition plans". The same page carries ESRS 2 GOV-1-G1, under which the AC oversees compliance, anti-corruption, data protection and trade controls and "receives semiannual updates on business conduct performance, investigations, remedial actions, and the operation of the Code of Conduct, Supplier Code of Conduct, and Integrity Line".

Integration of sustainability-related performance in incentive schemes

Reference: page 42 (content index, page 67; the E1 cross-reference ESRS 2 GOV-3-E1 is also indexed at page 42).

Short-term incentive (STI). "For the 2025 performance year, ESG-related metrics account for 10% of the total STI performance weighting" (page 42).

Long-term incentive (LTI). The 2025-2027 performance share unit conditions are Total Shareholder Return (45%), financial performance criteria (45%) and ESG-related performance criteria (10%) (page 42).

Climate link (ESRS 2 GOV-3-E1, page 42). "A climate-related performance metric linked to Scope 1 and Scope 2 GHG emissions reduction relative to the 2019 baseline formed part of the STI framework (10% of total STI weighting), with performance assessed against the company's climate targets disclosed under ESRS E1-4." ESG measures including climate metrics also form part of the PSU criteria.

Supervisory body. "Remuneration of Board members does not include sustainability-linked performance metrics. The BoD oversees the design of executive incentive schemes and periodically reviews whether sustainability-related performance measures should be integrated into future remuneration frameworks" (page 42). The PCC reviews structure, criteria and weighting; the BoD approves the performance conditions.

Statement on due diligence

Reference: pages 43-44 (content index, page 67).

Nordic presents the due diligence statement as a mapping table: "The following table maps the information in this Sustainability Statement to the due diligence process" (page 43). Each of the five core elements is mapped to specific page ranges and flagged as relating to people, the environment, or both.

• a) Embedding due diligence in governance, strategy and business model - ESRS 2 GOV-2 (page 41), GOV-3 (page 42), SBM-3 (pages 50-58) and every topical SBM-3 (E1 78-79, E2 88-89, E3 92, E5 94-95, S1 104-105, S2 114-115, S4 119-120, G1 124-125).
• b) Engaging with affected stakeholders - GOV-2 (page 41), SBM-2 (pages 48-49), IRO-1 (pages 59-66), the MDR-P policy disclosures (E1-2, E2-1, E3-1, E5-1, S1-1, S2-1, S4-1, G1-1) and the topical engagement DRs S1-2, S2-2, S4-2.
• c) Identifying and assessing adverse impacts - IRO-1 (pages 59-66) and SBM-3 across all topics.
• d) Taking actions - the MDR-A action disclosures E1-3, E2-2, E3-2, E5-2, S1-4, S2-4, S4-4, plus E1-1 and G1-1 (page 44).
• e) Tracking effectiveness and communicating - the MDR-M metrics (E1-5, E1-6, E2-5, E5-4, E5-5, S1-9, S1-13, S1-14, S1-15, S1-16, S1-17) and MDR-T targets (E1-4, E2-3, E3-3, E5-3, S1-5, S2-5, S4-5), together with the entity-specific metrics for value chain workers (page 118), cybersecurity (page 126) and whistleblowing (page 126).

Risk management and internal controls over sustainability reporting

Reference: page 45 (content index, page 67).

Nordic is candid that integration is incomplete: "In 2025, Nordic advanced the alignment of the Double Materiality Assessment (DMA) and the Enterprise Risk Management (ERM) framework. The integration of sustainability-related risks into the ERM system will continue in the next reporting cycle" (page 45). IRO-1 puts it more bluntly - "Sustainability-related risks are not yet integrated into Nordic's Enterprise Risk Management (ERM) framework" (page 60).

Control environment (page 45): documented ownership of sustainability data, defined roles for Finance, Quality, Supply Chain, People & Culture and Compliance, and reporting lines through the ESG Committee, EMT, AC and BoD, documented in the Quality Management System.

Principal reporting risks: data quality and completeness; estimation uncertainty ("reliance on assumptions for Scope 3 emissions and value-chain indicators"); human error and control gaps in manual consolidation; and timing of supplier data (page 45). Mitigations are data-validation controls, competence development, supplier engagement and periodic control reviews. Results are "reported semi-annually to the AC", and "The BoD conducts bi-annual reviews of major exposures and internal controls".

Strategy, business model and value chain

Reference: pages 46-47 (content index, page 67).

Nordic is a fabless designer of low-power wireless connectivity and power-management devices, headquartered in Trondheim. The 2025 framework is built on three "Sustainability Building Blocks - Products, People, and Production" (page 46).

Product groups for 2025: Short-range (Bluetooth Low Energy, Thread, Zigbee, Matter, proprietary), Long-range (cellular, proprietary, Cloud services), and Other (PMIC, Wi-Fi, ASIC components, development tools). Customer groups are Consumer, Industrial and Healthcare, and Other. In 2025 Nordic added lifecycle management through the acquired Memfault platform and edge AI through Neuton AI; these "do not constitute standalone revenue-generating product groups in 2025".

Value chain (page 46). "The upstream value chain includes wafer fabrication, assembly, test, and packaging, primarily in Taiwan and the Philippines, and accounts for the majority of Nordic's environmental footprint." Downstream comprises distributors, OEMs and end-users. "Nordic occupies a mid-chain position as a fabless semiconductor designer dependent on collaboration with manufacturing partners and distributors."

Challenges named: "renewable-energy constraints in the upstream chain, limited comparative ESG data from suppliers, and implementation of the Climate Transition Plan".

Interests and views of stakeholders

Reference: pages 48-49 (content index, page 67; SBM-2-S1, SBM-2-S2 and SBM-2-S4 are all indexed at page 49).

A four-category table on page 48 covers Market, Society, Internal and Owners groups. Mechanisms include supplier meetings and surveys, RBA audits and HRDD questionnaires, EcoVadis supplier ratings, quarterly distributor reviews, customer meetings one to two times per year, monthly employee-representative forums, a pulse survey "(introduced in 2025)" and exit interviews.

What stakeholders said (page 49). Employees "highlighted integrity, workplace fairness, inclusion, and opportunities for development as priorities". RBA audits, HRDD questionnaires and third-party ESG assessments "highlighted expectations regarding fair working conditions, accommodation, safety, and effective grievance mechanisms". Customers and end-users "expressed expectations for energy efficiency, durability, security, and transparency throughout the lifecycle".

Changes made in 2025: consolidation of the strategy into three building blocks; introduction of pulse surveys; strengthened supplier engagement including third-party ESG ratings and enhanced HRDD; adjusted product-development priorities.

Nordic states that "Affected communities (S3) are not material in the 2025 Double Materiality Assessment (DMA) and are therefore not included" (page 48).

Material impacts, risks and opportunities

Reference: pages 50-58 (content index, page 67), with per-topic IRO tables on pages 52-58 and a materiality matrix on page 51.

"Material environmental impacts arise primarily upstream and relate to GHG emissions, water use, pollution, and resource intensity in manufacturing and logistics. Material social impacts mainly occur at Tier 1 and Tier 2 suppliers, with additional impacts in Nordic's own operations" (page 50).

Material topics: E1, E2, E3, E5, S1, S2, S4 and G1. E4 and S3 are not material. Twenty-seven typed IRO rows appear across the topic tables (E1 4, E2 2, E3 1, E5 4, S1 5, S2 5, S4 3, G1 3).

Changes versus 2024 (page 50): "Corporate culture (G1) was reassessed and did not meet the thresholds for inclusion as a material IRO for 2025"; "Corruption and bribery (G1) were reassessed and did not meet the thresholds for inclusion as a material financial risk for 2025"; "Equal treatment and opportunities (S1) remain material but are now classified under impact instead of double materiality"; positive impacts added for product durability (E5) and peer learning (S1); desk-based health impacts (S1) reclassified from borderline to material; and "Upstream decarbonization cost exposure has increased significantly due to supplier policy developments".

Climate-specific resilience is also presented under E1-3 (2025 ESRS numbering).

Processes to identify and assess material IROs

Reference: pages 59-66 (content index, page 67; topical cross-references at E1 60-61, E2 64, E3 64, E4 64-65, E5 65, G1 65-66).

The 2025 DMA "was conducted using an ESRS-aligned digital workflow (Position Green) to document scoring, rationales, and outputs, replacing the Excel-based approach used in 2024" (page 59). The change "strengthened documentation, traceability, and governance of the DMA process but did not materially change the overall outcome compared with the prior year".

Scoring (page 59). Negative impacts: "Severity = (Scale + Scope + Remediability) / 3"; positive impacts: "Severity = (Scale + Scope) / 2"; for human rights "the severity threshold is adjusted downward by 0.5". Financial materiality uses "Position Green's 5x5 matrix".

Process governance (page 60): SME scoring in Position Green, quality assurance by the ESG Reporting Specialist, validation by the ESG Committee, oversight by the Audit Committee, Board approval before publication.

Limits disclosed. "The DMA and the ERM framework remained largely separate in 2025... Beyond this consistency check, no process integration was implemented in 2025" (page 60). "Nordic did not apply the TNFD LEAP approach in 2025." "The DMA was last updated in Q3 2025. The next full revision is scheduled for Q3 2026."

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

Disclosure requirements covered by the sustainability statement

Reference: pages 67-74. A genuine ESRS content index headed "List of material DRs" runs across pages 67-69, with the Appendix B table of datapoints derived from other EU legislation on pages 70-74.

"Nordic determines the content of its sustainability statement based on the outcomes of its Double Materiality Assessment (DMA)... Topics assessed as not material are omitted from the sustainability statement, and the corresponding DRs are therefore not disclosed. These omissions reflect the results of the DMA and do not indicate the absence of impacts, risks, or opportunities" (page 67).

DRs listed in the index: ESRS 2 BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2; E1-1 to E1-6 and E1-9; E2-1, E2-2, E2-3, E2-5; E3-1, E3-2, E3-3; E5-1 to E5-5; S1-1 to S1-7, S1-9, S1-13 to S1-17; S2-1 to S2-5; S4-1, S4-2, S4-4, S4-5; and G1-1. No E4 topical DR appears - only the ESRS 2 IRO-1-E4 screening cross-reference (pages 64-65).

The Appendix B table marks each EU-legislation datapoint "Material" or "Not material" with a page reference, and evidences several non-material conclusions (E2-4, E3-4, the E4 datapoints, S3-1, S3-4 and both G1-4 datapoints are marked "Not material").

Transition plan for climate change mitigation

Reference: pages 76-77 (content index, page 67).

"Nordic began formulating a transition plan to mitigate climate change in 2024. The qualitative transition plan was approved in 2025 by Nordic's Executive Management Team and the Board of Directors as part of the 2025 strategy" (page 76). It "is embedded in and aligned with its overall strategy and annual business", and "Funding is provided through Nordic's ordinary financial planning and budgets for decarbonization-related initiatives".

"The plan aligns with a 1.5C pathway, as reflected in Nordic's SBTi-validated targets, with the Paris Agreement, and is consistent with EU climate ambitions" (page 76).

Levers. "Given that the vast majority of Nordic's emissions arise in the value chain, the transition plan primarily focuses on Scope 3 decarbonization levers": engagement with manufacturing suppliers, non-manufacturing suppliers, customers, and industry peers through the Semiconductor Climate Consortium. Scope 1 and 2 "are managed through operational measures, including energy efficiency improvements and renewable energy sourcing".

Locked-in emissions (page 77). "Nordic does not currently identify any significant locked-in GHG emissions for Scope 1 and 2." Upstream purchased-goods emissions are not treated as locked in "as suppliers retain discretion to implement measures to reduce the emission intensity of their production processes". Use-phase locked-in emissions are quantified: "The estimated locked-in emissions for 2025 are 3743 tCO2, compared to 3172 tCO2 in 2024."

"Nordic is not excluded from the EU Paris-aligned Benchmarks." For FY2025 Nordic reports no taxonomy-aligned turnover, CapEx or OpEx.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1-E1 and the TCFD disclosure, where this content is disclosed in the FY2025 report (pages 60-63). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification. Risks are separated into physical (acute and chronic) and transition (policy and legal, technology, market, reputation) in the TCFD tables on pages 62-63.

Methodology (pages 60-61). Physical hazard screening focuses "on extreme weather and water-stress-related hazards relevant to semiconductor supply chains", covering "Nordic's own small office footprint and - more materially - across upstream manufacturing locations in Southeast Asia and Europe". Exposure is assessed through "geographic vulnerability and local climate trends; supplier infrastructure resilience; the sensitivity of wafer fabrication and assembly/test operations to water stress and extreme weather; and the availability of supplier business continuity planning measures". Transition drivers include regulatory requirements for upstream decarbonisation, renewable-energy availability in manufacturing regions, customer expectations and technology change.

No scenario analysis was performed. "Nordic has not yet conducted climate-related scenario analysis. Accordingly: physical-risk identification has not yet been informed by a range of scenarios; high-emission climate scenarios have not yet been incorporated; and the planned scenario-analysis framework will align with ESRS E1 and TCFD guidance and is expected to be implemented in a later reporting cycle" (page 61). "Nordic has not yet applied geospatial coordinate-based modeling for physical risk assessment."

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the TCFD resilience narrative, where this content is disclosed in the FY2025 report (pages 50, 62-63, 76). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

No ESRS-defined resilience analysis was performed. "Nordic has not yet conducted a formal climate-related scenario analysis. Climate risk identification in 2025 is based on the Double Materiality Assessment and other qualitative risk inputs" (page 76). The TCFD section states that "In 2025, this approach did not include scenario analysis" (page 62).

What is disclosed instead (page 50). "Nordic assesses resilience annually through the DMA, climate risk evaluation, and supplier risk assessments. The fabless model provides structural flexibility, as Nordic does not own fabrication facilities and can in principle adjust manufacturing partners. In practice, however, supplier diversification and dual sourcing are constrained by technological requirements, qualification cycles, and the limited number of suppliers capable of meeting Nordic's specifications."

Capacity to adapt (page 63). "In the short term, it maintains a reserve of wafers and finished products to operate under extreme weather conditions... To mitigate medium-term risk, Nordic uses a dual-sourcing strategy... To mitigate long-term risk, its key manufacturing partners have their own business continuity plans." Nordic notes it "has already experienced water rationing in some of the countries where its manufacturing suppliers operate"

Policies related to climate change mitigation and adaptation

Reference: page 79 (content index, page 67).

"Nordic's Climate Change Policy sets requirements for responsible practices across the Group's own operations and value chain. The policy addresses all its identified material IROs related to climate change, as disclosed in the table for ESRS 2 SBM-3" (page 79).

Scope covers both limbs of E1: "implementing measures for climate change mitigation through GHG emissions reductions in line with SBTi targets, and for climate change adaptation through assessing climate risks and enhancing resilience to climate impacts". The policy "outlines Nordic's approach to improving energy efficiency and increasing the use of renewable energy in its own operations. It also describes expectations for suppliers' collaboration, sustainable sourcing practices, and ongoing refinement of environmental management across its business activities."

Accountability. "The Chief Executive Officer is responsible for the policy's execution and its alignment with Nordic's strategic goals. The policy is reviewed annually by the Executive Management Team" (page 79).

Availability. "The policy is available for all employees on Nordic's intranet and publicly available on Nordic's website."

The disclosure does not name a third-party standard the policy is aligned to, and does not describe stakeholder consultation in its formulation - both of which Nordic does supply for its Environmental Impact Reduction policy under E2-1 (pages 89-90).

Actions and resources in relation to climate change policies

Reference: pages 79-80 (content index, page 67).

Nordic's actions run through named levers (pages 79-80):

• Engagement with manufacturing suppliers. "the key action for reducing emissions from purchased goods and services is to engage with its outsourced manufacturing suppliers, which have the largest impact, accounting for roughly 70% of its total GHG emissions". Wafer supply is concentrated - "provided by only a few manufacturing suppliers, such as TSMC and GlobalFoundries".
• Non-manufacturing suppliers through "a structured third-party supplier sustainability assessment framework (currently supported by EcoVadis)".
• Customers, to "amplify climate action across the value chain, particularly by influencing manufacturing suppliers".
• Industry peers. "In 2025, Nordic joined the Semiconductor Climate Consortium (SCC)".
• Renewable electrification of own operations. "By investing in renewables, 92% of the energy purchased for Nordic's own operations in 2025 originated from renewable sources. Compared to the 2019 baseline, this represents a 89% reduction in scope 2 market-based emissions." "By 2030, Nordic aims to reach 100% of its electricity consumption from renewable ources."
• Energy-efficient product design through optimised SoC designs and power management.

Resources. "The implementation of Nordic's climate change mitigation actions does not require significant CapEx or OpEx expenditure at this stage" (page 79). No monetary amounts are given.

Progress caveat. "As of 2025, compared to 2019, Nordic's Scope 3 emissions intensity (emissions per USD value added) has decreased by 38%, while Scope 3 absolute emissions have increased by 42%"

Targets related to climate change mitigation and adaptation

Reference: pages 81-83 (content index, page 67).

"In April 2024, Nordic's science-based targets were validated by SBTi" (page 81). Base year is 2019, selected "in accordance with SBTi criteria".

Target table (page 83):

Value added is defined as "sales revenue - the cost of goods and services purchased from external suppliers" (page 83).

Progress. "In 2025, Nordic's Scope 1 and 2 emissions accounted for 0.1% of its total emissions. Relative to the 2019 base year, Nordic's Scope 1 and 2 emissions have decreased by 89% in 2025, well beyond the 60% target" (page 81).

Intensity rather than absolute for Scope 3. "By taking future developments into account, Nordic has set targets based on emission intensity" (page 82). "Due to increased production activities with its manufacturing suppliers, Nordic anticipates an increase in absolute Scope 3 emissions until renewable energy availability improves in the countries where its suppliers are located, while still reducing Scope 3 emissions intensity." No adaptation target is set.

Energy consumption and mix

Reference: page 83 (content index, page 67). Appendix B marks E1-5 paragraph 37 "Material" and the high-climate-impact-sector energy intensity datapoints (paragraphs 38, 40-43) "Not material" (page 71).

Total consumption fell 14% year on year while the renewable share slipped from 95% to 92%. Self-generated renewable energy is solar "generated on-site at Nordic's head office in Trondheim" (page 86). "Currently, more than 50% of Nordic's employees work in office buildings with green building certifications, like BREEAM and LEED" (page 86). Energy from the outsourced manufacturing base is not included in this table; it sits in Scope 3.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 84-87 (content index, page 67). Operational control approach, GHG Protocol, base year 2019.

Scope 3 by category (2024 / 2025): 1 Purchased goods and services 84,201 / 91,187; 2 Capital goods 5,183 / 13,393 (+158%); 3 Fuel- and energy-related 43 / 96; 4 Upstream transport 87 / 83; 5 Waste 3 / 1; 6 Business travel 1,128 / 1,852; 7 Employee commuting 413 / 421; 9 Downstream transport 1,122 / 794; 10 Processing of sold products 155 / 187; 11 Use of sold products 3,172 / 3,743; 12 End-of-life 22 / 25. Categories 13-15 are not applicable.

"In 2025, Nordic refined its GHG emissions inventory methodology and excluded emissions related to Scope 3 Category 8 (Upstream leased assets)... to avoid double-counting" (page 84); base-year emissions were not recalculated because the effect was below the 5% threshold.

"95% of Scope 3 emissions is calculated using primary data obtained from suppliers" (page 86). Category 1 is 82% of the total, "while manufacturing processes alone accounted for 71%". Intensity fell 11%, to 0.169 (location-based) and 0.168 (market-based) tCO2eq per USD 1,000 (page 85).

Policies related to pollution

Reference: pages 89-90 (content index, page 68).

"Nordic's Environmental Impact Reduction policy addresses its identified pollution-related material impacts. These include air pollution during product production and transportation, as well as hazardous substances in products" (page 89).

Content. The policy "sets requirements for identifying, controlling, and monitoring pollution sources within Nordic's operations, and to reduce potential releases to air, water, and soil. The policy encourages waste reduction and promotes reuse and recycling. It aims to minimize the use of substances of concern and replace substances of very high concern by promoting the adoption of safer alternatives or technologies where technically and economically feasible" (pages 89-90). It also "sets expectations for suppliers to meet Nordic's pollution prevention standards and to follow procedures for reporting and managing pollution incidents and emergencies".

Accountability and standards. "The implementation of Nordic's Environmental Impact Reduction policy falls under the Chief Executive Officer's accountability. The policy adheres to internationally recognized standards, such as ISO 14001 for environmental management" (page 90).

Stakeholders and availability. "In formulating the policy, Nordic has considered the interests of key stakeholders, including regulatory bodies, customers, and suppliers. Direct stakeholder engagement sessions and feedback mechanisms, including surveys, have informed Nordic's policy development." The policy is available through the website, intranet and internal communications, with training "with a particular focus on roles that interface with suppliers".

Actions and resources related to pollution

Reference: page 90 (content index, page 68).

Substances of concern. "manufacturing suppliers must sign and adhere to a declaration confirming their compliance with the requirements outlined in the Hazardous Substances Specification for Suppliers. This specification outlines requirements for substances such as volatile organic compounds (VOCs), ozone-depleting substances (ODCs), and substances of very high concern (SVHCs)" (page 90). Products "undergo testing to verify compliance with relevant hazardous-substance requirements, including independent third-party testing where applicable. Material composition reports and hazardous substance testing certificates for all products are available on the company website".

"In 2025, Nordic continued to use its supplier environmental survey to assess the use of substances of concern and substances of very high concern in manufacturing processes."

PFAS. "In 2025, Nordic also continued its PFAS-free material qualification program... PFAS are currently used in Nordic products delivered as CSP packages. In response to growing concerns and restrictions, Nordic is qualifying PFAS-free materials for its existing and future CSP product portfolio" (page 90).

Air pollution. "To address air pollution from product transportation, Nordic has mapped its distributor partners to better understand relevant transport routes and practices. Air pollution from outsourced production is monitored annually, including suppliers' emission sources and the treatment measures implemented."

Resources. Managed "with resources allocated from its Quality and Supply Chain departments and Compliance unit"; the actions "are not anticipated to require significant operational (OpEx) or capital (CapEx) expenditures".

Targets related to pollution

Reference: pages 90-91 (content index, page 68).

One quantified target: PFAS-free material qualification. "Nordic's PFAS-free material qualification target covers all CSP products in its product portfolio. The target supports Nordic's efforts to phase out PFAS use and minimize their potential release and accumulation in air, water, and soil" (page 90). It "aligns with anticipated future regulations to restrict PFAS use".

Performance, stated plainly (page 91). "A qualification program for PFAS-free materials began in 2023, progressively replacing PFAS with safer, more sustainable alternatives. For 2025, Nordic set a target to have 90% of its CSP products qualify as PFAS-free. Actual completion in 2025 was 64.5%. While the target was not fully achieved due to low demand and delays in qualifying certain CSP products, progress was made. In 2026, it continues to advance PFAS-free solutions across its CSP product portfolio to achieve the 90% coverage."

Methodology: "identifying all existing CSP products containing PFAS and qualifying PFAS-free alternatives". The Executive Management Team approved the target, set in consultation with the Quality and Supply Chain departments.

Two material impacts carry no target, with reasons given (page 91). For air pollution in production: "While Nordic has not set targets for air pollution in the production process, it collaborates with suppliers to communicate pollution-prevention expectations". For transport: "Regarding air pollution generated in the transportation of Nordic's products, the company has not established specific targets. Nordic's distributors manage these operations, and Nordic does not have direct control over them."

Substances of concern and substances of very high concern

Reference: page 91 (content index, page 68).

"Nordic has identified substances of concern and very high concern based on the criteria outlined in Articles 57 and 59 (1) of the REACH Regulation, as well as the hazard classification specified in Part 3 of Annex VI of the CLP Regulation. The presence of these substances in Nordic products is identified through supplier disclosures" (page 91).

Total weight in Nordic IC products, in grams, by hazard class (2024 comparative / 2025):

Substances of concern - carcinogenicity categories 1 and 2: 1,663.2 / 3,144.1; germ cell mutagenicity category 2: 993.9 / 1,879.0; reproductive toxicity category 1: 993.9 / 1,879.0; respiratory sensitisation category 1: 993.9 / 1,879.0; skin sensitisation category 1: 1,645.5 / 3,110.4; chronic hazard to the aquatic environment categories 1 to 4: 8,236.1 / 12,871.1; specific target organ toxicity, repeated exposure, categories 1 and 2: 651.6 / 1,231.4.

Substances of very high concern - carcinogenicity categories 1 and 2: 16,190.9 / 6,762.7; reproductive toxicity category 1: 16,392.0 / 6,871.2; PBT: 16,190.9 / 6,762.7; endocrine disruption for human health: 16,190.9 / 6,762.7.

SVHC weights roughly halved year on year while substances-of-concern weights roughly doubled. Named substances include "NMP, PFAS, boron oxide, and lead oxide" (page 89).

Limb coverage. These are amounts present in products, that is the outflow limb of paragraph 34. Amounts generated, used or procured in production are not quantified - the substances are used in outsourced manufacturing, and Nordic's own operations use only laboratory quantities (page 88). "The metrics presented below for the substances have not been validated by external bodies other than Nordic's assurance provider."

Policies related to water and marine resources

Reference: pages 92-93 (content index, page 68). Appendix B marks "ESRS E3-1 Water and marine resources paragraph 9" as "Material" at pages 92-93, while "ESRS E3-1 Dedicated policy paragraph 13" and "ESRS E3-1 Sustainable oceans and seas paragraph 14" are both marked "Not material" (page 72).

"Nordic's Environmental Impact Reduction policy includes provisions for water, including all geographies in which Nordic operates. The Chief Executive Officer is accountable for implementing the policy. The Environmental Impact Reduction policy adheres to internationally recognized standards such as ISO 14001 for environmental management" (page 92).

Content (page 93). The policy "covers water consumption reduction, reuse and recycling, wastewater treatment, and pollution prevention in its suppliers' operations. The policy's general objectives are to reduce negative environmental impacts proactively and to mitigate risks that could affect health, the environment, or business continuity."

There is no water-specific standalone policy: water sits inside the same Environmental Impact Reduction policy that serves E2 and E5.

Marine resources are excluded. "No material IRO has been identified addressing marine life. Hence, the following sections of this chapter will address only water-related aspects" (page 92). Nordic also states it "does not depend on marine-resource commodities such as seafood or extracted marine products" (page 64).

Stakeholder consultation and availability mirror E2-1: website, intranet, internal communications and training focused on supplier-facing roles.

Actions and resources related to water and marine resources

Reference: page 93 (content index, page 68).

"In line with its Environmental Impact Reduction policy and to address the identified material impact, Nordic continued in 2025 to monitor water withdrawal, consumption, treatment, and discharge in outsourced manufacturing operations" (page 93). The monitoring is expected to provide reliable data on water usage across outsourced production, insight into suppliers' potential water pollutants, better identification of water-related risks "particularly in water-stressed regions", and understanding of "necessary contingency measures for facilities in medium to high-water-risk areas".

Risk screening. "To further strengthen its understanding of water-related risks in its supply chain, Nordic has conducted a risk assessment using external resources, such as the WWF Water Risk Filter. The majority of Nordic's outsourced production is located in Southeast Asia, a region WWF classifies as having medium physical water risk" (page 93).

"In 2025, Nordic conducted an assessment of its manufacturing subcontractors' water use and conservation practices. The insights from this assessment informed the planning and establishment of its water resource target for 2026."

Scope. Water management and contingency plans "have been addressed directly with key suppliers and tier-1 subcontractors via an environmental survey. These stakeholders are located in countries such as the Philippines, Taiwan, Germany, China, Singapore, Poland, and Malaysia."

Resources. "Implementing the water resources action plan does not require significant operational expenditures (OpEx) or capital expenditures (CapEx)." No monetary amount is disclosed.

Targets related to water and marine resources

Reference: page 93 (content index, page 68).

"In 2025, Nordic established a water-related target for 2026 to address material impacts associated with water consumption in upstream production" (page 93). The target uses 2025 as the baseline year and applies to "Tier-1 manufacturing suppliers included in Nordic's supplier monitoring scope, including those operating in medium- to high-water-risk regions".

Target for 2026: "Maintain a minimum of 70 percent water-management-target coverage (covering water withdrawal, conservation, or consumption) among Tier-1 manufacturing suppliers."

2025 position. "In 2025, 70% of Tier-1 manufacturing suppliers reported having established water-management targets. For the purpose of this indicator, a supplier is considered to have a water-management target where it has documented at least one quantitative goal related to water withdrawal, water consumption reduction, or water conservation, with a defined baseline and target year, either publicly disclosed or reported through Nordic's environmental survey." The figure is "the number of suppliers meeting these criteria divided by the total number of Tier-1 suppliers within the monitoring scope".

Nordic states the limitation itself. "Nordic has not established ESRS-aligned outcome targets related to water consumption or water reduction in the value chain. Instead, Nordic applies a process-based indicator to monitor supplier engagement on water stewardship." The indicator "functions as a process indicator of supplier engagement rather than an outcome-based environmental target" (page 93).

Policies related to resource use and circular economy

Reference: page 95 (content index, page 68).

"Nordic has implemented an Environmental Impact Reduction policy that provides a framework for promoting sustainable resource use and fostering circular-economy principles across the company's own operations and its manufacturing suppliers" (page 95).

Content. The policy "aims to reduce reliance on virgin resources where relevant by prioritizing sustainable material choices and integrating renewable or recycled content into products and packaging. The policy also promotes practices to minimize waste in production and responsible recycling of Nordic's products, addressing the material impacts related to resource use in semiconductor manufacturing and packaging, downstream waste treatment of electronic components, and waste generated across the supply chain." Requirements include exploring innovative solutions to reduce dependence on virgin resources, prioritising responsibly sourced materials, and integrating recycled and recyclable materials into product designs and packaging.

Gap acknowledged. "The policy does not explicitly address product durability and reliability as circularity measures. Still, it requires Nordic to promote circular-economy principles, reflecting its intention to reduce environmental impact and support the sustainable product lifecycle" (page 95). Product durability is one of the four material E5 IROs, so this is a stated policy gap against a material impact.

Implementation responsibility, standards, stakeholder consultation and availability are cross-referenced to E2-1 (pages 89-90): CEO accountability, ISO 14001 alignment, website and intranet availability.

Actions and resources related to resource use and circular economy

Reference: pages 95-96 (content index, page 68).

Waste management in production. "As part of the 2025 annual environmental survey, Nordic collected production waste data from manufacturing suppliers, supported by resources provided by its Quality and Supply Chain departments" (pages 95-96).

Raw materials. "While Nordic does not purchase raw materials directly from mining companies and has no influence over mining operations, the company strengthens oversight of material use by systematically collecting and maintaining material composition reports and material safety data sheets for each component" (page 96).

Recycled plastic packaging. "In 2021, Nordic launched a plastic reduction program in collaboration with assembly suppliers in its upstream value chain... The first reels made of recycled plastic were qualified and introduced for Nordic devices in 2022." A limitation is stated: "some of its customers still require devices packed in trays for which no recycled-plastic version is available. This limits the portion of production volumes that can use recycled plastics."

Product longevity. "In 2025, Nordic acquired the cloud platform provider Memfault", enabling "remote diagnostics, device monitoring, and firmware updates". Integration "is planned to progress over the medium term, including 2026-2027".

Impacts without actions, with reasons (page 96). For downstream packaging waste: "Nordic has not set any actions for this material impact, as the Group does not have control or influence over how its distributors and customers manage packaging waste." For downstream EEE waste treatment: "The responsibility for actual waste disposal lies with customers, and Nordic has no means to verify this."

Each action "does not require significant operational (OpEx) and/or capital (CapEx) expenditures".

Targets related to resource use and circular economy

Reference: page 96 (content index, page 68).

Nordic states the position directly: "Nordic has not set any measurable targets for resource use and the circular economy. Further groundwork is required before setting goals, including defining their scope, measurement approach, and appropriate timeframes" (page 96).

Reason for the gap on supplier waste. "Waste management at Nordic's manufacturing suppliers' sites is material; however, because it is outside Nordic's direct control, the company has not set targets for this material impact. By regularly monitoring and analyzing waste data collected from its suppliers, Nordic can monitor the implementation of its policy and actions in this area, using 2024 as a baseline year" (page 96).

Tracking in place of a target. "Aligned with its Environmental Impact Reduction policy and commitment to reducing reliance on virgin plastic resources, Nordic focuses on using recycled plastic for device packaging... To evaluate progress in recycled plastic use, Nordic monitors the share of containers made from recycled plastic and the total volume of recycled plastic used in their production, with 2021 as the baseline year" (page 96).

This is the MDR-T alternative limb - effectiveness tracked through monitored indicators in the absence of a measurable outcome target. The share of device containers made from recycled plastic reached 51% in 2025 from a 2021 base of 0% (page 97), but Nordic does not attach a target value or target year to it.

Resource inflows

Reference: pages 96-98 (content index, page 68).

Materials named by the company (page 96). "In semiconductor manufacturing, the primary raw materials include silicon and a range of essential metals, such as aluminum, copper, tin, and silver." "The manufacture of wafers for Nordic products involves trace amounts of rare-earth elements; however, these are not present in the final products."

Total weight of materials. "In 2025, Nordic product manufacturing used approximately 38 tons of materials, compared to 32 tons in 2024, including all substances and components used in the products. This metric is based on product material composition reports, which provide accurate product weight data and Nordic's internal production records for 2025" (page 96).

Secondary and biological content (page 97). "Semiconductor production requires high-purity materials to meet the stringent requirements of nanometer-scale technology nodes. Therefore, recycled materials are not suitable for Nordic products. Biological materials are not used in the production of Nordic products or packaging." That is a nil return on the secondary-reused-component limb, not an absence of disclosure.

Packaging plastics (page 97):

Development kit packaging is "Forest Stewardship Council (FSC) certified, recyclable cardboard". "The metrics related to Nordic's resource inflows have not been validated by external bodies other than the assurance provider" (page 98).

Resource outflows

Reference: page 98 (content index, page 68).

Recyclable content, quantified. "The average recyclable content of Nordic's products is 53% for QFN components and 22% for CSP components, based on the weight of the metals relative to the total material weight, as specified in the product material composition reports" (page 98).

Durability, quantified with method. "Nordic's products are designed with an emphasis on reliability (durability and long-lasting performance), with a minimum expected operational lifespan of 9 years. The lifespan is based on a 1000-hour HTOL (High-Temperature Operating Life) test, with an acceleration factor (Arrhenius equation) of 78.6, using an activation energy of 0.7 eV and a use temperature of 55 C" (page 98).

Reparability, stated as a limit. "While Nordic products are not designed for repair, the ability to perform firmware updates over the air keeps them functional and up to date without requiring remanufacturing." "While Nordic products cannot be reused after assembly, they can still contribute to resource conservation and waste reduction through recycling efforts."

Packaging. "Reels are also 100% recyclable... In addition, packaging for development kits is made of 100% recyclable FSC-certified cardboard."

Nordic does not report tonnages of products and materials leaving its own operations, consistent with a fabless model where production sits at suppliers. "The metrics related to Nordic's resource outflows have not been validated by external bodies other than its assurance provider" (page 98).

Waste

Reference: page 98, within the E5-5 disclosure indexed at page 68; supplier waste actions at pages 95-96.

No waste tonnages are reported. Nordic generates no material waste in its own operations - it is fabless and office-based - and does not disclose quantities for the upstream and downstream waste it identifies as material. The Appendix B table marks "ESRS E5-5 Non-recycled waste paragraph 37 (d)" and "ESRS E5-5 Hazardous waste and radioactive waste paragraph 39" as "Not material" with no page reference (page 72).

What is disclosed (page 98). "Nordic collaborates with suppliers on measures related to production yields, material use, and waste-management practices, including sorting and recycling in line with applicable local requirements. To support effective waste management practices, Nordic qualifies all manufacturing suppliers and mandates that they obtain ISO 14001 certification as a standard for environmental management." "Nordic lacks visibility or control over the disposal of its products at the end of their lifecycles. To support responsible waste management, product data sheets include guidelines for proper disposal."

Where the impact sits (pages 54 and 95). Supplier and distributor waste generation covers "defective wafers and chips, process chemicals, and packing materials", while downstream EEE waste "may release hazardous chemicals into the air and contaminate soil and water sources". Nordic states that "Environmental impacts are further amplified by inefficiencies in waste sorting, differences in local waste treatment practices, and limited visibility into waste handling across different regions".

Waste is also the smallest Scope 3 category: category 5 fell from 3 to 1 tCO2eq (page 85).

Policies related to own workforce

Reference: page 106 (content index, page 68). Appendix B marks the S1-1 datapoints on human rights policy commitments (paragraph 20), ILO due diligence policies (21), trafficking prevention (22) and workplace accident prevention (23) all "Material" at page 106 (page 73).

Policies "draw on international frameworks, including the UN Global Compact, the UN Guiding Principles for Business and Human Rights, the OECD Guidelines for Multinational Enterprises, the International Bill of Rights, and the ILO core conventions" (page 106).

• Code of Conduct - "sets expectations on integrity, human and labor rights, health and safety, diversity, equity, inclusion, and personal conduct", approved by the Board, CEO accountable, embedded in onboarding through mandatory training.
• Equal Opportunities Policy - "sets principles for fair recruitment, equitable practices, and the removal of systemic barriers", with BoD oversight and EMT accountability.
• Health and safety - "Nordic operates a safety management system across all locations... In Norway and Finland, the system is ISO 45001-certified."
• Human Rights Policy - standalone, adopted by the BoD, implemented by the EMT.

Gap stated by the company. "Nordic does not currently maintain a formal Learning & Development policy. Still, it relies on established practices such as role-based onboarding, on-the-job and peer learning, mandatory training, and manager-led development discussions... a policy is under development and expected to be implemented in 2026" (page 106). "Not all material impacts identified under S1 currently have a dedicated formal policy."

Processes for engaging with own workforce and workers' representatives

Reference: pages 106-107 (content index, page 68).

"The Senior Vice President of People & Culture oversees these engagement processes and monitors the effectiveness of actions based on feedback" (page 106).

Representatives. "Nordic has house and union employee representatives in Norway, Finland, and Poland. In Norway and Poland, it holds monthly forums to discuss business updates and strategic decisions, while in Finland, meetings are held as needed." "It does not have a specific agreement on human rights with employee representatives, as this is covered in its Code of Conduct and regulated by local laws." Designated Health and Safety representatives in each office escalate safety concerns.

Direct feedback (page 107). "In 2025, it has moved from one annual survey to quarterly surveys to gauge employee sentiment more frequently... In 2025, the surveys had an average response rate of 80%, with the highest participation in its baseline survey conducted in Q3."

Scores on a 1-10 scale: "Zero tolerance for unethical behavior (9.1), Peer relations (8.9), Acceptance (8.9), Psychological safety (8.9), and Manager Support (8.8). Its biggest improvements were in Communicating strategy (+0.7) and Transformation & Change (+0.5)."

"In 2025, 74.4% of employees formally completed annual appraisal conversations (2024: 80.7%)."

Survey results "also provided feedback that helped inform its Double Materiality Analysis and strategic priorities", and gender-disaggregated analysis "informed its Equal Opportunity Analysis focused on female employees".

Processes to remediate negative impacts and channels to raise concerns

Reference: page 107 (content index, page 68). Appendix B marks "ESRS S1-3 Grievance/complaints handling mechanisms paragraph 32 (c)" as "Material" at page 107 (page 73).

"Employees are encouraged to report concerns or complaints related to harassment, legal or financial impropriety, or other issues to their manager, a local HR Business Partner, employee representatives, or through Nordic's independent whistleblowing mechanism, as detailed in G1-1" (page 107).

Handling. "Upon receiving a grievance, it conducts thorough due diligence to collect and verify the facts of a case and, when necessary, implement corrective actions to address any negative impacts. The nature of remedial action depends on the issue at hand. Concerns are tracked in a case system and reported to the Audit Committee for monitoring."

Non-retaliation. "Nordic has a zero-tolerance policy for retaliation against anyone who speaks up in good faith by raising a concern, reporting a suspected violation, or participating in an internal investigation. The Head of Compliance is responsible for regular reporting to the Chief Executive Officer and the Audit Committee of the Board."

Effectiveness testing. "In its annual Engagement Baseline Survey, Nordic gathers feedback to monitor awareness and assess employees' trust in the structures and processes. This year's feedback indicates that employees consider unethical and illegal behavior to be appropriately addressed, feel comfortable raising concerns, and are aware of the available reporting channels" (page 107). No numeric awareness figure is given.

Taking action on material impacts on own workforce

Reference: page 108 (content index, page 68).

Training and skill development. "In 2025, Nordic has taken steps to centralize its administration and reporting systems, enabling greater visibility to support broader, more equitable access to training. In 2026, Nordic plans to further strengthen its approach to learning by formalizing training and skill development." "In 2025, Nordic introduced a blended onboarding program for new managers across its global operations", alongside an expanded internal course portfolio "in onboarding, compliance, and other organization-specific areas".

Representation and equal opportunities. "In 2025, alongside monitoring employee experience through its surveys, Nordic conducted an Equal Opportunity Analysis focused on women to identify potential systemic issues. In 2026, it plans to expand this analysis to include international employees." "In 2025, Nordic launched the Women@Nordic Community", including "the GetConnected Program, which pairs young female engineers with experienced women at Nordic".

Health and work-life balance. "In 2025, it launched an Ergonomics Initiative to adapt work environments to employees' physical needs and reduce health risks associated with desk-based work. This initiative will be rolled out across locations in 2026 and includes ergonomic assessments by external specialists, instructional webinars, and an Active Breaks Campaign." After the 2024 restructuring, "Nordic conducted a dedicated survey in 2025 to monitor well-being and identify teams struggling with high workloads", followed by "targeted, case-by-case measures such as restructuring, process optimization, or hiring".

Resources. The actions "are not expected to have a significant impact on operational and/or capital expenditures in 2026" (page 108).

Targets related to own workforce

Reference: pages 108-109 (content index, page 68).

2025 targets and outcomes (page 108). "Based on the 2024 baseline, the targets for 2025 were to increase the Overall Engagement score from 7.3 to 7.7, the Transformation & change score from 6.6 to 7.0, and the Learning & Growth score from 7.3 to 7.6. Nordic achieved the targets for Overall Engagement (2025: 7.8) and Transformation & Change (2025: 7.1), but fell slightly short on Learning & Growth (2025: 7.5)."

2026 targets. "Nordic's actions aim to increase the Learning & Growth score from 7.5 to 7.7 in 2026." For health and wellbeing, "the key target is to maintain short-term sick leave <=2.5 % in each country of operation" (page 109).

Representation - a deliberate absence of a deadline. "Based on the results of the Equal Opportunity Analysis conducted during 2025, Nordic strives to increase the number of women in senior leadership roles in the long term. A specific deadline has been intentionally avoided to avoid the risk of tokenistic or non-merit-based promotions. Instead, Nordic commits to continuous progress and long-term talent development, which aligns with ESRS expectations for realistic workforce objectives" (page 109).

"Following gaps observed in 2024, Nordic strengthened its governance arrangements, data foundations, and analytical work related to equal opportunities and talent development in 2025. The definition and operationalization of measurable targets remains ongoing" (page 109). Targets "were developed by a group of internal experts and anchored with the corresponding management team member" (page 108).

Characteristics of the undertaking's employees

Reference: pages 109-111 (content index, page 68).

"Headquartered in Trondheim, Nordic has a total headcount of 1,426 employees across 24 countries (2024: 1,371 employees across 22 countries). Of these, 1,390 were full-time employees" (page 109). "The majority of the increase in headcount is due to the acquisitions of Memfault and Neuton, both in 2025, which added 55 additional permanent employees."

By gender, headcount (2024 / 2025): male 1,133 / 1,171; female 238 / 252; other gender categories not disclosed 0 / 3; total 1,371 / 1,426. "Due to privacy considerations and a low number of individuals, additional gender categories are not broken out."

By contract type, 2025 (page 111): permanent 1,418 (female 247, male 1,168, other 3); temporary 8 (female 5, male 3); non-guaranteed hours 0; full-time 1,390; part-time 28.

Turnover. "In 2025, 130 employees left the company, of which 78 left voluntarily, resulting in a voluntary turnover rate of 5.70% (2024: 7.24%)" (page 109). The accompanying table rounds this to 6% for 2025 and 7% for 2024, with 78 voluntary leavers against 101 in 2024.

By country, 2025 (pages 110-111): Norway 569, Finland 293, Poland 110, USA 93, Philippines 72, Taiwan 58, UK 53, India 49, Sweden 35, China 30, Germany 12, Hong Kong 11, Singapore 8, Japan 6, South Korea 4, Canada 4, and smaller populations in Denmark, Netherlands, Australia, Spain, UAE, France, Italy and Portugal. Nordic reports 58 nationalities across 24 countries.

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

Reference: page 112 (content index, page 68).

"In addition to its employees, Nordic's workforce also comprises 67 non-employees. These consist of contractors counted at year-end. The contractors are employed by third parties but engaged in employment activities with Nordic. The number is gathered from its HRIS as of December 31, 2025" (page 112). The comparative is 51 for 2024, a 31% year-on-year increase.

Nordic defines a contractor as "a person hired through a third party on a time-limited contract" (page 112).

Method and its limits, stated by the company. "This provides a snapshot of the Group's use of non-employees. The downside is that the number fluctuates throughout the year and will not capture these fluctuations. The upside is that, by consistently reporting this number from the same date, it will be able to see trend changes in the use of non employees" (page 112).

The disclosure is a single headcount. There is no split between self-employed people and people provided by undertakings primarily engaged in employment activities, and no breakdown by gender or country for the non-employee population.

Diversity metrics

Reference: page 112 (content index, page 68).

Gender diversity at top management. Women in top management: 1 (9%) in 2024 and 1 (9%) in 2025 (page 112). This is consistent with the EMT composition reported under GOV-1 - eleven members, one female (9%) and ten male (91%) at 31 December 2025 (page 40).

Age distribution.

"Age group percentages are calculated using employees with available age information in the HR system; employees without recorded age data are included in total headcount but not allocated to age categories" (page 112).

"The average employee age in 2025 was 41.5 years old. The youngest employee was 22, and the oldest was 68 in 2025." Nordic frames the metric around its ambition "to be an inclusive and attractive workplace for employees across all age groups and phases of life".

Women are 252 of 1,426 employees, and the S1 narrative states that "Women represent approximately 18 % of Nordic's total workforce. Representation varies significantly by region and function, with notably lower proportions in engineering roles and senior leadership positions" (page 105). None of the S1 metrics "has been validated by external bodies other than its assurance provider" (page 108).

Health and safety metrics

Reference: page 112 (content index, page 68). Appendix B marks "ESRS S1-14 Number of fatalities and number and rate of work-related accidents paragraph 88 (b) and (c)" and "Number of days lost to injuries, accidents, fatalities, or illness paragraph 88 (e)" as "Material" at page 112 (page 73).

"Nordic's Health and Safety Management System is designed to cover 100% of its workforce" (page 112).

2025 outcomes (page 112):

• "There was 1 recordable work-related accident and 2 cases of work-related ill health."
• "There were 0 fatalities due to work-related injuries or work-related ill health in the year."
• "0 days were lost due to work-related injuries or work-related ill health."

No 2024 comparatives are printed alongside these figures, and no accident rate per million hours worked is given, so the disclosure is a count rather than a rate. The management system "is ISO 45001-certified" in Norway and Finland (page 106), which is narrower than the 100% coverage claim for the system itself.

The related material impact is desk-based rather than industrial: "Prolonged desk-based work exposes employees to musculoskeletal strain and other chronic health risks. Although individual cases remain limited, the exposure is broad and persistent across functions" (page 55). The 2025 Ergonomics Initiative responds to it (page 108). None of the S1 metrics "has been validated by external bodies other than its assurance provider" (page 108).

Work-life balance metrics

Reference: pages 112-113 (content index, page 69).

"Nordic's employees' social protection entitlement means 100% of employees are entitled to parental leave. In 2025, 6% of employees took parental leave, of which 80% were men and 20% were women" (page 112).

Parental leave is defined as "leave from work to take care of the newborn child in accordance with local law and legislation" (page 112).

Take-up rose from 4% to 6% of employees, and the male share of that take-up rose from 71% to 80%. Because Nordic's workforce is roughly 82% male (1,171 of 1,426), the gendered split is not on its face out of line with headcount, but the report offers no commentary on the shift.

The disclosure covers entitlement and take-up. It does not break the take-up rate down by gender as a share of each gender's entitled population, which is the form ESRS S1-15 asks for. Related workload material impacts are addressed qualitatively under SBM-3 and S1-4: recurring high workloads in project-driven R&D "may create stress, fatigue, and risks to well-being" (page 55), and quarterly pulse surveys now "include questions to track employee wellbeing and balance" (page 108).

Remuneration metrics (pay gap and total remuneration)

Reference: pages 112-113 (content index, page 69). Appendix B marks "ESRS S1-16 Unadjusted gender pay gap paragraph 97 (a)" as "Material" at pages 112-113 and "Excessive CEO pay ratio paragraph 97 (b)" as "Material" at page 113 (page 73).

"The gender pay ratio is calculated as the average across positions. In the R&D department in Norway, the average salary for women in 2025 was 85 % of the average salary for men. The average global salary for female employees in all departments was 77% of that of men, excluding executive management. Within executive management, the average salary for female employees was 77% of that of men" (page 112).

Gender pay ratio by category (2024 / 2025, page 112-113): overall excluding EMT 75% / 77%; Executive Management Team 78% / 77%; Business Support 81% / 83%; R&D 81% / 88%; Sales 76% / 97%; Supply Chain 46% / 44%.

Pay ratio. "In 2025, the ratio of Nordic's highest-paid individual's annual total remuneration to the median annual total remuneration for all employees (excluding the highest-paid individual) was 9.68:1. This calculation includes base salary, bonuses, stock options, and other benefits" (page 113).

Explanation offered. "The general salary gap between women and men is explained by a larger share of men in senior positions and a higher proportion of men in customer-facing roles with higher salaries... This affects the ratio, for instance, in the Supply Chain department, where its main locations are in Asia" (page 112).

Comparability caveat. "The remuneration metric was revised in 2025 to refine role classification. As a result, the 'Sales' category now includes only revenue-generating sales roles; sales support functions were included in 2024 but are no longer in scope. This refinement affects year-on-year comparability" (page 112). The calculation population for 2025 is 1,431 payroll employees.

Incidents, complaints and severe human rights impacts

Reference: page 113 (content index, page 69). Appendix B marks "ESRS S1-17 Incidents of discrimination paragraph 103 (a)" and "Non-respect of UNGPs on Business and Human Rights and OECD Guidelines paragraph 104 (a)" as "Material" at page 113 (page 73).

"In 2025, Nordic recorded eight employee complaints through its Integrity Line and other grievance channels. There were no incidents of discrimination or harassment, no severe human rights incidents (such as forced labor, human trafficking, or child labor) connected to its own workforce, including no cases of non-respect of the UN Guiding Principles, ILO Declaration, or OECD Guidelines. There were no related fines or penalties during the reporting period" (page 113).

This is a complete nil return on the discrimination, severe human rights and penalties limbs, together with a positive count of eight complaints. The G1 whistleblowing table gives the matching movement: whistleblowing reports received rose from 4 in 2024 to 8 in 2025, with confirmed retaliation cases at 0 in both years (page 126). No amount of fines, sanctions or damages is disclosed because none was incurred.

The report does not break the eight complaints down by subject, outcome or remediation status, and gives no comparative for the discrimination count. Complaint handling is described under S1-3: concerns "are tracked in a case system and reported to the Audit Committee for monitoring" (page 107). None of the S1 metrics "has been validated by external bodies other than its assurance provider" (page 108).

Policies related to value chain workers

Reference: page 115 (content index, page 69). Appendix B marks the S2-1 datapoints on human rights policy commitments (paragraph 17), policies related to value chain workers (18), non-respect of UNGPs and OECD guidelines (19) and ILO due diligence policies (19) all "Material" at page 115 (pages 73-74).

"Nordic manages its material impacts on value chain workers through its Human Rights Policy, Supplier Code of Conduct, and Conflict Minerals Policy. These policies apply across upstream raw material extraction and processing, Tier 1 and Tier 2+ manufacturing, and downstream logistics operations" (page 115).

• Human Rights Policy - "aligned with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises", prohibiting child labour, forced or compulsory labour, human trafficking, discrimination and retaliation. Nordic "publishes an annual Human Rights Statement in accordance with the Norwegian Transparency Act".
• Supplier Code of Conduct - "based on the RBA Code of Conduct", covering "labor standards, responsible recruitment, working hours and wages, worker safety, humane treatment, and suitable accommodation for migrant workers".
• Conflict Minerals Policy - requiring due diligence "consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas".

Accountability. CEO for the Human Rights, CSR and Conflict Minerals policies; "The Executive Vice President of Supply Chain is responsible for the Supplier Code of Conduct."

Nil return. "Nordic did not identify any instances of non-compliance with the UN Guiding Principles, the ILO Declaration... or the OECD Guidelines for Multinational Enterprises in the upstream or downstream value chain" (page 115).

Processes for engaging with value chain workers about impacts

Reference: pages 115-116 (content index, page 69).

Nordic is explicit that engagement is indirect: "Nordic engages with value-chain workers indirectly through credible proxies, consistent with its fabless business model and limited operational control over manufacturing or logistics facilities. Engagement is primarily conducted through RBA Validated Assessment Program audits, which include auditor-led worker interviews, and through Nordic's human rights due diligence (HRDD) questionnaires completed by supplier management" (page 115).

Timing. "Engagement takes place during scheduled RBA audit cycles, annual HRDD reassessments, and targeted follow-ups triggered by risk indicators or audit findings. Frequency depends on supplier risk profiles and audit schedules" (page 116).

Responsibility. "Operational responsibility for ensuring engagement and integrating results into Nordic's approach rests with the Executive Vice President of Supply Chain. The Head of Compliance oversees the effectiveness of HRDD activities."

Global framework agreements - a stated absence. "Nordic has not established Global Framework Agreements with global union federations; however, it participates in multilateral initiatives such as the RBA and the UN Global Compact" (page 116).

Effectiveness. Assessed "by tracking questionnaire response rates, analyzing audit findings and non-conformities, monitoring corrective action implementation, and reviewing supplier-level improvements".

Vulnerable groups. "To gain insight into vulnerable groups - particularly migrant workers, women, young workers, and workers reliant on employer-provided accommodation - Nordic incorporates targeted questions in its HRDD questionnaire and reviews relevant summaries from RBA assessments" (page 116).

Processes to remediate negative impacts and channels to raise concerns

Reference: page 116 (content index, page 69).

"Nordic addresses material negative impacts through its HRDD framework, which is aligned with the UN Guiding Principles and the OECD Guidelines for Multinational Enterprises. When adverse impacts are identified, Nordic responds directly where it may contribute to the impact and exercises leverage with suppliers where impacts are linked to business relationships" (page 116).

Channel. "The third-party Integrity Line provides confidential, anonymous reporting via an external portal. All reports are handled in accordance with the Reporting and Handling of Concerns Procedure, which sets defined timelines for acknowledgement, assessment, and closure." A "dedicated Transparency Act pathway separate from grievance mechanisms" handles public human rights inquiries (page 116).

Supplier-level channels. "Through the HRDD questionnaire and RBA-aligned assessments, Nordic evaluates whether such channels exist, how they function, and whether migrant workers, young workers, or workers in employer-provided accommodation have adequate access to them."

Limitation stated by the company. "While the Integrity Line provides confidential, anonymous reporting, Nordic has not yet established a formal process to assess workers' awareness of or trust in these mechanisms. Developing such an assessment method is planned as part of program development" (page 116). This is the datapoint ESRS S2-3 asks for on awareness and trust, and Nordic says plainly it does not have it.

Outcome. "No severe human rights incidents requiring formal remedies were identified in 2025" (page 116).

Taking action on material impacts on value chain workers

Reference: pages 116-117 (content index, page 69). Appendix B marks "ESRS S2-4 Human rights issues and incidents connected to its upstream and downstream value chain paragraph 36" as "Material" at pages 116-117 (page 74).

"In 2025, Nordic implemented targeted actions aligned with RBA and OECD expectations" (page 116), one per material impact:

• Gender-based role segregation - "Conducted high-level screening and follow-up dialogues with Tier-1 suppliers on gender-segregated roles and equal-opportunity indicators."
• Forced and child labour in raw materials and Tier 2+ - "Reviewed and followed up on third-party supplier sustainability assessments (including RBA VAP and equivalent ESG rating outputs) and HRDD findings."
• Migrant workers' rights at Tier 1 - "Assessed migrant-worker recruitment and accommodation practices at Tier-1 suppliers and initiated corrective-action tracking where needed."
• Upstream and Tier 2+ safety - "Reviewed smelter HSE-conformance status via RMI and reinforced upstream expectations through engagement with Tier-1 suppliers."
• Tier-1 working conditions - "Reviewed working hours, wages, and employment practice indicators and conducted follow-up dialogues."
• Logistics - "Communicated labor-rights expectations to logistics providers and included relevant indicators in supplier reviews."

Leverage and remedy. "Where Nordic identifies that it may have caused or contributed to an adverse impact, it seeks to provide for or cooperate in remediation. Where impacts are directly linked to Nordic through business relationships, Nordic uses leverage through corrective-action plans, supplier-qualification conditions, and structured follow-up routines" (pages 116-117).

Own-practice check. "Nordic also takes steps to avoid contributing to negative impacts through its own practices by maintaining realistic delivery timelines and clear communication with suppliers" (page 117).

Targets related to value chain workers

Reference: page 117, with the entity-specific metrics table on page 118 (content index, page 69).

"Nordic has established a limited set of interim, process-based targets for 2025... The targets align with the Human Rights Policy and the Supplier Code of Conduct, use 2024 as the baseline year, and apply across relevant tiers of the upstream and downstream value chain in high-risk jurisdictions" (page 117).

Operational targets for 2025 and outcomes (pages 117-118):

Supplier in-depth assessment coverage carries no numeric target; in 2025 it reached 13 Tier-1 high-risk suppliers and 57 Tier-1 medium-high-risk suppliers across RBA SAQ, EcoVadis and Nordic's HRDD questionnaire (page 118).

The company states the limitation. "These targets track implementation of key due diligence controls and therefore function as process indicators rather than outcome-oriented targets." "Nordic has not set outcome-oriented or positive-impact targets for value-chain workers" (page 117).

No worker involvement in target setting. "Nordic did not engage directly with value-chain workers or their representatives in setting these targets due to the structure of the fabless business model" (page 117). Comparability is caveated: the Tier-1 screening tool changed from KPMG's HRDD tool to EcoVadis IQ Plus, and the RMI denominator fell from 10 to 9 partners.

Policies related to consumers and end-users

Reference: page 120 (content index, page 69). Appendix B marks "ESRS S4-1 Policies related to consumers and end-users paragraph 16" and "Non-respect of UNGPs on Business and Human Rights and OECD guidelines paragraph 17" as "Material" at page 120 (page 74).

Three policies are described (page 120):

• Privacy Policy - "outlines its commitments to the lawful, transparent, and secure processing of personal data in accordance with relevant regulations, including the GDPR and CCPA". Its boundary is stated: "It does not extend to personal data processed within customer-built devices that incorporate Nordic's components."
• Information Security Policy - "forms part of the company's ISO 27001-certified Information Security Management System (ISMS)", covering "security governance, protective controls, supplier alignment, business continuity, regulatory compliance, and incident reporting".
• Vulnerability Disclosure Policy - "outlines the company's product security assurance model, including the responsibilities of the Product Security Incident Response Team (PSIRT), responsible disclosure processes, and the utilization of the YesWeHack bug bounty program".

Gap stated by the company. "Nordic does not have a dedicated policy governing the positive downstream impact associated with low-energy connectivity; this impact is advanced through product strategy and R&D priorities under the Sustainability Strategy 2025 - Products building block" (page 120).

Accountability. "Senior accountability for policy implementation rests with the Product Security Director. Operational responsibility is held by the Security Certifications Manager, who also oversees the R&D security program and leads PSIRT activities."

The policies do not reference the UN Guiding Principles or OECD Guidelines directly; they are framed around GDPR, CCPA and ISO 27001.

Processes for engaging with consumers and end-users about impacts

Reference: page 120 (content index, page 69).

"Nordic engages with consumers and end-users primarily through credible proxies, including customers, developer communities, and technical support channels. As Nordic supplies semiconductor components that are integrated into customer-designed devices, direct engagement with end-users is generally limited" (page 120).

Channels (page 120):

• "Customer satisfaction surveys conducted with customers and distributors"
• "Ongoing dialogue with key account customers regarding product performance and integration"
• "Technical support interactions through Nordic's DevZone developer platform"
• "Product quality communication through the Field Quality Group"

Timing. "Engagement occurs throughout the product lifecycle, including during product development through customer collaboration, after product launch through customer feedback processes, and during ongoing product use through technical support interactions. Customer surveys are conducted periodically, while technical support engagement occurs continuously."

Responsibility. "Operational responsibility for ensuring that feedback from these engagement channels informs Nordic's product development and documentation processes rests with the relevant business line management functions, supported by product-security, product-quality, and customer-support teams."

Effectiveness. Assessed "through review of customer survey results, analysis of support inquiries, product quality feedback, and internal management reviews".

No vulnerable end-user groups are identified, and no engagement is described with end-users themselves as distinct from Nordic's direct customers.

Taking action on material impacts on consumers and end-users

Reference: page 121 (content index, page 69).

Supporting the positive impact. Actions "included maintaining and enhancing product datasheets, application notes, and power-profiling documentation that describe low-power characteristics and enable customers to design sustainable IoT applications" (page 121).

Privacy risk. "Nordic maintained GDPR-aligned privacy processes and incident response procedures. In 2025, Nordic reviewed customer-facing documentation where privacy-relevant considerations arise and incorporated privacy considerations into selected security assessments." The boundary is stated: these actions "do not extend to personal data processed within customer-built devices that incorporate Nordic components, for which customers remain independently responsible". "Nordic does not provide customers with advice on legal or regulatory compliance."

Product security risk. "In 2025, Nordic expanded its penetration testing by engaging external security laboratories to conduct independent security assessments of selected chips, ROM, and firmware solutions." Planned actions include "extending penetration testing to additional product families and enhancing security audit routines across business lines".

Cyber Resilience Act. "In 2025, Nordic initiated a multi-year alignment program for the EU Cyber Resilience Act (CRA), which will fully apply from December 11, 2027. The program focuses on documentation governance, requirements for handling vulnerabilities, secure development practices, and lifecycle security management for products with digital elements."

Effectiveness and resources. Monitored "through ISO 27001 controls, internal ISMS audit and certification assessments, security testing results, PSIRT performance indicators, and customer feedback". Resources named are "dedicated product security and compliance personnel, PSIRT operations, secure development engineering time, security testing budgets, and ongoing R&D investment in ultra-low-power architectures", without monetary amounts.

Targets related to consumers and end-users

Reference: pages 121-122 (content index, page 69).

Nordic sets out three tiers of ambition (page 121): "(i) a qualitative objective to support the material positive impact related to sustainable IoT applications, (ii) monitoring-based indicators for privacy-related financial risks, and (iii) a quantitative target for product-security-related financial risks."

Positive impact - no target. "For the material positive impact on sustainable applications, Nordic has not set a quantitative target for 2025. Instead, Nordic applies a qualitative objective to identify and document representative customer use cases that demonstrate how its ultra-low-power connectivity enables more energy-efficient IoT applications... Nordic will use insights gathered during 2025 as the baseline for assessing the feasibility of defining a more structured, outcome-oriented target in a subsequent reporting period."

Privacy - no numeric target. "For privacy-related financial risks, Nordic did not set a numeric target. Monitoring of substantiated privacy incidents in Nordic's own digital services, as well as periodic internal reviews of Nordic's privacy documentation, serve as indicators."

Product security - a quantified target, met. "For product security-related financial risks, Nordic maintains an absolute target of zero critical, unresolved product vulnerabilities. This target was achieved in 2025, with zero critical vulnerabilities remaining unresolved at year-end" (page 121). Severity uses "Nordic's PSIRT severity classification methodology, which aligns with CVSS scoring". Resolution requires "(i) a corrective fix, (ii) an approved mitigation or workaround with documented risk acceptance, or (iii) formal customer communication and closure where remediation is not technically feasible". "The scope covers Nordic hardware, firmware, software, cloud services, and customer-facing technical documentation" (page 122).

No end-users or their representatives are described as involved in setting these targets.

Business conduct policies and corporate culture

Reference: page 125 (content index, page 69). Appendix B marks "ESRS G1-1 United Nations Convention against Corruption paragraph 10 (b)" and "Protection of whistle-blowers paragraph 10 (d)" as "Material" at page 125 (page 74).

"Nordic maintains a business conduct framework grounded in the Code of Conduct, its membership in the Responsible Business Alliance, and its commitment to the UN Global Compact... The Audit Committee (AC) oversees business conduct governance, supported by the Chief Executive Officer (CEO) and the Head of Compliance" (page 125).

Four core policies (page 125): Information Security Policy "aligned with ISO 27001"; Business Continuity Policy and Procedure; Code of Conduct, "setting expectations for ethical behavior, confidentiality, anti-corruption and anti-bribery, responsible system use, reporting obligations, and non-retaliation"; and the Reporting and Handling of Concerns Procedure.

Investigations. "Medium- and high-risk cases are overseen by the Head of Compliance, who may involve internal specialists or external advisors to support independent and impartial case handling. The procedures apply across all global operations and require documented case handling, risk-based escalation, and appropriate corrective actions."

Whistleblower protection. "Nordic enforces zero tolerance for retaliation... Nordic complies with Directive (EU) 2019/1937 and corresponding national law."

Training. "Nordic provides mandatory Code of Conduct training for all employees... Functions with elevated exposure to corruption and bribery - primarily Sales & Marketing and roles with access to confidential information - receive targeted training." No training completion percentage is disclosed for the Code of Conduct itself.

Corporate culture. "While corporate culture is not identified as a standalone material impact, risk, or opportunity, it supports the management of these impacts through governance mechanisms described under G1-1" (page 124).

Targets related to business conduct

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

Reference: page 126.

Nordic sets business conduct targets and reports against them. "Nordic sets interim, process-based targets for 2025. These use a 2024 baseline and apply across all global operations" (page 126):

• "Maintain zero critical unresolved cybersecurity incidents."
• "Achieve at least 90 percent security-awareness completion for campaign-based awareness training."
• "Maintain zero confirmed retaliation cases."
• "Maintain ISO 27001 certification coverage across core IT and information security processes supporting product development."

Outcomes (page 126). Security awareness completion: 96% in 2024, and for 2025 "Not applicable (no campaign-based awareness training conducted in 2025)" against a >=90% target - so that target was not measured this year. Confirmed retaliation cases: 0 in 2024 and 0 in 2025 against a target of 0. Availability of protected reporting channels: Yes in both years. Security incidents by severity moved from High 0, Medium 1, Low 0 in 2024 to High 7, Medium 0, Low 1 in 2025, all on a "Monitoring only" basis. Whistleblowing reports received rose from 4 to 8.

Stated limitation. "Nordic has not established outcome-oriented reduction targets for incident volumes due to evolving threat patterns and ongoing data classification harmonization" (page 126).

"Performance is monitored through incident management systems, Security Operations Center (SOC) reporting, training data, and reviews of whistleblowing cases. Results are reviewed by Information Security and Compliance and reported to the CEO and the AC. No confirmed cases of corruption, bribery, or retaliation occurred in 2025."