Orion

Orion discloses its sustainability governance on page 28, with detailed work experience of the bodies covered in the Corporate Governance Statement. The Board of Directors is the highest governing body overseeing all sustainability matters and approves key policies such as the Code of Conduct. It has 8 members, all non-executive and 100 percent independent, with 0 percent executive members. 62.5 percent are Finnish and 37.5 percent other nationality, gender diversity is 60 percent, average age is 60.3 years and average seniority is 14 years. Board committees include the Audit Committee, which assists the Board in overseeing financial and sustainability reporting, and the Nomination Committee, which ensures the Board has the necessary skills to oversee sustainability. Sustainability is led by the President and CEO, assisted by the 9-member Executive Management Board (88.9 percent Finnish, gender diversity 80 percent, average age 53.9 years, average seniority 7.7 years), which includes an employee representative. Day-to-day responsibility is delegated to the Senior Vice President of Corporate Functions, covering the Corporate Responsibility function. Independence follows the Corporate Governance Code for Finnish listed companies.

On page 28, Orion describes information flows to its governing bodies. Progress on the Sustainability Agenda and sustainability targets is reported quarterly to the Executive Management Board, which reviews and approves policies such as the Sustainability and EHS policies and EHS management principles, and is informed about the results and effectiveness of policies, actions, metrics and targets addressing material impacts, risks and opportunities. In fiscal year 2024, the Executive Management Board addressed topics including quarterly strategy review and alignment, company risk management results including sustainability-related risks, development of a regulatory management framework, updates and approvals of sustainability targets, approval of the climate transition plan, approval of the assessment of dependencies, impacts, risks and opportunities, review of due diligence implementation, diversity/equality/inclusion work, supply chain EHS and sustainability performance, the linkage of sustainability to incentives, and occupational health and safety. The Board of Directors and its committees reviewed policy updates and approvals, sustainability reporting and regulatory development including guiding the IRO assessment and assurance processes, company risk management updates, compliance and ethics, employee well-being, and work safety. Specific trainings on the CSRD and the NIS-2 directive were organised for both the Board and the Executive Management Board in 2024.

On page 30, Orion discloses that the Group maintains both short-term incentive (STI) and long-term incentive (LTI) plans for the President and CEO and other Executive Management Board members. STI performance criteria are decided annually and LTI criteria are set for a three-year performance period. Within the STI plan, 50 percent of targets are company-level and 50 percent are personal, and one of the personal targets is sustainability related. That target is defined by a sustainability index made up of three metrics, each weighted one third: an environmental metric focused on climate change, a social metric addressing occupational safety, and a patient safety metric ensuring reliable global supply of Orion products. These metrics address climate change, occupational health and safety, and health and safety impacts. The remuneration of the President and CEO is based on the remuneration policy approved by the Annual General Meeting 2024. The structure of the plans and related terms and conditions are decided by the Board of Directors. The personal targets of the President and CEO are set by the Board, while those of other Executive Management Board members are set by the President and CEO.

On page 31, Orion presents its statement on due diligence as a table mapping the core elements of the due diligence process to the paragraphs of the sustainability statement where the related information is disclosed. The disclosures relate to impacts on people and the environment. The table follows the five core elements: (a) embedding due diligence in governance, strategy and business model (mapped to GOV-1, GOV-2, GOV-3, SBM-3 and G1-1); (b) engaging with affected stakeholders in all key steps (mapped to GOV-1, GOV-2, SBM-2, IRO-1 and the S1 to S4 policies and engagement processes); (c) identifying and assessing adverse impacts (mapped to IRO-1, SBM-3 and the topical E1 to E5 and G1 IRO-1 sections); (d) taking actions to address adverse impacts (mapped to the topical actions such as E1-1, E1-3 and the S1 to S4 action and remediation disclosures); and (e) tracking effectiveness and communicating (mapped to climate and employee metrics, the E and S targets, and G1-2). The statement is a cross-reference index rather than narrative text.

On page 27, Orion describes risk management and internal controls over sustainability reporting. The purpose of internal control is to ensure sustainability reporting is accurate and compliant with internal guidelines, laws and regulations, as part of the Group's overall internal control. In preparation for the Finnish Accounting Act Chapter 7 and the CSRD/ESRS, in 2024 Orion reviewed and enhanced its internal controls, developing the reporting process, roles and responsibilities, reporting instructions and a new internal control catalogue. Main risks identified include miscalculations and human errors, ambiguities in definitions, and poor or missing data. Mitigation strategies include manual and automated controls such as data quality and availability reviews, trend analysis, sanity checks and up-to-date reporting instructions, integrated into the processes of organisations responsible for the data. The Audit Committee assists the Board of Directors in overseeing financial and sustainability reporting and control, monitoring reporting processes, internal control effectiveness, risk management systems and internal audit plans; shortcomings are communicated to responsible parties, management and the Board. During 2024 the Audit Committee monitored the CSRD reporting implementation project. The statement is subject to limited assurance by a sustainability reporting assurance provider, and comparative 2023 data was assured by PricewaterhouseCoopers Oy.

On pages 33 and 26, Orion describes a strategy confirmed and annually reviewed by the Board of Directors, built on three key elements: (1) build a customer-driven portfolio through competitive businesses (Innovative Medicines focused on oncology and pain, Branded Products in Respiratory and Parkinson's disease, Generics and Consumer Health, Animal Health, and Fermion which manufactures key active pharmaceutical ingredients); (2) expand to new geographies, including strengthening European and Asia Pacific positions and establishing operations in the USA; and (3) develop growth enablers such as competences and culture, safety and sustainability across the product life cycle, global commercialisation, data-driven execution, and mastering the end-to-end value chain. The three-step strategic roadmap is Strengthen and Expand, Build and Invest, and Accelerate. Orion uses a scenario-based continuous foresight and strategising process, with comprehensive scenarios describing possible operating environments in 2035 covering geopolitics, economic and business conditions, technology and sustainability, re-evaluated annually. During the first half of 2024 Orion revised its scenario descriptions with a heightened focus on sustainability, engaging internal stakeholders. Strategy validity, implementation and strategic risks are evaluated quarterly by the Executive Management Board and reported to the Board of Directors. Orion notes it has not assessed its significant market areas in relation to its sustainability-related targets.

On page 35, Orion presents a table of key stakeholder groups and how engagement is organised. The groups are own workforce, suppliers and value chain workers, affected communities (no direct engagement), patients/end-users and consumers, pharmacies, healthcare professionals, customers and partner sales, investors, and policy makers and authorities. Engagement methods are described for each: for own workforce these include country-level meetings with employee representatives, an informal European Works Council, an employee representative on the Executive Management Board and on operations and R&D leadership teams, an EHS platform, a bi-annual Pulse Survey, a biennial Equality survey, a triennial D&I survey, and annual employee reviews. For suppliers, methods include supplier due diligence, a sustainable procurement process, the Pharmaceutical Supply Chain Initiative, the Orion Compliance line grievance mechanism, and on-site audits. The table records the purpose of each engagement and how outcomes are taken into account, for example setting targets and development plans from Pulse Survey results. Views and interests of affected stakeholders about sustainability-related impacts are communicated to the Board of Directors as part of annual sustainability reporting, and in 2024 the Audit Committee received regular updates as part of the CSRD reporting implementation project.

On page 38, Orion presents its material impacts, risks and opportunities and their interaction with strategy and business model. Actual impacts are realised in the short term while the likelihood of potential impacts increases over medium and long term horizons. Material impacts include GHG emissions and climate change (actual across the whole value chain), water pollution from pharmaceutical residues, pollution to soil/water from hazardous substances, water use in high water risk areas, impacts on species (horseshoe crab lysate use), biodiversity and ecosystems, non-circular resource use, various own-workforce and value-chain worker impacts, consumer/end-user impacts (health and safety, access to quality information, privacy, protection of children, responsible marketing), and governance impacts (ethical corporate culture, supply chain sustainability, good governance, data protection, corruption and bribery, animal welfare, whistleblower protection). Of 29 identified risks only one was assessed as material, an aggregated ESG risk related to Orion's long and complex upstream supply chain, driven by social, environmental (pollution, water, biodiversity, most prevalent in India and China) and physical climate risk factors. Pharmaceuticals in the Environment (PiE) is Orion's most material environment-related impact. Of 12 opportunities considered, none were deemed material. Material risks are stated to have no current material financial effects on Orion's financial position, performance or cash flows.

On page 37, Orion describes its process to identify and assess material impacts, risks and opportunities, following ESRS and a double materiality approach combining impact and financial materiality. The materiality assessment was updated in 2023 to 2024, overseen by the Board of Directors and reviewed by the Executive Management Board. The assessment covered the whole value chain holistically. In 2023 a longlist of topics was created from ESRS and other frameworks, narrowed to a short list, then IROs were assessed in workshops with internal experts, with internal and external stakeholders consulted through a survey and workshop; value chain workers and affected communities were not consulted. In 2024 the scope was broadened to ESRS sub-topics and sub-sub-topics, using methodologies including climate and biodiversity scenario work, performance and sales data, Verisk Maplecroft risk data, WWF water and biodiversity risk maps, and an adaptation of the TNFD LEAP analysis, plus discussions with external experts including ecotoxicologists in the SUDDEN project. Impact scoring considered severity and likelihood for negative impacts and scale, scope and likelihood for positive impacts, adapting the PSCI double materiality analysis. Prominent risks and opportunities were assessed by Orion's risk management network using the 0 to 25 rating scale used for business risks. The risk management policy was updated and approved by the Board in 2024, and ESG risks are integrated into the existing risk management process using a three lines of defence model, with the President and CEO accountable. Future revision dates are to be confirmed later.

On page 45, Orion provides a sustainability statement content index listing the ESRS disclosure requirements covered and the page where each appears. For ESRS 2 general disclosures it lists BP-1 (page 27), BP-2 (reported alongside the relevant metric disclosures), GOV-1 (28), GOV-2 (28), GOV-3 (30), GOV-4 (31), GOV-5 (27), SBM-1 (33, 26), SBM-2 (35), SBM-3 (38), IRO-1 (37) and IRO-2 (45). The index then lists the topical standards found material: ESRS E1 Climate change, E2 Pollution, E3 Water and marine resources, E4 Biodiversity and ecosystems, E5 Resource use and circular economy, S1 Own workforce, S2 Workers in the value chain, S3 Affected communities, S4 Consumers and end-users, and G1 Business conduct, each with its disclosure requirements and pages. A separate table lists datapoints deriving from other EU legislation (SFDR, Pillar 3, Benchmark Regulation and EU Climate Law references). Several SBM-1 datapoints on involvement in fossil fuel, chemical production, controversial weapons and tobacco activities are marked Not material, and E1-9 exposure to physical risks is marked omitted from reporting.

Orion developed its first climate transition plan during 2024, approved by the Executive Management Board and adopted in December 2024, with commitment to update it biannually (report p57). The plan aims to make Orion's strategy and business model compatible with a Paris-aligned 1.5 degree world. For own operations, Orion targets a 70% absolute reduction in Scope 1 and 2 emissions by 2030 from a 2023 baseline, approved by the Science Based Targets initiative (SBTi) using the cross-sector absolute reduction (ACA) pathway. For value chain emissions, no absolute reduction target was set, but a SBTi-approved supplier engagement target commits that 78% of suppliers by emissions (purchased goods and services, capital goods, upstream transport and distribution) will have science-based targets by 2029. Orion also commits to net-zero emissions by 2050, though this longer-term target is new, lacks detailed methodology, and is not externally verified. The plan uses a two-pronged approach: an internal investment roadmap for 2030 own-operations targets, plus division-specific plans covering all scopes. Decarbonisation levers (energy efficiency, electrification, carbon-free energy) are expected to cut Scope 1 and 2 emissions by around 10,000 tCO2e by end-decade. Around 95% of emissions come from the value chain.

Orion reports the policies managing its material climate impacts, risks and opportunities (report p59). These are the EHS Policy, Code of Conduct, Third Party Code of Conduct, Sustainability Policy, and Risk Management Policy. The EHS Policy commits Orion to minimising its climate impacts and ecological footprint, covers all operations from R&D through the upstream value chain, and is monitored via measurable targets reported under E1-4; it was approved by the Executive Management Board. The Code of Conduct commits to minimising the ecological footprint including greenhouse gas emissions and extends this to all employees. The Third Party Code of Conduct requires partners to minimise environmental impacts, monitor their greenhouse gas emissions, and reduce them. The Sustainability Policy, effective December 2024 and approved by the President and CEO, commits Orion to limiting global warming to 1.5 degrees per the Paris Agreement, decarbonising operations to meet near-term SBTi-approved targets, and reaching net-zero emissions by 2050; it also addresses biodiversity, water, pollution and resource use, and human rights commitments. Orion states its policies do not currently specify a stance on renewable energy deployment or climate adaptation.

Orion reports actions and resources for climate change mitigation (report p60). In own operations, the main decarbonisation levers are energy efficiency measures and the electrification of production processes, including electrifying steam production and heating. Orion sees no hindrances to implementing planned actions. It has not implemented any significant climate adaptation solutions, and no nature-based solutions have been implemented or considered. One recent example is the Espoo heat pump plant, which began operating in late 2023 with 2024 marking its first full year. Orion notes overall energy consumption may rise due to process electrification, making carbon-free electricity essential. In the value chain, supplier engagement and collaboration is the main lever, advancing the near-term SBTi target that 78% of suppliers by emissions (purchased goods and services, capital goods, upstream transport and distribution) have their own approved SBTi targets by 2029. In 2024 Orion launched a pilot program, run by the Corporate Responsibility Function and Sustainable Procurement team, to understand supplier progress and raise awareness, with plans to expand it. Orion does not report a CapEx plan under Commission Delegated Regulation (EU) 2021/2178.

Orion reports three active climate targets (report p60). First, a legacy carbon neutrality target for own operations (Scopes 1 and 2) by 2030, originally set for Finnish operations and later expanded group-wide after the 2022 VMD acquisition; it has no absolute reduction figure and relies on an investment roadmap, with residual hard-to-abate emissions to be offset by cancelling voluntary carbon credits. No credits toward this target have yet been acquired, and using the original 2016 baseline of 44,456 tCO2e (market-based) absolute emissions have fallen 75%. Second, validated group-wide near-term science-based targets: a 70% absolute reduction in Scope 1 and 2 emissions by 2030 from a 2023 baseline (chosen as the most recent representative full year post-VMD), using market-based Scope 2; baseline Scope 1 and 2 emissions are 13,940 tCO2e. For Scope 3, a supplier engagement target that 78% of suppliers by emissions (categories 1, 2 and 4) have science-based targets by 2029, with no absolute baseline. Third, a net-zero emissions target by 2050, not yet externally approved. Main levers are expected to cut Scope 1 by around 1,100 tCO2e and Scope 2 by around 6,700 tCO2e, with carbon-free energy adding around 2,300 tCO2e by end-decade.

Orion reports total energy consumption of 158,532 MWh in 2024, down slightly from 159,242 MWh in 2023 (report p61 and p64). Total fossil energy consumption was 38,226 MWh (24% of the total), down from 53,158 MWh (33%) in 2023, comprising natural gas (19,150 MWh), purchased electricity, heat, steam and cooling from fossil sources (17,600 MWh), and crude oil and petroleum products (1,476 MWh); coal and other fossil sources were zero. Consumption from nuclear sources was 78,586 MWh, or 50% of the total (up from 46% in 2023). Total renewable energy consumption was 41,720 MWh, 26% of the total (up from 21%), made up of purchased renewable electricity, heat, steam and cooling (41,649 MWh) plus self-generated non-fuel renewable energy (71 MWh); fuel consumption from renewable sources including biomass was zero. Orion generates a small amount of renewable energy in Belgium, some sold back to the grid, with total production of 106 MWh in 2024. All Orion activities fall under NACE categories C20 and C21, classified as high climate impact sectors. Energy intensity was 103 MWh per EUR million net sales. The 2023 comparative data was assured by PricewaterhouseCoopers Oy under GRI Standards.

Orion reports gross GHG emissions for 2024 with a 2023 base year (report p62 and p64). Gross Scope 1 emissions were 5,625 tCO2e, up 2% from 5,511 tCO2e in 2023, with 0% from regulated emission trading schemes. Gross location-based Scope 2 emissions were 11,248 tCO2e (down 4% from 11,726), while market-based Scope 2 emissions were 5,330 tCO2e, down 37% from 8,429, driven by first-time purchase of renewable guarantees of origin for district heating. Total gross Scope 3 emissions were 361,961 tCO2e, down 13% from 417,464. The largest Scope 3 categories were Category 1 purchased goods and services at 277,588 tCO2e, Category 4 upstream transport and distribution at 25,426, Category 5 waste at 20,333, Category 9 downstream transport at 12,828, and Category 2 capital goods at 12,487. Total GHG emissions were 378,834 tCO2e location-based (down 13%) and 372,916 tCO2e market-based (down 14%). Milestone targets are Scope 1 of 1,000 tCO2e and market-based Scope 2 of 0 by 2030, with all scopes at 0 by 2050. Emissions follow the GHG Protocol; around 8% of Scope 3 uses primary supplier data. The 2023 comparative data was assured by PricewaterhouseCoopers Oy under GRI Standards.

Orion reports that it uses carbon credits (report p63). In 2024, Orion voluntarily purchased carbon credits outside its value chain to offset emissions from the entire life cycle of its Easyhaler product range, calculated using a cradle-to-grave life cycle assessment. These credits are not used to meet any GHG emission reduction targets reported in E1-4, are kept separate from reported emissions, and no reductions were made to the emissions reported in E1-6. Credits are purchased annually, and future credits have not yet been purchased with no existing contractual agreements. In 2024, Orion cancelled carbon credits totalling 7,874 tonnes of CO2e using the Gold Standard and Verified Carbon Standard quality standards. Of these, 100% came from reduction projects and 0% from removal projects. By quality standard, 38% were Gold Standard and 62% Verified Carbon Standard. The share from projects within the EU was 0%, and the share of credits qualifying as corresponding adjustments was 0%. Orion does not report any GHG removals from its own operations or value chain.

Orion reports on internal carbon pricing (report p63). Orion states that it does not currently use internal carbon pricing mechanisms or schemes. No internal carbon price, coverage, or application to decisions is disclosed because none is in use.

On report page 66, Orion lists the policies managing its pollution-related impacts, risks and opportunities: the EHS policy, the Code of Conduct, the Third Party Code of Conduct, the Sustainability Policy, and the risk management policy. Orion states these policies cover any relevant pollutants and are not limited to a defined list of substances. The EHS policy sets principles for protecting the environment, reducing EHS-related risks, and minimising Orion's ecological footprint by mitigating negative impacts to air, water and soil, requiring adherence to strict environmental management protocols and striving to go beyond compliance. The Code of Conduct commits Orion to minimising its ecological footprint and preventing environmental harm. The Third Party Code of Conduct requires partners to manage and treat waste, wastewater and emissions, control pharmaceutical releases, and prevent accidental spills. The Sustainability Policy addresses mitigating pollution through sustainable manufacturing, assessing risks from pharmaceutical residues, and combating antimicrobial resistance (AMR). Several policies are cross-referenced to the E1 climate section.

On report page 66, Orion describes actions to prevent pollution. Its primary approach is preventive maintenance and risk management for hazardous chemical handling and storage, including segregating hazardous waste for treatment and conducting regularly updated risk assessments. This approach is in use on all Finnish sites, while implementation at Animal Health sites in Belgium and France is still in process under the Animal Health Compliance and Sustainability development program. Orion has wastewater management practices in Finland that separate environmentally harmful, non-biodegradable streams into separate tanks for third-party hazardous waste treatment, with other wastewater sent to biological treatment. In 2024 Orion completed a project by its Finnish EHS team to better evaluate post-treatment wastewater emissions, improving understanding of Predicted No-effect Environmental Concentration (PNEC) and Predicted Environmental Concentration (PEC) values for Active Pharmaceutical Ingredients (APIs). At the Hanko site, Orion conducts soil remediation for historical pollution by pumping and monitoring groundwater. Orion also assesses suppliers via self-assessment questionnaires or on-site audits, and monitors new EU urban wastewater and Environmental Risk Assessment (ERA) requirements.

On report page 67, Orion discloses that it has not yet set time-bound, outcome-oriented targets related to pollution. Orion states it is working on developing meaningful, outcome-oriented and impact-driving targets for its environmental sustainability. No target years, quantitative values, or baseline figures for pollution are provided.

On report page 67, Orion reports that no thresholds for pollution emitted to air, water and soil, as indicated in the European Pollutant Release and Transfer Register (E-PRTR Regulation), were exceeded in any of Orion's own operations in 2024. No wastewater from Orion's own sites is directly discharged to natural waterways, and no water is recycled or reused by another organisation; wastewater is routed to treatment plants under industrial wastewater agreements. Orion's main air emissions are various volatile organic compounds (VOCs). Its own operations do not typically cause soil pollution except in rare cases such as accidents, and in the reporting year there were no accidents leading to soil emissions. On reporting principles, Finnish sites monitor wastewater pollutants through periodic concentration measurements, while emissions monitoring at Belgium and France Animal Health sites is still being integrated. VOC air emissions in Finland are estimated using mass balance calculations accounting for scrubber efficiency, with site-specific VOC limits set by authorities. Direct measurement of air emissions and off-site wastewater pollutants is deemed not feasible because potential emissions are minor; calculations used sensitivity analysis and the precautionary principle.

On report pages 69 to 70, Orion lists the policies managing its water-related impacts, risks and opportunities: the EHS policy, the Code of Conduct, the Third Party Code of Conduct, the Sustainability Policy, and the risk management policy. The EHS policy addresses water management and sourcing in own operations plus prevention and abatement of water pollution, mandating conservation of resources such as water and mitigation of negative impacts. The Code of Conduct addresses water management, sourcing and pollution prevention by requiring diligent resource conservation and minimising biodiversity impact. The Third Party Code of Conduct requires partners to conserve natural resources, preserve clean water and biodiversity, improve efficiency, reduce water consumption, and properly manage, control and treat wastewater before release, with systems to prevent accidental spills. The Sustainability Policy recognises access to clean water as a fundamental human right and water as a critical resource, committing Orion to sustainable sourcing and use of water across its operations and value chain, enhancing water efficiency, reducing consumption in water-risk areas, and managing discharges to prevent pollution. Policies are cross-referenced to the E1 climate and G1 governance sections.

On report page 70, Orion discloses that it has not yet adopted actions related to water. Orion states it will develop an action plan to achieve any water-related targets once those targets are set. No specific water actions, resources, or projects are reported under this disclosure.

On report page 70, Orion discloses that because water is not currently a material topic in its own operations, it has not yet set targets related to water and does not currently track its water efficiency. Orion states it is working on developing meaningful, outcome-oriented and impact-driving targets for its environmental sustainability. No target years, quantitative values, water withdrawal or consumption figures are provided under this disclosure.

On page 71, Orion explains how biodiversity is considered in its strategy and business model rather than presenting a formal biodiversity transition plan. Orion states that its activities in own operations and the supply chain affect direct drivers of biodiversity loss, mainly climate change and pollution, with potential indirect impacts on land-use change from material use in the value chain. Orion identifies supply chain activities that could potentially affect two threatened horseshoe crab species, the endangered Tachypleus tridentatus and the vulnerable Limulus polyphemus, noting the potential impact is not material but non-zero. Orion also flags potential impacts on other threatened species through material and resource use and says it is working to understand its material use and potential risk materials. To assess own-site impacts, Orion screened site locations against maps of protected and sensitive areas and found no direct material negative impacts. No stakeholder consultations were held, no habitat deterioration or species disturbance occurred in 2024, so no biodiversity mitigation measures were required. Biodiversity risks form part of aggregated supply chain ESG risks.

On page 72, Orion lists the policies managing its biodiversity-related impacts, risks and opportunities: the EHS policy, Code of Conduct, Third Party Code of Conduct, Sustainability Policy, and risk management policy. The EHS policy sets principles for protecting the environment and minimising Orion's ecological footprint, requiring adherence to environmental management protocols and going beyond mere compliance. The Code of Conduct states Orion's dedication to minimising its ecological footprint, conserving resources and reducing waste. The Third Party Code of Conduct requires partners to operate in an environmentally responsible manner, conserve natural resources and clean water, understand and reduce their biodiversity footprint, and manage emissions, waste and spills. The Sustainability Policy commits Orion to work towards no biodiversity loss caused by its business or value chain, to support sustainable resource use, establish supply chain traceability especially for naturally derived raw materials, and minimise pressure on vulnerable species. It acknowledges dependence on ecosystem services such as clean water. Orion states it has not adopted specific policies covering operational sites in or near biodiversity sensitive areas, nor policies to address deforestation.

On page 72, Orion describes actions taken in 2024 to understand the materiality of impacts from materials used in its own operations and upstream value chain. As an initial step, Orion launched a pilot project focusing on lactose and palm oil derivatives, chosen because they are focus materials of the Pharmaceutical Supply Chain Initiative (PSCI). The 2024 pilot mapped the presence of these materials in Orion's product portfolio for human pharmaceuticals and consumer health products. In 2025, Orion plans to continue by evaluating the volumes of these focus materials used in its own manufacturing and in priority products with external manufacturing, with results informing deployment of PSCI's traceability tools on selected raw materials. Orion also developed a screening process for new generics products in 2024 that addresses direct drivers of biodiversity loss and species impacts, including a requirement that lysates derived from the endangered horseshoe crab (Tachypleus tridentatus) are not used. Orion reviewed its own operations and began reviewing contracted Tier-1 suppliers on this. Orion has not incorporated local or indigenous knowledge, nature-based solutions, or biodiversity offsets into its action plans.

On page 73, Orion discloses that it has set targets for climate change, which it identifies as one of its most material impacts on direct drivers of biodiversity loss. Those climate targets are described under E1-4 Targets related to climate change mitigation and adaptation in the ESRS E1 section. Beyond the climate targets, Orion states it has not set other targets related to biodiversity. Orion says it is working on developing meaningful, outcome-oriented and impact-driving targets for its environmental sustainability. No specific biodiversity target years or numerical values are provided in the E4-4 disclosure.

On page 73, Orion states that metrics related to its most material impacts on direct drivers of biodiversity loss have been disclosed elsewhere in the report rather than as standalone biodiversity metrics. Specifically, these metrics are found in the Climate metrics section under ESRS E1 Climate change and in E2-4 Metrics: Pollution of air, water and soil under ESRS E2 Pollution. No dedicated biodiversity change metrics, such as land-use figures or species-level indicators, are quantified in the E4-5 disclosure itself.

On page 74, Orion lists the policies managing its resource use and circular economy impacts, risks and opportunities: the EHS policy, Code of Conduct, Third Party Code of Conduct, Sustainability Policy, and risk management policy. The EHS policy aims to minimise Orion's ecological footprint through diligent work to conserve resources and reduce waste, requiring adherence to environmental management protocols and going beyond compliance. The Code of Conduct states Orion's dedication to minimising its ecological footprint by conserving resources and reducing waste. The Third Party Code of Conduct requires partners to operate in an environmentally responsible manner, manage and treat waste, strive for circularity by designing out waste, improve efficiency, reduce resource consumption including water, favour renewable and sustainable sources, and take measures to reuse and recycle. The Sustainability Policy sets out Orion's dedication to circular economy principles, aiming to ensure own operations, value chain and products support sustainable resource use and waste reduction, and to integrate circular economy principles into production and packaging design where possible without risking patient safety. Orion notes strict industry limits on circularity due to patient safety.

On page 75, Orion describes actions on resource use and circular economy. In API manufacturing, solvents represent significant volumes of total material needs. Some solvents can be reused after regeneration by a distillation process, and regenerated solvents can be reused in steam generation and certain production processes. This solvent regeneration action is continuous at the Hanko and Oulu sites. Orion also runs an ongoing process in which side-stream ethanol, a by-product of API manufacturing at the Hanko site, is directed for use as a carbon source for microbes in a wastewater facility. This improves wastewater treatment plant operation, significantly reduces the nitrogen load entering the Baltic Sea from the factories, and reduces hazardous waste. Additionally, Orion developed a screening process for its upstream supply chain for new human generics products in 2024, which in relation to circular economy addresses measures to prevent packaging waste generation and promote circularity principles in packaging. That screening action is described in more detail under E2-2 Actions and resources related to pollution.

On page 75, Orion discloses that it has not yet set time-bound, outcome-oriented targets related to circular economy and resource use. Orion states it is working on developing meaningful, outcome-oriented and impact-driving targets for its environmental sustainability. In place of formal targets, Orion describes monitoring activities: it monitors solvent regeneration quarterly by measuring the percentage of reused solvents and aims to increase this percentage despite challenges posed by strict quality requirements. The use of regenerated by-product ethanol is monitored through periodic measurements and adjusted to ensure an optimal level of carbon feed for the microbes in the denitrification process. No numerical target values or target years are provided.

On page 75, Orion describes its resource inflows qualitatively without quantified tonnages. Orion states that both its API manufacturing and final product manufacturing require significant volumes of starting materials, raw materials and intermediates. For API manufacturing specifically, solvents represent a considerable volume of the total material needs. Different types of packaging materials also constitute a significant inflow of resources, both in Orion's own operations and in the value chain. No specific inflow tonnages, weights, or percentages of recycled or renewable content are disclosed for these resource inflows.

On page 75, Orion frames resource outflows through waste management, which it describes as a critical part of reducing its environmental impact. Orion aims to align with the EU's waste strategy, which prioritises reducing waste generated and increasing waste recycled. Orion states that most of the Group's waste is hazardous, and most of it comes from API production at the Hanko and Oulu sites. From Orion's other factories, typical hazardous waste fractions include pharmaceutical waste and organic and inorganic chemicals. A considerable part of Orion's non-hazardous waste consists of different types of packaging materials. The materials present in Orion's waste fractions mainly include solvents and other liquid waste fractions with potentially hazardous content. Waste data is sourced from waste transfer databases and waste transfer notes and invoices from contracted waste collectors, collected directly until end of October for France and Belgium and end of November for Finland, with the remainder of the year estimated based on averages. The detailed quantified figures appear in the E5-5 waste metrics table.

On page 75, Orion's waste metrics table reports total waste generated of 19,324 tonnes. Total hazardous waste was 16,111 tonnes, calculated as hazardous waste diverted from disposal plus hazardous waste directed to disposal. Radioactive waste was 0 tonnes. Total waste diverted from disposal by recovery was 5,353 tonnes (2,234 hazardous and 3,119 non-hazardous), split into preparation for reuse 1,900 tonnes (1,525 hazardous, 375 non-hazardous), recycling 813 tonnes (52 hazardous, 761 non-hazardous), and other recovery operations 2,640 tonnes (658 hazardous, 1,983 non-hazardous). Total waste directed to disposal was 13,971 tonnes (13,876 hazardous and 95 non-hazardous), comprising incineration 10,690 tonnes (10,607 hazardous, 83 non-hazardous), landfilling 6 tonnes (all hazardous), and other disposal 3,275 tonnes (3,264 hazardous, 11 non-hazardous). The sum of non-recycled waste, defined as waste directed to other recovery operations plus total waste directed to disposal, was 16,611 tonnes, giving a non-recycled waste percentage of 86 percent.

Orion discloses (p78) that the policies managing its material own-workforce impacts include the Code of Conduct, People Policy, Prevention and Response to Workplace Harassment and Discrimination Guideline, EHS Policy, Privacy Policy, Global Personnel Privacy Notice, and Privacy Statement. The People Policy commits Orion to fair, inclusive and sustainable working conditions for all employees and contingent workers, aligning with ILO conventions and addressing material impacts on working conditions and equal treatment. The EHS Policy sets the Group commitment to safety, injury prevention and continual EHS improvement, covering all employees across all geographies, and is built on ISO 45001 principles. The Harassment and Discrimination Guideline establishes a zero-tolerance approach and lists protected grounds including racial and ethnic origin, sex, sexual orientation, gender identity, disability, age, religion, and others. The Executive Management Board is ultimately responsible for the People Policy, while the Senior Vice President for People and Culture owns the Harassment Guideline and the Global Personnel Privacy Notice. In its Code of Conduct, Orion commits to the UN Guiding Principles on Business and Human Rights and prohibits trafficking, forced, bonded and child labour.

Orion describes (p80) a structured process for engaging with its workforce through both mandatory and voluntary forums and regular consultations with designated workers' representatives. Direct engagement includes employee feedback mechanisms, regular surveys and open forums, while workers' representatives take part in recurring meetings with management, giving a collective voice and enabling two-way communication on policies, initiatives and potential changes affecting the workforce. To reach individuals potentially more vulnerable to negative impacts, Orion runs personnel surveys with a methodology designed specifically for that purpose. Engagement happens at key stages such as when developing or evaluating changes to structures, ways of operating and processes, occurring regularly, at project milestones and in response to legal or stakeholder needs. Orion systematically handles employee feedback, integrates it into decision-making where possible, and communicates outcomes through newsletters, employee representative meetings and other announcements. The Senior Vice President for People and Culture holds operational responsibility for ensuring engagement takes place. Orion assesses engagement effectiveness by reviewing feedback, participation rates and outcomes related to workforce concerns.

Orion reports (p80) processes to remediate negative impacts and channels for workers to raise concerns. For health and safety, employees and contractors can report incidents, positive observations and near-misses via a dedicated reporting platform, including anonymously, with all incidents investigated and corrective actions tracked. Every site in Finland has an occupational safety and health committee with employer and employee representatives. For working conditions and privacy, Orion commits to providing or contributing to remedy where it has caused or contributed to negative impacts, engaging with the affected individual to assess the appropriate remedy and its effectiveness. Established channels include the Orion Compliance Line (a confidential reporting platform), a Notification Form for reporting inappropriate conduct, formal and informal social dialogue forums, and Pulse Surveys distributed globally to each employee. All channels are created and maintained by Orion, which opts not to participate in third-party mechanisms, and are available on the corporate intranet. Orion tracks and documents all issues raised, and regularly assesses awareness and trust in these channels through employee surveys. Retaliation policies are covered under section G1-1.

Orion describes (p81) actions on material workforce impacts. For health and safety, it runs an EHS development program in Finland with themes of safety leadership, safety performance management, risk awareness and learning organisation. The main ongoing action is the Safety Value Creation Program for 2023 to 2025, covering Finnish production sites, with projects on practical safety leadership, metrics and rewarding, competence management, root cause analysis and operational safety. In 2024 it increased line managers' root cause analysis competence, followed up on incident investigation quality, ran safety training for selected managers and documented safety-critical processes. Health and safety decisions for the France and Belgium sites will be taken in 2025, when EHS tools and the incident reporting system will also be deployed there. For working conditions and privacy, Orion revised onboarding, refresher and line manager trainings starting 2024 for 2025 implementation, adopted the global People Policy plus the Harassment and Discrimination Guideline and Global Personnel Privacy Notice in 2024, and rolled out globally consistent job grading to improve compensation transparency. There were no actual material impacts in 2024 requiring remedial action. Surveys are the primary method for tracking effectiveness.

Orion discloses (p83) targets related to workforce impacts, focused on health and safety. Its long-term target is zero accidents, monitored through the Group-level Lost-Time Incident Frequency indicator (LTIF 1). For 2024 the annual target was LTIF 1 of 2.5 or less for Orion Group, but the actual result was 4.9. In 2023 the Group LTIF was 4.8 against a target of 2.9 or less, and this comparative 2023 data was assured by PricewaterhouseCoopers Oy under limited assurance of the voluntary 2023 GRI-based reporting. The target covers all Orion operations and geographical locations. The Executive Management Board sets the annual targets, and employees and their representatives are informed of the decisions. Safety performance, indicators and key metric results are reported monthly on the Orion intranet and in the EHS IT system by site, with results available to all employees. Workforce representatives in Finland are involved in accident investigation and corrective action identification. Orion states it has not set measurable outcome-oriented targets for other material impacts beyond health and safety.

Orion reports (p83) a total employee head count of 3,712. By gender this comprises 1,598 male, 2,102 female, 0 other, and 12 not reported. By country of significant employment, Finland has 2,804 employees, France 182 and India 156. By contract type, of the 3,712 total, 3,523 are permanent (1,989 female, 1,528 male, 6 not disclosed) and 103 are temporary (59 female, 38 male, 6 not disclosed). There are also 86 non-guaranteed hours employees (54 female, 32 male). Gender is as specified by the employees themselves. The employee turnover rate in 2024 was 7 percent, with a total of 246 employees having left. Orion notes the figures are reported in head count and reflect the average number of all employees in 2024, based on the last day of each month, and the turnover rate excludes fixed-term employees.

Orion reports (p84) on collective bargaining coverage and social dialogue. For collective bargaining coverage of employees globally and in the EEA (for countries with significant employment), the coverage rate falls in the 80 to 100 percent band, described as Global. For social dialogue through workers' representation in the EEA (for countries with significant employment), coverage is identified for Finland and France. Orion has an unofficial European Works Council (EWC), established following a joint agreement with employee representatives. Orion notes that while this EWC agreement is not formalised, it facilitates social dialogue and gives employees a platform for representation and communication at the European level, underscoring Orion's commitment to engaging with its workforce through structured and meaningful dialogue.

Orion discloses (p84) diversity metrics for 2024. For gender distribution of top management, there are 59 people in total, of whom 20 are female (34 percent) and 39 are male (66 percent). For age distribution of all employees, 10 percent are under 30 years, 54 percent are between 30 and 50 years, and 36 percent are over 50 years. Orion notes these employee figures are reported in head count and include the average number of all employees in 2024, based on the last day of each month.

Orion reports (p84) health and safety metrics for 2024. The percentage of Orion's own workforce covered by a health and safety management system, based on legal requirements and/or recognised standards or guidelines, is 100 percent. There were 0 fatalities due to work-related incidents. The number of work-related accidents was 68, and the rate of work-related accidents was 11.2. Days lost due to work-related incidents and fatalities totalled 288. Orion explains the rate of work-related injuries is calculated by dividing the number of cases by total hours worked by employees and multiplying by 1,000,000, so the rate represents cases per one million hours worked.

Orion reports (p84) remuneration metrics for 2024. The gender pay gap is reported separately for two employee groups: for white collar employees the figure is 0.88 and for blue collar employees it is 0.92. Orion explains the pay gap is reported as the percentage of average female pay relative to average male pay in each group, so these figures reflect female pay as a proportion of male pay. The pay includes fixed annual basic salary but excludes variable components, and job grade and location are not taken into account; data is as at 31 December 2024. For CEO pay, the annual total remuneration ratio of the highest paid individual to the median annual total remuneration for all employees is 43. The median is based on the annual base salary of all employees working for Orion on 31 December 2024, excluding the highest paid individual, with estimated 2024 short-term incentives added, and purchasing power differences between countries are not taken into account.

Orion reports (p84) on incidents, complaints and severe human rights impacts within its own workforce for 2024. There were 3 incidents of discrimination, including harassment. The number of complaints filed through available channels for raising concerns was 22. The amount of fines, penalties and compensation for damages resulting from these incidents and complaints was 0. Orion states that no severe human rights incidents connected to the undertaking's workforce occurred in the reporting period. The reported numbers of discrimination and harassment incidents and filed complaints include those made by people in Orion's workforce across all of Orion's geographical locations.

Orion's policies for managing potential impacts on value chain workers are its Code of Conduct, Procurement Policy, Sustainability Policy, Risk Management Policy, and Third Party Code of Conduct (p87). The Third Party Code of Conduct covers all workers in the upstream value chain, both directly through first-tier suppliers under contract and indirectly by requiring those suppliers to conduct due diligence in their own supply chains. It addresses working conditions, equal treatment and opportunities, and other work-related rights, including freely chosen employment, child labour and young workers, non-discrimination, fair treatment, wages, benefits, working hours, freedom of association and collective bargaining. The Code of Conduct and Third Party Code of Conduct explicitly prohibit human trafficking, forced labour and child labour. In its Code of Conduct, Orion commits to the UN Guiding Principles on Business and Human Rights, the International Bill of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the ILO fundamental conventions, and requires the same commitments from business partners. No cases of non-respect of the UNGPs, ILO Declaration or OECD Guidelines involving value chain workers were reported during the period.

Orion engages with value chain workers through its systematic sustainability approach within procurement (p88). Based on risk assessment, a supplier may be audited on-site, where an auditor carries out worker interviews as a consultation to better identify potential or actual impacts on workers. Audits are conducted on a three to five year interval. Orion's general approach to engagement is described in its Sustainability Policy, which treats engagement as crucial to identifying negative impacts, designing appropriate measures, and evaluating their effectiveness. For VMD procurement (the upstream value chain for products at Orion's Animal Health sites in Belgium and France, including consumables and indirect procurement), implementation of a risk-based approach is ongoing, and at the moment there is no rights holder engagement within the VMD procurement process. The Senior Vice President for Global Operations is ultimately responsible for ensuring audits under the sustainability procurement process are conducted and that their results, including information gathered from engagement, inform Orion's approach to sustainable procurement and to managing impacts on supply chain workers.

Under Orion's Third Party Code of Conduct, third parties in the value chain must establish grievance mechanisms accessible to internal and external stakeholders and encourage their use to report concerns, illegal activities or breaches (p88). Third parties must have a transparent grievance policy that protects reporters and investigation participants from retaliation, reprisal, intimidation or harassment, records complaints, and protects reporter anonymity. The existence of grievance mechanisms and handling processes is monitored through self-assessment questionnaires and on-site audits, and workers' awareness of their employer's mechanism is assessed during on-site audits. Value chain workers or local communities can raise concerns directly to Orion via the Compliance Line, or by phone, mail or a meeting with the Compliance function. If Orion suspects it caused or contributed to material negative impacts, it conducts an internal investigation by an impartial function such as EHS, Compliance, Internal Audit or an external provider. In substantiated cases, remediation and effectiveness assessment consider case-specific circumstances and severity, require a decision by the applicable management representative, and always require consultation of the Corporate Responsibility and Compliance functions, which also monitor that agreed actions are performed.

Supplier adherence to Orion's Third Party Code of Conduct is the basis for preventing impacts on value chain workers, including beyond tier 1 (p89). Orion's risk-based approach evaluates tier 1 suppliers using Verisk Maplecroft country risk data for pharmaceutical suppliers and EcoVadis IQ data for indirect suppliers, covering social, environmental and governance topics. Orion relies on third party audits under the Pharmaceutical Supply Chain Initiative (PSCI) protocol and supplier self-assessments under the PSCI protocol or EcoVadis scorecard, with corrective action plans followed up by re-assessment. No severe issues or incidents connected to Orion's value chain were reported in 2024. Orion regularly screens suppliers against authoritative public reports on suspected or confirmed forced labour. In 2024 Orion initiated a risk material pilot on lactose and palm oil derivatives to better understand materiality of impacts on supply chain workers and local communities. As a PSCI member it can recommend supplier trainings on working conditions, equal treatment and work-related rights. In 2024 Orion put in place a process to provide or enable remedy; specific effectiveness measures will be developed later. Dedicated resources include a Sustainable Procurement Team, procurement teams, the EHS department, Corporate Responsibility, and Legal and Compliance functions.

Orion has not set measurable outcome-oriented targets on reducing negative impacts or managing material risks related to workers in the supply chain (p90). Instead, the audit and supplier self-assessment process is the mechanism for tracking the effectiveness of actions related to all identified material impacts. Orion targets continuous improvement of supplier scores and uses qualitative indicators to follow progress, with the base year being the onboarding of a supplier.

Orion's policies to manage material potential impacts on local communities are its Code of Conduct, Sustainability Policy, Procurement Policy, Risk Management Policy and Third Party Code of Conduct, covering affected communities in Orion's own operations and in its upstream and downstream value chain (p91). In its Code of Conduct, Orion commits to acting in accordance with the UN Guiding Principles on Business and Human Rights and to respecting human rights as expressed in the International Bill of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the ILO fundamental conventions. In its Third Party Code of Conduct, Orion requires the same commitments from business partners for their own operations and value chain. Orion commits to actively ensuring respect for the rights of its rights-holders, including affected communities, and to providing or cooperating in remediation when it becomes aware that its activities have caused or contributed to adverse human rights impacts. Orion's general approach to engaging with affected communities is described in the Sustainability Policy. No cases of non-respect of the UNGPs, ILO Declaration or OECD Guidelines involving value chain communities were reported during the period.

Orion has not adopted a general process to engage with affected communities (p92). This is the full extent of what Orion discloses under this disclosure requirement.

Orion's processes to remediate negative impacts, the channels available for affected communities, and the processes through which Orion supports the availability of these channels through business relationships are the same as those described for value chain workers under S2-3 (p92). Orion does not currently assess affected communities' awareness of or trust in these channels. Policies protecting individuals against retaliation are presented in the G1-1 Policies and Corporate Culture section describing the Compliance Line and the subsection on protection of persons reporting misconduct. In practice this means affected communities can raise concerns directly to Orion via the Compliance Line or by phone, mail or a meeting with the Compliance function, and third parties in Orion's value chain are required to maintain their own grievance mechanisms accessible to external stakeholders.

Orion's processes to prevent impacts on local communities and mitigate related risks are based on Third Party Code of Conduct requirements applying to all suppliers, including on-site audits and self-assessment questionnaires following Orion's risk-based approach to supplier sustainability assessment (p92). As a PSCI member, Orion recognises that industry collaborative action is necessary for preventing and mitigating local community impacts and supports such actions within the PSCI framework, including offering supplier training on managing environmental impacts and ensuing community impacts. The process for identifying what action is needed and the approach to taking action are the same as described under S2-4. Orion's action underway is the risk material pilot: in 2024 it initiated systematic actions to understand the materiality of potential sustainability impacts of materials used in its own operations and upstream value chain, starting with a pilot on lactose and palm oil derivatives. Orion did not have a tracking method in place for assessing the effectiveness of this action for affected communities. No severe issues or incidents connected to Orion's supply chain were reported in 2024. Orion put in place a process to provide or enable remedy in 2024, with specific effectiveness measures to be developed later. Resources are as described under S2-4.

Orion has not set measurable outcome-oriented targets on reducing negative impacts or managing material risks related to local communities in the supply chain (p93). The audit and supplier self-assessment process is the mechanism for tracking the effectiveness of actions related to all identified material impacts. Orion targets continuous improvement of supplier scores and uses qualitative indicators to follow progress, with the base year being the onboarding of a supplier.

Orion's policies for consumers and end-users include its Code of Conduct, Quality Policy, Research and Development Ethics Policy, Pharmacovigilance Policy, Ethics in Marketing Phase Policy, Patient Safety Reporting Privacy Statement, Procurement Policy, and Third Party Code of Conduct (p95). The Quality Policy ensures pharmaceutical product quality across all Orion pharmaceutical and consumer health products, addressing health and safety, access to quality information, and protection of children, and is approved by the President and CEO. The Procurement Policy addresses continued product availability. The R&D Ethics Policy ensures ethical, sustainable R&D and adherence to GLP, GCP and GMP guidelines. The Ethics in Marketing Phase Policy covers benefit-risk monitoring, adverse event reporting, pharmacovigilance systems, fighting counterfeit drugs and marketing training. The Pharmacovigilance Policy ensures monitoring of product safety across the life cycle, with a Qualified Person responsible for pharmacovigilance. The Patient Safety Reporting Privacy Statement governs personal data related to patient safety reporting. In its Code of Conduct, Orion commits to the International Bill of Human Rights, ILO instruments, the UN Convention on the Rights of the Child, OECD Guidelines and UNGPs. No cases of non-respect involving consumers or end-users were reported.

Orion engages with patients, consumers and end-users through dialogue with patient organisations (p96). Engagement aims to understand patient and consumer experiences of Orion's products to ensure safe, effective, high-quality and cost-effective products, to incorporate feedback into development of new medications, to provide product information and guidance supporting appropriate use and engagement to treatment, to improve usability and responsible disposal of medications, and to assess the effectiveness of measures taken on concerns raised. Orion's Chief Medical Officer has operational responsibility and ultimate accountability for ensuring this engagement takes place and that results inform relevant processes. Engagement frequency is determined by arising needs related to products and needs raised by patient organisations, and effectiveness is assessed as part of product safety reviews. Orion follows pharmaceutical industry requirements addressing special populations: vulnerable or typically excluded populations have special focus in post-approval safety surveillance, including follow-up of pregnancy and breastfeeding exposures and careful collection of paediatric and elderly data. Visually impaired patients are considered through Braille markings on medicinal product packaging to prevent medication errors.

Patients, consumers and end-users have several channels to report adverse effects, product complaints, feedback and questions: Orion websites, company representatives, authorities, and the weekday product information call centre (p96). Each Orion employee is trained and required to report adverse effects to the correct recipients. Patients, consumers and end-users can also use Orion's whistleblowing channel for concerns about ethical conduct. Orion has processes to ensure issues are processed without delay under strict legal timelines, which it closely tracks and monitors; processes are audited internally and by regulatory authorities regularly. Awareness of and trust in these channels is assessed as part of periodic product safety reviews, based on the volume of contacts and any non-conformity with complaints-handling timelines, with shortcomings duly addressed. Orion requires business partners marketing its products to have similar channels, backed by agreements ensuring compliance. Orion is committed to providing or contributing to remedy where it has caused or contributed to negative impacts; remedy for Orion-marketed products relies on a global insurance scheme covering product liability occurrences in any geography. Retaliation protection is covered under G1-1.

Orion does not have time-bound specific actions on preventing potential negative impacts on patients, consumers and end-users (p97). Impact prevention relies on ongoing processes applying the globally highest regulatory standards across the entire human pharmaceutical portfolio regardless of location, continuously reviewed and improved. Actions include continuous benefit-risk assessment through pharmacovigilance, coordinated by the Global Pharmacovigilance and Patient Safety organisation, which collects all global safety data into a single point. Product-specific Risk Management Plans (RMPs) mitigate identified and potential risks. Typical actions include updating product information, Direct Healthcare Professional Communications (DHPC), patient alert cards and educational materials, and post-authorisation safety studies. Quality assurance monitors products throughout shelf life via stability studies, product quality reviews and the customer complaint process; justified complaints trigger root-cause investigation and corrective and preventive actions, and quality issues can lead to recalls of defective batches, performed responsibly to protect continued patient treatment. Sales and marketing follow local law, the International Code on Advertising and Marketing Communication Practice, the Code of Conduct and internal guidelines, with continued training and testing. A scientific service is accessible to healthcare professionals and patients. Remediation availability is ensured through Orion's global product liability insurance scheme; no severe issues or cases requiring remediation were reported.

Orion has not set measurable outcome-oriented targets on reducing negative impacts on end-users, but it monitors several metrics with defined ambition levels (p99). It monitors continuous reliable supply of patient critical medicines for which no alternatives exist in a market, with a goal of 100% availability using the previous year as benchmark. It tracks the quality of good manufacturing processes for product quality, safety and efficacy through GxP inspections by authorities, with a level of ambition of zero critical observations and the previous year as base period. For pharmacovigilance, Orion tracks compliance with regulatory authority reporting timeframes: adverse event reporting timelines (ambition level 98%), Periodic Safety Update Report submissions (ambition level 100%), and implementation of safety-related changes into product information for prescribers and patients (ambition level 100%). Adherence to risk management plan commitments (additional risk minimisation activities) is evaluated periodically each year. Compliance of pharmacovigilance operations is frequently evaluated in internal audits and regulatory authority inspections, with an ambition level of zero critical findings.

On pages 101 and 102, Orion describes its corporate culture and business conduct policies. The foundation is the Corporate Governance Manual and the Code of Conduct, supplemented by the Sustainability Policy, Anti-Corruption Policy, Privacy Policy, and People Policy, plus Standard Operating Procedures. The Code of Conduct, approved by the Board of Directors, centres on three themes: compliance with laws and regulations, integrity, and sustainability. It was revised in 2024 to reflect regulatory and operational changes, is available in 18 languages, and is publicly accessible on Orion's website. All employees and Board members must complete Code of Conduct e-learning and pass its test every two years or whenever the course is updated, and the course collects a compliance commitment from every employee. Orion's whistleblowing channel, the Compliance Line, is a secure online reporting channel maintained by an external service provider, open to internal and external stakeholders reporting suspected misconduct. Reports can also be made directly to the Compliance function by phone, mail, or meeting. Reports are handled confidentially and investigated by the Head of Compliance or an independent function. The Code of Conduct includes a non-retaliation statement, and Orion has been a member of the Pharmaceutical Supply Chain Initiative (PSCI) since 2018.

On page 104, Orion discloses how it manages supplier relationships. Orion has a supplier network in over 50 countries providing packaging materials, raw materials, products, and services. Its Procurement Policy, approved and implemented under the Executive Management Board, covers all procurement activities across the Group and applies to both upstream and downstream value chains, aiming for quality, availability, cost efficiency, compliance with sustainability requirements, and innovation. Suppliers, distributors, and partners are expected to commit to Orion's Third Party Code of Conduct, which is central to using sustainability as a supplier selection principle. In 2019 the Executive Management Board set a target of 100% coverage of all active suppliers of packaging materials, raw materials, and products, with no fixed timeline. In 2024, 94% by spend and 73% by number of suppliers of these active suppliers confirmed adherence to the Third Party Code of Conduct. Orion uses a systematic risk-based approach, assessing suppliers by industry, location, and business criticality, and applies self-assessments or on-site audits as mitigation tools. Through PSCI, audit reports can be shared with other member companies to reduce audit burden. A Compliance and Sustainability development program is underway for VMD suppliers.

On page 105, Orion describes prevention and detection of corruption and bribery. Anti-corruption principles sit in the Code of Conduct and the Anti-Corruption Policy, which apply a zero-tolerance approach prohibiting employees from giving, promising, authorising, or offering anything of value to obtain an improper advantage. The Anti-Corruption Policy was approved by the Board of Directors, which also oversees compliance, and it is publicly accessible on the website and intranet. Business partners must comply with the Third Party Code of Conduct, which references the US Foreign Corrupt Practices Act and the UK Bribery Act. The group-level Anti-Bribery and Corruption compliance programme is driven by the Compliance function, with an annual action plan approved by the Executive Management Board and a compliance review reported to the Audit Committee twice a year. Training is a key preventive mechanism. All employees and the administrative, management and supervisory bodies must complete the Code of Conduct 2024 e-learning, which now includes comprehensive anti-corruption content. White-collar employees, considered functions at risk, must also complete an advanced anti-corruption e-learning module. For that advanced module, coverage was 84% for white-collar employees (2,437 of 2,903) and 100% for the Executive Management Board (9 of 9). Supply chain staff also received classroom training in 2024.

On page 105, under metrics related to business conduct, Orion reports on confirmed incidents of corruption or bribery. In 2024 there were no convictions or fines imposed on Orion Corporation or any Orion Group company for violation of anti-corruption and anti-bribery laws. Throughout the reporting period, no instances of confirmed corruption or bribery were identified within Orion's internal control mechanisms. To the best of Orion's knowledge, there were no legal cases regarding corruption or bribery brought against Orion or against Orion's own workers during the reporting period. In short, Orion reports zero confirmed incidents and zero fines. The reporting principles for these metrics cover Orion's Code of Conduct e-learning and the advanced Anti-Bribery and Corruption e-learning module, with target groups defined as functions at risk across all operating countries and personnel groups, and data validated by Orion's Compliance function.