Redcare Pharmacy

Reference: page 45.

Redcare Pharmacy N.V. is governed by a Managing Board and a Supervisory Board. The Board competence matrix (page 52) maps expertise across both boards against the material sustainability topics. Overall ownership of sustainability sits with the CEO through a direct reporting line from the Director Sustainable Development, who initiates and coordinates the materiality assessment and the related governance processes and controls. A matrix organisational structure combines a central sustainability team with decentral roles in functional departments such as procurement, and accountability for individual material topics is assigned to Managing Board members and the managers who own the relevant function. The Sustainability Steering Committee (SSC), launched in 2025, is chaired by the Director Sustainable Development, with the Executive Director Accounting and Finance as a permanent member overseeing integration with the risk and control framework.

Reference: page 50.

Results of material sustainability KPIs and performance against annual targets are presented to the Managing and Supervisory Boards regularly, and progress on strategic sustainability initiatives is reported in bi-monthly updates to the Sustainability Steering Committee (SSC). Since end-2024 these reports have been aligned to the IROs identified in the double materiality assessment and their related metrics. Throughout 2025 the Managing Board received regular updates on the development of the sustainability strategy, management of material IROs, progress towards targets and regulatory developments, and approved the Climate Transition Plan and the 2026 action plan. The SSC met six times in 2025, covering quarterly results, the Climate Transition Plan, inclusive access to healthcare, health and safety, and the regulatory framework. The Supervisory Board is updated on strategy, and the Audit Committee on reporting and auditing.

Reference: page 51.

Since 2023 Redcare has integrated sustainability-related performance into the incentive schemes applicable to the Managing Board, with general characteristics set out in the Remuneration Policy. Twenty percent of the long-term incentive scheme (three years) for all Managing Board members is linked to sustainability indicators. The ESG performance criterion is a climate-related KPI aligned to the metric Redcare steers internally across departments: GHG emissions per order, covering Scope 1, 2 (market-based) and 3, excluding emissions from products sold (which relate to a large share of Scope 3.1 and all of Scope 3.2, 3.11 and 3.12). The target was set by the Supervisory Board in consultation with the Director Sustainable Development. The Remuneration Policy will be resubmitted for approval at the 2026 Annual General Meeting, with the 2026 ESG performance criteria to be disclosed then.

Reference: page 117.

Redcare's statement on sustainability due diligence follows the EU Corporate Sustainability Due Diligence Directive (CSDDD) principles across five processes. First, embedding due diligence in governance and strategy, overseen by the Managing Board and the Sustainability Steering Committee. Second, stakeholder engagement through consultations and surveys under the Stakeholder Engagement Policy, referencing the UN Guiding Principles and OECD Due Diligence Guideline. Third, impact, risk and opportunity assessment through the DMA's 360-degree analysis of upstream and downstream adverse impacts. Fourth, mitigating risks through corrective actions including the Supplier Code of Conduct, to which suppliers representing 75.6% of core-entity sourcing spend had committed by end 2025. Fifth, quarterly internal tracking and transparent external reporting in the Annual Report, cross-referenced to the relevant topical ESRS chapters for metrics and targets.

Reference: page 50.

The core team from Accounting and Sustainable Development, led by the Executive Director Accounting and the Associate Director Sustainable Development, is responsible for the Annual Report's sustainability disclosures, working cross-functionally with Controlling, HR, Corporate Compliance and Governance, Facility Management and Procurement. An internal control system has been in place since 2024, aligned to financial reporting: an annual assessment identifies risks of material misstatement, including a report on process complexity and the probability of errors and omissions, and this risk assessment is reviewed by the Managing Board and Audit Committee. Risk mitigation is addressed largely through the quarterly internal reporting and steering process described under GOV-2, through which material sustainability KPIs and target performance are presented to the Managing and Supervisory Boards.

Reference: pages 47, 61.

Redcare is one of Europe's largest e-pharmacies, operating in seven countries: the DACH segment (Germany, Austria, Switzerland) and the International segment (Italy, Belgium, the Netherlands, France). Core business activities are B2C (online retail, own brands, medication management) and B2B (marketplace, wholesale, retail media). Main revenue streams sit under NACE codes 47.91.9 (mail order and internet retail) and 47.73.0 (pharmacies); all revenue was determined to fall under high climate impact sector activities. Key stakeholders are suppliers, customers and patients, investors and employees. Upstream activities span raw material and processing, product manufacturing, packaging and transport; downstream covers distribution to the customer, product use and end-of-life. All consolidated entities and all seven geographic markets are considered in scope. Redcare is not active in fossil gas, tobacco cultivation, controversial weapons or chemicals production, and is not excluded from the EU Paris-Aligned Benchmarks.

Reference: pages 53-54.

Redcare's key stakeholder groups for the DMA are customers and patients, employees and workers in the value chain, investors and capital market players, suppliers and business partners, healthcare system players/regulators/the public sector, and Planet Earth as a "silent stakeholder". Engagement combined direct and indirect methods per group: an online questionnaire to customers in Germany plus commercial-management interviews; a questionnaire to all employees plus HR interviews and value-chain desk research; a questionnaire to more than 20 largest investors plus ESG ratings and CFO interviews; a questionnaire to German suppliers and third-party marketplace sellers (with anonymous participation offered) plus commercial, procurement and logistics interviews; management interviews with Public Affairs, Legal, e-health experts and the CEO for healthcare/regulatory stakeholders; and extensive desk research using large language models to represent Planet Earth. All stakeholder groups responded and no new Redcare-specific topics were identified.

Reference: pages 49, 56-58.

Redcare organises its twelve material topics under three pillars: patient care (inclusive access to healthcare, patient health and pharmaceutical excellence, responsible marketing, robust data privacy and security), employee care (healthy, safe and satisfied employees; people development and equal opportunities; fair treatment of workers in the value chain; culture of trust and integrity) and planetary care (climate protection and decarbonization, circularity of products and packaging, minimized pollution in the value chain, preserved biodiversity). The 2025 interim update found no changes to the material topics identified in 2024. Redcare states this represents its most comprehensive assessment to date, that it has assessed the resilience of its strategy with regard to climate change, and that resilience assessments for other material topics remain in progress; future reports will further detail how material impacts connect to strategy and business model.

Reference: pages 53-55.

Redcare's 2024 DMA, updated on an interim basis in 2025, used a five-phase process: scoping of value chain activities and stakeholders; shortlisting IROs using the ESRS 1 AR16 sub-topic list narrowed by internal/external sources and due diligence insights; stakeholder analysis through questionnaires and interviews (see SBM-2); a structured 360-degree analysis by the core team supported by an external sustainability expert with over 20 years' experience; and final integration and Managing Board review, with the highest IRO score per topic determining its position in the materiality matrix. Impact materiality weighs severity (scale, scope, remediability) and likelihood, with severity taking precedence for human rights impacts; financial materiality uses revenue-impact bands from under 0.5% to over 4%. All parameters use a five-point scale with a qualitative threshold of three or higher, and short/medium/long time horizons of under 1, 1-5 and over 5 years. For 2025, deep-dive assessments were completed for E1 and S2, while other topics were reviewed against the 2024 360-degree analysis. Climate-specific risk identification and scenario analysis is also presented under E1-2 (2025 ESRS numbering).

Reference: pages 45, 111.

The sustainability statement discloses the ESRS 2 general disclosures and the topical disclosure requirements for Redcare's nine material standards, with a Reference table at the end of the statement (pages 111-116) listing every disclosure requirement in ESRS 2 and the material topical standards, the section it is addressed in, and an explanation where a requirement was omitted. E3 (water and marine resources) and S3 (affected communities) are omitted in full as below the materiality threshold. Some ESRS 2 disclosures are incorporated by reference to other Annual Report sections (Corporate Governance, Report of the Supervisory Board, Risk management, Remuneration report), with links given where this applies. Redcare states it has not omitted any information on the grounds of intellectual property, know-how or innovation, and applies the EU Quick Fix Regulation, with the specific phase-in applications described in the relevant chapters.

Reference: pages 60-65.

In 2025 Redcare launched its inaugural Climate Transition Plan, superseding its prior Climate Policy and re-affirming support for the Paris Agreement. Using a new 2025 baseline, the plan targets 100% renewable electricity from 2026, a 53% reduction in Scope 1 and 2 (location-based) emissions by 2035 and net zero by 2040, and a 66.4% reduction in Scope 3 emissions intensity (kgCO2e/order, for the interim-scope categories 3.1 and 3.9) by 2035 with net zero Scope 3 by 2050. The plan was guided by the SBTi Corporate Net-Zero Standard and the X-Degree Compatibility (XDC) model, though not all targets are science-aligned: Scope 1 and 2 cannot be considered science-aligned because of unavoidable near-term growth at Sevenum. A "target innovation gap" of roughly 34% is acknowledged for Scope 3, and locked-in emissions are named at Sevenum, in logistics, and in Rx/OTC product regulation (GMP/GDP). The Managing Board approved the plan; the CEO holds delivery responsibility and the Director Sustainable Development oversees implementation, with quarterly SSC review.

Reference: pages 61-62, 70, 242.

Back-filled from the E1 chapter's Impacts, risks and opportunities tables and the Climate risk management and resilience section of the Definitions appendix, where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Redcare's material climate risks are tabulated by sub-topic and classified as physical or transition risk (pages 61-62): transition risks include increased compliance costs, limited cold-chain delivery capacity and energy supply disruptions; physical risks include disrupted product supply and increased costs to maintain product quality through temperature variation. In 2025 Redcare conducted its first in-depth, geospatial climate risk assessment across eight logistics and warehousing sites, using four IPCC physical scenarios (SSP1, SSP2, SSP3, SSP5) over 2030-2100, and two IEA transition pathways: "Green Future" (Net Zero Emissions) and "Fossil Growth" (Stated Policies). The approach was guided by TCFD and ISSB recommendations, applied Redcare's ERM short/medium/long time horizons, and fed cross-functional workshops that identified risk drivers, opportunities and mitigation owners.

Reference: pages 70, 242.

Back-filled from the E1 chapter's "Enhancing business resilience by mitigating climate risk" section and the Definitions appendix's Climate risk management and resilience methodology, where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Alongside its first climate risk assessment, Redcare's Sustainable Development department led a qualitative resilience analysis covering the entire business model: upstream value-chain activities (manufacturers, wholesalers, logistics and packaging suppliers), own operations (warehouses, offices, workforce) and downstream activities (online platform, logistics network, customer servicing, returns/recycling), with particular focus on continued access to healthcare products through stock and delivery availability. The analysis concluded that Redcare's strategy and business model is "moderately resilient" to the identified climate risks, supported by its diversified carrier strategy and stock/energy controls, with its asset-light online platform seen as a further source of flexibility. Assumptions applied are consistent with those used in GHG target setting (page 240-241) and include areas of uncertainty and reliance on third-party information.

Reference: pages 62, 65.

Redcare's 2025 Climate Transition Plan supersedes its prior Climate Policy and sets out the objectives, decarbonisation levers and enabling mechanisms for meeting the company's GHG targets, taking "a reduction-first approach to emissions, while embedding climate resilience in our operations and value chain". The Managing Board holds ultimate accountability for the plan as part of the Sustainability Strategy; the CEO is responsible for delivery and the Director Sustainable Development for oversight and implementation across business units. Governance runs through the Sustainability Steering Committee, which steers progress and trade-offs and reviews performance quarterly, escalating deviations for corrective action. Climate-related IROs are consolidated into a Climate IRO Register aligned to Redcare's Enterprise Risk Management framework and TCFD guidance, integrated into the DMA. The plan is available on Redcare's public website, with key assumptions detailed in the Definitions chapter.

Reference: pages 63, 66, 76.

Scope 1 and 2 reductions are driven by fuel switching to biofuels, increased electric-vehicle uptake in the MediService joint venture, installation of photovoltaics at the new Pilsen warehouse, and efficiency improvements to energy-intensive logistics assets, with heat pumps and renewable electricity at Sevenum, Settala and Pilsen. In 2025, 89% of total energy consumption was from renewable sources (up from 87% in 2024), and Sevenum, Ennevelin, Pilsen and Milan are fully renewably powered. Scope 3 actions focus on eco-efficient operations (packaging fill rates, stock management, recycled materials), own-brand product carbon intensity, innovative logistics (reduced returns, load optimisation, electric vehicles), customer engagement and supplier decarbonisation, supported by national grid greening. Redcare continued its voluntary internal carbon pricing scheme in 2025 (EUR 35/tCO2e, EUR 1,131,830 collected on 32,338 tCO2e in scope), now applied through existing financial planning rather than a dedicated Climate Fund from 2026.

Reference: pages 63-64.

Using a new 2025 baseline (Scope 1 and 2 location-based: 3,154 tCO2e), Redcare's Climate Transition Plan targets a 53% reduction by 2035 (to 1,486 tCO2e), continuing to a 90% reduction by 2040 (315 tCO2e) in the target table, which the narrative text separately frames as reaching "net zero by 2040" (page 60); the table itself shows a residual balance rather than literal zero at that date. For Scope 3, the interim target covers categories 3.1 and 3.9 (about 82-90% of the Scope 3 boundary): a 66.4% intensity reduction by 2035 (from 4.726 to 1.591 kgCO2e/order), alongside a net zero Scope 3 target for 2050 that the table shows reaching 0 kgCO2e/order (a 97% reduction). Redcare separately met its prior 2020-baseline target, reducing Scope 1 and 2 market-based emissions by 80% by 2025 (338 tCO2e against a 335 tCO2e target). Targets were developed against the SBTi cross-sector pathway and Net-Zero tools and the XDC model; the Scope 1 and 2 target is not considered science-aligned because of locked-in Sevenum growth, and Scope 3 carries an acknowledged "target innovation gap".

Reference: page 66.

Total energy consumption from own operations was 12,799 MWh in 2025, up from 10,460 MWh in 2024. Of the 2025 total, 11,363 MWh (89%) came from renewable sources (11,312 MWh purchased electricity/heat plus 51 MWh renewable fuel) and 1,436 MWh (11%) from fossil sources (600 MWh crude oil and petroleum products, 570 MWh natural gas, 266 MWh purchased fossil electricity/heat). There was no coal, nuclear or self-generated non-fuel renewable consumption. Sevenum, Ennevelin, Pilsen and Milan are fully powered by renewable energy. All Redcare revenue was determined to fall under high climate impact sector activities (NACE 47.91), giving a net revenue of EUR 2,939,284 thousand and an energy intensity of 4.35 MWh per million euro of net revenue, down slightly from 4.41 in 2024. As of 2025, 100% of Scope 2 electricity was covered by bundled or unbundled contractual instruments (94% Guarantees of Origin), up from 98% in 2024.

Reference: pages 67-68.

Gross 2025 emissions were: Scope 1 of 284 tCO2e (down 6% from 302 in 2024); Scope 2 location-based of 2,870 tCO2e (up 5%); Scope 2 market-based of 54 tCO2e (down 58%); and Scope 3 of 240,892 tCO2e (up 31%, restated 2024: 183,683). Total market-based emissions were 241,230 tCO2e (up 31% versus restated 2024), driven mainly by capital-expenditure categories: C2 Capital goods rose 697% to 19,997 tCO2e on the Sevenum automation project and the new Pilsen site, and C1 Purchased goods and services rose 24% to 185,203 tCO2e. Ten of fifteen Scope 3 categories were assessed material; 6.5% of Scope 3 was calculated from primary data (15,618 tCO2e). GHG intensity per order (market-based) rose 12% to 5.756 kgCO2e. Redcare reports no GHG removal or storage projects and purchased no carbon credits in 2025. The reporting boundary was confirmed unchanged from 2024, though additional Scope 3 sources within that boundary were newly included (see restatements).

Reference: page 67.

Redcare reports that it "has not developed and is not associated with any GHG removals or storage projects in its operations or value chain" and that no carbon credits were purchased in 2025. This is a change from FY2024, when Redcare purchased and cancelled 10,000 nature-based carbon credits (via 44.moles, EUR 145,000 funded through the internal carbon fund) to offset emissions outside its value chain. The Climate Transition Plan (page 64) instead confines the future use of carbon credits to compensating residual emissions from Redcare's net zero years onward (2040 for Scope 1 and 2, 2050 for Scope 3), capped at no more than 10% of base-year emissions in line with the SBTi's definition, with strict selection criteria to be detailed closer to the net zero year; Redcare states that carbon credits will not count toward progress on its interim emission reduction targets.

Reference: page 70.

Redcare continued to apply a voluntary internal carbon pricing scheme in 2025, since it is not covered by any sectoral carbon taxation or trading scheme. The set price remained EUR 35 per tCO2e, unchanged from 2024. Emissions in scope rose to 32,338 tCO2e (2024: 29,012 tCO2e), covering Scope 1 and market-based Scope 2 in full and Scope 3 at 13.3% (2024: 15.6%), with a significant share of category 3.1 excluded and categories 3.2, 3.11 and 3.12 fully excluded; total scope coverage was 13.4% of market-based emissions (2024: 15.8%). The total internal carbon fee collected was EUR 1,131,830 (2024: EUR 1,015,420), applied as a notional cost in departmental financial planning to incentivise low-carbon decisions. Redcare states it applied no scientific guidance or science-based pricing trajectory in setting the price, instead adopting a gradual increase intended to build departmental awareness. From 2026, accruals into a dedicated Climate Fund are being removed in favour of existing budgeting processes.

Reference: page 71.

Redcare's E2 material topic is scoped to water pollution, since air pollution from GHG emissions and packaging waste are addressed under climate change and circularity respectively. The company states it has "not yet implemented formal policies to manage water pollution outside its own operations", attributing this to a prioritised focus on other high-impact topics and reporting compliance, with formal policies, actions and targets on water pollution planned by the end of 2026. In the interim, the Supplier Code of Conduct reflects Redcare's general commitment to reducing environmental impacts beyond its own operations. A 2026 DMA update is planned to refine the IRO definitions underpinning the Pollution chapter. The sites in scope for E2 are all logistics and warehouse locations, as defined in the Definitions appendix.

Reference: page 71.

Redcare has not yet implemented formal actions to manage water pollution outside its own operations, applying the ESRS transitional provisions for gathering comprehensive value chain data in the meantime. It relies on internal and public data sources: screening its product information management system, drawing on internal Quality and Pharma expertise, and using external laboratory analyses. Scientific research helped clarify the root causes of water pollution in the downstream supply chain (excretion of consumed medications, inappropriate disposal of products and packaging) and highlighted the industry's lack of unified assessment standards. Because reporting on E2-4 and E2-5 metrics depends on supplier-specific data that Redcare does not yet hold, the company plans to engage collaboratively with key suppliers to build the reporting and steering systems needed as a basis for the water pollution measures planned by 2026.

Reference: page 71.

Redcare has not yet set formal targets to manage water pollution outside its own operations. As with its policies and actions, formal targets are planned to be developed by the end of 2026, following a 2026 DMA update that will refine the Pollution chapter's IRO definitions. The stated rationale for the current gap is a prioritised focus on progressing other high-impact sustainability topics and on meeting reporting compliance obligations, combined with the challenge of collecting upstream and downstream data across Redcare's broad medication and related-products assortment. Building the supplier-specific reporting and steering systems described under E2-2 is presented as the necessary basis before quantified water pollution targets can be set.

Reference: page 71.

Redcare's pollution-of-water impacts arise mainly upstream, from the manufacturing of medicines and their ingredients in sourcing regions with lower environmental standards, and downstream, from the excretion of consumed medications and the inappropriate disposal of products and packaging, including microplastics. These impacts were identified through desk research, expert consultations and stakeholder surveys; Redcare states it has not assessed specific upstream sites and has not conducted consultations with affected communities on this topic. Reporting on the quantitative E2-4 metric depends on supplier-specific data that Redcare does not yet hold, so it plans to engage collaboratively with key suppliers to build the necessary reporting basis. Redcare reports no major pollution-related incidents, deposits, or provisions or expenditures for environmental protection or remediation during 2025.

Reference: page 71.

Redcare screened the ESRS list of substances of concern to assess whether any are used or emitted within its own operations. It identifies that the negative water pollution impacts in its value chain relate in part to substances of concern and microplastics in the downstream supply chain, an issue identified through scientific research that also highlighted the industry's lack of unified assessment standards. As with E2-4, Redcare states it is dependent on supplier-specific data to report the quantitative E2-5 metrics required by the ESRS, and plans to engage collaboratively with key suppliers to build the reporting and steering systems and processes needed as a basis for the water pollution measures targeted for 2026.

Reference: page 72.

Redcare has not set out a dedicated biodiversity transition plan. Its double materiality assessment identified one material negative impact upstream: resource use for, and production of, products sold via Redcare could potentially harm biodiversity or ecosystem quality. The assessment behind this finding was limited to desk research with only a high-level view of dependencies and transition, physical and systemic risks and opportunities; Redcare has not assessed specific upstream sites or raw material sourcing, has not involved upstream communities, and has not implemented measures to avoid ecosystem impacts on potentially affected communities. Consequently the company states its contribution to direct impact drivers of biodiversity loss, and the associated mitigating measures, "remains to be fully assessed and disclosed". A more detailed understanding is targeted through the 2026 DMA update, which Redcare intends to use to get a better view of biodiversity-related impacts, risks and opportunities in its own operations and value chain.

Reference: page 72.

Redcare reports that it has "not yet implemented policies to specifically manage biodiversity", noting that materiality for the topic was only assessed in 2024. In the absence of a dedicated biodiversity policy, the Supplier Code of Conduct's general commitment to minimise environmental impact beyond Redcare's own operations also applies in the biodiversity context. The company plans to develop biodiversity-related policies following the 2026 DMA update, once it has a more detailed understanding of the material biodiversity-related IROs across its supply chain, and intends to use that update to inform its supplier engagement and management processes, including revisions to the Supplier Code of Conduct.

Reference: page 72.

Redcare states it has not yet implemented actions specifically to manage biodiversity, again citing that materiality for the topic was only established in 2024. Beyond the general environmental commitment embedded in the Supplier Code of Conduct, the company's plan is to use the 2026 DMA update to build a more detailed understanding of biodiversity-related impacts, risks and opportunities across its own operations and supply chain, and to use those findings to update its supplier engagement and management processes. No resources, budget or dedicated biodiversity workstream are described for 2025; the current approach remains limited to the desk-research screening described under E4-1.

Reference: page 72.

Redcare has not set biodiversity-related targets. As with its policies and actions, materiality for biodiversity was only assessed in 2024, and the company states it has not yet implemented targets to specifically manage the topic. Target-setting is deferred to follow the 2026 DMA update, once Redcare has developed a more detailed understanding of biodiversity-related IROs across its value chain and used that understanding to revise its supplier engagement and management processes, including the Supplier Code of Conduct. No interim milestones or qualitative objectives are disclosed for biodiversity in the 2025 statement.

Reference: page 72.

Redcare does not disclose quantitative biodiversity impact metrics for 2025. Its materiality assessment relied on desk research providing only a high-level view of dependencies and risks, and did not extend to assessing specific upstream sites, raw material sourcing or communities, or to implementing measures against ecosystem impacts on potentially affected communities upstream. As a result, Redcare states that its contribution to direct impact drivers of biodiversity loss, and the associated mitigating measures, "remains to be fully assessed and disclosed". Consultations with affected communities on biodiversity have not been conducted. The company intends to use the 2026 DMA update to build the more granular, site-level understanding that would support future quantitative impact metrics.

Reference: pages 73-74.

Redcare's material E5 topic is circularity of products and packaging. To date the company's circularity approach has focused on its own operations: shipping packaging and waste management, with data collection, reporting and steering processes established across all international locations. No composition-altering production occurs within Redcare's operational control, so materials categorised as inflows also constitute the outflows. The 2024 DMA, updated in 2025, found circularity-related IROs primarily in the upstream supply chain (manufacturer resource consumption) and downstream (customer and patient behaviour). Redcare states it has not yet developed a dedicated circularity policy beyond its general operational practices and plans to develop policies, actions and targets, including active supplier and customer engagement, following the 2026 DMA update, with the objective of complying with the EU Packaging and Packaging Waste Regulation (PPWR) and Circular Economy Act.

Reference: pages 74, 76.

Redcare's circularity actions concentrate on its largest logistics site, Sevenum, and are being extended to Milan and Pilsen. In 2025 the paper-based protective packaging introduced for fragile goods in 2024 was extended to Sevenum and fully implemented in Milan and Pilsen, reducing material use, breakage rates and improving net promoter score; carton sizes for shipping packaging at Pilsen were optimised, cutting material use and improving logistics efficiency. Redcare holds regular employee sales on products no longer suitable for customer sale and operates a waste separation system at all logistics locations. It is preparing for ISO 14001 certification of its environmental management system at Sevenum by end 2026, with the same standardised processes planned, though not yet targeted for certification, at Milan and Pilsen. The return rate, a proxy for both environmental impact and product quality, was kept below 1% (0.74% in 2025).

Reference: pages 73, 76.

Redcare's stated circularity targets and achievements for 2025 are qualitative and process-based rather than numerically targeted from a formal target-setting exercise: achieving 97% recyclable content in packaging of parcels shipped, rolling out paper-based protective packaging for fragile goods, and achieving ISO 14001 certification for Sevenum by the end of 2026. The company frames its broader ambition as decoupling environmental impact from continuing business growth by steering the amount of materials used per parcel shipped. Redcare-specific policies, actions and targets for circularity are planned for development in 2026, following the 2026 DMA update; in 2025 the framework for this approach was drafted, including an action plan for compliance with the EU Packaging and Packaging Waste Regulation for own brands and warehouses, alongside deeper supplier collaboration to gather reliable packaging data.

Reference: page 77.

Total weight of materials used in 2025 was 6,069 tonnes (2024: 5,426 tonnes), or 0.145 kg per order (2024: 0.152 kg). This comprised 5,120 tonnes of shipping materials, 126 tonnes of consumable materials and 822 tonnes of marketing materials; products' packaging (category 1) is omitted under the ESRS Annex I transitional provision for supply chain data, as the underlying supplier data was not available to Redcare. Sustainable biological materials used totalled 184 tonnes, a 3.0% share (2024: 3.1%). Total reused and recycled materials were 5,005 tonnes, an 82.5% share of materials used (2024: 82.2%), while the share of reused/recycled input specifically in shipping packaging materials rose to 95.8% (2024: 94.4%). Reported reused and recycled materials refer solely to recycled inputs, avoiding double counting.

Reference: page 77.

Because no composition-altering production occurs within Redcare's operational control, the materials counted as inflows also constitute the outflows. Redcare reports a recyclability rate of materials used (resource outflows) of 97% for 2025. For the second year, it also discloses recyclability of parcel packaging specifically: the total weight of recyclable parcel packaging was 5,009 tonnes against total parcel packaging of 5,166 tonnes, giving a recyclable content in parcel packaging share of 97.0% (2024: 96.8%). Only own-stock business parcel packaging used in preparation and delivery is in scope. Redcare frames this figure as reflecting its commitment to responsible sourcing, considering both the materials it buys for internal use and their end-of-life recycling potential; detailed waste outflow figures by category and treatment method are presented separately under the Waste disclosure.

Reference: page 78.

Redcare reports total waste generated in 2025 of 2,674 tonnes (2024: 2,264 tonnes), or 0.064 kg per order (2024: 0.063 kg), split into 37 tonnes hazardous and 2,637 tonnes non-hazardous. By treatment method, recycled waste totalled 2,178 tonnes (all non-hazardous), and disposed waste totalled 496 tonnes (37 hazardous, 459 non-hazardous), all incinerated, with zero landfilled and zero other disposal. This gives a non-recycled waste share of 18.6% (2024: 18.8%). Office locations generate waste similar to household municipal waste; facilities and warehouses manage supplier packaging and customer returns, and as a pharmacy Redcare also handles medical waste, reported as hazardous. A waste separation system operates at all logistics locations, and the ongoing Rx expansion project in Sevenum is expected to increase on-site logistics waste volumes going forward.

Reference: page 90.

Redcare's approach and policies for own workforce are prepared for core entities, covering 85% of FTEs, with quantitative metrics covering all entities. Two main policies address people development and equal opportunities: the Diversity and Inclusion Policy, publicly available on the corporate website, and the internal Protocol for Transgressive Behaviour, which defines discrimination (covering gender, age, origin, marital status, religion, sexual orientation, disability, political affiliation or employment contract), harassment, bullying, physical aggression and verbal abuse. Both apply to all Redcare entities and embody the company's commitment to Article 23 of the UN Universal Declaration of Human Rights on equal pay. The current policies are not formally aligned to internationally recognised guidelines such as the UN Guiding Principles on Business and Human Rights, though Redcare states its approach is compliant with applicable discrimination legislation. As part of a biennial DMA update starting in 2026, affected policies including the Diversity and Inclusion Policy will be revised.

Reference: page 89.

Redcare commits to Article 19 of the UN Universal Declaration of Human Rights on freedom of opinion and expression, and under Dutch law grants employees the rights to meet, to receive information, to consent, of initiative and to be heard. Internal communication runs across all entities via regular letters from the Managing Board, town hall meetings and the internal portal and mobile app RedLive, aimed particularly at employees without a desk. A works council in Sevenum, the largest logistics site, provides a platform for dialogue between employees and management on economic and social topics; it meets every second week, with the CEO quarterly and with HR bi-monthly. The Speak Up Policy separately provides a channel to report breaches of values or responsible business conduct, operated by an independent provider with anonymous, 24/7 reporting in all languages by phone, portal or app.

Reference: page 89.

Employees are encouraged to raise concerns about non-adherence to Redcare's values through the Speak Up Policy, with routes including managers, HR, trusted persons, the Corporate Compliance team, or the independent Speak Up line offering anonymous, 24/7 reporting in all languages by phone, portal or app. Redcare commits to confidentiality, thorough investigation, anonymity and non-retaliation as detailed in the policy published on its corporate website. In 2024 the company's employee survey found that 74% of office staff and 81% of shop floor staff were aware of the Speak Up line. In 2025 reporting channels were extended to nu3, a non-core subsidiary, and the Speak Up line was rolled out to the new Pilsen warehouse and logistics location; the line continued to be evaluated with HR colleagues on a continuous basis to improve handling of reports and follow-up actions.

Reference: pages 90-91.

Actions and resources are prepared for Redcare's core entities; MedApp, smartpatient, MediService and nu3 run connected HR strategies as a transitional arrangement, with MediService remaining a standalone operation. For healthy, safe and satisfied employees, Redcare measures satisfaction via the Employee Net Promoter Score (last major survey 2024, results shared and follow-up initiatives created in 2025), targets ISO 45001 certification for the Sevenum logistics site by 2026, and is developing a Risk Assessment and Evaluation framework. Business Continuity Plans were completed for Sevenum and Milan in 2025. For people development and equal opportunities, Redcare runs Continuous Learning (digital and in-person courses, an internal learning marketplace) and the RISE career development programme (two check-ins per year, launched 2023); new leadership principles replace the former Servant Leadership model in early 2026. Wellbeing initiatives include seven physical health events in 2025 and anonymous counselling via Nilo, used by 212 employees.

Reference: page 91.

No quantitative target is set for healthy, safe and satisfied employees, which Redcare treats as a continuous engagement and improvement process. For people development and equal opportunities, two targets carry over from prior years: by 2027, a minimum of 33.33% of the Managing Board, 40% of the Supervisory Board and 33.33% of sub-top roles are to be female, in compliance with the Dutch Inclusion Quota and Target Figures Act; and Redcare aims to employ up to 0.5% of its workforce from groups distanced from the labour market (people with disabilities, the long-term unemployed, refugees, those with limited skills, and under-represented communities), directly or through subcontractors. Reporting on the latter target relies on voluntary employee disclosure, and 2025 data is not yet available; Redcare states the work to develop this measurement remains ongoing.

Reference: pages 92-93.

Total headcount at year-end 2025 was 3,274 (2,649 FTE), comprising 1,769 women, 1,441 men, 1 other and 62 not reported (2024: 2,659 headcount, 1,455 women, 1,117 men). By age, 674 employees were below 30, 1,995 between 30 and 50, and 604 above 50 (total 3,273). By contract type, permanent employees totalled 1,246 women and 877 men, temporary employees 338 women and 282 men, and non-guaranteed hours employees 184 women and 283 men. By region, the Netherlands remained the largest workforce (1,060 women, 924 men headcount), followed by Germany (411 women, 357 men) and Other markets aggregated. From 2024 Redcare includes data from all entities for own-workforce metrics; employees are defined per ESRS as those with permanent, temporary or non-guaranteed hours contracts.

Reference: page 94.

Redcare has no agreement with employees for representation by a European Works Council, an SE Works Council or an SCE Works Council; a works council is in place in Sevenum. For employees not covered by collective bargaining agreements, working conditions and employment terms follow local laws and market practices. As of end 2025, collective bargaining coverage for Germany and the Netherlands sits in the lowest band, 0-19%. Workplace representation in the EEA falls in the 0-19% band for Germany and the 40-59% band for the Netherlands. Social dialogue is also supported by the Sevenum works council, which meets every second week and consults with management and the Managing Board on economic and social topics.

Reference: page 95.

In 2025 the Managing Board comprised 4 men (80%) and 1 woman (20%), unchanged from 2024. The Supervisory Board's female share fell from 40% to 20% after Michael Köhler and Stephan Weber succeeded Frank Köhler and Henriette Peucker in May 2025; Redcare maintains a 40% female target for the board. Sub-top management (Directors and Executive Directors) comprised 49 men and 25 women (34% female), of 75 total, broadly stable versus 2024's 34%. Gender diversity targets for 2027, formulated under the Dutch Inclusion Quota and Target Figures Act, are 33.33% female on the Managing Board and sub-top management and 40% on the Supervisory Board. By age, headcount at year-end 2025 was 674 below 30, 1,995 between 30 and 50, and 604 above 50 (total 3,273).

Reference: page 95.

Redcare defines an adequate wage as the minimum remuneration an employee is entitled to receive, set by the statutory minimum wage per country and assessed against EU Directive 2022/2041 (Article 5). In countries without a statutory minimum wage, Italy, Belgium and Switzerland, adequate wages are instead determined by collective agreements. Redcare states that all employees are paid adequate wages, in line with the applicable benchmarks set out in the Definitions section of the report. No quantitative below-benchmark headcount or percentage is disclosed, as no gap was identified against the applicable wage benchmarks.

Reference: page 94.

All Redcare employees are covered by health and safety management systems based on legal requirements: 100.0% coverage in both 2025 and 2024. There were zero fatalities in the own workforce and zero fatalities of other workers in both years. The number of recordable work-related accidents for the own workforce, defined as accidents reported externally to the respective national authorities, fell to 5 in 2025 from 12 in 2024, and the rate of recordable work-related accidents fell to 1.14 per 1,000,000 hours worked from 3.16. Redcare states it is "pleased to see the absolute and relative number of accidents decreasing significantly"; the number of hours worked underlying the rate is estimated. Redcare applies a localised approach to safety measures, adhering to national legal requirements at each site.

Reference: page 95.

The Remuneration metrics table for 2025 shows an average gender pay gap across all entities and levels of 10.4%, down from 16.3% in 2024, and a shop-floor gender pay gap of 2.5%, down from 4.1%. The remuneration ratio between the highest-paid employee and the median employee (excluding the highest-paid individual) rose to 28.43 (2024: 27.72). A one-time payout of outstanding incentives to the departing CFO, Jasper Eenhorst, lifted the CFO-specific ratio to 41.30 in 2025, which Redcare states reflects a departure payment rather than regular annual compensation. A new job architecture project, piloted in one Managing Board department in 2025 and launching in 2026, will standardise salary bands; shop-floor logistics staff already show a marginal pay gap below the 5% threshold that triggers a joint pay assessment under the EU Pay Transparency Directive.

Reference: page 95.

Redcare's definitions of discrimination and undesired behaviour, and its reporting channels, sit in the Code of Conduct, Speak Up Policy and Protocol for Transgressive Behaviour. During 2025, a total of 12 complaints were raised through Redcare's reporting channels, and the company had one reported incident of discrimination, with zero complaints filed to National Contact Points for OECD Multinational Enterprises. There were no incidents of severe human rights impacts during the reporting period, and no fines, penalties or compensation for damages related to any complaints were imposed on Redcare.

Reference: page 97.

Redcare's Supplier Code of Conduct (SCoC), launched in 2024 and governed by the Executive Director Procurement, is the company's policy for managing material impacts, risks and opportunities related to value chain workers. It sets expectations aligned with the Principles of the UN Global Compact, the Universal Declaration of Human Rights, the OECD Guidelines for Multinational Enterprises and the Principles of the Pharmaceutical Supply Chain Initiative, with provisions on material impacts found in its "Ethics and Compliance", "Health and Safety" and "Human Rights and Labor" sections. During 2025 Redcare engaged with suppliers across its markets to build commitment to the SCoC, with a target that suppliers representing at least 75% of total buying volume commit by year-end.

Reference: page 97.

In 2025 Redcare conducted a social impact assessment for value chain workers, informed by human-rights due diligence requirements and undertaken to prepare for upcoming due diligence regulation, in three steps: value chain mapping (stakeholder groups, per-segment and per-supplier-type risk levels, and classification of Redcare's business relationship as cause, connected to, or contributing to); IRO identification and stakeholder engagement, combining desktop research with interviews of internal departments and external suppliers, including an assessment of existing controls such as the SCoC; and development of a Social IRO Register applying Redcare's DMA methodology and criteria to the findings, intended as the starting point for mitigation measures linked to a planned ESRS-aligned human rights due diligence approach.

Reference: page 97.

Redcare states it plans to develop ESRS-aligned policies, actions and targets to prevent, mitigate and remediate the impacts and risks identified for value chain workers by the end of 2026, guided by the OECD Guidelines for Multinational Enterprises and prepared to meet the EU Corporate Sustainability Due Diligence Directive and EU Forced Labor Directive. This planned work is explicitly intended to include processes and channels for engaging with value chain workers and for those workers to raise concerns, and processes to remediate negative impacts, building on the Social Impact Register developed through the 2025 social impact assessment described under S2-2.

Reference: page 97.

Redcare's principal 2025 action for value chain workers was completing a social impact assessment (value chain mapping, IRO identification via desktop research and supplier/department interviews, and a resulting Social IRO Register), building on the 2024 introduction of the Supplier Code of Conduct. During 2025 Redcare engaged with suppliers across its markets, working toward the target of 75% of total buying volume committed to the Code by year-end, reported in the Business Conduct chapter's results section. Next year, Redcare plans to continue this supplier engagement, review and update the Code to align with the Climate Transition Plan and other sustainability topics, and develop ESRS-aligned policies, actions and targets for value chain workers by the end of 2026.

Reference: page 97, 110.

Redcare's target is for suppliers representing at least 75% of total buying volume (75% of net sourcing spend for core entities) to commit to the Supplier Code of Conduct by year-end 2025. The target was developed through business consultation and market research and applies to Redcare's core entities and to suppliers of products sold in its retail business. As of end 2025 the result achieved was 75.6% for core entities (2024: 30.1%), and 56.9% across total Redcare sourcing spend (2024: 21.6%), against core-entity sourcing spend of EUR 1,836.0 million. Beyond this target, Redcare intends to develop further ESRS-aligned targets by the end of 2026, alongside policies and actions, to address the material impacts and risks affecting value chain workers identified in its 2025 social impact assessment.

Reference: pages 102-103.

Redcare's approach to consumers and end-users centres on the four As (Accessibility, Availability, Affordability, Awareness), aligned with Article 25 (health) and Article 12 (privacy) of the UDHR, Article 8 of the ECHR, Principle 11 of the UN Guiding Principles, and Chapter VIII of the OECD Guidelines. Four policies, applicable to all entities except MediService, cover the material topics: the Inclusive Access to Healthcare Policy, revised in 2025 under CEO leadership with Public Affairs oversight; the Health, Quality and Safety (HQ&S) policy, led by the COO and Executive Director of Pharma Operations and Quality, aligned to GDP and ISO 9001:2015; the Information Security Practices, overseen by the CIO and Director of Corporate Compliance and Governance, aligned to ISO/IEC 27001:2022, ISO/IEC 27701 and GDPR; and the Responsible Marketing Policy, overseen by the CCO, aligned to the ICC Code.

Reference: page 103.

Redcare integrates customer perspectives through structured mechanisms including real-time Net Promoter Score (NPS) surveys, daily customer service interactions and complaint management systems, engaging across the full customer journey from product development to post-sale service, and in collaboration with external bodies such as patient advocacy groups. The Executive Director of Marketing, the Director of Public Affairs and the Executive Director of Quality oversee the operational and strategic implementation of these engagements. Effectiveness, and whether customers are aware of and trust the available channels, is assessed through NPS scores and regular reviews of customer concerns. Steps to address vulnerable groups include enhancing digital accessibility and advocating for policies that expand access to healthcare, and Redcare states it is not aware of incidents equating to a failure to respect the UN Guiding Principles, ILO Declaration or OECD Guidelines involving consumers.

Reference: page 103.

Redcare integrates customer perspectives through real-time NPS, daily customer service interactions and complaint management systems, supported by external arbitration options including the European Commission's Dispute Resolution platform and the Dutch Consumer Arbitration Board. Complaints are tracked and analysed systematically to identify trends and improve processes, with oversight from the Executive Director of Quality and the Director of Public Affairs, and feedback directly informs decisions in healthcare services, marketing strategy and safety practices. Redcare requires business partners to maintain equivalent complaint-handling systems. On accessibility specifically, all customer service inquiries in 2025 were resolved in both national and dominant migrant-community languages at a 100% resolution rate, and Redcare's digital channels achieved full WCAG 2.1 AA accessibility compliance, externally verified.

Reference: pages 103-105.

For accessibility, Redcare engaged in legislative advocacy on the European Health Data Space Regulation for cross-border e-prescriptions, participated in two related EU infrastructure projects, extended online prescription services with local pharmacies in remote areas, and advocated for the Digital EU Wallet. For patient health, Redcare adhered to the Falsified Medicine Directive with real-time alert-rate monitoring (average 0.01% in 2024 and 2025, against an EMVS target below 0.05%) and piloted a repeat-prescription service for chronic-condition patients. For data privacy, Redcare's combined ISO/IEC 27001 and ISO/IEC 27701 audit was validated without conditions, and it expanded GDPR breach reporting, recording two substantiated breaches in 2025 with no enforcement action. For responsible marketing, Redcare met its target of 100% of marketing team members trained on the new Responsible Marketing Policy by end 2025.

Reference: pages 104-105.

For inclusive access to healthcare, no quantitative target is set; Redcare will develop an action plan by end 2026 based on its 2025 inclusivity analysis and external accessibility evaluation. For patient health and pharmaceutical quality, there is no adopted numerical target beyond the objective of excellent product and service quality, tracked via the falsified-medication alert rate and a confidential Quality Score assessed by YouGov's BrandIndex. For data privacy, the 2026 objective is to maintain both ISO/IEC 27001 and ISO/IEC 27701 certification and substantiate NIS2 compliance through external assessment; no formal target had been set for 2025. For responsible marketing, Redcare set and met a target of 100% of marketing team members trained on the new Responsible Marketing Policy by end 2025; all new marketing starters will complete the training as part of onboarding from 2026.

Reference: pages 108-109.

Redcare treats culture of trust and integrity as its one material governance topic, covering business conduct policies, corporate culture, whistleblower protection, corruption and bribery, and political influence and lobbying. High standards of integrity and compliance are set for the company and each employee, covering human rights, safe work environments, and avoidance of cartel violations, corruption, bribery and other illegal practices. The Code of Conduct, published on Redcare's website and approved by the Managing Board (and, where published externally, also by the Supervisory Board), provides the framework for sub-policies including Labor Principles, an Anti-bribery and Corruption Policy and an Anti-Trust Policy. Compliance training and communication are tailored by role, using all-hands meetings, workshops, flyers and wiki pages, with 2026 plans to continue awareness-building around Speak Up and the Code of Conduct. In 2025, 12 reports were addressed through the Speak Up Line; there were no significant instances of non-compliance and no significant fines or non-monetary sanctions.

Reference: page 109.

Redcare's Code of Conduct sets the general anti-bribery and corruption guidelines. In November 2025 the company published a dedicated policy on preventing and detecting corruption and bribery, replacing the existing Gift and Hospitality Policy. Certain functions, including Managing Board members, are identified as elevated-risk because of their involvement in critical financial transactions, public-sector interactions and regulatory sensitivity; these at-risk functions were enrolled in an anti-bribery and corruption training programme. Allegations can be reported through the existing Speak Up channels. The CFO is accountable for Corporate Compliance including anti-corruption and bribery, with no separate investigation committee outside the management chain; the Director Corporate Compliance and Governance and the General Counsel provide ongoing support to business and functional teams. Anti-bribery and corruption risks are managed within Redcare's broader risk management system.

Reference: page 109.

Redcare states it "has not been convicted for any violations of anti-corruption and anti-bribery laws." Since the introduction of the Speak Up Line, 12 reports were addressed through the channel in 2025 (2024: 14), which Redcare reads as evidence that employees are aware of and use the reporting channel. Outside of Speak Up reports, no other concerns related to the Code of Conduct were reported to the Managing Board or the Supervisory Board. The process is owned by the Director, Corporate Compliance & Governance, with quarterly reports to the Managing Board and bi-annual updates to the Audit Committee covering cases, actions and effectiveness.

Reference: pages 109-110.

Redcare's political engagement is governed by its Public Affairs Policy, applying to all employees and aiming for ethical, fair, open, transparent and accountable engagement. Redcare is registered in the EU Transparency Register (ID 337860539739-52) and the German Lobbyregister (ID R001374). Responsibility sits with the Director of Public Affairs under CEO oversight; no Managing Board or Supervisory Board member held a comparable public administration position in the two years before appointment. Redcare is a member of thirteen associations including the European association of e-pharmacies (EAEP), Bitkom and Bundesverband Deutscher Versandapotheken. Redcare made no direct political contributions to parties, elected representatives or persons seeking office; indirect financial political contributions totalled EUR 771 thousand in 2025 (DACH 273, International 498; 2024: EUR 650 thousand), covering healthcare, digitalisation and party-affiliated associations, trade associations and event sponsoring.

Reference: page 107.

Back-filled from the Business conduct chapter's Targets and objectives summary, where this content is disclosed in the FY2025 report. G1-3 became a standalone disclosure requirement only in the 2025/2026 ESRS; under the 2023 ESRS this fell within MDR-T.

Redcare's G1 topic box (page 107) states its objective as continued policy engagement at EU and national level, alongside the 2025 achievements of awareness-building around the Speak Up Policy and the roll-out of anti-bribery and corruption training to at-risk functions. Consistent with MDR-T's alternative limb, effectiveness is tracked in the absence of a numeric target: 12 reports were addressed through the Speak Up Line in 2025, with quarterly reporting to the Managing Board and bi-annual reporting to the Audit Committee on cases, actions and effectiveness (G1-4, page 109), and functions identified as at-risk in the annual assessment are enrolled in anti-bribery and corruption training (G1-3, page 109).