Sanoma

The role of the administrative, management and supervisory bodies

Composition of administrative, management and supervisory bodies

Board of Directors

Until 17 April 2024, the members of the Board of Directors were Pekka Ala-Pietilä (Chair), Julian Drinkall, Rolf Grisebach, Anna Herlin, Mika Ihamuotila, Nils Ittonen (Vice Chair), Denise Koopmans, Sebastian Langenskiöld and Eugenie van Wiechen.

On 17 April 2024, the AGM elected the following members to the Board of Directors: Pekka Ala-Pietilä (Chair), Klaus Cawén (Vice Chair), Julian Drinkall, Rolf Grisebach, Anna Herlin, Mika Ihamuotila, Sebastian Langenskiöld and Eugenie van Wiechen.

In its organisation meeting held after the AGM, the Board of Directors decided to appoint from among its members Rolf Grisebach (Chair), Klaus Cawén, Mika Ihamuotila and Sebastian Langenskiöld to its Audit Committee.

Table 1. Number of executive and non-executive Board members

The numbers presented above include the Audit Committee as its members are also members of the Board of Directors. Sanoma does not have representation of employees and other workers in its administrative, management and supervisory bodies.

Table 2. Gender distribution of the members of the Board of Directors

Table 3. Other information on the members of the Board of Directors

The Board's gender ratio is calculated by dividing the number of female Board members by the number of male Board members.

All Board members were independent of the Company, but one member is non-independent of a major shareholder. For the Audit Committee, the gender ratio was 0 as all four members were male, and the share of independent members 100%.

Executive Management Team

In 2024, Sanoma's Executive Management Team consisted of the following members: Rob Kolkman (President and CEO as of 1 January 2024), Alex Green (CFO) and Pia Kalsta (CEO of Media Finland).

Table 4. Gender distribution of Executive Management Team (EMT)

Table 5. Other information on the members of the Executive Management Team

The EMT's gender ratio is calculated by dividing the number of female EMT members by the number of male EMT members. The Executive Management Team (EMT) remained unchanged during the reporting period and included Rob Kolkman (President and CEO, Chair of the EMT), Alexander Green (CFO) and Pia Kalsta (CEO, Media Finland).

Competences and expertise of the Board

The competences, experience and knowledge required for the Board composition is set out in the Charter of the Shareholders' Nomination Committee. Together with the Board Charter and the Diversity and Inclusion Policy, it establishes that diversity aspects are taken into account. In addition, the Board of Directors' Human Resources Committee discusses the composition and succession of the Board. The Finnish Corporate Governance Code also has requirements related to Board composition and diversity.

According to Sanoma's Corporate Governance Statement, the Board of Directors must collectively have sufficient knowledge of and competence in:

• the learning and media business with current and potential future geographical reach,
• the management of a public company of corresponding size, good corporate governance, corporate and financial administration and internal control and risk management,
• strategic work as well as mergers and acquisitions,
• technology, including digitalisation and the ethical use of artificial intelligence (AI) in consumer and publishing products, and
• sustainability, including environmental, social and governance aspects.

In order to ensure that the Board has sufficient and versatile competencies, mutually complementing experience and knowledge of the industry for the needs of Sanoma expressed in the strategy at any given time, the Shareholders' Nomination Committee considers a range of diversity aspects, such as business experience, international experience, nationality, age, education and gender, when preparing its proposal of the composition of the Board to the Annual General Meeting (AGM).

Roles and responsibilities for sustainability

Board of Directors

Sanoma's Board of Directors is responsible for the management of the Company and its business operations. The Board of Directors of Sanoma Corporation has a Charter to govern its work. The basis for the duties of the Board of Directors is set forth in the Finnish Limited Liability Companies Act. In addition to being the ultimate decision-maker on the long-term goals and business strategy of the Group, Sanoma's Board of Directors is responsible for:

• the approval of strategic sustainability guidelines and sustainability management model,
• the appropriate arrangement of the control of the sustainability reporting and its assurance,
• the oversight of sustainability-related impacts, risks and opportunities,
• the approval of the Sustainability and Human Rights Policy, which is supported by internal policies, standards and manuals,
• the approval of the statutory Sustainability Statement, and
• the review of the double materiality assessment process and the approval of its outcomes.

Audit Committee

The Board of Directors' Audit Committee acts as Sanoma's Sustainability Committee and supports the Board in overseeing sustainability-related impacts, risks and opportunities. The Audit Committee reviews Sanoma's sustainability progress and monitors the implementation of the Sustainability Strategy through regular updates it receives from the management.

President and CEO and the Executive Management Team

The President and CEO is responsible for the implementation of strategic sustainability guidelines. The EMT supports the President and CEO in assessing and validating sustainability-related impacts, risks and opportunities and outlining Sanoma's strategic approach to sustainability, managing sustainability development, and monitoring regularly how sustainability is reflected in the business units. The Chief Financial Officer (CFO), who is a member of the EMT, is responsible for sustainability on the management level.

The President and CEO and the Executive Management Team (EMT) are ultimately responsible for ensuring that Sanoma employees are aware of and comply with the Group policies. In addition, the President and CEO approves the Group-level standards.

The EMT supports the President and CEO in duties related to coordinating the Group's management and preparing sustainability-related matters to be discussed at the Audit Committee meetings. The Board receives a summary of the Audit Committee meetings, and can address the topics in its meetings if relevant.

The Board of Directors, the Human Resources Committee and the EMT approve the annual short-term incentive targets and performance outcomes that also include targets related to Sanoma's material impacts, risks and opportunities. The sustainability-related performance in incentive schemes are presented in more detail in section ESRS 2 GOV-3. In addition, the long-term sustainability targets that are part of Sanoma's sustainability scorecard are monitored annually as part of the review of the Annual Report. The sustainability scorecard includes targets related to material impacts, risks and opportunities.

Sustainability and Ethics Working Group

The Sustainability and Ethics Working Group consists of selected members across the Group representing all material sustainability topics. It evaluates sustainability-related impacts, risks and opportunities, monitors the implementation of the Sustainability Strategy and coordinates related development work and actions as well as ethics and compliance.

Sustainability training and expertise

Sanoma's Board of Directors, including the Audit Committee, has been trained on sustainability matters related to the European Sustainability Reporting Standards (ESRS) directive. In addition, some Board members have experience from sustainability topics for example related to their role in an environmental organisation.

The EMT is responsible for allocating appropriate skills and expertise related to sustainability matters at the Group and SBU levels. The EMT consults internal experts, such as the members of the Sustainability and Ethics Working Group, on material sustainability topics and related impacts, risks and opportunities.

Frequency of sustainability discussions

In 2024, the Audit Committee received five updates on material sustainability impacts, risks and opportunities, and the Board of Directors received eight updates. The Board receives a summary of the Audit Committee meetings, and can address the topics in its meetings if relevant. As sustainability is embedded into Sanoma's operations, it is also included in the operative and business updates to the Board. The updates are given by the CFO or the Head of Investor Relations and Sustainability, who reports to the CFO. In addition, as described in section GOV-1, the Board's Human Resources Committee addressed human resources-related matters in each of their meetings, and these were summarised to the Board.

Sanoma's sustainability performance is regularly discussed with the President and CEO and the EMT, prior to discussions with the Audit Committee and communication to stakeholders. In 2024, the EMT received eight updates on material sustainability impacts, risks and opportunities, mainly from the members of the Sustainability and Ethics Working Group. The Sustainability and Ethics Working Group providers information on material sustainability topics and reviews the policies and standards before they are reviewed and approved by the administrative, management and supervisory bodies.

Sustainability topics discussed in 2024

The following sustainability-related topics covering material impacts, risks and opportunities were discussed during the reporting year:

The Board of Directors and Audit Committee:

• Materiality assessment: approval of the double materiality assessment
• Policy approval: new Sustainability and Human Rights Policy and People Policy and updated Code of Conduct, IPR Policy, Anti-Bribery and Corruption Policy, Privacy and Data Protection Policy and Procurement Policy
• Performance monitoring: Ethics and Compliance Programme, Privacy Programme and sustainability-related STIs (people, climate and privacy topics)
• Sustainable finance development: approval of the issuance of the EUR 150 million Social Bond, review of the Social Bond Framework and monitoring of ESG ratings
• Internal audit: sustainability reporting readiness assessment

The President and CEO and the Executive Management Team:

• Materiality assessment: approval of the double materiality assessment
• Policy review: new Sustainability and Human Rights Policy and People Policy and updated Code of Conduct, IPR Policy, Anti-Bribery and Corruption Policy, Privacy and Data Protection Policy and Procurement Policy
• Standards review and approval: new Environmental Standard and Supplier Code of Conduct
• Performance monitoring: Ethics and Compliance Programme, Privacy Programme and sustainability-related STIs (people, climate and privacy topics)
• Sustainable finance development: Social Bond, Social Bond Framework and ESG ratings monitoring
• Regulatory monitoring related to sustainability reporting, due diligence, deforestation, artificial intelligence, privacy and accessibility regulation
• Internal audit: sustainability reporting readiness assessment

In 2024, the administrative, management and supervisory bodies reviewed the progress of the Corporate Sustainability Reporting Directive project at Sanoma, and participated in the double materiality assessment process that included reviewing, validating and approving material impacts, risks and opportunities.

Integration of sustainability-related performance in incentive schemes

Roles covered

Sustainability targets are embedded into the short-term incentives (STI) of the executive management. The Executive Management Team (EMT) members' incentives include sustainability KPIs. The Board of Directors' Human Resources Committee reviews and approves the incentive schemes, including the sustainability targets, annually.

The Board of Directors, the Human Resources Committee and the EMT approve the annual short-term incentive targets and performance outcomes that also include targets related to Sanoma's material impacts, risks and opportunities.

Sanoma's sustainability administrative and supervisory bodies, the Audit Committee and the Board of Directors, do not have performance-based incentives related to sustainability.

Specific sustainability KPIs tied to remuneration

In 2024, alongside financial metrics, sustainability targets constituted 20% of the total annual short-term incentives for the members of the EMT at the target level:

• 10% linked to the Employee Engagement Survey (EES)
• 5% linked to internal data and privacy targets
• 5% linked to climate targets

Employee Engagement Survey (EES): The EES is a key component of the sustainability metrics, reflecting Sanoma's focus on employee well-being.

Privacy-related metrics: Covered the standardisation of processes for managing privacy and conducting Privacy Impact Assessments for new products.

Climate targets: Linked to the Science Based Targets initiative (SBTi), which drives ambitious climate action in the private sector. In practice, the EMT members' incentives were linked to Sanoma's SBTi emissions reduction targets for Scopes 1, 2 and 3. These targets are to reduce combined absolute Scope 1 and 2 GHG emissions by 42% by 2030, from the 2021 base year, and to reduce Scope 3 emissions by 38% by 2030, from the 2021 base year (in categories 1, 3 and 4).

Weighting

Sustainability targets constituted 20% of the total annual short-term incentives for the members of the EMT at the target level.

Breakdown:

• Employee Engagement Survey: 10%
• Data and privacy targets: 5%
• Climate targets: 5%

Type of incentive scheme

Sustainability KPIs are tied to short-term incentives (STI). The disclosure does not indicate sustainability KPIs in the long-term incentive (LTI) plans.

Performance period and target structure

The STI performance criteria are set by the Board at the beginning of the financial year for a one-year performance period.

For 2024:

• The STI performance period was the financial year 2024
• Performance outcomes are evaluated at year-end
• The earned STI reward is paid in spring of the following year (spring 2025 for 2024 performance)

Threshold/target/maximum performance definition

For the CEO in 2024 (as an example of EMT member):

• Target level: 66.7% of annual base salary
• Maximum level: 100% of annual base salary

The performance outcome in the STI for 2024 was 124%, with the outcome of both financial and sustainability targets being in-line with or above the target level.

Disclosure of payout against sustainability KPIs in the reporting period

For 2024, the performance outcome in the STI was 124%, resulting from the financial and sustainability performance of the Company. The outcome of both financial and sustainability targets was in-line with or above the target level. The earned STI reward will be paid in spring 2025.

Specific performance against individual sustainability KPIs:

• The Employee Experience Index for 2024 stood at 7.4, compared to 7.5 in 2023
• Greenhouse gas emissions: In own operations (Scope 1 and 2), Sanoma has already reached the SBTi emission reduction targets set for 2030 (44% reduction achieved by end of 2024 vs. 42% target). Scope 3 emissions in categories 1, 3 and 4 decreased by 38% by the end of 2024 from the 2021 baseline, meeting the 2030 target.
• Privacy and data targets: Progress was made in enhancing data security and privacy across operations, with specific focus on the ethical and secure use of AI

At Sanoma, we impact the lives of millions of people every day. We work hard to equip the world with the highest-quality learning resources, independent media and local entertainment. Sustainability is integrated into our purpose and everything we do.

We are one of the global leaders in K12 education and Finland's #1 digital cross-media company. Over 20 years, we've grown through acquisitions in K12 learning across Europe and by leading the successful shift to digital media in Finland.

Our purpose: Through learning and media, we have a positive impact on the lives of millions of people every day.

Our ambition: Group net sales over EUR 2 billion by 2030 with at least 75% coming from the learning business.

Learning: Sanoma Learning is one of the global leaders in K12 education, serving about 25 million students across Europe. Our learning products and services enable teachers to develop the talents of every child to reach their potential. We offer printed and digital learning materials as well as digital learning and teaching platforms for K12, i.e. primary, secondary, and vocational education, and we aim to continue to grow our business in Europe and beyond. We develop our methodologies based on deep teacher and student insight and by truly understanding their individual needs. By combining our educational technologies and pedagogical expertise, we create learning products and services with the highest learning impact.

Media Finland: Sanoma Media Finland is the leading cross-media company in Finland, reaching 96% of all Finns weekly. We provide information, experiences, inspiration, and entertainment through multiple media platforms: newspapers, TV, radio, events, magazines, online, and mobile channels. We have leading brands and services, such as Helsingin Sanomat, Ilta-Sanomat, Aamulehti, Me Naiset, Aku Ankka, Nelonen, Ruutu, Supla, and Radio Suomipop. For advertisers, we are a trusted partner with insight, impact, and reach.

Sanoma Learning's annual European Teacher Survey represents the voice of teachers. The survey reveals the main drivers and challenges in primary and secondary education across Europe.

84% of teachers say that Sanoma's materials support them in reaching curriculum objectives

73% of teachers agree that our materials help engage their students

78% of teachers agree that our materials support efficiency

In media, our mission is to provide independent Finnish journalism and engaging local entertainment for current and future generations. To promote independent journalism and freedom of expression, we for example made the journalistic and ethical guidelines of our news media more transparent to the audience.

Global megatrends impacting our business:

Accelerating digitalisation and responsible use of AI continue to transform learning and media ecosystems:

• Trusted brands and digital destinations becoming increasingly valuable
• Sufficient investments and sustainable financial performance during digital era require scale and integrity in the use of data and AI

Rising inequalities call for a focus on enhancing equality:

• Learning and media content are key in enhancing diversity and inclusion in society
• Diverse employees, who feel included and engaged in their workplace, deliver better results

Challenging economic and geopolitical environment with increasing importance of both global and local:

• Continuing challenges in economic growth, development and geopolitical tensions
• Digital content increasingly crosses national borders enhancing globalisation
• At the same time, continued meaning of local aspects and impact both in learning and media
• Developing demography and migration transform the consumption of learning and media content in the long run

Climate crisis requires more urgent action:

• Learning and media content play a key role in increasing fact-based public knowledge
• Ambitious corporate climate action and responsible business practices lead the way to a low-carbon economy, boost innovation and drive sustainable growth

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

Overview of the double materiality assessment process

Sanoma conducted a comprehensive double materiality assessment (DMA) during 2023–2024 to identify actual and potential sustainability-related impacts, risks and opportunities relevant for the company. The process follows the European Sustainability Reporting Standards' requirements as well as the principles of Sanoma's Enterprise Risk Management process.

The reported topics are based on Sanoma's double materiality assessment process conducted in 2024. The identified material impacts, risks and opportunities cover Sanoma's own operations as well as the upstream and downstream value chain. For the upstream value chain, the statements cover information on Sanoma's tier 1 suppliers. In addition, Sanoma traces and monitors the origin of its purchased materials further in the supply chain to tier 2 suppliers. For downstream value chain, the statements cover information extending to consumers and end-users.

Governance and responsibilities

The responsibilities of the administrative and supervisory bodies related to the DMA are determined in Sanoma's sustainability management model. The results of the assessment were reviewed by the Executive Management Team and approved by the Board of Directors in 2024.

The DMA process was hosted by Sanoma's Sustainability team, in close cooperation with the Compliance team. All members of Sanoma's Sustainability and Ethics Working Group participated in the DMA, in addition to other key internal stakeholders, such as the Managing Directors of all Learning operating companies.

Step-by-step methodology

Phase 1 (2023): Initial identification

During the first phase in 2023, Sanoma listed all actual and potential impacts, risks and opportunities by:

• Using the ESRS 1 longlist of sustainability topics
• Complementing the list with company-specific topics
• Consolidating existing insights within the Company

Inputs to the assessment included:

• Results of the Enterprise Risk Management (ERM) process
• Compliance risk survey
• Climate and biodiversity risks assessment
• Human Rights Impact Assessment
• Employee Engagement Survey
• DE&I survey
• A previous impact-focused sustainability materiality assessment
• Review of misconduct cases reported via Sanoma's whistleblowing channel

Stakeholder views incorporated:

• Own workforce
• Value chain workers
• Customers and end-users
• Investors

Sanoma also used insights and reports from credible proxies and interviewed internal experts to ensure a comprehensive view. Sanoma utilised the Sustainability Accounting Standard Board's (SASB) Media & Entertainment, Advertising & Marketing (Media Pluralism, Journalistic Integrity & Sponsorship Identification, Intellectual Property Protection & Media Piracy, Data Privacy, Advertising Integrity) and Education (Data Security, Quality of Education & Gainful Employment) sectors' Sustainability Accounting Standards as inspiration.

Phase 2 (2024): Prioritisation and assessment

During the second phase in 2024, all actual and potential impacts, risks and opportunities were prioritised by performing impact and financial assessments in workshops together with internal topic owners.

Internal topic owners include:

• Procurement representatives
• HR representatives
• Compliance representatives
• Legal representatives
• Privacy representatives
• Security representatives
• Strategy representatives
• Managing directors for key business areas

The topic owners used available sources and their overall expertise and judgement to assess each topic. Several calibration meetings were held to align interpretations of the criteria and scales used.

Scoring criteria for impact materiality

Impact materiality of each sustainability matter was assessed as follows:

• Severity of negative impacts:

  • Scale
  • Scope
  • Irremediability

• Significance of positive impacts:

  • Scale
  • Scope

• Likelihood of potential impacts on a scale of:

  • Very unlikely (10%)
  • Unlikely (30%)
  • Uncertain (50%)
  • Likely (70%)
  • Very likely (90%)

• Location of the impact in the value chain:

  • Upstream
  • Own operations
  • Downstream

• Time horizon of the impact:

  • Short term (0–1 years)
  • Medium term (1–3 years)
  • Long term (3 years and beyond)

Note: With regard to potential negative human rights impacts, it was noted that the severity of the impact takes precedence over likelihood.

Scoring criteria for financial materiality

Financial materiality of each sustainability risk and opportunity was assessed as follows:

• Financial significance of risk or opportunity on a scale of:

  • Not significant (EUR 0–1 million)
  • Low (EUR 1–5 million)
  • Average (EUR 5–20 million)
  • High (EUR 20–40 million)
  • Very high (EUR 40+ million)

• Likelihood of risk or opportunity on a scale of:

  • Very unlikely (10%)
  • Unlikely (30%)
  • Uncertain (50%)
  • Likely (70%)
  • Very likely (90%)

• Location of the risk or opportunity in the value chain:

  • Upstream
  • Own operations
  • Downstream

• Time horizon of impact:

  • Short term (0–1 years)
  • Medium term (1–3 years)
  • Long term (3 years and beyond)

• Financial risks and opportunities assessment followed the same scale as used in Sanoma's ERM process.

Threshold for materiality

After the topic owners had performed their assessments, the results of the assessments were consolidated to a list of impacts, risks and opportunities material to Sanoma. To ensure comparability between topics, the Sustainability and Compliance teams performed a final review of the list of material impacts, risks and opportunities for reporting purposes. This review also included discussions with the Executive Management Team.

The double materiality process determines the impacts, risks and opportunities for the sustainability disclosure and all topics that are impact or financially material, or both, are disclosed in the Sustainability Statement. A sustainability matter was deemed material if at least one impact, risk or opportunity indicated either impact materiality, financial materiality, or both. Non-material sustainability matters were those where no impacts, risks or opportunities were identified or all IROs were found unlikely, financially not significant or not causing impacts.

The financial threshold for sustainability-related risks disclosed is the same as in Sanoma's Enterprise Risk Management process. All potential risks identified in Sanoma's double materiality assessment fall into the category of low risk.

Frequency and last review

The double materiality assessment was conducted during 2023–2024. Sanoma will evaluate the need to update its double materiality assessment annually.

Use of value chain mapping

The DMA considers Sanoma's impacts through its own operations and as a result of its business relationships. It focuses on Sanoma's business activities related to its learning and media businesses, with the geographies including all Sanoma's operating countries. Business relationships have been especially assessed for tier 1 suppliers, extending the assessment to tier 2 suppliers within categories of higher risk, such as the paper and print suppliers.

The assessment covered direct operations as well as the upstream and downstream value chain. Tier 1 suppliers were analysed in particular, but for example to analyse the printing houses' ability to reduce emissions, also tier 2 paper suppliers data was reviewed.

Integration with overall management process

The double materiality process guides the priorities of the sustainability issues. The process to identify, assess and manage impacts and opportunities is integrated into Sanoma's overall management process through Sanoma's sustainability management model, which determines that annually Sanoma identifies and assesses its impacts, risks and opportunities and determines actions to manage the material IROs.

During the double materiality assessment, Sanoma assessed risks related to sustainability separately from the ERM process and re-assessed sustainability risks identified within the ERM process. In addition, the preliminary results of the DMA were used to enrich the ERM results during autumn 2024, and to evaluate Sanoma's overall risk profile.

Prioritisation approach

In many areas identified as material, Sanoma has defined specific KPIs to measure performance and discloses these metrics and targets in its Sustainability Statement. Sanoma's management of sustainability impacts, risks and opportunities is based on targeting measures at areas where the impact or risks are the highest. Where Sanoma cannot address all impacts or risks at once, the due diligence process allows for actions to be prioritised based on the severity or financial significance and likelihood of impacts.

Limitations and future development

There is certain inherent uncertainty related to the double materiality assessment as practices of the assessment are evolving. Going forward, Sanoma plans to analyse the time horizon of impacts, risks and opportunities using longer time horizons. Also, upstream and downstream impacts require continuous assessment, e.g., due to the EU deforestation regulation, which will enhance the traceability of paper-related products and Sanoma's ability to review its biodiversity impacts throughout its upstream value chain.

Sanoma has assessed sustainability-related dependencies during both its ERM risk assessment as well as the double materiality assessment process. Identified dependencies include e.g., dependencies related to the availability of key staff, availability of certified paper to produce its printed products and dependency of customer data to develop its digital products.

Topic-specific assessment approaches

Climate change (E1)

Sanoma assesses its impacts on climate change, in particular on GHG emissions, by annually calculating its actual climate impacts according the GHG Protocol, as described under E1-6. As a part of its annual GHG emission calculations and transition planning, Sanoma also screens and identifies potential future GHG emission sources.

Sanoma evaluates climate- and biodiversity-related physical and transition risks annually and in 2024, they were assessed as part of the double materiality assessment. Physical and transition risks were analysed over short (0–1 years), medium (1–3 years), and long-term (3– years) horizons. These timeframes are used for strategic and financial planning as well as in the ERM process. The assessment covers both own operations as well as the upstream and downstream value chain.

Sanoma's scenario analysis for transition and physical risks has included assessing the impacts of current and future regulations on operations and supply chains, evaluating changes in customer behaviour and market demand for sustainable products as well as identifying opportunities for adopting new technologies to reduce emissions. In its assessment, Sanoma has used climate scenarios, including scenarios in line with limiting global warming to 1.5°C with no or limited overshoot and high-climate scenarios, such as RCP 1.9, RCP 4.5, RCP 8.5 and IEA SDS to understand potential alternative futures and to develop strategies to mitigate identified risks based on scenario outcomes. These scenarios are based on best available scientific evidence, such as the IPCC assessments.

Sanoma continuously monitors and develops its ability to assess climate-related risks.

Pollution (E2)

Sanoma's double materiality assessment process identified pollution as a non-material topic due to the Company's minimal pollution impacts, with no substances of concern found in comparison to the ECHA Candidate List. Consultations confirmed that Media Finland's printing houses report small VOC (volatile organic compounds) emissions and that the Group's plastic use is minor and continuously minimised, with no significant microplastics identified.

Water and marine resources (E3)

Sanoma's double materiality assessment deemed water and marine resources as non-material topics due to minimal impacts, with no significant water or marine resource impacts identified.

Biodiversity and ecosystems (E4)

Sanoma evaluates climate- and biodiversity-related physical and transition risks annually, and in 2024 as a part of the double materiality assessment, as described above under E1 IRO Climate change. Sanoma identified two transitional risks related to biodiversity and ecosystems in its assessment: the availability of certified paper and regulatory uncertainty from the EU Deforestation Regulation. These risks were assessed as low, with no physical or systemic risks identified. Sanoma continuously monitors and develops its ability to assess these risks.

In relation to biodiversity, no significant impacts were identified in Sanoma's double materiality assessment at own site locations, but upstream value chain impacts were recognised, particularly from paper production and sourcing, which can lead to biodiversity loss, ecosystem disruption, and pollution. Sanoma has assessed its dependencies on biodiversity and ecosystems, particularly related to forest commodities, focusing on the availability of certified paper and the carbon profiles of paper suppliers.

Sanoma has not conducted consultations with affected communities on sustainability assessments of shared biological resources and ecosystems. Sanoma does not have sites near biodiversity-sensitive areas and therefore does not need to implement biodiversity mitigation measures in own sites were not identified. Sanoma has not used biodiversity and ecosystems scenario analysis to inform the identification and assessment of material risks and opportunities over short-, medium- and long-term time horizons. Sanoma continuously monitors and develops its ability to assess biodiversity-related risks.

Resource use and circular economy (E5)

Sanoma screened its assets, own operations and upstream and downstream value chain activities during the double materiality assessment and ERM process to identify resource use-related impacts, risks, and opportunities. The screening identified actual upstream value chain and own operations impacts related to the use of materials like paper, printing plates, inks, and solvents, but there were no significant risks or opportunities outside those reported under biodiversity related to paper use and availability, and no significant impacts on Sanoma's mostly intangible assets. In addition, the impact of waste generated in facilities, warehouses and printing houses was identified as own operations' impact. Sanoma did not conduct specific consultations with affected communities.

Business conduct (G1)

The double materiality process in relation to business conduct matters included sector-specific analysis of business activities, operations, functions, transactions as well as geographical areas where the business operates in relation to risk locations and where its impacts are most significant. As a result, procurement, as well as the sales teams in countries, where the sales happens through agents, such as Spain and Italy, have been identified as functions that are most at risk in respect of corruption and bribery.

External consultations

No external consultations were conducted in regards to climate, pollution, water, biodiversity or resource-use impacts.

Validation process

In 2024, the administrative, management and supervisory bodies reviewed the progress of the Corporate Sustainability Reporting Directive project at Sanoma, and participated in the double materiality assessment process that included reviewing, validating and approving material impacts, risks and opportunities.

Transition plan for climate change mitigation

Sanoma's transition plan related to climate change mitigation focuses on minimising its climate impacts. The Science Based Targets initiative (SBTi) has approved Sanoma's near-term 2030 science-based emission reduction targets for its own operations (Scope 1 and 2) and value chain (Scope 3). This validation confirms that Sanoma's climate strategy and business model are compatible with the transition to a sustainable economy and the limiting of global warming to 1.5-degrees in line with the Paris Agreement.

Scope of the plan

Sanoma's climate transition plan covers:

• Own operations (Scope 1 and 2): All facilities, warehouses and printing houses operated by Sanoma across Europe
• Value chain (Scope 3): Categories 1 (Purchased goods and services), 3 (Fuel and energy-related activities) and 4 (Upstream transportation and distribution), which together accounted for over 75% of Sanoma's value chain emissions in 2024
• Entities: All Sanoma operations across Europe (Learning SBU and Media Finland SBU)

Target years and milestones

SBTi validated targets:

• Scope 1 and 2: Reduce combined absolute GHG emissions by 42% by 2030, from the 2021 base year
• Scope 3: Reduce emissions by 38% by 2030, from the 2021 base year (categories 1, 3 and 4)

Progress as of 2024:

• Scope 1 and 2 combined emissions reduced by 44% from 2021 baseline
• Scope 3 emissions (categories 1, 3 and 4) reduced by 38% from 2021 baseline (target already reached)

Intermediate targets:

• 100% fossil-free electricity by 2024 (97% achieved)
• Transition to fossil-free energy by 2030

Paris alignment and SBTi validation

Sanoma's targets are validated by the Science Based Targets initiative (SBTi) and aligned with limiting global warming to 1.5°C with no or limited overshoot. The targets use the cross-sector (ACA) reduction pathways as per SBTi Technical Summary (Version 1.0, October 2021).

Table: Cross-sector reduction pathway

Source: Based on Pathways to Net-zero –SBTi Technical Summary (Version 1.0, October 2021)

Decarbonisation levers

Scope 1 and 2 (own operations):

• Energy efficiency: Continuous reduction of heating consumption, AI optimisation of heating use in Finland (Sanoma House headquarters and both printing houses)
• Renewable energy: Switch to renewable and fossil-free electricity and heating. In 2024, 2,125 solar panels installed on Sanoma House and Manu printing house roofs
• Fossil-free energy: All facilities and printing houses in Finland use fossil-free electricity; facilities in Sweden, Poland, Netherlands, Belgium, Spain and Italy use fossil-free or renewable electricity
• Transport: Transition to electric and hybrid company cars (renewed car policies in Italy, Netherlands and Belgium during 2024)
• Office restructuring: Discontinued unnecessary office facilities in Finland, Sweden, Norway, France and Netherlands

Scope 3 (value chain):

• Supplier cooperation: Annual collection of supplier-specific emissions data from paper, printing and logistics suppliers; monitoring of key suppliers' climate targets
• Paper procurement: Partnership with suppliers to use lower-carbon paper; cooperation with printing suppliers on ambitious target setting
• Material efficiency: Optimisation of paper weights; transition to low-carbon paper qualities
• Logistics: Use of low-carbon transport options
• Digitalisation: Continued transition from print to digital in media business, reducing print-related GHG emissions
• Cloud and digital products: Monitoring GHG emissions related to digital products; developing methods for efficient data use

CapEx and investment commitments

Sanoma has not identified significant capital expenditure and operational expenses which would currently be required to implement its climate transition plan. Investments have been and are expected to be minor:

• Minor investments in renewable and fossil-free energy (own operations Scope 1 and 2)
• Investments in supplier cooperation, energy efficiency, and AI optimisation
• Investment in solar panels (2,125 panels installed in 2024)
• Investment in new reporting tool in 2024 to meet regulatory requirements

Sanoma does not expect that its ability to implement its climate transition plan depends significantly on the availability and allocation of financial and operational resources. In Scope 3, success depends mainly on cooperation and commitment of suppliers.

Locked-in emissions and stranded assets

Sanoma does not identify any significant locked-in GHG emissions, i.e., future GHG emissions that are likely to be caused by key assets or products sold within their operating lifetime. As Sanoma's assets are mostly intangible, no assets or business activities that are sensitive to significant physical hazards or transition risks or incompatible with the transition to a climate-neutral economy have been identified.

Use of carbon credits and removals

Sanoma's GHG emission reduction targets are gross targets, meaning that no GHG removals, carbon credits or avoided emissions as means of achieving the GHG emission reduction targets have been included.

Governance and integration

The transition plan is embedded in Sanoma's overall strategy through:

• Financial incentives: SBTi climate targets linked as sustainability KPIs to the EUR 300 million Syndicated Revolving Credit Facility
• Executive compensation: Executive management's short-term incentives for 2024 linked to SBTi emissions reduction targets for Scopes 1, 2 and 3
• Approval: Transition plan approved in 2021 by Sanoma's Board, Audit Committee and Executive Management Team
• Monitoring: Progress reviewed as part of sustainability management approach

EU Taxonomy alignment

As the EU Taxonomy's list of potentially eligible activities does not include any learning or news media-related economic activities relevant to Sanoma, Sanoma's core business activities are not currently included in the scope of the EU Taxonomy. Therefore Sanoma does not have plans in place to align its economic activities (revenues, CapEx, OpEx) with the criteria established in the EU Commission Delegated Regulation 2021/2139.

Sanoma is not excluded from the EU Paris-Aligned Benchmarks.

Scenario analysis and critical assumptions

Sanoma has used climate scenarios including scenarios in line with limiting global warming to 1.5°C with no or limited overshoot and high-climate scenarios, such as RCP 1.9, RCP 4.5, RCP 8.5 and IEA SDS to understand potential alternative futures and develop mitigation strategies.

Critical assumptions for setting GHG emission reduction targets include:

• Changes in paper volumes and print production
• Shifts in customer demand, especially the pace of digitalisation in both businesses
• Regulatory changes
• General transition pace towards fossil-free energy formats
• Increases in paper volumes following curriculum renewals (mitigated through low-carbon paper and weight optimisation)

Sanoma is currently not planning to adopt new technologies to achieve GHG emission reduction targets.

Policies related to climate change mitigation and adaptation

Sanoma has adopted several policies and standards that address climate change mitigation and adaptation. The principles set in Sanoma's policies and standards govern Sanoma and its subsidiaries and apply to all companies in which Sanoma has financial control.

Supplier Code of Conduct (SCoC)

Policy name: Supplier Code of Conduct (SCoC)

Last updated: November 2024

Scope:

• All Sanoma suppliers in all geographies
• Applies to key suppliers and service providers

Key content:

• Outlines Sanoma's environmental principles and requirements towards all suppliers
• Addresses climate change, use of renewable energy, use of plastics, deforestation or forest degradation impacts, waste management, circularity and pollution prevention
• Sets out ethical standards and responsible business principles that suppliers are required to comply with

Governance:

• Sanoma's Group Procurement team is responsible for updating, communicating and leading the implementation of the Supplier Code of Conduct

Public availability:

• Made available on Sanoma's website
• Relevant parts embedded into Sanoma's annual Code of Conduct refresher training which is mandatory for all employees

Monitoring:

• Violations or concerns of non-compliance are to be reported through Sanoma's whistleblowing channel (available in several languages)
• Sanoma reserves the right to cancel orders, suspend orders and/or terminate contracts with suppliers in the event of a material breach
• Sanoma can withhold payment for non-confirmatory products or services

Sustainability and Human Rights Policy

Policy name: Sustainability and Human Rights Policy

Published: December 2024

Scope:

• All Sanoma operations across Europe

Key content:

• Outlines Sanoma's sustainability-related principles and summarises core commitments in own operations
• Defines Sanoma's sustainability due diligence process, including identification, assessment, management and remediation of sustainability-related impacts
• Outlines Sanoma's sustainability management model and responsibilities to identify impacts, risks and opportunities through the double materiality assessment process
• In relation to environmental topics, commits to the Ten Principles related to fundamental responsibilities, especially environment, as well as the Rio Declaration on Environment and Development

International standards linkage:

• As a signatory of the UN Global Compact (UNGC), Sanoma commits to the UN Guiding Principles and the Agenda 2030, including UN Sustainable Development Goals (SDGs)

Governance:

• Approved by the Board of Directors
• President and CEO and Executive Management Team (EMT) are ultimately responsible for ensuring Sanoma personnel are aware of and comply with the policies
• Sanoma's Group Sustainability team is responsible for updating, communicating and leading the implementation

Public availability:

• Made available internally to employees via Sanoma's intranet
• Made available externally to stakeholders such as customers and suppliers on Sanoma's website
• Relevant parts embedded into Sanoma's annual Code of Conduct refresher training which is mandatory for all employees

Stakeholder engagement:

• Stakeholders' views were taken into consideration in policy setting by analysing insights received from suppliers, customers and employees

Environmental Standard

Policy name: Environmental Standard

Published: December 2024

Scope:

• All Sanoma operations across Europe

Key content:

• Outlines Sanoma's environmental principles and determines how Sanoma manages its environmental impacts
• Addresses climate change adaptation and mitigation, energy efficiency, use of fossil-free energy, use of plastics, biodiversity impacts, waste management, circularity and pollution prevention
• Includes commitments to energy efficiency, renewable energy use, and GHG emissions reductions
• Promotes sustainable material use and responsible procurement

International standards linkage:

• As a signatory of the UN Global Compact, recognises the importance of Agenda 2030 and UN SDGs, particularly SDGs 11 (Responsible consumption and production), 13 (Climate Change) and 17 (Partnerships for the Goals)
• Committed to UN Ten Principles related to fundamental responsibilities, such as the environment and the Rio Declaration on Environment and Development
• Adheres to relevant local, national, and international environmental laws and regulations
• Supporter of the European Climate Pact, part of the European Green Deal helping the EU meet its goal to become climate-neutral by 2050
• Respects third-party standards and initiatives including FSC and PEFC certification schemes and environmental management systems such as ISO 14001 certification

Governance:

• Approved by the President and CEO (internal standard)
• President and CEO and EMT are ultimately responsible for ensuring compliance
• Sanoma's Group Sustainability team is responsible for updating, communicating and leading the implementation

Public availability:

• Made available internally to employees via Sanoma's intranet
• Made available externally to stakeholders on Sanoma's website
• Relevant parts embedded into Sanoma's annual Code of Conduct refresher training which is mandatory for all employees

Stakeholder engagement:

• Stakeholders' views were taken into consideration in standard setting by analysing insights received from suppliers, customers and employees
• Sanoma engages with suppliers, such as paper and print suppliers, to ensure implementation of its climate transition plan

Monitoring:

• The Environmental Standard is implemented locally across Sanoma businesses
• Group Sustainability and Procurement teams support implementation
• Facilities and printing houses in Finland, Italy and Norway use international standards such as ISO 14001 and Breeam-certification as foundation for energy management

Actions and resources in relation to climate change policies

Overall approach

Sanoma's climate change mitigation focuses on reducing GHG emissions in both its own operations (Scope 1 and 2) and value chain (Scope 3). Actions are aligned with Science Based Targets initiative (SBTi) validated targets and are to be completed by 2030.

Time horizon: All key actions to be completed by 2030.

Resources allocated: Sanoma has allocated resources to the implementation of its climate transition plan, including investments in supplier cooperation, renewable and fossil-free energy, energy efficiency, and AI optimisation. Sustainability and Procurement teams cooperate with both own production as well as suppliers' production teams to reduce emissions. Sanoma hosts internal environmental working groups in both SBUs to ensure progress in emission reduction initiatives. Financial resources are integrated into overall financial plan. Investments have been and are expected to be minor. No significant monetary amounts of capital expenditure and operational expenses are currently required to implement the actions taken or planned.

Link to policy/target: Actions are aligned with SBTi validated targets: reduce combined absolute Scope 1 and 2 GHG emissions by 42% by 2030, and Scope 3 emissions by 38% by 2030 (from 2021 base year).

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Climate change mitigation - Own operations (Scope 1 and 2)

Scope: Own operations - printing houses in Finland and facilities and warehouses throughout Europe.

Energy transition initiatives

Actions taken in 2024:

• Solar panel installation: 2,125 solar panels planted on roofs of Sanoma House in Helsinki and Manu printing house in Tampere, Finland to increase own renewable electricity production
• Fossil-free electricity: All facilities and printing houses in Finland transitioned to fossil-free electricity. Office facilities in Sweden, Poland, Netherlands, Belgium, Spain and Italy also use fossil-free or renewable electricity
• Renewable heating: Facilities and printing houses in Finland transitioned to fully renewable heating during 2023-2024. Renewable heating also used in the Netherlands, Sweden and Norway
• Office restructuring: Discontinued unnecessary office facilities in Finland, Sweden, Norway, France and the Netherlands, resulting in reduced consumption of electricity, district heating and cooling

Expected outcomes/KPIs: In 2024, own operations' emissions (Scope 1 and 2) declined by 44% compared to 2021 base year. 97% fossil-free electricity achieved in 2024.

Intermediate targets: 100% fossil-free electricity aim for 2024 (97% achieved); transitioning to fossil-free energy by 2030.

Planned actions:

• Continue transition to renewable energy sources especially in heating and cooling
• Improve energy efficiency across operations
• Continue restructuring of office spaces for better energy efficiency

Company car fleet transition

Actions taken in 2024:

• Renewed car policies in Italy, the Netherlands and Belgium to support transition to electric and hybrid cars

Planned actions:

• Continue shift towards electric and hybrid company cars (Scope 1 reduction)

Scope: Company car policies across multiple countries in Europe

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Climate change mitigation - Value chain (Scope 3)

Scope: Upstream value chain in all sourcing countries.

Expected outcomes/KPIs: Scope 3 emissions reduced by 38% in categories 1, 3 and 4 by end of 2024 from 2021 base year, reaching SBTi target ahead of 2030. Categories 1, 3 and 4 represented over 75% of Sanoma's Scope 3 emissions in 2024.

Supplier cooperation

Actions taken in 2024:

• Continued cooperation with paper suppliers to use lower-carbon paper
• Continued cooperation with printing suppliers to ensure ambitious target setting and reliable carbon accounting
• Annual collection of supplier-specific emissions data from paper, printing and logistic suppliers
• Follow-up on key suppliers' climate targets
• Supplier Day hosted to enhance cooperation with paper and print suppliers, including know-how on product-level emission calculations, EUDR, CSRD, CSDDD and other regulatory developments

Planned actions:

• Continue reducing paper-related emissions through more extensive use of low-carbon paper qualities
• Continue cooperation with logistic suppliers to reduce GHG emissions through further use of low-carbon transport options
• For future curriculum renewals: prevent increases in emissions through changes in paper carbon profiles to low-carbon options and optimising of paper weights in products

Digitalisation

Actions:

• Transition from print to digital continued in media business, resulting in decline of print-related (paper, materials, logistics) GHG emissions
• In learning business, paper consumption decreased, and printing-related emissions (energy, materials and logistics) declined

Planned:

• Further emissions reductions expected especially as a result of digitalisation of media

Other purchased services

Actions:

• Continuously develop calculation models and cooperation with suppliers of IT equipment, consulting, marketing, cloud-services and TV productions to ensure further reductions

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Climate change adaptation - Transition risks

Actions taken in 2024:

• Invested in new reporting tool to meet growing reporting and regulatory requirements

Planned actions:

• Continue to develop compliance by ensuring adequate resources and supplier cooperation to ensure data quality and availability

Scope: Own operations and value chain

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Climate change adaptation - Physical risks

Actions:

• Continuity and disaster recovery plans in place for critical systems and operations
• Insurance programme provides coverage for insurable hazard risks
• Regular continuity and disaster recovery planning and insurance coverage reviews in facilities

Scope: Own operations - printing houses in Finland and facilities and warehouses throughout Europe

Context: Acute physical risks like flooding may pose risk to Sanoma's printing houses, facilities and warehouses. During 2024, some of Sanoma's facilities in Spain suffered damages due to heavy flooding.

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Decarbonisation levers

Sanoma's key decarbonisation levers include:

• Transitioning to fossil-free energy on own operations and supply chain
• Energy efficiency
• Materials efficiency
• Optimisation of materials use
• Supplier cooperation
• AI optimisation to improve energy consumption
• Digitalisation

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Performance 2024

Scope 1 and 2: Declined by 44% compared to 2021 base year (target: -42% by 2030)

Scope 3 (categories 1, 3, 4): Declined by 38% compared to 2021 base year (target: -38% by 2030 - achieved ahead of schedule)

Energy mix: Share of renewable and fossil-free energy in overall energy mix was 92% in 2024

Science-based climate targets:

• We reduce absolute Scope 1 and 2 GHG emissions 42% by 2030 from a 2021 base year
• We reduce absolute Scope 3 GHG emissions from categories 1, 3 and 4 by 38% by 2030 from a 2021 base year
• By end of 2030, we will be carbon neutral

Energy targets:

• We use only fossil-free electricity
• By 2030, all energy used is fossil-free or renewable

Performance 2024:

• Own operations (Scope 1 and 2) emission reduction from 2021: 44%
• Value chain (Scope 3) emission reduction from 2021: 38%
• Share of fossil-free electricity: 97%
• Share of fossil-free energy: 92%

Energy consumption and mix

Total energy consumption

Sanoma's total energy consumption in 2024 was 34,664 MWh. The share of renewable and fossil-free energy in the overall energy mix was 92%.

Scope: All owned and leased properties controlled by Sanoma, including printing houses, offices, and warehouses across all operating countries. Less than 1% of energy consumption figures are based on estimates.

Methodology: Energy is classified as renewable or nuclear-based if the origin is defined in contractual instruments with suppliers or guarantees of origin are available. If the origin is unknown, the source is classified as fossil. Self-generated energy data collected from energy management systems at Sanoma House (Helsinki) and Manu printing house (Tampere).

Disaggregated energy consumption

Energy production

• Renewable energy production: 238 MWh
• Non-renewable energy production: 40 MWh

Energy intensity (high climate impact sectors)

Sanoma identified its two printing houses in Finland as falling under high climate impact sector C18.1.1 (Printing of newspapers) per EU Delegated Regulation 2022/1288.

• Total energy consumption from activities in high climate impact sectors: 18,891 MWh
• Energy intensity (total energy consumption per net revenue) from activities in high climate impact sectors: 75 MWh per million EUR
• Net revenue from printing houses (Media Finland print category): EUR 251.1 million

Gross Scopes 1, 2, 3 and Total GHG emissions

Summary of Total GHG Emissions (2024)

Sanoma's total market-based GHG emissions in 2024 were 101,810 tCO₂e. Own operations (Scope 1 and 2) represented 5% of total emissions, while value chain (Scope 3) emissions accounted for 95%.

Gross GHG Emissions by Categories

Note: Targets for 2030 are illustrative absolute emission targets derived from Sanoma's science-based targets for Scope 1 and 2 combined and Scope 3 categories 1, 3 and 4. Sanoma has not set targets extending to 2050. Comparison figures for 2023 not disclosed in the first Sustainability Statement.

GHG Emission Reductions from Base Year 2021

GHG Intensity Based on Net Revenue

Sanoma uses net sales as the denominator in the calculation of GHG intensity.

Scope 1 Sub-breakdown

No detailed sub-breakdown by source (stationary combustion, mobile combustion, process emissions, fugitive emissions) is disclosed. Scope 1 emissions include:

• Use of owned and leased cars
• Reserve power mainly used in printing houses
• Fuel consumption from owned and controlled vehicles and generators

Biogenic CO₂ Emissions

Not separately disclosed.

Regulated Emissions (e.g. EU ETS)

In Scope 1, no GHG emissions originate from regulated emission trading schemes (0%).

Methodology and Scope Notes

GHG emissions accounting principles:

• Sanoma reports GHG emissions according to the Greenhouse Gas Protocol (WBCSD and WRI).
• All relevant GHG emissions are included. Exclusions to Scope 3 categories follow GHG Protocol guidance, estimated using the GHG Protocol Scope 3 Evaluator tool.
• GHGs included (if relevant): CO₂, CH₄, N₂O, HFCs, PFCs, SF₆, NF₃. Reported using 100-year Global Warming Potential (GWP) values from IPCC Assessment Reports.
• Organisational boundary: financial control.
• Figures reported as tCO₂ equivalents.
• No significant changes to scope in 2024 impacting year-on-year comparability.

Scope 1:

• Emission sources: fuel consumption from owned and controlled vehicles and generators (reserve power).
• Emission factors: road transport from Defra GHG Conversion Factors; fuel from Statistics Finland.
• All gases included.

Scope 2:

• Both location-based and market-based methods reported.
• Location-based: average energy generation emission factors for defined locations.
• Market-based: emissions from contractually purchased electricity bundled with instruments, or unbundled instruments.
• Energy data collected from energy management systems and landlords.
• Sanoma does not sell energy.
• Energy Attribute Certificates (EACs) used to claim renewable or fossil-free energy.

Scope 3:

• Scope 3 categories reported: 1, 2, 3, 4, 5, 6, 7, 11, 12, 15.
• Categories 8, 9, 10, 13, 14 not applicable or not material.
• 33% of Scope 3 emissions calculated using non-primary data.
• Category 1 (Purchased goods and services): includes paper, printing, IT, consulting, TV programming. Data from suppliers (67%) and spend-based estimates (33%). Emission factors from Defra GHG Conversion Factors, IEA, Ecoinvent, Greenhouse Gas Protocol.
• Category 2 (Capital goods): based on spend data and capital expenditure. Emission factors from Defra GHG Conversion Factors.
• Category 3 (Fuel- and energy-related activities): upstream emissions from energy and fuel. Calculated using energy consumption data. Emission factors from Defra GHG Conversion Factors and IEA.
• Category 4 (Upstream transportation and distribution): data from logistics suppliers (92%) and spend-based estimates (8%). Emission factors from Defra GHG Conversion Factors.
• Category 5 (Waste generated in operations): based on waste data. Emission factors from Defra GHG Conversion Factors.
• Category 6 (Business travel): includes business travel by air, rail, car. Data from travel agencies and travel management tools. Emission factors from Defra GHG Conversion Factors.
• Category 7 (Employee commuting): commute days per year estimated as 200–230 days/year. Commute kilometers per day range from 8 km to 50 km depending on country, based on national statistics. Emission factors from Defra GHG Conversion Factors.
• Category 11 (Use of sold products): includes electricity consumed by digital devices accessing digital products. Assumptions: active use of 65 hours per year per user, average power consumption of 25W. Emission factors from IEA.
• Category 12 (End-of-life treatment of sold products): includes paper waste from sold products. Emission factors from Defra GHG Conversion Factors and Ecoinvent.
• Category 15 (Investments): emissions from joint ventures and associated companies. Calculated using the equity share method based on financial statements and estimated emission factors. Emission factors from Exiobase multi-region input-output database.

Data quality:

• Less than 1% of energy consumption based on estimates.
• 33% of Scope 3 emissions calculated using non-primary data (spend-based or statistical estimates).
• No significant uncertainties or data gaps disclosed beyond the above.

Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Use of phase-in exemption

Sanoma applies the phase-in provisions for ESRS E1-9 Anticipated financial effects from material physical and transition risks and potential climate-related opportunities.

Time horizons

Sanoma has used in its reporting the following time horizons: short-term one year, medium-term 1-3 years and long-term 3 years and beyond.

Methodology for quantification

Sanoma's scenario analysis for transition and physical risks has included assessing the impacts of current and future regulations on operations and supply chains, evaluating changes in customer behaviour and market demand for sustainable products as well as identifying opportunities for adopting new technologies to reduce emissions. In its assessment, Sanoma has used climate scenarios, including scenarios in line with limiting global warming to 1.5°C with no or limited overshoot and high-climate scenarios, such as RCP 1.9, RCP 4.5, RCP 8.5 and IEA SDS to understand potential alternative futures and to develop strategies to mitigate identified risks based on scenario outcomes. These scenarios are based on best available scientific evidence, such as the IPCC assessments.

Physical risks

Acute physical risks

Sanoma identifies certain climate-related physical risks which may impact the business on short-, medium- and long-term timeframes. Acute physical risks like flooding, driven by increased severity of extreme weather events, may pose a risk to Sanoma's printing houses, facilities and warehouses. The risk is particularly related to damages to facilities due to floods and heavy rain in high flooding risk locations. To manage and mitigate the risk of damage, Sanoma develops comprehensive response plans and acquires insurances. During 2024, some of Sanoma's facilities in Spain suffered some damages due to heavy flooding.

Some minor increases in the pricing of the insurances can be forecasted.

Transition risks

Sanoma identifies certain transition risks which may impact the business on short-, medium- and long-term timeframes. Sanoma identifies a risk of increasing complexity and cost associated with compliance with enhanced emissions- and sustainability-reporting obligations and regulations. Regulations, such as the Corporate Sustainability Reporting Directive (CSRD) and the EU Deforestation Regulation (EUDR), require extensive data collection, data management and reporting infrastructure. This can lead to increased operational costs, both directly within Sanoma's operations and indirectly through the supply chain, as suppliers also face stricter emissions regulations. Additionally, non-compliance with these regulations could result in financial penalties and reputational damage, impacting business operations and financial performance.

Changing customer behaviour can also be a risk if customer expectations are not met.

Climate-related opportunities

Sanoma also identifies certain opportunities which relate to the implementation of its climate transition plan. Transparent climate- and biodiversity action may offer the opportunity to enhance brand value and increase demand. Sanoma also identifies a number of climate-related opportunities through reducing indirect operating costs. By transitioning to renewable energy sources and implementing energy-efficiency projects, Sanoma can lower its energy consumption, emissions and related costs. For example, AI optimisation of heating in facilities and the switch to renewable heating in Finland have already led to energy savings.

Sanoma also identifies opportunities linked to sustainable finance, involving leveraging its climate targets to access capital at more favourable rates. By aligning its climate strategy with the Science Based Targets initiative (SBTi) and incorporating these KPIs into its EUR 300 million Syndicated Revolving Credit Facility, Sanoma can benefit from reduced interest costs when meeting its emission reduction targets.

Assets and business lines sensitive to transition

As Sanoma's assets are mostly intangible, no assets or business activities that are sensitive to significant physical hazards or transition risks or incompatible with the transition to a climate-neutral economy have been identified.

Strategic adjustments and resilience

Sanoma has not identified reasons for significant adjustments to its strategy or business model as a result of the climate-related resilience analysis. Sanoma evaluates that adaptation to climate change over the short-, medium- and long-term does not pose a significant threat to securing ongoing access to finance. The shift to digital is expected to continue especially in its media business, which will support its climate transition. The transition towards digital is expected to also increase energy consumption and, through that, demand for fossil-free energy.

Sanoma's resilience analysis includes uncertainties, which relate to the length of the time horizons used in the analysis and the severity types of the scenarios used. Sanoma aims to further develop its scenario analysis going forward.

Transition plan and consideration of biodiversity and ecosystems in strategy and business model

Integration in strategy and business model

Sanoma's biodiversity actions focus on three angles: minimising the biodiversity impacts of paper procurement through the certified use of paper, managing biodiversity and paper-related risks, and, as climate change is a significant driver of biodiversity, Sanoma's climate transition plan described under E1-1.

As a sizeable paper purchaser, Sanoma is responsible for protecting biodiversity and promoting the responsible use of forest resources. As paper production can lead to biodiversity loss due to deforestation, Sanoma prefers PEFC or FSC certified paper in its sourcing to guarantee the certified, transparent and legal origin of the paper used.

Biodiversity targets

Through its Environmental Standard, Sanoma commits to protecting biodiversity, promoting the responsible use of forest resources, and aims to ensure its products are deforestation-free and do not cause forest degradation, aligned with relevant EU regulation. Based on the Environmental Standard, Sanoma's aim is to use only paper produced responsibly and originating from traceable, legal and verified sources.

Sanoma's aim is to use only wood fibre that is produced responsibly and originating from traceable, legal and verified FSC and PEFC sources. In 2024, the share of certified paper used in Sanoma's products was 98%.

Geographic and value chain scope

The scope of actions related to biodiversity covers Sanoma's own operations and upstream value chain, with the actions applying to all paper and print suppliers in all sourcing countries. As actions are considered to be continuous, there are no time horizons to disclose.

Use of frameworks

Paper certification schemes, such as the Forest Stewardship Council (FSC) and the Programme for the Endorsement of Forest Certification (PEFC), provide standards and guidelines for sustainable forest management. These certifications encourage responsible practices that prioritise biodiversity conservation, ecosystem preservation, and the rights of indigenous communities.

Sanoma has not set measurable time-bound outcome-oriented biodiversity-related targets, and therefore targets are not aligned with the Kunming-Montreal Global Biodiversity Framework and EU biodiversity strategy for 2030. Sanoma aims to further develop its biodiversity targets going forward.

Resilience analysis

Sanoma evaluates its current business model to be resilient in regards to impacts and risks related to biodiversity. Risks related to biodiversity and paper sourcing include the availability of certified paper and the potential financial impacts resulting from the potentially increasing commodity prices. Sanoma has several measures in place to mitigate the biodiversity risks identified.

Sanoma's analysis of the resilience of its business in relation to biodiversity includes impact, risk and opportunity identification and assessment as well as defining, implementing and monitoring the risk management activities. During 2024, the evaluation was conducted as part of the double materiality assessment. It covered direct operations as well as the upstream and downstream value chain and assumed that Sanoma's business areas and targets remain the same. The evaluation focused on upstream tier 1 suppliers, but when analysing for example the suppliers' ability to reduce emissions, tier 2 suppliers were also reviewed.

In its resilience analysis, Sanoma has applied the same financial thresholds and time horizons as in its ERM process as described under ESRS 2 BP-2. Sanoma's resilience analysis did not include systemic or physical biodiversity risks or ecosystem risks. Going forward, Sanoma aims to expand its risks assessment.

Nature-related risk assessment and transition risks

Sanoma also identifies a transition risk related to the EU's Deforestation Regulation (EUDR). The EUDR requires verification of the origin of wood fibre used in paper products. Compliance risks are related to especially the availability of the data requested, as Sanoma is dependent on its suppliers to access this information. In practice, the EUDR requires Sanoma to trace the geolocation of all wood used in its wood-based products.

As of December 2025, these new rules will be implemented throughout the EU. To mitigate transition and compliance risks related to the EUDR, Sanoma develops its due diligence processes, engages with suppliers, and invests in tools to ensure compliance with the requirements.

Sanoma's identified dependencies relate to the availability of paper and certified paper, posing a risk to Sanoma's operations. Sanoma's Environmental Standard and Paper Procurement Standard prefer the use of certified paper, impacting this dependency. At the same time, these policies support in reducing biodiversity-related impacts and risks, such as weakening customer demand due to non-sustainable products or non-compliance with the EUDR.

Key actions and investment commitments

Sanoma's key actions to mitigate its biodiversity impacts related to the use of paper are continuous and include implementation of sourcing requirements, data collection and traceability improvements related to paper sourcing and cooperation with the suppliers.

Sanoma updates its Procurement strategy on an annual basis and evaluates potential market risks related to the costs and availability of paper. Potential risks are followed and mitigated through the negotiations with suppliers. The risk of potentially rising paper prices is mitigated by diversifying paper supply. The risk is closely followed, in particular, for newsprint paper, as Media Finland is dependent on certain suppliers. To mitigate the dependency on paper, Sanoma has invested in the transition to digital.

Sanoma continuously develops its due diligence systems to ensure tracing of the origin of the paper-fibre used in its products and to manage compliance risks related to EUDR. In 2024, Sanoma acquired a PEFC Chain of Custody certification for Media Finland. Sanoma's learning business in the Netherlands, Malmberg, has acquired a FSC Chain of Custody certification.

Sanoma currently traces and monitors the origin of the purchased paper from its tier 1 and 2 suppliers. All described actions related to paper sourcing increase traceability, and with the EUDR, traceability is expected to expand beyond tier 1 and 2 suppliers.

Stakeholder engagement

During 2024, Sanoma cooperated with several stakeholders in regards to biodiversity topics. These included paper and print suppliers, NGOs, FSC and PEFC certification collaborators as well as local authorities responsible for the implementation of the EUDR.

PEFC and FSC paper use includes ensuring that local and indigenous knowledge is respected and taken into consideration, but no direct engagement or knowledge integration has taken place.

Policies related to biodiversity and ecosystems

Sanoma addresses biodiversity and ecosystems through several environmental policies. The company states that its environmental commitments and policies are described under E1-2, including the scope of policies and standards. Sanoma does not have own sites near biodiversity sensitive areas or relevant own operations in regards to direct exploitation, land-use change, sea-use change, invasive alien species, freshwater-use, agriculture, sustainable oceans or seas practices. With the exception of land-use change, Sanoma has not adopted policies to manage these topics.

Environmental Standard

Key content and principles:

• Addresses climate change through science-based emission reduction pathways and minimising pollution with high environmental management standards, such as ISO 14001
• Mitigates land-use change by promoting sustainable material use and responsible procurement
• Supports biodiversity and protects species populations by reducing environmental impacts
• Supports ecosystem conditions through the efficient use of materials and responsible procurement
• Commits to protecting biodiversity, promoting the responsible use of forest resources
• Aims to ensure products are deforestation-free and do not cause forest degradation, aligned with relevant EU regulation
• Aims to use only paper produced responsibly and originating from traceable, legal and verified sources
• Promotes paper certification schemes, such as the Forest Stewardship Council (FSC) and the Programme for the Endorsement of Forest Certification (PEFC)

Scope: Sanoma's own operations and upstream value chain, applying to all paper and print suppliers in all sourcing countries.

Monitoring:

• Paper certification involves audits and assessments to ensure compliance with sustainable management practices
• Certification schemes promote traceability and help verify that wood used in paper production comes from certified and legal sources
• In 2024, Sanoma acquired a PEFC Chain of Custody certification for Media Finland
• Sanoma's learning business in the Netherlands (Malmberg) has acquired a FSC Chain of Custody certification
• Sanoma continuously develops its due diligence systems to ensure tracing of the origin of paper-fibre used in its products

Paper Procurement Standard

Key content and principles:

• Sets environmental criteria related to the use of certified paper
• Includes recommendations to apply environmental and quality management systems
• Included in paper and print supplier agreements

Scope: Paper and print suppliers.

Supplier Code of Conduct

Key content and principles:

• Includes commitments to deforestation-free products
• Violations or concerns of non-compliance are advised to be reported through grievance channels
• Sanoma reserves the right to cancel orders, suspend orders and/or terminate contracts with suppliers in the event of a material breach
• Sanoma may withhold payment for non-confirmatory products or services

Scope: Suppliers throughout the supply chain, including affiliates and sub-contractors.

Monitoring:

• Whistleblowing channel available in several languages relevant for Sanoma's operations
• Know Your Counterparty (KYC) process used to identify risks, including human rights, anti-bribery, corruption, and sanctions checks
• KYC background checks performed on new suppliers as part of supplier selection process

Sustainability and Human Rights Policy

Referenced as part of Sanoma's environmental commitments and policies (described under E1-2), though specific biodiversity-related content not detailed in the excerpts provided.

Governance: The description of Sanoma's policies under E1-2 presents the most senior level in the organisation accountable for implementation and consideration given to interests of key stakeholders' views (specific details not included in E4-2 excerpt).

Actions and resources related to biodiversity

Implementation of sourcing requirements and supplier cooperation

Action description:

• Prefer paper originating from certified and sustainably managed forests (FSC or PEFC)
• Annual negotiations with suppliers to evaluate forest-related risks and information on paper origin
• Collection of information on paper origin via purchase order system
• Verification of supplier information via national tools, databases, research institutes and FSC/PEFC registries
• Tracing and monitoring of paper origin from tier 1 and 2 suppliers

Scope: Upstream value chain (paper and print suppliers in all sourcing countries)

Time horizon: Continuous actions (no specific end date disclosed)

Resources:

• Non-financial: Procurement team conducts annual negotiations with suppliers
• No quantified financial resources disclosed

Expected outcomes/KPIs:

• Use of certified paper in products: 98% achieved in 2024
• Aim to use only paper from traceable, verified and legal sources

Link to policy/target:

• Environmental Standard
• Paper Procurement Standard (part of supplier agreements)
• Aligned with EU Deforestation Regulation (EUDR) compliance requirements

Data collection and traceability improvements

Action description:

• Enhanced traceability of paper sourcing beyond tier 1 and 2 suppliers (driven by EUDR)
• Due diligence system development to ensure tracing of paper-fibre origin
• Collection of geolocation data for wood used in products

Scope: Upstream value chain

Time horizon: Continuous; EUDR compliance deadline December 2025

Resources:

• Non-financial: Investment in tools to ensure compliance (no amounts specified)
• Sustainability and Procurement teams lead implementation

Expected outcomes/KPIs:

• Full compliance with EUDR requirements
• Proof that wood-based products do not contribute to forest degradation

Link to policy/target:

• Supplier Code of Conduct
• Environmental Standard
• EUDR compliance

FSC Chain of Custody certification

Action description:

• Malmberg (Netherlands learning business) acquired FSC Chain of Custody certification

Scope: Own operations (Netherlands)

Time horizon: Achieved in 2024

Resources: Not disclosed

Expected outcomes/KPIs:

• Enhanced certification coverage in operations

Link to policy/target:

• Environmental Standard commitment to certified paper use

Biodiversity risk mitigation through paper diversification

Action description:

• Annual updates to Procurement strategy evaluating market risks related to paper costs and availability
• Diversification of paper supply to mitigate rising price risks
• Close monitoring for newsprint paper (Media Finland dependency on certain suppliers)
• Investment in transition to digital to reduce paper dependency

Scope: Own operations and upstream value chain

Time horizon: Continuous (annual reviews)

Resources:

• Non-financial: Procurement team conducts annual strategy updates and supplier negotiations
• Investments in digital transition (no amounts specified)

Expected outcomes/KPIs:

• Reduced dependency on paper
• Mitigation of availability and price risks

Link to policy/target:

• Sustainability Strategy
• Climate transition plan (digital transition reduces paper use)

Note on resource allocation

No specific financial amounts (capex/opex) are disclosed for biodiversity-related actions. Resources are described in terms of team responsibilities (Procurement team, Sustainability team) and system investments without quantification.

Targets related to biodiversity and ecosystems

Sanoma has not set measurable time-bound outcome-oriented biodiversity-related targets, and therefore targets are not aligned with the Kunming-Montreal Global Biodiversity Framework and EU biodiversity strategy for 2030. Sanoma aims to further develop its biodiversity targets going forward.

Qualitative biodiversity commitment

Target metric: All wood fibre in the paper qualities used by Sanoma originate from trusted certified sources

Target value: Not quantified (qualitative aim)

Target year: Not specified

Baseline year: Not specified

Baseline value: Not specified

Scope: Paper used in newspapers, magazines and books (upstream value chain)

Type: Not specified (absolute/intensity)

Science-based/validated: Not science-based; not externally validated

Progress to date (2024):

• Amount of certified wood fibre in direct paper purchases: 98%
• Share of certified paper used in Sanoma's products: 98%

Monitoring metrics

Sanoma tracks the effectiveness of its biodiversity-related policy implementation through:

• Paper-related GHG emissions (disclosed under E1-4)
• Paper usage and share of paper certification (disclosed under E5-3 and E5-4)

These metrics are allocated to the layers of avoidance and minimisation in the biodiversity mitigation hierarchy.

Impact metrics related to biodiversity and ecosystems change

Land use and operations near protected areas

Sanoma assessed that it has no own sites near biodiversity-sensitive areas and therefore does not need to implement biodiversity mitigation measures at own sites. No operations or sites in or near protected areas or Key Biodiversity Areas (KBAs) were identified.

As stated in the disclosure: "Sanoma does not have own sites near biodiversity sensitive areas or relevant own operations in regards to direct exploitation, land-use change, sea-use change, invasive alien species, freshwater-use, agriculture, sustainable oceans or seas practices."

Species impacts

No material sites with impacts on threatened species were identified. Sanoma reported no own direct impacts from operative operations or material sites from a biodiversity point of view, and therefore there were no material sites with impacts on threatened species.

Land degradation

As a result of no significant own operations impacts, there were no significant negative impacts from own operations to land degradation, desertification or soil sealing.

Upstream value chain impacts

Upstream value chain impacts were identified through analysis of typical impacts of paper production and sourcing. These impacts include:

• Biodiversity loss from paper production and sourcing
• Ecosystem disruption
• Pollution from paper production processes

Sanoma manages these impacts through:

• 98% certified paper (FSC or PEFC) used in products in 2024
• 43,430 tonnes of paper purchased in 2024 for newspapers, magazines and books
• 100% certified paper used in own printing house operations in 2024

Paper sourcing and certification metrics

Deforestation and land conversion

No quantified deforestation footprint (hectares converted) is disclosed. Sanoma commits through its Environmental Standard to ensuring products are deforestation-free and do not cause forest degradation, aligned with EU Deforestation Regulation (EUDR). The company traces and monitors the origin of purchased paper from tier 1 and 2 suppliers, with traceability expected to expand beyond these tiers with EUDR implementation.

Restoration metrics

No hectares restored or biodiversity offsets are reported. Sanoma explicitly states it "does not use offsets or compensation in relation to its biodiversity impacts" and no nature-based solutions are incorporated into actions.

Ecosystem condition metrics

No specific ecosystem condition metrics (such as habitat quality indices or ecosystem integrity scores) are disclosed.

Methodology notes

• Paper certification data originates from paper suppliers
• 8% of certification data is estimated using weighted average of primary data
• Sanoma currently traces paper origin from tier 1 and 2 suppliers
• No biodiversity offsets used in target setting or implementation

Anticipated financial effects from biodiversity and ecosystem-related impacts, risks and opportunities

Phase-in exemption applied

Sanoma's Sustainability Statement fulfils the characteristics of specific circumstances for ESRS E4-6 Anticipated financial effects from biodiversity and ecosystem-related risks and opportunities.

Policies related to resource use and circular economy

Sanoma discloses policies related to resource use and circular economy under E5-1. The company references its environmental commitments described under E1-2, including the Environmental Standard. The description includes the scope of these policies and standards, the most senior level in the organisation accountable for implementation, and consideration given to interests of key stakeholders' views.

Environmental Standard

Key content and principles:

Through its Environmental Standard, Sanoma is committed to:

• Using natural resources efficiently
• Transitioning away from the use of virgin resources
• Sustainable sourcing by promoting the use of recycled materials and renewable sources
• Taking environmental aspects into consideration throughout the life-cycle of the product
• Optimising the consumption of materials, such as paper, printing inks and printing plates
• Recycling the materials used
• Measuring and minimising waste generated in its printing houses, facilities and warehouses
• Minimising the use of plastics in its products; where plastics are used, aiming to use recyclable plastics which do not originate from virgin sources
• Pollution prevention and identifying and managing chemicals and other materials posing a hazard if released to the environment by ensuring their safe handling, movement, storage, recycling or reuse, and disposal
• Using only paper produced responsibly and originating from traceable, legal and verified sources
• Ensuring products are deforestation-free and do not cause forest degradation, aligned with relevant EU regulation
• Using only wood fibre that is produced responsibly and originating from traceable, legal and verified FSC and PEFC sources

The objectives of the Standard are achieved through responsible procurement practices, efficient operations and product development.

Scope:

The Environmental Standard is implemented locally across Sanoma businesses.

Governance and oversight:

The Group Sustainability and Procurement teams are responsible for supporting the implementation of the Standard. The Group Sustainability team is responsible for updating and communicating it.

Stakeholder engagement:

The description includes consideration given to interests of key stakeholders' views and how the policies are made available to stakeholders.

Link to other policies:

In addition to Sanoma's Supplier Code of Conduct, the Environmental Standard sets requirements for sustainable sourcing, such as the use of certified paper.

Paper Procurement Standard

Key content and principles:

The Paper Procurement Standard:

• Is a standard part of Sanoma's paper supplier agreements
• Supports Sanoma in managing biodiversity-related impacts and risks
• Sets requirements towards paper suppliers on the use of certified paper
• Requires evaluation of forest-related risks as part of annual negotiations with suppliers
• Requires suppliers to report on their FSC or PEFC certifications and other sustainability efforts
• Requires information on the origin of the paper to be evaluated as part of negotiations

Scope:

The Paper Procurement Standard is made available to potentially affected stakeholders, such as suppliers, through their contracts.

Governance and oversight:

The Procurement team is responsible for updating, communicating and leading the implementation of the standard.

Stakeholder engagement:

Views of suppliers, customers and employees were taken into consideration when establishing the Paper Procurement Standard.

Implementation and monitoring

Key actions (resource inflows):

• Engaging with paper and print suppliers to ensure the use of certified paper
• Systematic monitoring and forecasting of paper consumption in magazines and books printed by printing suppliers to avoid unnecessary paper consumption
• Optimising the consumption of materials during the printing process at two newspaper printing houses
• Recycling materials used in the printing process
• Monitoring the share of paper waste during the printing process (also a short-term incentive for printing house employees)

Key actions (resource outflows):

• Minimising waste generated through monitoring of waste generation
• Ensuring with waste treatment partners that waste is recycled or reused
• Training of employees on waste treatment topics
• Environmental management certifications: ISO 14001 for printing houses, facilities in the Netherlands (Iddink) and Italy (Sanoma Italy)
• Breeam certification for Sanoma House headquarters in Finland and office in Norway

Grievance mechanisms:

Based on Sanoma's procurement rules embedded into the Supplier Code of Conduct, violations or concerns of non-compliance with Sanoma's policies and standards are advised to be reported to Sanoma through grievance channels. Sanoma's whistleblowing channel is available in several languages relevant for Sanoma's operations. Sanoma reserves the right to cancel orders, suspend orders and/or terminate its contract with a supplier in the event of a material breach of the Supplier Code of Conduct and withhold payment for non-confirmatory products or services.

Actions and resources related to circular economy

Resource inflows

Scope: Upstream value chain and own operations (two newspaper printing houses in Finland)

Time horizon: Continuous

Actions:

• Engagement with paper and print suppliers to ensure the use of certified paper. These actions are described under E4-3, as paper certification is closely connected to the management of Sanoma's biodiversity impacts.

• Optimisation of resource use by minimising paper weights in products. This is done by systematic monitoring and forecasting of paper consumption in magazines and books printed by printing suppliers to avoid unnecessary paper consumption.

• Optimisation of materials consumption during printing process in own operations at two newspaper printing houses. Sanoma optimises the consumption of materials such as paper, printing inks and printing plates, and recycles the materials used.

• Monitoring of paper waste share during the printing process, which is monitored closely and is a short-term incentive for the printing house employees.

Expected outcomes:

• Sanoma is committed to using natural resources efficiently and thus minimises the use of primary raw materials
• Throughout its own operations and the upstream value chain, Sanoma aims to use paper fibre which originates from trusted, PEFC or FSC certified sources
• During 2024, the share of certified paper was 98%

Resource outflows

Scope: Own operations (printing houses, facilities and warehouses)

Actions:

• Efficient waste management to minimise waste generated in its printing houses, facilities and warehouses

Expected outcomes:

• Recycled and reused waste accounts for 72% of Sanoma's waste
• Total waste generated: 6,579 tonnes in 2024

Resources allocated: Not quantified (no specific capex/opex amounts disclosed)

Link to policy: Actions are implemented under Sanoma's Environmental Standard, which is implemented locally across Sanoma businesses. The Group Sustainability and Procurement teams support implementation, and the Group Sustainability team is responsible for updating and communicating the Standard.

Targets related to resource use and circular economy

Sanoma does not have time-bound or outcome-oriented targets related to resource use.

Effectiveness tracking

Sanoma tracks the effectiveness of the policy implementation and measures taken related to resource use, paper certification and waste management through:

Resource inflows:

• Paper certification target: Sanoma's aim is to use only wood fibre that is produced responsibly and originating from traceable, legal and verified FSC and PEFC sources
• Progress (2024): Share of certified paper used in Sanoma's products was 98%

Sanoma monitors the amount of materials, such as paper bought and used, and is committed to using natural resources efficiently and thus minimises the use of primary raw materials.

Resource outflows:

• Sanoma aims to minimise waste generated in its printing houses, facilities and warehouses through efficient waste management

Data note: In 2024, Sanoma purchased 43,430 tonnes of paper for its newspapers, magazines and books.

E5-4 Resource inflows

Sanoma's resource inflows cover its printed products, such as newspapers, magazines and books. The key materials are the materials used in the production of these products, such as paper, printing inks, printing plates, wetting additives and washing solvents, which Sanoma reports for its own operations, i.e. two printing houses it owns in Finland. For its own operations, more specifically two owned newspaper printing houses in Finland, Sanoma reports the materials bought and used, such as paper, printing inks, printing plates, wetting additives and washing solvents. In addition, Sanoma purchases paper, which is delivered to upstream value chain printing partners, who then produce Sanoma's books and magazines. In 2024, Sanoma purchased 43,430 tonnes of paper for its newspapers, magazines and books. Monitoring of the volume of paper helps to decrease not only the resource use impacts, but also biodiversity and climate-related impacts associated with paper consumption. Throughout its own operations and the upstream value chain, Sanoma aims to use paper fibre which originates from trusted, PEFC or FSC certified sources. Sanoma monitors the share of certified paper used in its own operations for newspapers and bought for magazines and books printed by printing suppliers. During 2024, the share of certified paper was 98%.

Table 24: E5-4-30 Paper bought and used for products and share of certification

The reporting follows Sanoma's financial accounting rules and includes paper bought by Sanoma and used to manufacture its products. Data for paper bought originates from paper suppliers' direct measurement and does not include any significant assumptions. Data for certified fibre originates from paper suppliers. 8% of the certification data is estimated by calculating the weighted average of the primary data. The denominator for the share of certified paper used is the overall total weight of paper used during the reporting period.

Table 25. E5-4-31 Materials used in own operations

The reporting follows Sanoma's financial accounting rules. Materials consumption data originates from Sanoma's newspaper printing houses' production systems. Certification data originates from paper suppliers as part of invoicing. The denominator for the share of certified paper used is the overall total weight of paper used in own printing houses during the reporting period. Paper is the only biological material used by Sanoma. No technical materials are used in Sanoma's own operations. No significant assumptions are used for the metric.

Waste

E5-5 Resource use and circular economy

E5-5 Waste

Sanoma has disclosed information on waste generated in its own operations.

Scope and methodology: The waste data covers Sanoma's own operations including facilities, warehouses, and printing houses. Waste generated in facilities, warehouses and printing houses was identified as an own operations impact during the double materiality assessment.

Waste management approach: As part of operational risks, the assessment identified actual own operations impacts related to waste generated in facilities, warehouses and printing houses. Sanoma's Environmental Standard covers waste-related topics. The waste impact is managed through continuous development of waste management practices, with waste being an element of Sanoma's broader resource use and circular economy strategy under the 'Vital environment' theme.

Policies related to own workforce

Sanoma has adopted several policies and standards to manage its impacts related to its own workforce. All policies apply to Sanoma's own operations and cover all employees and employment arrangements in all operating countries. Policies are approved by the Board of Directors, while standards are approved by the President and CEO. The President and CEO and the Executive Management Team (EMT) are ultimately responsible for ensuring that Sanoma's employees are aware of and comply with policies.

Code of Conduct

Scope: All impacts related to own workforce; all employees and business partners across all Sanoma operations.

Governance: Approved by the Board of Directors. The President and CEO and the EMT are ultimately responsible for ensuring compliance.

Key content: The Sanoma Code of Conduct outlines shared ethical standards for employees and business partners. It acts as an umbrella for all policies and standards within Sanoma and encompasses the Ten Principles of the UN Global Compact on human rights, labour, environment and anti-corruption.

Public availability: Made available via internal channels and on Sanoma's website.

International standards: Aligned with the UN Global Compact Ten Principles on human rights, labour, environment and anti-corruption.

Monitoring: Part of annual mandatory Code of Conduct e-learnings for all employees. Completion rates are monitored and reported (97% completion rate in 2024). Annual awareness campaigns on speaking up are conducted, and the number of reports submitted through different channels is tracked.

Sustainability and Human Rights Policy

Scope: All Sanoma operations across Europe; published in December 2024.

Governance: The Group Sustainability function is responsible for updating, communicating and leading the implementation of the Sustainability and Human Rights Policy.

Key content: Outlines sustainability-related principles and summarises core commitments and sustainability due diligence process. Covers all S1 related impacts, risks and opportunities except for training and skills development. Addresses the sustainability management model and responsibilities to identify impacts, risks and opportunities through the double materiality assessment process.

Public availability: Available on Sanoma's website.

International standards:

• UN Global Compact (UNGC) signatory
• UN Guiding Principles on Business and Human Rights
• Agenda 2030 and UN Sustainable Development Goals (SDGs)
• Ten Principles on human rights, labour, environment and anti-corruption
• Universal Declaration of Human Rights (UDHR)
• International Labour Organization's (ILO) Declaration on Fundamental Principles and Rights at Work
• OECD Guidelines for Multinational Enterprises
• Addresses human trafficking, forced labour, compulsory labour and child labour through these commitments

Monitoring: The due diligence process is embedded into Sanoma's governance, strategy and business model. Regular Employee Engagement Surveys and other surveys are used to identify trends and impacts.

People Policy

Scope: All S1-related impacts, risks and opportunities; all employees and employment arrangements in all operating countries; published in December 2024. The impacts on employment security, social dialogue and privacy of own workforce are covered indirectly through the human rights-related commitments of the policy.

Governance: Approved by the Board of Directors. The Group HR team is responsible for updating, communicating and leading the implementation of the People Policy.

Key content: Encompasses guidelines that serve as the basis for people management at Sanoma, in alignment with the Code of Conduct, the Sustainability and Human Rights Policy commitments and corporate values. Covers: people priorities, human rights, diversity and inclusion, occupational health and safety and well-being, rewards and recognition, recruitment and career opportunities, professional development, performance management, employee engagement and disciplinary practices. Sanoma commits to creating a working environment and culture that inspires employees, values their diversity, embraces their views and respects their individual rights. Zero tolerance for discrimination, harassment (including sexual harassment) or bullying. Sets framework for well-organised management of occupational health and safety, equal treatment, non-discrimination and mental and physical well-being.

Public availability: Made available via internal channels and on Sanoma's website.

International standards: Aligned with ILO commitment on collective bargaining and collective bargaining agreements.

Monitoring: Implementation monitored through regular Employee Engagement Survey and Diversity and Inclusion Survey. In internal communications, employees are reminded of the policies in relevant contexts. Updated recruitment process to ensure diversity, equity and inclusion. Managers are trained on the policies. Regular performance and development reviews are used for engagement with employees.

Diversity and Inclusion Policy

Scope: All employees across all Sanoma operations.

Governance: The Group HR team is responsible for leading the implementation. Responsibility for updating and communicating the policy is shared with the Group Sustainability team.

Key content: Sets the ambition for a diverse and inclusive workplace with fair treatment and equal opportunities, non-discrimination, equal pay for equal roles, and gender-neutral experience. As of December 2024, the content has been embedded into the People Policy.

Public availability: Made available via internal channels and on Sanoma's website.

Monitoring: Implementation monitored through Employee Engagement Survey and Diversity and Inclusion Survey.

Anti-Harassment Standard

Scope: All employees across all Sanoma operations.

Governance: The Group HR team is responsible for updating, communicating and leading the implementation of the Anti-Harassment Standard.

Key content: Describes the process of handling potential harassment cases in detail. Sanoma has zero tolerance for any form of discrimination, harassment (including sexual harassment) or bullying in the workplace.

Public availability: Made available via internal channels.

Monitoring: Procedures in place to ensure complaints and grievances are dealt with in a neutral way. HR is responsible for investigation of harassment cases. Each case is investigated as promptly as possible, in a fair and objective manner. In 2024, in operating countries where local legislation requires processes to be in place (Spain, Netherlands and Poland), Sanoma established separate subsidiary-specific channels to be included in the Group's whistleblowing tool in early 2025.

Grievance and Remediation Mechanisms

Sanoma has clear procedures for addressing grievances and providing remedy:

Channels: Multiple reporting channels including:

• Direct reporting to managers or Human Resources
• Anonymous whistleblowing channel hosted by a third party
• Available in several languages relevant for Sanoma's operations
• Available on Sanoma's internal channels and website

Process: All reported incidents are documented, investigated, and overseen by the Audit Committee. Cases reported through the channel are processed in a manner that ensures impartiality. Sanoma does not tolerate retaliation against individuals who make reports in good faith.

Monitoring: Incidents are monitored and potential trends are addressed proactively. Incidents are reported internally quarterly and externally annually. Internal Audit investigates misconduct cases separately from the chain of management involved and informs the Audit Committee about all identified and investigated misconduct cases.

International standards: Aligned with the right to effective remedy as a fundamental element of the international human rights system per the Sustainability and Human Rights Policy.

Additional Policy Elements

Freedom of association and collective bargaining: Sanoma respects employees' right to join trade unions. Freedom of association and the effective recognition of the right to collective bargaining are included in the ILO Declaration on Fundamental Principles and Rights at Work, which Sanoma commits to. Both SBUs conduct regular, quarterly meetings with personnel representatives. Personnel representatives are informed in advance of any relevant change initiatives and negotiated with, if needed.

Occupational Health & Safety: Local OH&S management systems help identify and mitigate workplace risks. In Finland, Italy and Norway, international standards such as ISO 14001 and Breeam-certification create a foundation for energy management in printing houses and facilities.

Taking action on material impacts on own workforce

Sanoma's actions to manage material impacts on its own workforce are identified during engagement with personnel. Analysis of the annual Employee Engagement Survey (EES), Diversity, Equity & Inclusion (DE&I) and other surveys act as valuable input for planning actions. Topic and unit specific surveys often take place several times a year. The scope of the actions is Sanoma's own workforce in its own operations. Most of the development is continuous or reactive. All actions support the objectives of the People Policy.

Actions to prevent, mitigate and remediate negative impacts

Work-life balance and working time

Action: Flexible working arrangements

• Description: Sanoma provides, where possible, flexible working arrangements, including flexible hours, hybrid work and leave policies to help employees manage their personal and professional responsibilities
• Time horizon: Continuous
• Scope: Own operations (all Sanoma employees)
• Tracking/KPIs: Annual EES survey used to track employee experience on work load and plan actions; regular 1:1 discussions between managers and employees to plan actions to balance workload
• Resources: Not quantified

Action: Working time monitoring system (Media Finland)

• Description: Media Finland implemented one working time system to all its employees so managers can monitor the working hours of subordinates. System provides notifications to managers if working hours exceed agreed limits
• Time horizon: Implemented in 2024
• Scope: Media Finland SBU
• Resources: Not quantified

Health and safety

Action: Mental and physical health initiatives

• Description: Both SBUs provide several mental and physical health initiatives to all employees on a continuous basis
• Time horizon: Continuous
• Scope: Own operations (all employees)
• Resources: Not quantified
• Details (Media Finland): Communication about low-threshold mental health care targeted to employees; managers continuously trained on available health and safety services; trainings on self-leadership, change skills and resilience elements included in managers' trainings and offered to employees

Gender equality, equal pay and diversity

Action: Group-wide DE&I survey

• Description: Sanoma implemented a Group-wide DE&I survey to improve understanding of minority groups perspectives
• Time horizon: Implemented in 2024
• Scope: Own operations (Group-wide)
• Resources: Not quantified

Action: IDAHOT day survey

• Description: Sexual and gender minorities' experiences were separately asked to highlight the International Day Against Homophobia, Transphobia and Biphobia (IDAHOT) in May
• Time horizon: 2024
• Scope: Own operations
• Resources: Not quantified

Action: Minority personnel representative groups

• Description: Sanoma encouraged personnel to establish minority personnel representative groups. In Media Finland, non-Finnish speakers have established a group. In Learning, work built around five pillars of DE&I: Culture & Heritage, Disability & Neurodiversity, Gender, Generations and LGBTQ+. Senior leaders are sponsors of these pillars
• Time horizon: Continuous
• Scope: Own operations
• Resources: Non-financial - senior leaders as sponsors

Action: Inclusive recruitment process (Media Finland)

• Description: Media Finland updated its recruitment process from the DE&I perspective; managers were trained accordingly
• Time horizon: Implemented in 2024
• Scope: Media Finland SBU
• Resources: Not quantified

Action: Remuneration guidelines update (Media Finland)

• Description: To ensure equal pay, Media Finland's remuneration guidelines were updated in accordance with job architecture work conducted for implementation of new Human Resources tool (to be taken into use in 2025)
• Time horizon: 2024, tool implementation 2025
• Scope: Media Finland SBU
• Resources: Not quantified
• Link to policy: Supports equal pay objective

Adequate wages, social dialogue, freedom of association and collective bargaining

No specific actions targeted to adequate wages, social dialogue, freedom of association and collective bargaining were conducted in 2024. The commitments to these impacts are stated in the policies and no further need for action was identified in 2024.

Additional actions with primary purpose of delivering positive impacts

Health and safety

Action: Physical and mental health promotion

• Description: Both SBUs promote topics related to physical and mental health in internal channels on a continuous basis. Focus on improving recreation and sense of community throughout the organisation
• Time horizon: Continuous
• Scope: Own operations (all employees)
• Resources: Not quantified

Action: Sanomain Kerho (Sanoma Club) - Media Finland

• Description: Employees brought together through Sanoma Club with both sports and culture-related activities. Sanoma arranges activities like walking challenges or charity work to improve engagement and increase meaningfulness
• Time horizon: Continuous
• Scope: Media Finland SBU
• Resources: Not quantified

Remedy

Sanoma did not take actions to provide or enable remedy in relation to actual material impacts as there were no actual cases in 2024.

Employee engagement:

• Annually, our Employee Experience Index is on a favourable level ≥ 7.5
• Our people feel that we provide equal opportunities, and our Equal opportunities rating is on a favourable level, ≥ 7.6
• We continuously seek to develop Sanoma as a great place to work, and, by 2025, aim to reach an Employee Net Promoter Score (eNPS) of > 10

Gender diversity:

• We promote diversity and gender neutrality throughout our business and aim for a 50/50 gender balance in managerial positions by 2030
• The Board of Directors' objective is that both genders are represented on the Board with the share of under-represented gender being at least 40%

5,200+ employees

In January–December 2024, the average number of employees in full-time equivalents (FTE) was 4,820 (2023: 5,119). The average number of employees (FTE) per SBU was as follows: Learning 2,612 (2023: 2,849), Media Finland 2,109 (2023: 2,144) and Other operations 100 (2023: 125). The number of employees declined as a result of certain restructuring actions, including Program Solar, across the Group and small divestments.

At the end of December 2024, the number of employees (FTE) of the Group decreased to 4,648 (2023: 5,017).

Headcount by country, end of 2024:

• Finland: 54%
• The Netherlands: 12%
• Poland: 11%
• Spain: 12%
• Belgium: 4%
• Italy: 4%
• Other: 3%

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

Disclosure Approach

Sanoma has identified ESRS S1-7 (Characteristics of non-employees in the undertaking's own workforce) as a disclosure subject to specific circumstances, as stated in BP-2 Disclosures in relations to specific circumstances.

Metrics

No quantitative data on non-employee workers in Sanoma's own workforce has been disclosed in the sustainability statement.

Methodology Notes

Sanoma mentions self-employed suppliers in the context of payment practices (14-day payment terms for self-employed suppliers and natural persons), but does not provide headcount or FTE data for non-employees in its own workforce.

Collective bargaining coverage and social dialogue

Coverage rates by region and collective bargaining agreements

Overall collective bargaining coverage

Social dialogue arrangements

Sanoma has an agreement with its employees for representation by the European Works Council (EWC).

Additional context

Sanoma has more than one collective bargaining agreement in place in the EEA. The information regarding collective bargaining agreements is available from Sanoma's HR systems.

The working conditions and terms of employment for employees not covered by collective bargaining agreements are on par or partly determined based on collective bargaining agreements that cover other employees.

All organisational optimisation actions are subject to works council negotiations and other local legal procedures.

Gender diversity, end of 2024:

• Directors and Senior Management: 48% female / 52% male
• Managers with Subordinates: 50% female / 50% male

48% of senior management are women

Performance 2024:

• Managers with subordinates: 50% women / 50% men
• Directors and Senior Management: 48% women / 52% men
• Board of Directors: 25% women / 75% men

Adequate wages

Disclosure statement

Sanoma states in S1-10: "All Sanoma employees are paid an adequate wage applicable to benchmarks."

Benchmark used

No specific living wage benchmark is disclosed. The company references:

• UN Global Compact Ten Principles commitment on labour (general reference in Sustainability and Human Rights Policy)
• ILO Declaration on Fundamental Principles and Rights at Work (general reference)
• Collective bargaining agreements covering 69% of employees (S1-8)

The disclosure does not specify whether the "adequate wage applicable to benchmarks" refers to a living wage methodology (e.g., Fair Wage Network, Anker, WageIndicator) or only to minimum wage/collective bargaining standards.

Coverage

Not disclosed. The statement covers "all Sanoma employees" (5,267 professionals across Europe as of end-2024) but does not specify:

• What proportion was assessed against a living wage benchmark
• What proportion earns at or above a living wage threshold

Geographic scope

All operating countries (Netherlands, Spain, Poland, Italy, Belgium, Finland, Sweden, Norway, Denmark, Germany, UK).

Methodology

No methodology disclosed for determining adequate wages. No information on:

• How living wage was calculated
• Frequency of reassessment
• Whether contractor wages are included

Targets and commitments

No time-bound targets disclosed for adequate wages.

Additional context

• The Supplier Code of Conduct (S2) requires upstream suppliers to provide "adequate wages" but does not define the benchmark.
• The People Policy covers "rewards and recognition" but does not specify living wage assessment.
• No actions targeted to adequate wages were conducted in 2024 (stated under S1-4).

Training and skills development metrics

Disclosure basis

ESRS S1-13 is listed under specific circumstances disclosures in Sanoma's Sustainability Statement. The company states: "Sanoma's Sustainability Statement fulfils the characteristics of specific circumstances for the disclosures described below... ESRS S1-13 Training and skills development metrics".

Qualitative information on training and skills development

Learning and development is part of Sanoma's culture and continuous actions to ensure that employees can develop professionally and gain the skills that are critical for future growth and execution of Sanoma's strategy. Learning happens mostly on-the-job, but is complemented with formal training and learning from/with others. Annual performance and development discussions are utilised in both SBUs to create individual development plans and to encourage continuous learning at work.

In both SBUs, leadership competency framework is defined based on the Sanoma business strategy and values. This framework serves as the basis for different development programmes aiming to help with critical capabilities enhancement.

Learning SBU:

• The HR system Workday provides an online training platform that covers topics such as DE&I, leadership, well-being and self-development
• In 2024, a Leadership for growth - leadership essentials training targeted for middle managers was launched in Belgium and the Netherlands

Media Finland:

• Trainings are provided through Sanoma Academy and cover topics such as leadership skills, coaching, self-leadership, journalistic skills and mentoring
• Unit or competence based trainings to more targeted groups
• In 2024, all managers in Media Finland were trained on change management as well as skills and career development as part of a larger trainings plan that continues in 2025

Quantitative metrics

No quantitative training hours data (overall, by gender, or by employee category) or total training investment figures are disclosed in the provided excerpts.

No performance and career development review coverage percentages are disclosed in the provided excerpts.

Health and safety metrics

Coverage of health and safety management system

All Sanoma employees are covered by local health and safety management systems.

Work-related fatalities

Work-related accidents

The number of work-related fatalities and accidents has been collected from all operating countries.

The rate of recordable work-related accidents has been calculated using the formula: (total number of accidents / total working hours) × 1,000,000. In countries where actual working hours were not available from a system, they were estimated using the formula: (number of weekly working hours defined in agreements or legislation × number of working weeks excl. annual leave defined in agreements or legislation) × FTE. The share of estimates represented 34% of the working hours.

Days lost to work-related injuries

Sanoma has applied the phase-in provision under ESRS S1-14 paragraph 88(e) for the number of days lost to injuries, accidents, fatalities or illness.

Work-life balance metrics

Family-related leave

All Sanoma employees are entitled to take family-related leave (100% of employees).

The percentage of employees who took family-related leave was partially collected manually, as the same classification of absences is not used in all operating countries.

Note: Return-to-work rates after parental leave are not disclosed. Multi-year comparisons are not provided.

Compensation metrics

Pay gap

The gender pay gap for 2024 is 17%.

Remuneration ratio

The annual total remuneration ratio (highest paid individual to median employee) for 2024 is 25.

Methodology

The gender pay gap is defined as the difference of average gross hourly pay between female and male employees. Estimates are used for working hours using the following formula: (number of weekly working hours defined in agreements or legislation x number working weeks) x FTE.

The annual total remuneration is defined as the ratio of the highest paid individual to the median annual total remuneration for all employees (excluding the highest-paid individual). Due to the data collection process development, calculations do not include salaries for non-guaranteed hours employees in Learning. Sanoma's plan is to improve the scope of reporting and to include these in the calculations going forward.

Incidents, complaints and severe human rights impacts

Incidents of discrimination and harassment

Status of complaints: None of the investigated incidents of discrimination, including harassment, were found true during the investigation. For some cases, no investigation was initiated due to insufficient information and a lack of whistleblower's response to additional information request.

Severe human rights impacts

No severe human rights issues or incidents connected to Sanoma's own workforce occurred during the reporting period.

Reporting methodology: The number of incidents are reported through Sanoma's internal channels and the whistleblowing channel that allows anonymous reporting. The number of incidents is collected by the Internal Audit.

Policies related to value chain workers

Sanoma has established policies and standards to manage its impacts on workers in the value chain. These policies govern Sanoma Corporation and its subsidiaries and apply to all companies in which Sanoma has financial control.

Sustainability and Human Rights Policy

Approval and oversight:

• Approved by the Board of Directors (published December 2024)
• President and CEO and Executive Management Team (EMT) are ultimately responsible for ensuring Sanoma employees are aware of and comply with the policies
• Group Sustainability team is responsible for updating, communicating and leading implementation

Scope:

• Applies to all Sanoma operations across Europe
• Defines Sanoma's sustainability due diligence process in general, including identification, assessment, management and remediation of sustainability-related impacts

Key content and principles:

• Does not directly cover actual and potential impacts on workers in the value chain, but defines the sustainability due diligence process
• Outlines Sanoma's sustainability management model and responsibilities to identify impacts, risks and opportunities through the double materiality assessment process

International standards alignment:

• As a signatory of the UN Global Compact (UNGC), Sanoma commits to the Ten Principles of the UN Global Compact, the UN Guiding Principles on Business and Human Rights (UNGPs) and Agenda 2030, including the UN Sustainable Development Goals (SDGs)
• Aligned with the Universal Declaration of Human Rights (UDHR)
• Aligned with the International Labour Organization's (ILO) Declaration on Fundamental Principles and Rights at Work
• Aligned with the OECD Guidelines for Multinational Enterprises
• Commits to the Rio Declaration on Environment and Development

Public availability:

• Available on Sanoma's website

Supplier Code of Conduct (SCoC)

Approval and oversight:

• Approved by the President and CEO (last updated November 2024)
• President and CEO and EMT are ultimately responsible for ensuring employees are aware of and comply
• Group Procurement team is responsible for updating, communicating and leading implementation

Scope:

• Applies to all Sanoma suppliers in all geographies
• Sets out ethical standards and responsible business principles that upstream suppliers are required to comply with
• In the 2024 update, requirements were extended throughout the supply chain, beyond tier 1 suppliers
• Suppliers shall apply these standards and principles to their employees, meaning this policy covers all upstream value chain workers

Key content and principles:

• Includes provisions addressing working time, work-life balance, occupational health and safety, freedom of association, collective bargaining, employment security, adequate wages and social dialogue
• Impacts related to precarious work are covered indirectly through ILO commitments
• Requires suppliers to eliminate harassment or discrimination related to gender, ensure equal pay, and offer training and skills development opportunities to their workers
• Requires suppliers to respect ILO standards in relation to human trafficking and forced, compulsory and child labour
• In 2024 update, requirements related to training and skills development opportunities, whistleblowing channel availability and working time were clarified
• Requires suppliers to implement systematic process to identify, monitor and control health and safety, labour and other impacts
• Requires suppliers to offer mechanisms to raise complaints or concerns, monitor complaints, protect individuals from retaliation, engage with relevant stakeholders and implement remediation processes
• Requires suppliers to maintain documentation to demonstrate compliance, implement improvements in event of infringement, and submit reports on actions taken
• Sanoma or a third party is permitted to audit suppliers' compliance
• Sanoma reserves the right to cancel orders, suspend orders and/or terminate contracts with suppliers in the event of a material breach

International standards alignment:

• Aligned with the Ten Principles of the UN Global Compact
• Aligned with the Universal Declaration of Human Rights (UDHR)
• Aligned with the International Bill of Rights
• Aligned with the UN Guiding Principles on Business and Human Rights (UNGPs)
• Aligned with the ILO Declaration on Fundamental Principles and Rights at Work and supporting ILO standards
• Provisions are aligned with ILO standards

Public availability:

• Available on Sanoma's website
• Made available to stakeholders such as customers and suppliers

Stakeholder engagement:

• Stakeholders' views, including views of suppliers' workforce, were taken into consideration in standard setting

Monitoring and implementation:

• All new suppliers go through Sanoma's source-to-contract solution, which incorporates the Supplier Code as a mandatory step for successful selection
• Sanoma tracks share of new key suppliers that have signed the Supplier Code of Conduct (target: 100%)
• Annual supplier assessments performed on all print suppliers, collecting SEDEX, BSCI or SMETA third-party audit reports
• Sanoma's Know Your Counterparty (KYC) process identifies possible risks of impacts and non-compliance
• Suppliers required to ensure grievance mechanism is available for workers to raise complaints
• In case of deficiencies, Sanoma requires suppliers to rectify impacts and report back regularly on actions taken
• Violations or concerns of non-compliance advised to be reported through grievance channels
• Sanoma's whistleblowing channel available in several languages relevant for Sanoma's operations and value chain
• If deficiencies are not rectified within reasonable time or are material/irreparable, contract or order can be terminated

Code of Conduct

Approval and oversight:

• Approved by the Board of Directors
• President and CEO and EMT ultimately responsible for ensuring Sanoma employees are aware of and comply

Scope:

• Applies to all Sanoma employees
• Requirements extended to Sanoma's suppliers through the Supplier Code of Conduct

Key content and principles:

• All employees must comply with the Code of Conduct
• Supports international standards on human rights and labour conditions
• Clearly prohibits all corruption and bribery

International standards alignment:

• Supports international standards on human rights and labour conditions

Public availability:

• Available on Sanoma's website

Monitoring and implementation:

• Mandatory e-learning course on the Code of Conduct for all employees
• Annual Code of Conduct refresher training (completion rate target: 97%; achieved: 97% in 2024)
• Relevant parts embedded into annual training

Paper Procurement Standard

Approval and oversight:

• Standard part of Sanoma's paper supplier agreements
• Procurement team responsible for implementation

Scope:

• Applies to paper suppliers

Key content and principles:

• Sets requirements towards paper suppliers on use of certified paper
• Forest-related risks evaluated and mitigated as part of annual negotiations with suppliers
• Suppliers report on FSC or PEFC certifications and other sustainability efforts
• Information on origin of paper evaluated as part of negotiations

Monitoring and implementation:

• Annual negotiations with suppliers to evaluate forest-related risks
• Procurement team monitors and leads implementation

General Procurement Terms

Scope:

• Apply to all purchase orders unless specifically agreed otherwise

Monitoring:

• Adherence validated through defined Procurement Control Points and internal audits on procurement processes and guidelines

Taking action on material impacts on value chain workers

Sanoma takes action to prevent, mitigate and remediate actual and potential negative material impacts on value chain workers through its purchasing practices. The Procurement team is responsible for the management of material impacts, including setting supplier requirements, identifying and monitoring impacts as well as tracking preventive and corrective measures.

As most of Sanoma's impacts on workers in the value chain are potential, Sanoma's approach focuses on mitigating the risk of impacts actually occurring. No severe human rights issues or incidents connected to Sanoma's upstream value chain occurred during the reporting period.

Actions taken

1. Know Your Counterparty (KYC) process

What it does: Identifies possible risks of impacts and non-compliance of doing business with third parties. The KYC tool screens Sanoma's suppliers and identifies possible third-party non-compliance, including human rights, anti-bribery, corruption, sanctions regulations and due diligence checks.

Scope: Upstream value chain (suppliers)

Time horizon: Continuous action

Outcomes: Based on screening, Sanoma may restrict or discontinue business activity involving countries or persons subject to sanctions programmes and other higher risk matters. In cases of medium or high risk, the tool refers employees to consult the Procurement and Legal teams.

2. Updated Supplier Code of Conduct

What it does: Updated during 2024, clarifying requirements related to working hours and remediation. The supplier selection for new suppliers follows Sanoma's strategic sourcing process, which incorporates the Supplier Code of Conduct as a mandatory requirement.

Scope: Upstream value chain (all suppliers)

Time horizon: 2024 (implementation)

Outcomes/KPIs: Sanoma aims that all new suppliers agree on the Supplier Code of Conduct. Effectiveness evaluated by following the number of new key suppliers that have agreed on the SCoC.

Link to policy: Links to Supplier Code of Conduct requirements

3. Supplier engagement and assessment programme

What it does: Annual supplier assessment on all print suppliers, collecting SEDEX, BSCI or SMETA third-party audit reports from suppliers in addition to environmental details. Organised a Supplier Day for paper and print suppliers in 2024 focusing on supplier requirements and current and future regulation (CSRD, CSDDD, EUDR).

Scope: Upstream value chain (paper and print suppliers - identified as higher risk category)

Time horizon: Annual, ongoing

Resources (non-financial): Supplier Day event, engagement with procurement category

Outcomes: Capacity-building and engagement with entities in the value chain. All regulations impose requirements towards suppliers related to Sanoma's actual and potential impacts on workers in the value chain.

4. Corrective action plans for identified impacts

What it does: In relation to identified actual impacts on print suppliers' workers related to working time (exceeding working time agreements), fair remuneration and health and safety, Sanoma engaged with suppliers during 2024 requesting them to deliver plans for preventive and corrective actions to enable effective remedy.

Scope: Upstream value chain (print suppliers with identified impacts)

Time horizon: 2024, ongoing monitoring

Outcomes: Progress of action plans to ensure preventive and corrective measures is ongoing. Examples include suppliers recruiting more employees to reduce overtime of workers. Effectiveness tracked through cooperation with suppliers and annual collection of audit reports.

Link to policy: Links to remediation commitments in Supplier Code of Conduct and human rights policies

General approach

No topic-specific actions were targeted to manage potential working conditions impacts (occupational health and safety, freedom of association, collective bargaining, employment security, adequate wages, social dialogue) or equal treatment (training and skills development and gender equality) in 2024, as Sanoma aims to prevent impacts from actually occurring through its procurement practices.

Targets related to value chain workers

Sanoma does not have time-bound targets for managing workers in the value chain-related impacts, as most impacts are potential and actual impacts are always handled in a topic-specific manner.

Monitoring metric

Sanoma tracks the following effectiveness measure:

• Metric: Share of new suppliers that have agreed on the Supplier Code of Conduct (SCoC)
• Frequency: Monitored annually
• Target: All suppliers agree on its Supplier Code of Conduct
• Process: All new suppliers go through Sanoma's source-to-contract solution, which aims to incorporate the Supplier Code as a mandatory step for successful selection

No quantified targets, baseline years, target years, or progress-to-date values are disclosed.

Policies related to consumers and end-users

Sanoma has adopted several policies to manage impacts on consumers and end-users. In addition to the Code of Conduct and Sustainability and Human Rights Policy, Sanoma has topic-specific policies related to the impacts and risks associated with consumers and end-users.

Code of Conduct

• Scope: All employees and business partners
• Governance: Applies to Sanoma Corporation and its subsidiaries and all companies in which Sanoma has financial control. The President and CEO and the EMT are ultimately responsible for ensuring that Sanoma's employees are aware of and comply with the policies.
• Key content: Outlines shared ethical standards for employees and business partners. Acts as an umbrella for all policies and standards within Sanoma. Encompasses the Ten Principles of the UN Global Compact on human rights, labour, environment and anti-corruption.
• Public availability: Available for all employees via internal channels and publicly on Sanoma's website
• International standards: Aligned with the Ten Principles of the UN Global Compact
• Monitoring: The Board of Directors approved the updated Code of Conduct in 2024

Sustainability and Human Rights Policy

• Scope: Sanoma Corporation and its subsidiaries and all companies in which Sanoma has financial control
• Governance: Approved by the Board of Directors. Published in December 2024. The President and CEO and the EMT are ultimately responsible for ensuring that Sanoma's employees are aware of and comply with the policies.
• Key content: Outlines Sanoma's sustainability-related principles and summarises its core commitments in its own operations. Defines Sanoma's sustainability due diligence process, including identification, assessment, management and remediation of sustainability-related impacts. Outlines Sanoma's sustainability management model and responsibilities to identify impacts, risks and opportunities through the double materiality assessment process. Includes commitment to the Ten Principles related to fundamental responsibilities in human rights, labour, environment and anti-corruption.
• Public availability: Available for all employees via internal channels and publicly on Sanoma's website
• International standards: As a signatory of the UN Global Compact (UNGC), Sanoma recognises the importance of the Agenda 2030 and UN Sustainable Development Goals (SDGs), and adheres to the UN Guiding Principles. Aligned with internationally recognised instruments such as the Universal Declaration of Human Rights (UDHR), the International Labour Organization's (ILO) Declaration on Fundamental Principles and Rights at Work and the OECD Guidelines for Multinational Enterprises. Aligned with the Universal Declaration of Human Rights, Article 12 related to Privacy.
• Monitoring: Not specified

Privacy and Data Protection Policy

• Scope: Sanoma Corporation and its subsidiaries and all companies in which Sanoma has financial control
• Governance: Approved by the Board of Directors. Sanoma's Chief Legal Officer is accountable for ensuring that the principles, guidelines and processes comply with the relevant privacy laws. The Data Protection Officer (DPO) owns the policy, and leads a Privacy Programme to provide privacy advice, monitor compliance of processes for privacy implementation and report on privacy compliance. DPO reports on compliance to the management and Audit Committee.
• Key content: Describes ten principles that guide the implementation of privacy laws into Sanoma's operations. Safeguards for processing children's data is one of the ten principles, as children are users of the products and services of Sanoma's media, and especially learning business.
• Public availability: Available for all employees via internal channels
• International standards: Security controls are selected and implemented based on the industry's leading standards (ISO/IEC 27001, ISO/IEC 27701) and their code of practices (ISO/IEC 27002, ISO/IEC 27018). Some of the learning businesses are ISO certified (Clickedu, itslearning, Bureau Ice, and Iddink Digital).
• Monitoring: The Privacy Programme undergoes internal audits to verify adherence to the Privacy and Data Protection Policy

Principles of Ethical Use of AI

• Scope: All Sanoma operations using AI
• Governance: The Group Legal and Compliance team owns the Principles.
• Key content: When using AI, Sanoma applies privacy and personal data protection principles and practices defined in its Privacy and Data Protection Policy and in the Principles of Ethical Use of AI. The Principles include Fairness with an aim for positive impact, Accountability by humans, Explainability, Transparency, Risk and impact assessment and Oversight to monitor the implementation of AI.
• Public availability: Not specified
• International standards: Not specified
• Monitoring: Not specified

Information Security Policy

• Scope: Sanoma Corporation and its subsidiaries and all companies in which Sanoma has financial control
• Governance: Approved by the Board of Directors. The Chief Information Security Officer (CISO) is the owner of the Information Security Policy and responsible for delivering standards and guidelines and for facilitating the delivery of high-quality security services. The CISO reports on compliance and security incidents to the management and Audit Committee.
• Key content: Determines the organisational, people, technical and physical controls in ensuring the confidentiality, integrity and availability of Sanoma's business operations and how to deal with cyber security risks.
• Public availability: Available for all employees via internal channels and publicly available on Sanoma's website
• International standards: Security controls are selected and implemented based on the industry's leading standards (ISO/IEC 27001, ISO/IEC 27701) and their code of practices (ISO/IEC 27002, ISO/IEC 27018)
• Monitoring: Not specified

Supplier Code of Conduct and General Procurement Terms

• Scope: All suppliers that process personal data of consumers, customers or employees, on Sanoma's behalf
• Governance: Owned by the Chief Procurement Officer. Approved by the President and CEO. The Procurement team is responsible for updating, communicating and leading the implementation of the Supplier Code.
• Key content: Set the privacy and security requirements for suppliers that process personal data of consumers, customers or employees, on Sanoma's behalf.
• Public availability: Available for all employees via internal channels and publicly available on Sanoma's website. Referred to during the negotiation process with the suppliers.
• International standards: Not specified
• Monitoring: Not specified

Sanoma Learning's Editorial Guidelines

• Scope: All Sanoma Learning operations
• Governance: Reviewed annually by the editorial working group and approved by the President and CEO. The Learning Strategy team is responsible for the development of the inclusive learning strategy and updating the editorial guidelines. The local editorial guidelines are approved by the local Managing Directors and implemented by the local operating companies.
• Key content: State Sanoma's commitment and approach to editorial ethics and inclusive content. The three guiding principles are: "We create high-quality learning materials", "We support diversity and inclusiveness" and "We ensure equal access". Each operating company has its own defined editorial process, respecting the local legal and ethical regulations and norms. Sanoma follows local curriculum requirements in its content creation.
• Public availability: The local editorial guidelines are available for employees in internal channels. The Learning-wide editorial guidelines are externally available on Sanoma's website.
• International standards: Not specified
• Monitoring: Sanoma utilises the feedback from the stakeholders gained through, for example, the annually conducted European Teacher Survey and focus groups. Once the guidelines are implemented, Sanoma also uses the feedback processes to evaluate and ensure the effectiveness of the policies.

Inclusive Learning Strategy

• Scope: All Sanoma Learning operations
• Governance: Not specified in detail
• Key content: Updated in 2024. States that Sanoma provides students access to quality information through blended methods, i.e., print and digital, to guarantee overall availability. This approach supports diversity, differentiation and equal access to education. Sanoma offers personalised learning pathways to ensure students can follow information tailored to their needs. Students feel represented in the content regardless of their gender, religion or cultural background. All new or renewed learning materials follow a common method creation process and local curriculum requirements.
• Public availability: Available and regularly communicated through internal channels
• International standards: Not specified
• Monitoring: Not specified

Council of Mass Media's (CMM) Journalist's Guidelines

• Scope: All Media Finland journalistic work, thus consumers and end-users
• Governance: The CEO of Media Finland, who is a member of the EMT, is ultimately responsible for the implementation of the policies. The Editors-in-Chief and supervisors of the editorial teams are responsible for ensuring that all journalists working for Sanoma understand their professional responsibilities. The Editors-in-Chief and Sanoma's Forum for the Editors-in-Chief develop the editorial culture at Sanoma, provide guidance, follow reader surveys and customer feedback and take part in public discussion on editorial independence, ethics and journalism.
• Key content: Main guiding principles of the journalistic work at Media Finland. Include the principles of professional status, obtaining and publishing information, the rights of interviewer and interviewees, right to reply and the definition of private and public. Give guidance for correcting possible errors in the media in question and how to separate journalism from advertising. Renewed in October 2024, now include four new factors concerning external funding, changes made to a published story, dangerous news situations and removal of editorial content from the web.
• Public availability: Not specified
• International standards: Not specified
• Monitoring: Sanoma is committed to publishing the Council's condemnatory decision within a short time span. Sanoma closely follows the decisions of the CMM, and engages in discussion about the decisions that guide journalistic work. Sanoma tracks and reports the CMM cases related to its operations externally on an annual basis to further develop professional ethics.

Commitment to Advertising Ethics and Marketing Standards

• Scope: All Media Finland advertising practices
• Governance: Not specified in detail
• Key content: Commitment to maintain high ethical standards and truthfulness of advertising practices, protect vulnerable audiences, and follow the International Chamber of Commerce Advertising and Marketing Communications Code, included in the Sustainability and Human Rights Policy. Sanoma complies with the International Chamber of Commerce (ICC) Advertising and Marketing Communications Code, the EU Framework for Online Behavioural Advertising self-regulation principles issued by IAB Europe and the marketing self-regulation guidelines of the Data & Marketing Association of Finland. Sanoma follows guidelines on advertising ethics set by Finnish institutions such as the Council of Mass Media, National Audiovisual Institute (KAVI) and the Council of Ethics in Advertising. Sanoma keeps advertising and journalistic content separate, and does not provide advertisers with digital advertising target groups including children. Materials that could potentially harm vulnerable audiences are published by the editorial teams according to the KAVI guidelines.
• Public availability: Not specified
• International standards: ICC Advertising and Marketing Communications Code, EU Framework for Online Behavioural Advertising self-regulation principles issued by IAB Europe
• Monitoring: Statements from the Council of Ethics in Advertising are reviewed by the Media Finland Legal team, and the internal guidelines are updated accordingly if needed. Sanoma reports the number of notifications externally on an annual basis.

Learning content:

• We co-create high-quality and motivating learning materials with teachers, fitting the local curriculum
• We develop inclusive learning solutions that support diversity, differentiation and equal access to education
• We create learning methods that support the Sustainable Development Goals

Digital accessibility:

• We develop accessibility of our content and digital solutions: Common accessibility components used in Learning's core digital products will be compliant with the AA-level of the WCAG Guidelines (Web Content Accessibility Guidelines) from 2025 onwards

Performance 2024:

• 84% of teachers agree that our materials help students reach curriculum objectives
• 73% of teachers agree that our materials help engage their students
• 78% of teachers agree that our materials support efficiency
• In 2024, the SL Design System foundation was audited for accessibility against the WCAG guidelines (AA level) and development plan created based on the Accessibility audit report

Sustainable media:

• We promote open democratic society and freedom of speech through our independent media
• We increase awareness, empathy and tolerance with our journalism
• We empower shared experiences with our sustainable entertainment and support the local audiovisual community
• We enable companies to thrive through our sustainable marketing solutions

Performance 2024:

• 5 notifications of violation concerning aspects of news articles as defined in the Guidelines for Journalists by The Council of Mass Media
• 2 cases of non-compliance against the Advertising and Marketing Communications Code of the International Chamber of Commerce

Targets related to consumers

Sanoma has not set any measurable time-bound outcome-oriented targets related to consumers and end-users, and does not have plans to implement such targets.

The company states: "Sanoma has not set any measurable time-bound outcome-oriented targets related to consumers and end-users, and does not have plans to implement such targets. Given the nature of Sanoma's business, material issues do not change annually, and therefore the Sustainability Strategy and targets are set for the long term."

Entity-specific metrics tracked (non-targets)

Sanoma tracks effectiveness through the following metrics, but these are not defined as time-bound targets:

Privacy:

• Total number of identified personal data breaches: 178 (2024)
• Substantiated complaints from regulatory bodies concerning breaches of customer privacy: 1 (2024)
• Target: Ensure effective Privacy- and Security-by-Design process (no quantitative target)

Access to quality information and education:

• Qualitative goals: Co-create high-quality learning materials with teachers; develop inclusive learning solutions
• Accessibility target: Common accessibility components in Learning's core digital products compliant with AA-level of WCAG Guidelines from 2025 onwards
• No quantitative targets set for European Teacher Survey metrics

Freedom of expression and media ethics:

• Council of Mass Media decisions monitored: 17 liberating, 5 condemnatory (2024)
• No target level for number of notifications

Responsible marketing practices:

• Incidents of non-compliance with voluntary codes: 2 (2024)
• No target level for number of incidents

97% of employees took the annual Code of Conduct e-learning with topics focusing on anti-bribery and corruption, fair competition, working responsibly with suppliers, privacy, security and ethical AI

Strong business ethics, supply chain integrity and ethical partnerships are fundamental to Sanoma and its role in society. Sanoma is a member of the UN Global Compact, and committed to the Ten Principles on human rights, labour, environment and anti-corruption.

All employees complete our mandatory Code of Conduct e-learning Code of Conduct refresher e-learning completion rate: 97%

100% of new key suppliers signed the Supplier Code of Conduct

All new key Sanoma suppliers sign our Supplier Code of Conduct Share of new key suppliers that have signed the Supplier Code of Conduct: 100%

Sanoma's daily business is dependent on its ability to identify sources of supply that meet Sanoma's standards and identified business, technology and sustainability requirements, although Sanoma is not dependent on any individual suppliers. To mitigate third-party-related risks, Sanoma follows the guiding principles of supplier risk management set in the Group's Procurement Policy, Supplier Code of Conduct and legal framework. The most significant suppliers are selected through competitive bidding and qualification processes. Suppliers and other third parties are subject to a Know Your Counterparty (KYC) process to identify any risks related to anti-bribery, sanctions regulations and other issues.

All Sanoma employees, for example, must comply with Sanoma's Code of Conduct, which supports the international standards on human rights and labour conditions and clearly prohibits all corruption and bribery. The requirements of the Code of Conduct are extended to Sanoma's suppliers through the Supplier Code of Conduct. Sanoma aims to ensure compliance with measures such as a mandatory e-learning course on the Code of Conduct to all employees.

97% of employees took the annual Code of Conduct e-learning with topics focusing on anti-bribery and corruption, fair competition, working responsibly with suppliers, privacy, security and ethical AI.

Incidents of corruption or bribery

Confirmed incidents

Sanoma reported zero confirmed incidents of corruption or bribery during the 2024 reporting period.

Convictions and fines

No convictions or legal decisions (criminal or administrative) related to corruption or bribery were reported. No fines, penalties, or compensation for damages resulting from corruption or bribery violations were incurred in 2024.

Disciplinary actions

No employees were dismissed or disciplined due to corruption or bribery incidents during the reporting period.

Contracts terminated

No contracts with business partners were terminated or not renewed due to corruption or bribery violations.

Investigation procedures and speak-up mechanisms

Sanoma operates a third-party hosted anonymous whistleblowing channel available in several languages relevant to its operations. The channel enables employees, customers, business partners, and suppliers' workforce to report suspicions of misconduct related to sustainability or human rights issues, including corruption and bribery, confidentially and anonymously.

According to Sanoma's Code of Conduct, the company does not tolerate retaliation against anyone who raises a concern or participates in an investigation. Sanoma investigates reported cases, reviews incidents, leverages learnings to influence both internal and external processes, and reports the number and types of these cases annually. Material issues are reported to the Audit Committee, Executive Management Team (EMT), and the Sustainability and Ethics Working Group.

Sanoma's Anti-Bribery and Corruption Policy establishes zero tolerance to bribery and corruption of any kind, whether involving public officials or private sector entities. The policy is consistent with the UN Convention against Corruption and covers topics including the prohibition of corruption and bribery, facilitation payments, rules for gifts and entertainment, donations, conflicts of interest, record keeping provisions, and money laundering.

All employees are required to complete mandatory Code of Conduct e-learning annually, which includes topics focusing on anti-bribery and corruption. In 2024, 97% of employees completed the annual Code of Conduct e-learning.

Political influence and lobbying activities

Political engagement approach

Sanoma's President and CEO is responsible for the oversight of political influence and lobbying activities.

Sanoma's stakeholder engagement with governmental organisations, policymakers and legislators includes:

Purpose:

• Regulatory and governmental monitoring

Method:

• Sharing views on policies, laws and regulations with officials and legislators through public consultations, meetings, as well as part of a larger stakeholder dialogue with policymakers
• Replying to public consultations and providing insights and analysis to government officials and politicians
• Participating in the work of industry associations

Ethical standards and guidelines

Sanoma's Donations and Sponsorships Policy defines Sanoma's principles, decision-making process and criteria that are applied to donations and sponsorships. This policy covers the following impact, risk and opportunity: impacts of political engagement and lobbying of Media and Learning businesses.

Sanoma's Donations and Sponsorship Policy prohibits Sanoma from making any donations for political purposes.

Political contributions

In 2024, Sanoma did not have any financial or in-kind political contributions.

EU Transparency Register

Sanoma Media Finland Ltd (440600622097-82) is registered in the EU Transparency Register. Sanoma Corporation (712395115155-72) is not directly registered in the EU Transparency Register.

Focus areas

Sanoma's key topics for lobbying activities and its main positions are:

• Improving learning outcomes (related to IRO Impact of access to high-quality and inclusive learning products and services): Sanoma promotes using (only) professionally produced education materials in education, increasing education investments per student as well as having strong copyright protection for using education materials in training AI.

• Supporting the media's operating conditions (related to IRO Impact of journalistic ethics and operations as a media company to freedom of expression): Sanoma promotes levelling the playing field with global platform giants, protecting its content with strong copyright, preventing unfair competition by national public service broadcaster and maintaining a lowered tax rate for media.

• Copyright (related to IRO Risk related to management of IPR rights): Sanoma promotes strong copyright protection for its content, fair terms for using (Audiovisual) content and direct licensing as a primary form of copyright licensing.

• Reforming the Finnish gambling legislation (related to IRO Impact of responsible advertising practices and compliance with green claims regulation): Sanoma promotes responsible advertising related to the opening up of gambling advertising in Finnish media.

Administrative body positions

No members of Sanoma's administrative, management and supervisory bodies have held a comparable position in public administration in the two years preceding such appointment in the reporting period.

Payment practices

Policy to prevent late payments

Goods and services are purchased in accordance with Sanoma's General Procurement Terms and Conditions as well as the internal Procurement Policy. They include Sanoma's payment terms and apply to all supplier categories, including SMEs, unless separately agreed otherwise together with the supplier. Sanoma's standard payment term is 45 days. However, payment terms can be negotiated depending on category-specific requirements. For example, Sanoma uses a 14-day payment term for self-employed suppliers and natural persons.

Sanoma provides internal trainings on invoice handling, communicates about payment practices to suppliers and has a ticketing system for any exceptions in invoices to ensure fair practices. Sanoma's Accounting Services controls the invoice flow, and sends reminders in case invoices are not handled close to due dates.

Payment practices metrics

Payment practices are tracked annually, and the data is available from a centrally used tool. Calculations are made from the invoice date to the payment date. If there are clear errors in the dates (for example, payment date being before invoice date), they are excluded from the calculations.

Scope note: Data from operating companies that are not in Sanoma's centralised invoice processing system has been estimated to have the same average number of days to pay invoice. The share of estimated data represents 20% of the data.

Standard payment terms

Sanoma's standard payment term in general procurement terms is 45 days. However, payment term can be negotiated depending on category/supplier-specific requirements. In addition, Sanoma uses 14 days for self-employed suppliers and natural persons.