Sanoma

The role of the administrative, management and supervisory bodies

Reference: pages 58-60.

From a sustainability governance perspective, Sanoma's "administrative body is the Board of Directors, the management body the President and CEO supported by the EMT, and the supervisory body the Board of Directors' Audit Committee" (page 59). The Audit Committee "acts as Sanoma's Sustainability Committee" (page 59). A Sustainability and Ethics Working Group, drawn from across the Group and representing all material topics, sits below the EMT.

Board composition at 31 December 2025 (page 58):

"Sanoma does not have representation of employees and other workers in its administrative, management and supervisory bodies" (page 58). The EMT (Rob Kolkman, Alexander Green, Pia Kalsta) was unchanged in 2025: 1 female, 2 male, gender ratio 0.5 (pages 58-59).

Board responsibilities include approving the strategic sustainability guidelines, the Sustainability and Human Rights Policy, the statutory Sustainability Statement, and reviewing the DMA process and approving its outcomes (page 59). Board members were trained on the ESRS in 2024 (page 60).

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

Reference: pages 60-61.

Frequency of updates in 2025 (page 60): the Audit Committee received six updates on material impacts, risks and opportunities (2024: five), the Board of Directors eight (2024: eight), and the EMT seven (2024: eight). The Ethics and Compliance Programme, covering corporate culture and corruption and bribery risks, "is reviewed by the Audit Committee twice a year" (page 60).

Topics discussed during the reporting year (page 61) by both the Board/Audit Committee and the President and CEO/EMT: approval of the double materiality assessment; the Code of Conduct update; performance monitoring of the Ethics and Compliance Programme, the Privacy Programme and sustainability-related short-term incentives (people, climate and privacy); and sustainable finance development, including review of the Social Bond Report and monitoring of ESG ratings. The EMT additionally covered "regulatory monitoring related to sustainability reporting, due diligence, deforestation, artificial intelligence, privacy and accessibility regulation, EU Pay Transparency Directive" (page 61).

Effectiveness of policies, actions, metrics and targets is "integrated into the sustainability scorecard that is monitored annually by the Board of Directors, Audit Committee and the EMT as part of the review of the Annual Report" (page 60).

Integration of sustainability-related performance in incentive schemes

Reference: page 62 (GOV-3 and E1 GOV-3).

"In 2025, alongside financial metrics, sustainability targets constituted 20% of the total annual short-term incentives for the members of the EMT at the target level. A total of 10% out of the overall targets were linked to the Employee Engagement Survey (EES), 5% to internal data and privacy targets and 5% to the climate targets" (page 62).

The climate component is tied directly to the validated science-based targets: "the EMT members' incentives were linked to Sanoma's SBTi emissions reduction targets for Scope 1, 2 and 3", which are set out under E1-4 (page 62). Privacy metrics covered standardising processes for managing privacy and ethical AI use, and conducting Privacy Impact Assessments for new products (page 62).

The Board of Directors' Human Resources Committee "reviews and approves the incentive schemes, including the sustainability targets, annually" (page 62).

A boundary is stated explicitly: "Sanoma's sustainability administrative and supervisory bodies, the Audit Committee and the Board of Directors, do not have performance-based incentives related to sustainability" (page 62).

Statement on due diligence

Reference: page 62.

Sanoma's due diligence process is defined in its Sustainability and Human Rights Policy and follows the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises (page 62).

Mapping of the core elements of due diligence to the statement (page 62):

Note that row (c) also lists policies (E1-2, E4-2, E5-1, S1-1, S2-1, S4-1, G1-1) alongside IRO-1, as printed on page 62.

Risk management and internal controls over sustainability reporting

Reference: page 62.

Roles and responsibilities for sustainability reporting and management are defined in the Sustainability and Human Rights Policy. The Board is responsible for "the appropriate arrangement of the risk management and controls of sustainability reporting and its verification" and for approving the statutory Sustainability Statement (page 62).

Sustainability-related risks are also reviewed through the Enterprise Risk Management process, "which also contributed to Sanoma's double materiality assessment update during 2025" (page 62). "Risks related to sustainability reporting are managed through developing internal controls and processes" (page 62), and Sanoma states that in 2025 it "continued to develop the control environment related to sustainability information" (page 60).

The Internal Audit function reports to the CFO and directly to the Audit Committee, works to annual plans and follows the Global Internal Audit Standards; findings and follow-up are reported to the Audit Committee (page 62). "In 2025, internal audits on data governance and lifecycle management in Learning and Media Finland were performed" (page 62).

The disclosure does not describe a formal risk assessment of the reporting process itself (for example a scoping of reporting risks by likelihood and magnitude), nor a mitigation strategy tied to identified reporting risks.

Strategy, business model and value chain

Reference: pages 63-66.

Sanoma runs two strategic business units. Learning supplies printed and digital learning products and services for primary, secondary and vocational education (K12, 6-18 year-olds) in the Netherlands, Spain, Poland, Italy, Belgium, Finland, Sweden, Norway, Denmark, Germany and the UK; Media Finland supplies journalism, entertainment (TV, video-on-demand, radio, audio, events) and advertising in Finland (page 63). "At the end of 2025, Sanoma employed 5,065 professionals in total" (page 63). "No significant changes in products and services offered or markets and customer groups served took place during the reporting period" (page 63).

The Sustainability Strategy is organised around six topics: Inclusive learning, Sustainable media, Valued people, Trustworthy data, Vital environment, and Responsible business practices (page 63).

Value chain (pages 65-66). Upstream: content creation (including freelancers), technology and digital suppliers, logistics partners, marketing and sales agencies, plus printing, materials (notably paper) and energy. "Paper, print and logistics procurement are categories with the most significant environmental impacts" (page 66). Own operations: employees, owned and leased offices, warehouses and two newspaper printing houses in Finland. Downstream: schools and teachers, students, Finnish consumers, B2B customers, distributors, third-party data processors and investors.

Sanoma applies the ESRS 1 phase-in for SBM-1 40(b) revenue breakdown by significant ESRS sector and 40(c) additional significant sectors (page 57).

Interests and views of stakeholders

Reference: pages 67-68 (SBM-2, S1 SBM-2, S2 SBM-2 and S4 SBM-2 are disclosed jointly).

Sanoma identifies eight stakeholder categories with purpose, method and material topics per group: learning customers and end-users; Media Finland end-users, consumers and customers; own workforce; investors; supply chain partners and workers in the value chain; governmental organisations, policymakers and legislators; NGOs and industry associations; and local communities, universities and research organisations (pages 67-68).

Engagement methods include teacher meetings and webinars, customer satisfaction surveys, Pulse and annual Employee Engagement Surveys, employee representative cooperation and the European Works Council, investor roadshows and Social Bond engagement, Supplier Day events for paper and print suppliers, and public consultations with policymakers (pages 67-68).

A significant limitation is stated plainly: "In the double materiality assessment, the interests and views of Sanoma's stakeholders were considered indirectly. Instead of engaging stakeholders through a formal process, information about their perspectives were gathered from informal, ongoing discussions that Sanoma's topic owners have with stakeholders as part of regular business activities" (page 67).

The DMA, including relevant stakeholder interests, "has been reviewed and approved by the EMT, Audit Committee and the Board" (page 67).

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

Reference: pages 69-75; IRO tables on pages 71-75.

Material topics are ESRS 2, E1, E4, E5, S1, S2, S4 and G1. The tables list 41 individually typed IRO rows: E1 8 (3 opportunities, 3 risks, 2 actual negative impacts), E4 2, E5 2, S1 9, S2 6, S4 7 and G1 7.

Financial effects. "Sanoma has assessed its material sustainability impacts, risks and opportunities as identified in the double materiality assessment, and did not identify any significant current financial effects related to them. Sanoma has not identified any material sustainability risks that would pose a significant risk for its financial position, performance, cash flows, or a risk of a material adjustment to the carrying amounts of assets and liabilities" (page 69). The ESRS 1 phase-in is applied to SBM-3 48(e) anticipated financial effects (page 57).

Resilience. "During its double materiality assessment (DMA), Sanoma has qualitatively assessed that its current strategy and business model are in general resilient in regards to its capacity to address the material topics identified... Resilience was assessed until 2030, as that is the current time horizon of Sanoma's strategy" (page 69).

Changes versus 2024 (pages 69-70) include: the EUDR-related biodiversity risk deemed non-material after printed products were ruled out of scope; S1 working-time impact deemed non-material; freedom of association impacts combined and reclassified as an actual positive impact; a new S4 positive AI impact; G1 payment practices and the regulatory-landscape risk deemed non-material.

Climate-specific risk identification and scenario analysis is also presented under E1-2, and climate resilience under E1-3 (2025 ESRS numbering).

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

Reference: pages 76-78 (including E1, E2, E3, E4, E5 and G1 IRO-1).

Sanoma carried out its first DMA in 2023-2024 and "updated the DMA during 2025" (page 76). The process ran in two phases: a review and consolidation of all 2024 IROs by the Sustainability and Compliance teams, then prioritisation through workshops with topic owners from Procurement, HR, Compliance, Legal, Privacy, Security and Strategy (page 76).

Assessment criteria (page 76). Impacts: severity (scale, scope, irremediability) and significance of positive impacts; likelihood on a five-point scale from very unlikely (10%) to very likely (90%); value chain location; time horizon of short (0-1 years), medium (1-5) or long (beyond 5). Risks and opportunities: financial significance banded as not significant (EUR 0-1 million), low (1-5), average (5-20), high (20-40) or very high (40+), the same scale as the ERM process.

Thresholds "were set slightly below the median score for both the impact and financial assessments" (page 79), and Sanoma acknowledges that its scoring "tends to assign lower scores to actual impacts compared to potential impacts with high likelihood", so final scores were reviewed and some items reclassified in both directions (page 76).

Non-material environmental topics. E2 Pollution: "no substances of concern found in comparison to the ECHA Candidate List", small VOC emissions at Media Finland printing houses, minor plastic use and "no significant microplastics identified" (page 77). E3: "no significant water or marine resource impacts identified" (page 78). No external consultations were conducted on climate, pollution, water, biodiversity or resource-use impacts (page 77).

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

Reference: pages 79-84.

Sanoma prints a full ESRS content index, "Content index: Disclosure Requirements complied with in preparing the Sustainability Statement" (pages 79-80), followed by the list of datapoints deriving from other EU legislation (pages 81-84).

Disclosure requirements listed as covered (pages 79-80): ESRS 2 BP-1, BP-2, GOV-1 (with G1 GOV-1), GOV-2, GOV-3 (with E1 GOV-3), GOV-4, GOV-5, SBM-1, SBM-2 (with S1/S2/S4 SBM-2), SBM-3, IRO-1 (with E1, E2, E3, E4, E5 and G1 IRO-1) and IRO-2; EU Taxonomy; E1 SBM-3 and E1-1 to E1-7; E4-1, E4 SBM-3, E4-2, E4-3, E4-4; E5-1 to E5-5; S1 SBM-3, S1-1 to S1-6, S1-8 to S1-11, S1-13 to S1-17; S2 SBM-3 and S2-1 to S2-5; S4 SBM-3 and S4-1 to S4-5; G1-1 to G1-5.

Not listed: E1-8, E1-9, E4-5, E4-6, E5-6, S1-7, S1-12 and G1-6, and every E2, E3 and S3 requirement. The EU-legislation datapoint table marks E2-4, E3-1, E3-4, S3-1 and S3-4 explicitly as "Not material" (pages 82-83).

Phase-in provisions applied (page 57): ESRS 2 SBM-1 40(b) and (c), ESRS 2 SBM-3 48(e), E1-9, E4-6, S1-7, and the S1-14 datapoints on work-related ill health, days lost and non-employee health and safety.

The statement is prepared under "the European Sustainability Reporting Standards (ESRS) defined in the Commission Delegated Regulation (EU) 2023/2772 as well as the Commission Delegated Act 2025/1416" (page 56), that is, the 2023 ESRS.

Transition plan for climate change mitigation

Reference: page 90.

"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" (page 90).

Targets: Scope 1 and 2 combined absolute reduction of 42% by 2030 from a 2021 base year; Scope 3 reduction of 38% by 2030 from 2021, covering categories 1, 3 and 4, "which together accounted for about 76% of Sanoma's value chain emissions in 2025" (page 90).

Decarbonisation levers: improving energy efficiency, reducing energy consumption and using fossil-free energy in Scope 2; cooperating with suppliers, improving efficiency and the emissions intensity of materials, and reducing energy consumption in Scope 3; transition to rechargeable and hybrid cars for Scope 1; and, for Learning curriculum renewals, "transitioning to lower-carbon paper, optimising paper emission intensity, adopting low-carbon printing processes, and utilising low-carbon logistics" (page 90).

Funding and approval: "Sanoma has not identified significant capital expenditure and operational expenses which would currently be required to implement its climate transition plan" (page 90). The plan is embedded through the linking of SBTi climate targets as sustainability KPIs to the EUR 300 million Syndicated Revolving Credit Facility and through executive short-term incentives. "The transition plan was approved in 2021 by Sanoma's EMT, AC and Board" (page 90).

Locked-in emissions: "Sanoma does not identify any significant locked-in GHG emissions" (page 90). "Sanoma is not excluded from the EU Paris-Aligned Benchmarks" (page 90). Progress 2021-2025: Scope 1 and 2 down 59%, Scope 3 categories 1, 3 and 4 down 46% (page 90).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and E1 IRO-1 (pages 77-78) and E1 SBM-3 (page 91), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification of risks (paragraph 15). Sanoma separates physical from transition risks explicitly. Physical: "Acute physical hazards like flooding, driven by increased severity of extreme weather events, may pose a risk to Sanoma's facilities and warehouses" (page 77). Transition: "increasing complexity and cost associated with compliance with enhanced emissions reporting obligations and regulations", naming CSRD and CSDDD, plus reputational risk from a "lack of active and transparent climate action" (pages 77, 91).

Methodology (paragraph 16). "Sanoma evaluates climate- and biodiversity-related physical and transition risks annually and in 2025, they were assessed as part of the double materiality assessment. Physical and transition risks were analysed over short (0-1 years), medium (1-5 years), and long-term (beyond five years) horizons... The assessment covers both own operations as well as the upstream and downstream value chain" (page 77). Tier 1 suppliers were analysed in particular, with tier 2 paper suppliers reviewed when assessing printing houses' ability to reduce emissions (page 91).

Scenarios used (paragraph 17). "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... These scenarios are based on best available scientific evidence, such as the IPCC assessments" (pages 77, 91). Assumptions cover current and future regulation, changes in customer behaviour and market demand, and technology adoption (page 91).

Gaps. No global average temperature projection is stated per scenario (paragraph 17(a)(iii)), and the disclosure does not date the analysis beyond confirming it was performed as part of the 2025 DMA. "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" (page 77).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 (page 69) and E1 SBM-3 (page 91), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Results of the analysis (paragraph 19(a)). "This resilience analysis includes identifying and assessing risks and opportunities, defining risk management activities as well as reporting of risks and opportunities to the EMT, AC and Board, where relevant. The assessment is qualitative and quantitative and performed annually by the Sustainability and Procurement teams as a part of the double materiality assessment process" (page 91). It "covers direct operations as well as the upstream and downstream value chain" (page 91).

"Sanoma has not identified any reasons that would require significant adjustments to its strategy or business model as a result of the climate-related resilience analysis. Sanoma evaluates that adaptation to climate change in the short-, medium- and long-term does not pose a significant threat to securing ongoing access to finance" (page 91). At group level: "As the management of impacts, risks and opportunities is embedded into the current strategy and business model, Sanoma does not identify significant needs... to adapt its current strategy or business model" (page 69).

Uncertainties (paragraph 19(b)). "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" (page 91).

Capacity to adjust or adapt (paragraph 19(c)). Sanoma's ability to adapt "depends on and includes transitioning to renewable and fossil-free energy sources, engaging and cooperating with suppliers to reduce GHG emissions, setting and achieving ambitious science-based targets... as well as regularly updating the Sustainability Strategy and risk management processes" (page 91). "The shift to digital is expected to continue especially in the media business, which will support Sanoma's climate transition. Accelerated digitalisation is expected to also increase energy consumption and, consequently, the demand for fossil-free energy" (page 91).

Policies related to climate change mitigation and adaptation

Reference: page 92 (ESRS 2 MDR-P table).

Four instruments are disclosed (page 92):

• Code of Conduct - approved by the Board, implemented by Group Legal, covering all employees in all operating countries. "From an environmental perspective, the COC emphasises the commitment to minimising negative environmental impacts through efficient operations, responsible supply chain management, and increasing environmental awareness."
• Sustainability and Human Rights Policy - Board-approved, implemented by Group Sustainability. "Emphasises protecting the environment, climate, and biodiversity, raising awareness, and integrating sustainability into business practices" and sets out measures to identify, prevent and mitigate negative environmental impacts across operations and the value chain.
• Supplier Code of Conduct - approved by the President and CEO, implemented by Procurement, applying to "all upstream and downstream suppliers and workers in the value chain". It "addresses climate change, energy efficiency, use of renewable energy, use of plastics, deforestation or forest degradation impacts, waste management, circularity and pollution prevention".
• Environmental Standard - applying to all own operations, approved by the President and CEO. It "sets principles for managing environmental impacts, including climate change adaptation and mitigation, energy efficiency, fossil-free energy, plastics use, biodiversity, waste, circularity, and pollution prevention" and commits Sanoma to the European Climate Pact under the EU Green Deal for climate neutrality by 2050, respecting ISO 14001.

Third-party standards referenced include the UN Global Compact, the Rio Declaration, the European Climate Pact, TCFD, SBTi, FSC and PEFC certifications, and ISO 14001 for own printing houses (page 92). The Code of Conduct and Sustainability and Human Rights Policy are publicly available; relevant parts are embedded in the annual mandatory Code of Conduct refresher training (page 92).

Actions and resources in relation to climate change policies

Reference: page 93.

Scope 1 and 2 own operations. "Sanoma has reduced its combined Scope 1 and 2 emissions by 59% (2024: 44%) by the end of 2025 from the 2021 baseline" (page 93). In Scope 2, reductions come from the shift to renewable and fossil-free electricity and heating plus office restructuring. Intermediate targets: fossil-free electricity, with 98% reached, and transitioning to fossil-free energy by 2030, with 89% reached. In Scope 1, Sanoma "reduced emissions from company cars by renewing its car policy in Italy" (page 93).

Energy actions. In 2025 Sanoma renewed its voluntary energy efficiency agreement in Finland for a 2026-2035 period; "all facilities and printing houses in Finland used fossil-free electricity and renewable district heating"; offices in Sweden, Poland, Belgium and Spain, and some in the Netherlands and Italy, used fossil-free or renewable electricity; office restructuring in Finland, Sweden, Norway, the Netherlands and Germany reduced consumption; and AI is used to optimise heating at the Helsinki headquarters and both Finnish printing houses (page 93).

Scope 3 value chain. "Sanoma has reduced Scope 3 emissions by 46% (2024: 39%) in categories 1, 3 and 4 by the end of 2025 from the 2021 base year, reaching its SBTi target already ahead of 2030" (page 93). 2025 actions: continued cooperation with paper suppliers on lower-carbon paper, printing supplier target setting and carbon accounting, annual collection of supplier-specific emissions data, supplier sustainability segmentation, low-carbon logistics, digital climate solutions to monitor advertising ecosystem emissions, and a Nelonen Media climate plan for TV productions including emission analysis of AV productions (page 93).

Resources. "Minor financial resources have been earmarked for the implementation of the climate transition plan, and these are integrated into Sanoma's overall financial plan... No significant monetary amounts of capital expenditure (CapEx) or operational expenses (OpEx) are currently required to implement the actions taken or planned" (page 93).

Adaptation. Physical risk is handled through operational policies, continuity and disaster recovery plans for critical systems, and an insurance programme covering insurable hazard risks (pages 93-94).

Targets related to climate change mitigation and adaptation

Reference: pages 94-95.

SBTi-validated targets (page 95):

The cross-sector (ACA) pathway used is -42% by 2030 and -90% by 2050 against a 2020 reference year (page 95).

"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" (page 94).

Energy targets. Transition to fossil-free energy (electricity, heating, cooling and reserve power) by 2030, and use of only fossil-free or renewable electricity in offices, warehouses and printing facilities. Both were established in 2021 and are continuous, so no base year or values are disclosed. "In 2025, 89% (2024: 92%) of energy used offices, warehouses and printing facilities was fossil-free. The share of fossil-free renewable and nuclear electricity was 98% (2024: 97%)" (page 94).

Assumptions. Critical assumptions include "changes in paper volumes and print production, shifts in customer demand especially related to the pace of digitalisation in both businesses as well as regulatory changes and the general transition pace towards fossil-free energy formats" (page 94). Curriculum renewals may increase paper volumes and emissions, to be mitigated by low-carbon paper options and optimised paper weights. "Sanoma is currently not planning to adopt new technologies to achieve GHG emission reduction targets" (page 94).

Adaptation targets. No quantified adaptation target is set; effectiveness is tracked "through, for example, regular continuity and disaster recovery planning as well as insurance coverage reviews", plus internal audits for transition risks (page 94).

Energy consumption and mix

Reference: page 95.

"Sanoma's total energy consumption in 2025 was 39,586 MWh. The share of fossil-free energy in the overall energy mix was 70% (2024: 67%)" (page 95).

Energy and fuel consumption, MWh (page 95):

Renewable energy production was 511 MWh (2024: 238) from solar at the Helsinki headquarters and the Tampere printing house; non-renewable energy production was 0 (2024: 40) (page 95).

High climate impact sectors. Sanoma's two Finnish printing houses are classified under NACE C18.1.1 Printing of newspapers. Energy consumption in high climate impact sectors was 16,346 MWh (2024: 18,891) and energy intensity 69 MWh per EUR million (2024: 75), against print net sales of EUR 236.4 million (page 95).

"Around 24% of energy and fuel consumption figures are based on estimates" (page 95). Car energy use is estimated from vehicle mileage; energy is classified as renewable or nuclear only where contractual instruments or Guarantees of Origin prove the source (page 95).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 96-98.

"In 2025, Sanoma's total market-based GHG emissions were 91,799 tCO2e... In 2025, 96% of Sanoma's total GHG emissions resulted from the value chain" (page 96). Own operations Scope 1 and 2 represented 4% of the total. "In Scope 1, no GHG emissions originate from regulated emission trading schemes" (page 96).

Gross GHG emissions, tCO2-eq (page 96):

GHG intensity per net revenue: 70 tCO2-eq per EUR million market-based (2024: 77; 2021: 119) on net sales of EUR 1,302.5 million (pages 97-98).

Methodology. GHG Protocol, financial control boundary, all majority-owned companies; associates and joint ventures reported under category 15. Workiva is used for Scope 1, 2 and Scope 3 categories 2, 3, 5 and 15; spreadsheets for categories 1, 4, 6, 7, 11 and 12. "From Sanoma's GHG inventory, an estimated 38% of Scope 3 is calculated using various estimation methods" (page 97). Categories 8, 9, 10, 13 and 14 are stated as not relevant (pages 97-98). Biogenic emissions were 94 tCO2-eq for Scope 1, 2,702 for Scope 2 and 3,075 for Scope 3 (page 98).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 98; see also page 94.

Sanoma reports no GHG removals and no carbon credits used in the reporting year. The whole of the E1-7 disclosure reads: "In addition to the science-based emission reduction targets, Sanoma aims to be carbon neutral in all operations by 2030. This means that in 2030, Sanoma's aim is to compensate emissions that cannot be avoided or reduced" (page 98).

This is consistent with the target basis stated under E1-4: "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" (page 94).

E1-7 is listed in the ESRS content index against "Environmental disclosure, ESRS E1 Climate change, Metrics and targets" (page 79), so the requirement is treated by the company as covered. The disclosure is nonetheless thin against the standard: no removals in tonnes, no breakdown of any carbon credit portfolio by project type, standard or vintage, and no quantification or timetable for the 2030 carbon-neutrality ambition. The stated intention to compensate residual emissions from 2030 is disclosed without a supporting plan or budget.

Transition plan on biodiversity and ecosystems

Reference: page 99.

Sanoma does not present a standalone biodiversity transition plan but discloses how biodiversity is considered in strategy and business model: "Sanoma's biodiversity actions focus on three angles: minimising the biodiversity impacts of paper procurement through the use of certified paper and/or paper made of the certified fibre, managing biodiversity and paper-related risks, and, as climate change is a significant driver of biodiversity, through Sanoma's climate transition plan described under E1-1" (page 99).

"Sanoma evaluates its current business model to be resilient in regards to impacts and risks related to biodiversity. 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 the Forest Stewardship Council (FSC) or the Programme for the Endorsement of Forest Certification (PEFC) certified paper in its sourcing" (page 99).

Risk mitigation is described concretely: the procurement strategy is updated annually with an evaluation of paper cost and availability; risks are followed through annual supplier negotiations; "The risk of potentially rising paper prices is mitigated by diversifying the paper supply. The risk is closely monitored, 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" (page 99).

Limits are stated: "Sanoma's resilience analysis did not include systemic or physical biodiversity risks or ecosystem risks. Going forward, Sanoma aims to expand its risks assessment" (page 99). During 2025 Sanoma cooperated on biodiversity with paper and print suppliers, NGOs, FSC and PEFC certification collaborators and local authorities (page 99).

Policies related to biodiversity and ecosystems

Reference: page 100.

Two instruments are disclosed (page 100):

• Environmental Standard - applying to all own operations, implemented by Procurement, approved by the President and CEO. "Through the 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. Sanoma aim's to use only paper produced responsibly and originating from traceable, legal and verified sources."
• Paper Procurement Standard - "a part of Sanoma's paper supplier agreements", implemented and approved by Procurement. "It sets requirements towards paper suppliers on the use of certified paper and certified fibre. In-line with the standard, forest-related risks are evaluated and mitigated as part of annual negotiations with the suppliers by the Procurement team. In this evaluation, short-, medium- and long-term forest-related risks are evaluated, and suppliers report on their FSC or PEFC certifications." It is internally available and made available to suppliers through their contracts.

Scope limits are stated explicitly: "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" (page 100).

Grievance handling is covered by the Supplier Code of Conduct commitments to deforestation-free products, with reporting through anonymous channels including the Whistleblowing channel; 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 SCoC" (page 100). Third-party standards cited include FSC and PEFC certifications and ISO 14001 (page 100).

Actions and resources related to biodiversity and ecosystems

Reference: page 101.

"Sanoma's key actions to mitigate its biodiversity impacts related to the use of paper are continuous and include implementing sourcing requirements, improving data collection and traceability related to paper sourcing and cooperating with the suppliers" (page 101).

Specific measures: preference for paper "originating from certified and sustainably managed forests, i.e., from traceable, verified and legal sources"; evaluation of paper certification as part of annual supplier negotiations; collection of certification information from suppliers via the purchase order system; verification of supplier information "via national tools and databases, research institutes and the FSC and PEFC registries"; and tracing and monitoring of purchased paper certification "from its tier 1 and 2 suppliers" (page 101).

Risk-side actions mirror E4-1: annual procurement strategy updates evaluating market risks on paper cost and availability, mitigation of rising prices by diversifying supply, close monitoring of newsprint given Media Finland's dependence on certain suppliers, and investment in the transition to digital media (page 101).

Scope and boundaries: "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" (page 101).

Three explicit negatives are disclosed: "Sanoma does not use offsets or compensation in relation to its biodiversity impacts"; "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"; and "No nature-based solutions are incorporated into Sanoma's actions" (page 101). No monetary resources are quantified.

Targets related to biodiversity and ecosystems

Reference: page 101.

Sanoma discloses that it has set no biodiversity targets in the ESRS sense: "Sanoma has not set ESRS-aligned 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" (page 101).

Effectiveness is tracked instead through proxy metrics disclosed elsewhere: "Sanoma tracks the effectiveness of its biodiversity-related policy implementation through monitoring of paper-related GHG emissions, as disclosed under E1-4, and of paper usage and share of paper certification, as disclosed under E5-3 and E5-4. These can be allocated to the mitigation layers of avoidance and minimisation in the biodiversity mitigation hierarchy" (page 101). The relevant 2025 figures are 37,504 tonnes of paper purchased (2024: 43,430) and a 100% share of certified fibre in paper (2024: 98%) (page 103).

Methodological limits are stated: "As Sanoma's impacts occur through the upstream value chain, no ecological thresholds and allocation of impacts to the undertaking have been applied in the monitoring of the effectiveness of the policy implementation. Biodiversity offsets were not used in the target setting. External stakeholders were not involved in the target setting" (page 101).

Policies related to resource use and circular economy

Reference: page 102.

One instrument is disclosed: the Environmental Standard, applying to all own operations, implemented by Procurement and approved by the President and CEO (page 102).

"From a resource use perspective, it outlines Sanoma's commitment to using natural resources efficiently. It addresses the transitioning away from the use of virgin resources, sustainable sourcing by promoting the use of recycled materials and renewable sources and taking environmental aspects into consideration throughout the life-cycle of the product. The objectives are achieved through responsible procurement practices, efficient operations and product development. Sanoma commits to optimising the consumption of materials, such as paper, printing inks and printing plates, to recycling the materials used and to measuring and minimising waste generated in its printing houses, facilities and warehouses" (page 102).

On plastics: "According to the standard, Sanoma aims to minimise the use of plastics in its products. In products, where plastics are used, Sanoma aims to use recyclable plastics, which do not originate from virgin sources" (page 102). The standard also commits Sanoma to pollution prevention and to the safe handling, storage, recycling, reuse and disposal of hazardous chemicals and materials, and "specifies requirements for sustainable sourcing, such as the use of certified paper" in addition to the Supplier Code of Conduct (page 102).

Third-party standards referenced: UN Global Compact and Ten Principles, the Rio Declaration, the European Climate Pact, TCFD, SBTi, FSC and PEFC certifications, and ISO 14001 for own printing houses. The standard is publicly available on the company website (page 102). Sanoma's wider environmental commitments are cross-referenced to E1-2 (page 102).

Actions and resources related to resource use and circular economy

Reference: page 103.

"Sanoma's key actions to manage resource use-related impacts relate to the use of paper in Sanoma's products. The scope of these actions is Sanoma's upstream value chain and most of the actions are continuous" (page 103).

Resource inflows. Sanoma engages paper and print suppliers to ensure the use of certified paper and/or fibre, with those actions described under E4-3 "as paper or fibre certification is closely connected to the management of Sanoma's biodiversity impacts". Beyond certification, "Sanoma is committed to using natural resources efficiently and aims to optimise resource use, for example by minimising paper weights in its products. This is done by systematic monitoring and forecasting of paper consumption in products printed by printing suppliers to avoid unnecessary paper consumption" (page 103). In its own newspaper printing houses Sanoma "optimises the consumption of materials, such as paper, inks and printing plates, and recycles the materials used. The share of paper waste during the printing process is monitored closely and is linked to the short-term incentives for the printing house employees" (page 103).

Resource outflows and waste. Key actions "include continuously minimising the waste generated by monitoring waste generation, ensuring with waste treatment partners that waste is recycled or reused as well as training employees on waste treatment topics" (page 103). Certification underpins the management systems: the two printing houses are ISO 14001 certified; the Finnish headquarters and the Norway and Poland offices are BREEAM-certified; and facilities in the Netherlands (Iddink) and Italy (Sanoma Italy) hold ISO 14001 certification (page 103).

No monetary CapEx or OpEx is quantified for these actions, and no time horizons are given because the actions are described as continuous.

Targets related to resource use and circular economy

Reference: page 103.

Sanoma discloses that it has set no ESRS-aligned resource use targets and does not intend to: "Sanoma tracks the effectiveness of the policy implementation and measures taken related to resource use, paper or fibre certification and waste management as described below. Sanoma does not have ESRS-aligned measurable time-bound or outcome-oriented targets related to resource use, and does not have plans to implement such targets" (page 103).

Resource inflows. "To measure the effectiveness of its policies and action plans, Sanoma monitors and measures the share of certified paper or fibre used in its newspapers, magazines and books. Sanoma's aim is to use only wood fibre that is produced responsibly and originating from traceable, legal and verified FSC and/or PEFC sources. In 2025, the share of certified fibre in paper used in Sanoma's products was 100%" (page 103). Sanoma also monitors the amount of paper bought and used, "committed to using natural resources efficiently and thus minimises the use of primary raw materials" (page 103).

Resource outflows and waste. "With efficient waste management, Sanoma aims to minimise waste generated in its printing houses, facilities and warehouses" (page 103), tracked through the waste metrics reported under E5-5 (page 104).

The absence of targets means no base year, target year, milestone or quantified ambition is disclosed for resource inflows, outflows, waste or the transition away from virgin resources.

Resource inflows

Reference: page 103.

"Sanoma's resource inflows cover its printed products, such as newspapers, magazines and books. The key materials are the paper, printing inks, printing plates, wetting additives and washing solvents used in the production, which Sanoma reports for its own operations, i.e., for the two printing houses it owns in Finland. In addition, Sanoma purchases paper, which is delivered to upstream value chain printing partners, who then produce Sanoma's books and magazines" (page 103).

Paper bought and used, and certification (page 103):

Materials used in own operations, tonnes (page 103):

Share of certified paper used in own operations: 100% (2024: 100%). Percentage of biological materials sustainably sourced: 100%. "Total weight of recycled and reused materials used, tonnes: 0" and "Share of recycled and reused materials used: 0%" in both years (page 103).

"Paper is the only biological material used by Sanoma. No technical materials are used in Sanoma's own operations" (page 103). Certified fibre data comes from suppliers, with 3% estimated using a weighted average; the share of certified paper is calculated against total paper weight used in the period (page 103).

Resource outflows

Reference: page 104.

Sanoma's E5-5 disclosure is confined to waste; no products-and-materials outflow disclosure on durability, reparability, recyclability or recycled content is provided.

"Sanoma's printing houses, facilities and warehouses generated 5,211 tonnes of waste in 2025. Recycled and reused waste accounts for 70% (2024: 72%) of Sanoma's waste" (page 104).

Waste streams are described concretely: "paper waste generated from the production of newspapers, metal waste from printing plates (used in the printing process and reused by partners after use), inks and solvents as residuals from the printing process as well as general office and warehouse waste" (page 104). In leased facilities and warehouses "mainly general office and packaging waste is generated" (page 104).

Assessment of risk and methodology. "Sanoma evaluates waste impacts by reporting waste generated in its facilities, warehouses and two owned printing houses in Finland, with no material identified risks or opportunities related to waste. Sanoma uses a combination of direct measurement and estimation methods (48% of data based on estimates) to calculate waste data. This includes weighing waste in printing houses, using data provided by waste management suppliers and estimating waste quantities based on floor space and the number of employees using the facility. Waste data estimations include estimating the amount of waste by using Statistics Finland data and estimations on waste treatment type as based on Eurostat Waste Statistics" (page 104).

"No radioactive waste is generated in Sanoma's printing houses, facilities or warehouses" (page 104). Environmental management is certified to ISO 14001 in the printing houses, with BREEAM certification at the Finnish headquarters and the Norway and Poland offices (page 104). The detailed waste-by-type table is reproduced under the Waste entry.

Waste

Reference: page 104 (E5-5 37 a-d table).

Waste by type and disposal method, tonnes (page 104):

Total waste fell 21% year on year, largely through lower non-hazardous volumes, while hazardous waste directed to disposal rose from 83 to 196 tonnes, driven by "other disposal operations" (39 to 165 tonnes). "Recycled and reused waste accounts for 70% (2024: 72%)" (page 104), and 48% of the waste data is estimated (page 104). Related Scope 3 category 5 emissions were 259 tCO2-eq (2024: 317) (page 96).

Policies related to own workforce

Reference: pages 105-107.

Five instruments are disclosed (pages 106-107):

• Code of Conduct - Board-approved, all employees in all operating countries. It "emphasises Sanoma's commitment to fostering a people-centric and inclusive culture ensuring equal opportunities for all employees, irrespective of personal circumstances, and the zero tolerance for discrimination, harassment, or bullying".
• Sustainability and Human Rights Policy - Board-approved, implemented by Group Sustainability, covering "all S1-related IROs... except for training and skills development".
• People Policy - Board-approved, implemented by HR. It "covers people priorities, human rights, diversity and inclusion, occupational health and safety and wellbeing, rewards and recognition, recruitment and career opportunities, professional development, performance management, employee engagement as well as disciplinary practices".
• Diversity and Inclusion Policy - approved by the President and CEO, setting "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".
• Anti-Harassment Standard - approved by the President and CEO, covering employees, Board members, freelancers, consultants and suppliers; internally available only.

Human rights commitments (page 107). Sanoma is a UN Global Compact signatory and adheres to the UN Guiding Principles; the Sustainability and Human Rights Policy is aligned with the UDHR, the ILO Declaration on Fundamental Principles and Rights at Work and the OECD Guidelines. "Human trafficking, forced labour, compulsory labour and child labour are addressed in these commitments" (page 107).

Discrimination. "Sanoma does not tolerate discrimination based on any attributes", with diversity defined across gender identity, sex, age, national extraction, race, ethnicity, colour, physical and mental abilities or disabilities, religion, political opinions, sexual orientation and social origin (page 107). Implementation is monitored through the annual Employee Engagement Survey and the Diversity and Inclusion Survey "that was last carried out in 2024" (page 107).

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

Reference: pages 107-108.

Engagement runs through regular internal communications and quarterly updates plus SBU-specific channels. Learning holds an annual Share Views Week and, from 2025, extended monthly SL Connects online events to all Learning employees; Media Finland runs an annual strategy session, quarterly all-employee updates with interaction, "Three questions" interviews with the Media Finland CEO, a monthly manager communications package and weekly newsletters (page 107).

"Regular Employee Engagement Surveys (EES) are key tools to identify and assess potential and actual impacts, risks and opportunities as well as to evaluate the effectiveness of engagement related to Sanoma's own workforce. The survey results are analysed on unit and SBU levels" (page 107), supplemented by topic-specific pulse surveys.

Workers' representatives. "Both SBUs conduct regular, quarterly meetings with the personnel representatives. Personnel representatives are informed in advance of any relevant change initiatives and negotiated with, if needed. In addition, there are established forums to ensure personnel representation: Media Finland's employee advisory board, European Working Council for the whole of Sanoma and administrative representation in unit management teams" (page 108).

"The most senior role that has operational responsibility for the engagement with Sanoma's own workforce is the Chief Human Resources Officer" (page 108).

Vulnerable or marginalised groups. "Sanoma carried out a Group-wide DE&I survey in 2024 to better understand minority groups' perspectives, and those results were used to plan actions in 2025" (page 108). Sanoma has encouraged personnel to establish minority personnel representative groups, and Learning's DE&I work continued around five pillars: Culture & Heritage, Disability & Neurodiversity, Gender, Generations and LGBTQ+. Exit interviews are also used to identify barriers faced by marginalised employees (page 108).

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

Reference: page 108.

"Aligned with Sanoma's Sustainability and Human Rights Policy, the right to effective remedy is a fundamental element of the international human rights system. Sanoma has a remediation process to address adverse human rights impacts its operations cause or contribute to" (page 108).

Channels: managers, Human Resources, and a third-party hosted anonymous Whistleblowing channel available in several languages on internal channels and the website, with annual internal communication campaigns about raising concerns (page 108). "Cases reported through the reporting channels are processed in a manner that ensures impartiality. According to its Code of Conduct (CoC), Sanoma does not tolerate retaliation against individuals who make reports in good faith, or against any third persons, facilitators or legal entities connected to the reporting individual" (page 108). "Internal Audit investigates misconduct cases separately from the chain of management involved, and it informs the Audit Committee about all identified and investigated misconduct cases" (page 108).

Two limitations are disclosed candidly. First: "In addition to having processes and channels in place to remediate negative impacts, Sanoma has not separately assessed the effectiveness of the provided remedy of a potential case" (page 108). Second: "Trust on the available channels is difficult to measure, since an increase in the number of reports may indicate growing trust, though it could also reflect an increase in identified issues" (page 108).

Awareness is built through the annual mandatory Code of Conduct e-learning, whose completion rates are reported in G1-1, and an annual speak-up campaign; Sanoma "tracks the number of reports submitted and investigated through different channels" (page 108). In 2025 subsidiary-specific channels were established in Spain, the Netherlands and Poland where local legislation requires them (page 109).

Taking action on material impacts on own workforce

Reference: pages 108-110.

Actions are identified from the annual EES and other surveys, with dedicated focus groups where needed; "The scope of the actions is Sanoma's own workforce in its own operations. Most of the development is continuous or reactive" (page 108).

Work-life balance. Flexible working arrangements including flexible hours, hybrid work and leave policies; "For the 2025 EES survey, specific questions were added regarding wellbeing and work-life balance"; regular 1:1 discussions used to balance workload (page 108).

Health and safety. Media Finland targets communication about low-threshold mental health care, trains managers on health and safety services, and in 2025 "carried out a wellbeing survey to all team leads, and initiated a strategic wellbeing development plan that aims to focus on mental wellbeing in 2026" (pages 108-109). "In 2025, Learning launched Nadia, a personal AI-powered Coach available for all employees... available on all devices 24/h and it supports over 100 languages" (page 109).

Anti-harassment. The Anti-Harassment Standard governs case handling, with HR responsible for investigation; in 2025 separate subsidiary-specific channels were established in Spain, the Netherlands and Poland (page 109).

Privacy and security of employee data. Group-level processes, Code of Conduct training, Privacy and Security Champions in HR teams, and a process to review and fix reported data breaches; employee data is handled through the same Privacy, Security and AI by Design process as customer data (page 109).

"Sanoma did not take actions to provide or enable remedy in relation to actual material impacts as there were no actual cases" (page 109).

Positive-impact actions. DE&I work across five Learning pillars with ambassadors and senior sponsors, gamified DE&I training, DE&I calendar communications, applicant-centred recruitment training in Media Finland, and job architecture work in both SBUs "to advance equal pay through greater transparency" ahead of the pay transparency directive (page 109). Training includes a Leadership Competencies cascade for about 80 leaders, a piloted talent programme for 15 employees, a Media Finland leadership programme for about 50 leaders and a new Future Skills programme (pages 109-110).

"No specific actions targeted to adequate wages, employment security, social dialogue, freedom of association and collective bargaining were conducted in 2025" (page 110).

Targets related to own workforce

Reference: page 110.

"Sanoma has not set any ESRS-aligned measurable time-bound outcome-oriented targets related to its own workforce, and does not have plans to implement such targets. Sanoma assesses the effectiveness of its own workforce-related policies and actions through targets related to the Employee Engagement Survey (EES) and by monitoring the gender distributions at managerial levels. These targets originate from the Sustainability Strategy" (page 110).

Targets disclosed (page 110): an Employee Engagement Score between 70% and 75% in 2025; an Equal Opportunities Score above 77%; an employee Net Promoter Score above 10; a 50/50 gender balance in managerial positions by 2030; and at least 40% representation of the under-represented gender on the Board of Directors.

Performance against them (page 110):

The engagement score is "below the target level of 70-75% but close to the European benchmark level of 65%" (page 110). Sanoma notes the measurement changed in 2025: "The previous Employee Experience Index was replaced by Employee Engagement Score that is based on five science-based and market-comparable questions", establishing a new baseline and breaking year-on-year comparability (pages 57, 110).

"Stakeholders were involved when the targets were set in 2021, when launching the Sustainability Strategy, by participating in surveys and workshops" (page 110).

Characteristics of the undertaking's employees

Reference: pages 111-113.

Headcount at the end of the reporting period; "All employees are included in the total number of employees" (page 111). Sanoma notes it reports full-time equivalents rather than headcount in its Financial Statements (page 111).

Gender distribution and contract type, headcount 2025 (pages 112-113):

Total headcount fell from 5,267 in 2024 to 5,065 in 2025.

By country, headcount 2025 (page 112): Finland 2,708; Poland 659; Netherlands 616; Spain 550; Belgium 175; Italy 168; Sweden 100; Norway 61; Germany 14; United Kingdom 9; Denmark 5. Countries representing at least 10% of employees are Finland, Spain, Poland and the Netherlands (page 112). All 368 non-guaranteed hours employees are in Finland (page 112).

Turnover (page 113):

"The number of employees who left the Company includes the impact of certain restructuring actions and minor divestments in Finland and Spain, in particular" (page 113). Turnover is calculated by dividing leavers, whether voluntary or by dismissal, retirement or death in service, by total employees at the end of the period (page 113).

Collective bargaining coverage and social dialogue

Reference: page 113.

Collective bargaining coverage (page 113):

Coverage and social dialogue by band, EEA countries with more than 50 employees representing more than 10% of total employees (page 113):

The same pattern is reported for 2024 (page 113).

"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" (page 113). "Sanoma has more than one collective bargaining agreement in place in the EEA... Sanoma has an agreement with its employees for representation by the European Works Council (EWC)" (page 113). No non-EEA coverage estimate is required, as Sanoma has no non-EEA region with more than 50 employees in the table.

Restatement. "The share of employees covered by workers representatives in 2024 have been restated. The restatement concerned the figures for Finland, Spain and the Netherlands, for which the information was reflecting the number of workers representatives instead of the number of employees covered by workers representatives... The restatement resulted in the number of employees covered by workers representatives to increase from 0-19% to 60-79% in Finland and the Netherlands and from 0-19% to 80-100% in Spain" (page 113).

Diversity metrics

Reference: pages 113-114.

Gender distribution of top management (page 113):

In 2024 top management was 11 female (50%) and 11 male (50%) (page 113). "The Executive Management Team includes the members of Sanoma Group's EMT. Management teams include the SBUs' management teams, excluding the EMT members" (page 113).

Age distribution of employees (page 114):

Entity-specific metric, gender distribution of management (page 114):

In 2024 the equivalents were 73 female (48%) / 79 male (52%) and 314 (50%) / 309 (50%). "Directors and Senior managers include subordinates to the EMT and management team members. Managers with subordinates include all managers that are not part of the Directors and Senior managers or top management definitions" (page 114). Progress against the 50/50 by 2030 managerial gender balance target is discussed under S1-5 (page 110).

Adequate wages

Reference: page 114.

The full disclosure reads: "All Sanoma employees are paid an adequate wage applicable to benchmarks. The assessment of adequate wages is based on national legislation, collective labour agreements and their wage tables, official and statistical sources, as well as internal Company calculations" (page 114).

This is a nil-exception return: because all employees are paid at or above the applicable benchmark, ESRS S1-10 requires no country-by-country breakdown of employees paid below an adequate wage. Sanoma operates in eleven countries, all within the EEA or the United Kingdom (page 112), so the applicable reference points are national minimum wages and collective agreement wage tables rather than a living-wage benchmark for non-EEA operations.

The disclosure is corroborated by the underlying materiality assessment, which records adequate wages as an actual positive impact: "Sanoma's employees are paid adequate wages in all countries where it has operations providing financial security and improved quality of life for employees" (page 72). Consistently, S1-4 states that "No specific actions targeted to adequate wages, employment security, social dialogue, freedom of association and collective bargaining were conducted in 2025. The commitments to these impacts are stated in the policies and no further need for action was identified in 2025" (page 110).

The company does not name the specific benchmark used per country, nor disclose the lowest wage paid against it.

Social protection

Reference: page 114.

The full disclosure reads: "All Sanoma employees are covered by social protection" (page 114).

This is a complete nil-exception answer under ESRS S1-11: where all employees are covered against sickness, unemployment from the point of job loss, employment injury and acquired disability, parental leave and retirement, the standard requires no breakdown of the countries or employee groups that are not covered.

The claim is consistent with the geographic footprint disclosed under S1-6 - Finland, the Netherlands, Belgium, Poland, Sweden, Spain, Norway, Germany, Denmark, the United Kingdom and Italy (page 112) - all of which operate statutory social security schemes. Family-related leave entitlement is reported separately at 100% of employees under S1-15 (page 115), and health and safety management system coverage at 100% under S1-14 (page 115).

The disclosure gives no breakdown by the five ESRS social protection events, no country-level confirmation and no reference to the source of the coverage assessment. It also does not distinguish statutory from company-provided protection.

Training and skills development metrics

Reference: page 114.

Performance and development reviews, percentage completed (page 114):

"In Learning, performance reviews are conducted through a three-part process; for reporting purposes, the completion rate of the goal-setting phase has been used" (page 114). "The percentage of completed performance reviews for Media Finland is subject to some uncertainty, as the Workday platform was implemented in the SBU after the performance review process had been completed. This required supervisors to manually input data on completed reviews retrospectively" (page 114).

Average number of training hours by gender (page 114):

The figure is very low, and the report explains why: "Training hours only include formal online trainings that are completed in the Workday platform. Employee-initiated training hours are excluded. Sanoma's approach to trainings is based on the 70-20-10 model, where 70% of learning happens on the job by doing, 20% happens in the social context from others, coaching and feedback and 10% through the formal training methods such as online trainings and lectures" (page 114). "The duration of the trainings is determined by the default completion time of the training not the actual completion time for each individual", and non-guaranteed hours employees in Learning are excluded because they do not use Workday (page 114). No prior-year comparative is given for either metric.

Health and safety metrics

Reference: page 115.

Coverage: "All Sanoma employees are covered by local health and safety management systems", 100% of the workforce in both 2025 and 2024 (page 115).

Work-related fatalities (page 115):

Work-related accidents (page 115):

"Approximately one third of the reported occupational accidents were attributable to operations in printing facilities. The majority of all work-related accidents were attributable to slips and falls" (page 115). The rate is calculated as total accidents divided by total working hours times 1,000,000; where actual hours were unavailable they were estimated from contractual weekly hours and working weeks times FTE, and "The share of estimates represented 31% of the working hours" (page 115).

Restatement. "In 2025, the assessment criteria for work-related accidents were refined. As a result, the 2024 comparative data was reassessed based on the updated criteria... the number of work-related accidents increased by four cases, which also raised the rate of recordable work-related accidents from 3.1 to 3.6" (page 115).

Phase-in. Sanoma applies the ESRS 1 phase-in to the S1-14 datapoints "on cases of work-related ill health and on number of days lost to injuries, accidents, fatalities and work-related ill health as well as health and safety data related to non-employees" (page 57), so those figures are not given.

Work-life balance metrics

Reference: page 115.

Family-related leave (page 115):

All employees are entitled to family-related leave in both years, so no exception breakdown is required. Take-up fell from 8% to 6% overall, with the female rate down from 9% to 7% and the male rate from 6% to 5%.

Methodology and limitation. "All Sanoma employees are entitled to take family-related leave. 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. Family-related leaves include maternity, paternity and parental leaves as well as child care leaves" (page 115).

The manual, non-standardised collection across eleven operating countries is a stated data quality caveat on this metric. Related actions on work-life balance, including flexible hours, hybrid work and the addition of wellbeing and work-life balance questions to the 2025 Employee Engagement Survey, are reported under S1-4 (page 108).

Compensation metrics (pay gap and total compensation)

Reference: page 115.

Gender pay gap and remuneration ratio (page 115):

Definitions and methodology. "The remuneration metrics includes all employees. Calculations are based on actual data with the exception of non-guaranteed hours employees in Learning, for which the hourly rate has been estimated based on average rate" (page 115). "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" (page 115). "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)" (page 115).

The gender pay gap definition follows the ESRS S1-16 formula of the difference between average gross hourly pay levels of male and female employees expressed as a percentage of the male average. The gap narrowed by one percentage point year on year and the pay ratio fell from 25 to 22.

Sanoma reports contextual work rather than a target: both SBUs continued job architecture work in 2025, which "establishes a consistent framework that objectively defines roles, levels and jobs, enabling fair comparisons among roles across the organisation. The framework also provides the structured data needed for gender pay-gap reporting" ahead of the EU pay transparency directive (page 109). No pay gap target is set (page 110).

Incidents, complaints and severe human rights impacts

Reference: page 116.

Incidents of discrimination (page 116):

"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 Compliance function in Legal. Three 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" (page 116).

Severe human rights impacts. "No severe human rights issues or incidents connected to Sanoma's own workforce occurred during the reporting period" (page 116). Accordingly no fines, penalties or compensation for severe human rights incidents are reported, and no cases of forced labour, child labour, human trafficking or non-respect of the UN Guiding Principles or OECD Guidelines involving own workforce are recorded.

The disclosure of three substantiated cases out of eight reported incidents, and the acknowledgement that some cases could not be investigated for lack of information, is more specific than the bare counts the requirement demands.

Policies related to value chain workers

Reference: pages 118-119.

Three instruments are disclosed (page 118):

• Sustainability and Human Rights Policy - Board-approved, implemented by Group Sustainability. Sanoma is unusually direct about its limits: "From a workers in the value chain perspective, it does not directly cover Sanoma's actual and potential impacts on workers in the value chain, but it defines Sanoma's sustainability due diligence process in general".
• Supplier Code of Conduct - the key instrument, approved by the President and CEO, covering "All upstream and downstream suppliers and workers in the value chain". It "includes provisions addressing working time, work-life balance, occupational health and safety, freedom of association, collective bargaining, employment security, adequate wages and social dialogue. It also requires the suppliers to eliminate any harassment or discrimination related to gender, to ensure equal pay and to offer training and skills development opportunities to their workers".
• Procurement Policy - approved by the President and CEO, defining supplier selection and purchasing processes, validated through "a defined set of Procurement Control Points and internal audits".

Human rights commitments (page 119). "The SCoC requires suppliers to respect the ILO standards in relation to human trafficking and forced, compulsory and child labour." Suppliers must "implement a systematic process to identify, monitor and control health and safety, labour and other impacts", offer grievance mechanisms, protect individuals from retaliation and implement remediation. "Sanoma or a third party is also permitted to audit the suppliers' compliance with the SCoC" (page 119).

Incidents. "By the end of 2025, Sanoma had not become aware of any severe cases of human rights incidents related to the UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work or OECD Guidelines for Multinational Enterprises that involve value chain workers" (page 119).

Processes for engaging with value chain workers about impacts

Reference: page 119.

Sanoma discloses a gap rather than a process: "Sanoma has not adopted a general process to engage with workers in the value chain" (page 119).

What exists instead is indirect. "Sanoma seeks to identify and prevent human rights impacts in its supply chain through the Know Your Counterparty (KYC) process and by collecting certifications and audit reports from external information sources as described under S2-4. In addition, Sanoma uses information from credible proxies to assess and identify potential impacts related to its procurement categories" (page 119).

The boundary is stated plainly: "Sanoma does not directly engage with value chain workers or their legitimate representatives outside visits to the suppliers' premises and collection of third-party audit reports" (page 119).

Accountability. "The Procurement team is responsible for ensuring that engagement happens and the results inform Sanoma's approach, with the most senior role being the Head of Procurement in the SBUs" (page 119).

At group level, the stakeholder table under SBM-2 lists supply chain partners and workers in the value chain as a stakeholder category, engaged through Supplier Day events for paper and print suppliers, annual collection of climate and materials data in specific procurement categories, internal audits on supplier sustainability and support for corrective actions (page 68). Sanoma states it has "not identified particularly vulnerable groups of workers in the value chain, who would have a higher risk for negative impacts due to their inherent characteristics" (page 117), so no separate engagement route for vulnerable groups is described.

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

Reference: page 119.

"As a part of its procurement process, Sanoma continuously assesses potential and actual adverse human rights impacts and defines preventive and mitigation actions, where relevant. Sanoma is committed to remediation if its activities have caused or contributed to adverse human rights impacts. The approach to remediation is case-specific, taking into account the context and details of the impact" (page 119).

Channels. "Sanoma's third-party hosted anonymous Whistleblowing channel enables employees, customers, business partners and suppliers' workforce to report suspicions of misconduct related to sustainability or human rights issues, confidentially and anonymously. Sanoma does not tolerate retaliation against anyone who raises a concern or participates in an investigation" (page 119). Material issues are reported to the Audit Committee, the EMT and the Sustainability and Ethics Working Group, and the channel is available in several languages relevant to Sanoma's operations and value chain (page 119).

Supplier-level requirements. "All new suppliers go through Sanoma's supplier screening and due diligence process, which aims to incorporate the SCoC as a mandatory step for successful selection. Following the SCoC, Sanoma's suppliers are required to ensure that a grievance mechanism is available for workers to raise complaints." Where deficiencies are not rectified in a reasonable period or are material or irreparable, "the contract or order can be terminated" (page 119).

Stated limitation. "The effectiveness of corrective actions and remedy is currently evaluated case-by-case by analysing whether corrective actions rectify the impact. Sanoma lacks a systematic monitoring process to assess the effectiveness of the grievance channels and is unable to evaluate whether value chain workers are aware of and trust the structures or processes to raise concerns" (page 119).

Taking action on material impacts on value chain workers

Reference: pages 119-120.

"Sanoma prevents and mitigates actual and potential negative material impacts on value chain workers through its purchasing practices on a continuous basis. Sanoma's 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 the impacts on workers in the value chain are potential, Sanoma focuses on preventing the impacts of actually occurring" (pages 119-120).

Supplier selection. New supplier selection follows the strategic sourcing process, "which incorporates the SCoC or equivalent as a mandatory requirement. Sanoma aims that all new suppliers confirm the SCoC. To evaluate the effectiveness of this measure, Sanoma follows the number of new key suppliers that have confirmed the SCoC" (page 120).

Assessment and engagement. The Know Your Counterparty tool screens suppliers for "human rights, anti-bribery, corruption, sanctions and performs regulations and due diligence checks", with medium or high risk cases escalated to Procurement and Legal (page 120). "Sanoma annually performs a supplier assessment on all of its print suppliers, collecting SEDEX, BSCI or SMETA third-party audit reports from its suppliers in addition to environmental data. In relation to capacity-building and engagement with entities in the value chain, Sanoma organises Supplier Day events for its paper and print suppliers" (page 120).

Follow-up on identified non-compliance. "In relation to the identified impacts on print suppliers' workers related to actual working time (exceeding working time agreements), adequate wages and health and safety, during 2025, Sanoma has engaged with the suppliers requesting them to deliver plans for preventive and corrective actions to enable effective remedy. The process of these action plans to ensure preventive and corrective measures is ongoing" (page 120). Improvements are evidenced: "book printing suppliers have recruited more employees and invested in automation equipment to reduce the overtime of their workers" (page 119).

"No severe human rights issues or incidents connected to Sanoma's upstream value chain occurred during the reporting period" (page 120).

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 120.

"Sanoma does not have ESRS-aligned measurable 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. Sanoma tracks the effectiveness of its policies and actions in relation to the material actual and potential impacts as described under S2-3 and S2-4" (page 120).

Effectiveness tracking in place of targets. "Sanoma aims that all suppliers agree on its SCoC or equivalent. All new suppliers go through Sanoma's supplier due diligence process, which aims to incorporate the Supplier Code as a mandatory step for successful selection. To evaluate the effectiveness of its measures, Sanoma internally follows the share of new suppliers that have agreed on the SCoC annually" (page 120). The Report of the Board of Directors states the 2025 result for that measure: "Share of new key suppliers that have signed the Supplier Code of Conduct or equivalent: 100%" (page 17).

New in 2025. "Sanoma advanced its supplier due diligence by introducing a two-step supplier segmentation and ESG screening process: first, procurement categories are screened for environmental and human rights impacts and risks, then suppliers in higher-risk categories are assessed at the supplier level. This model defines targeted management actions to minimise and prevent material impacts and risks. Ongoing development will continue in 2026 with a dedicated working group to further refine and implement these processes" (page 120).

No base year, target year, milestone or quantified ambition is disclosed for value chain workers, and value chain workers were not involved in setting the measures.

Policies related to consumers and end-users

Reference: pages 122-125.

Sanoma discloses general policies plus topic-specific instruments across four themes.

General (page 122). The Code of Conduct, which "outlines that Sanoma prioritises customer trust by delivering products and solutions that inform, inspire, educate, and entertain, while ensuring transparent advertising, fair data privacy practices, and ethical use of AI", and the Sustainability and Human Rights Policy. Both are Board-approved and publicly available.

Privacy (pages 122-123). The Privacy and Data Protection Policy, owned by the Director, Privacy and Compliance and approved by the President and CEO, describing ten principles including that "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"; the Principles of Ethical Use of AI, covering "Fairness with an aim for positive impact, Accountability by humans, Explainability, Transparency, Risk and impact assessment and Oversight"; the Information Security Policy owned by the CISO and referencing ISO/IEC 27001, 27701, 27002 and 27018; and the Supplier Code of Conduct for suppliers processing personal data.

Inclusive learning (page 124). Learning's Editorial guidelines, approved by the President and CEO, with four principles: "We create high-quality learning materials", "We support diversity and inclusiveness", "We ensure equal access" and "We are committed the United Nations Sustainable Development Goals".

Accessibility (page 124). Accessibility guidelines launched in 2025 for the Learning SBU, requiring compliance with "WCAG 2.1 Level AA standards" and alignment with the European Accessibility Act. Sanoma discloses a gap: "Media Finland does not have SBU-level policies to manage the impact related to digital accessibility", relying instead on compliance with the European Accessibility Act and Finland's Act on the Provision of Digital Services (page 124).

Media ethics and marketing (page 125). Media-specific journalists' instructions complementing the Council of Mass Media's Journalist's Guidelines, and commitments to the ICC Advertising and Marketing Communications Code, IAB Europe self-regulation and KAVI age-limit guidance.

Processes for engaging with consumers and end-users about impacts

Reference: page 126.

Privacy. A limitation is stated openly: "Sanoma does not engage with customers and end-users to gain their perspectives on privacy-related matters so that they would be considered in Sanoma's decision-making in a manner that is aligned with the ESRS reporting requirements" (page 126). What exists instead: Privacy Policy Statements on websites and digital products with instructions for exercising data subject rights and contact details for the Data Protection Officers, case-by-case handling of inquiries, and notification of affected individuals at high risk following a personal data breach as required by GDPR. Effectiveness is assessed "through tracking that all data subjects are responded to and within the time required by the law" (page 126).

Inclusive learning. "On a continuing basis, Sanoma engages directly with teachers when co-creating and developing the learning materials. To follow up on Sanoma's impact... Sanoma annually conducts a European Teacher Survey (ETS)" (page 126). "Sanoma does not directly engage with students, as their perspective is gained through engaging with teachers" (page 126).

Accessibility. Local meetings and peer review groups with teachers, discussions with third-party disability experts in some countries, accessibility questions in the ETS, and publicly available accessibility statements for Ruutu.fi, the Ruutu mobile applications, Supla, Oma.Sanoma.fi and Tilaa.Sanoma, with feedback handled by dedicated accessibility coordination teams (page 126).

Freedom of expression. Direct feedback to editorial teams, correction obligations under the Journalist's Guidelines, and the ability to complain to the Council for Mass Media, whose condemnatory decisions Sanoma commits to publishing (page 126).

Responsible marketing. "Sanoma does not directly engage with consumers regarding advertising" and "does not assess the effectiveness of its engagement with consumers and end-users related to responsible marketing practices" (page 126).

Vulnerable groups, such as children, are addressed through data protection authority guidance and third-party guidelines rather than direct engagement (page 126).

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

Reference: page 127.

"Sanoma implements a remediation process to prevent and address material impacts related to consumers and end-users. Sanoma has identified both actual and potential negative impacts related to privacy, access to products and services as well as responsible marketing practices" (page 127).

General channel. "Sanoma's third-party hosted Whistleblowing channel enables anyone, including customers and end-users, to report suspicions of misconduct related to sustainability or human rights issues confidentially and anonymously." Cases are investigated, learnings fed back into internal and external processes, and material issues reported to the Audit Committee and the Sustainability and Ethics Working Group (page 127).

Stated limitation. "The effectiveness of this grievance channel is assessed by monitoring the number of cases reported as well as tracking the cases investigated and solved annually... Sanoma is unable to evaluate whether customers and end-users are aware of and trust the structures or processes to raise their concerns" (page 127).

Privacy-specific processes. "According to Sanoma's personal data breach management process, each personal data breach case is evaluated separately, taking into account the potential impacts to data subjects. As required by GDPR, Sanoma informs affected individuals, who are likely to be at high risk, about the data breach, how their data has been affected and what measures they can take to protect their privacy" (page 127). Data subjects can contact the Data Protection Officers directly, or the local data protection authority (pages 126-127).

"To monitor the effectiveness of addressing personal data breaches, the number of actual and potential personal data breach cases is reviewed on a quarterly basis in both Media Finland and Learning. Sanoma reviews the main causes and reasons behind personal data breaches annually, and plans additional measures to prevent them... In 2025, Sanoma addressed all detected personal data breaches in accordance with its personal data breach management process" (page 127).

Taking action on material impacts on consumers and end-users

Reference: pages 127-129.

"In 2025, Sanoma did not take actions to provide or enable remedy, as no need for such actions was identified. During the reporting period, there were no severe human rights issues or incidents linked to Sanoma's customers or end-users" (page 127).

Privacy (page 127). The continuous Privacy, Security and AI by Design process requires privacy impact assessments, security reviews and AI risk assessments for new processing or new AI systems. 2025 actions: training for product managers and developers in both SBUs "with special focus on learning how to classify AI systems in accordance with the EU AI Act"; completion of "a Group-wide data mapping tool that is used to manage the records of processing activities"; and AI governance measures including an inventory of AI use cases and embedding of the Ethical AI Principles and EU AI Act requirements into the by-design process.

Outcomes are reported candidly: "There was one substantiated formal warning and advice from the Dutch authority to adjust the cookie banner in a Learning website in the Netherlands, which was rectified." A 2023 Traficom decision finding Media Finland's cookie practices non-compliant was appealed to the Supreme Administrative Court and "At the end of 2025, resolution to the case is pending" (page 128).

Inclusive learning (page 128). An update of the Editorial Guidelines was initiated in 2025 for release in 2026 through a new Inclusive Learning working group; the Learning-wide method creation process is regularly reviewed; and AI tools automate lesson planning, grading and administration, with "the final product is always human-made. Authors take full editorial responsibility for the final output".

Accessibility (page 128). Launch of the Learning Accessibility Guidelines; introduction of accessibility requirements for external content creators; an external audit "confirming a 96% compliance of the SL Design System against the WCAG Guideline AA-level requirements"; and Media Finland accessibility audits of Oma.Sanoma.fi, Tilaa.Sanoma, Ruutu.fi, the Ruutu applications and Supla.

Freedom of expression (page 129). Helsingin Sanomat, Aamulehti, Satakunnan Kansa and Ilta-Sanomat published principles on AI use in journalism, complying with the Council for Mass Media statement on labelling personalisation and news automation. Media literacy work included the Lukuboost campaign, with "more than 6,000 young people participated... with more than 50,000 reading sessions", and participation in News Week.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: pages 129-130.

"Sanoma has not set any ESRS-aligned measurable time-bound outcome-oriented targets related to consumers and end-users, and does not have plans to implement such targets. Sanoma tracks the effectiveness of consumers and end-users-related policies and actions through entity-specific metrics described below" (page 129).

Customer privacy, entity-specific (page 129):

"Most of the data breach cases occurred mainly in the media business' B2C sales domain, and typically were related to a single customer's data. A slight increase in data breaches was observed during the reporting period, primarily linked to changes in the media sales processes. The incidents mainly resulted from human error and were promptly addressed through targeted training within the sales organisation" (page 129).

Accessibility (page 130). The Learning target was that common components in core digital products be WCAG AA compliant from 2025 onwards; the 2025 external audit confirmed 96% compliance of the SL Design System. Launching the new Accessibility guidelines was a 2025 target and "was achieved". In Media Finland the 2025 target was an external review verifying accessibility against WCAG AA standards, "which was successfully completed". "A minor part of the pricing of Sanoma's EUR 300 million Syndicated Revolving Credit Facility is linked to developing inclusive learning solutions, more specifically the accessibility of digital learning content and platforms" (page 130).

Journalism and marketing, entity-specific (page 130):

Inclusive learning effectiveness is tracked through the annual European Teacher Survey, for which "Sanoma has not set any quantitative targets" (page 130). Consumers and end-users do not participate in setting or tracking targets (pages 129-130).

Business conduct policies and corporate culture

Reference: pages 131-133.

Eight instruments are disclosed (pages 131-132): the Code of Conduct (Board-approved, publicly available); the Anti-Bribery and Corruption Policy, which "Establishes Sanoma's zero tolerance to bribery and corruption of any kind, whether involving public officials or private sector entities" and covers facilitation payments, gifts and entertainment, travel and accommodation, barter agreements, donations, conflicts of interest, record keeping and money laundering; the Fair Competition Policy addressing "anti-competitive agreements, cartels, information exchange, and abuse of dominance"; the Donations and Sponsorships Policy; the Intellectual Property Rights Policy, which "advises on performing risk assessments in using third-party generative AI solutions to avoid leakage or infringements of Sanoma's IPR"; the Anti-Harassment Standard; the Supplier Code of Conduct; and the Procurement Policy. "No stakeholders were involved in setting the policies" (page 131).

Corporate culture (page 133). "Sanoma has a mandatory CoC training which is an annually updated CoC refresher e-learning for all employees. It includes dedicated questions on general ethics, anti-bribery and corruption rules, competition law, privacy, security, AI, and compliance with supplier relationship management." The training was available in English, Finnish, Dutch, Spanish, Italian, Polish and French in 2025.

Whistleblower protection (page 133). An externally hosted channel open to employees, customers and business partners. "Only Sanoma's Chief Legal Officer and Head of Internal Audit, or specifically dedicated Local compliance officers in countries where required, are able to access the reports under strict confidentiality obligations." A gap is disclosed: "No specific training is provided for those handling the reports internally." Subsidiary-specific channels were implemented in 2025 in countries such as Spain and Poland.

Entity-specific metric, completion of Code of Conduct trainings (page 133):

Management of relationships with suppliers

Reference: page 134.

"Sanoma is committed to responsible business practices and ethics throughout its supply chain. Sanoma's key standard related to relationships with suppliers is the Supplier Code of Conduct (SCoC)... The suppliers shall apply these standards and principles throughout the supply chain, including their affiliates and sub-contractors" (page 134).

Category-specific requirements are layered on top: suppliers using data on Sanoma's behalf must comply with data protection and information security requirements, and "The paper and print supplier agreements include Sanoma's Paper Procurement standard that sets environmental criteria related to the use of certified paper as well as recommendations to apply environmental and quality management systems" (page 134). "As the majority of Sanoma's supply chain emissions is generated in paper and print production, Sanoma focuses its emission reduction initiatives on these procurement categories. Thus, when selecting paper suppliers, emissions are taken into account in decision-making. In the print category, Sanoma is currently building an analysis of the suppliers' sustainability approach, which will be implemented in the supplier evaluation process" (page 134).

Screening. "Sanoma utilises a Know Your Counterparty (KYC) process to identify risks of doing business with third parties by looking at their ownership, activities and role. KYC background checks are performed on new suppliers as part of the supplier selection process. The KYC tool identifies possible third-party non-compliance and includes human rights, anti-bribery, corruption, and sanctions checks" (page 134).

Payment practices. "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 defined process for any exceptions in invoices to ensure fair practices" (page 134). Vulnerability of suppliers to late payment is addressed by the shorter term for natural persons; the G1-6 payment metrics themselves are not reported, payment practices having been assessed as non-material in the 2025 DMA (page 70).

Prevention and detection of corruption and bribery

Reference: page 134.

"Sanoma has established procedures to prevent, detect, and address allegations or incidents of corruption and bribery" (page 134).

Risk-based scoping. "procurement, as well as the sales teams in Poland and 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" (page 78, repeated page 133).

Training. "Sanoma's CoC trainings... cover the topics of anti-corruption and bribery as well as raising concerns. The trainings are mandatory for all Sanoma employees, including the Executive Management Team, and the completion rate is monitored" (page 134). A boundary is disclosed: "The Board of Directors or the Audit Committee are not in the scope of the trainings" (page 134). Coverage of the at-risk functions is quantified: "60% of the functions-at-risk, as described in G1-1, were specifically trained for anti-corruption and bribery in 2025 (2024: 0%). The training was rolled out to the employees in Spain and Italy in late 2025, and for Procurement and Poland the training is planned to be rolled out in 2026" (page 134).

Detection. Annual awareness campaigns on gifts and hospitality reporting, with a gift and hospitality tool available on internal channels; "The Supplier KYC process identifies flags related to suspected, investigated and confirmed instances of bribery and corruption among potential and actual suppliers. In Italy, criminal records for specific roles, such as agents used for promotional purposes, may be checked" (page 134).

Investigation independence. "All misconduct cases pertaining to incidents of corruption and bribery, regardless of the channel through which they are reported, are promptly and independently investigated by Internal Audit separately from the chain of management involved. Italy also has in place an independent local compliance committee called 'Controlling Board' for investigation purposes, which includes an external member... Internal Audit informs the Audit Committee about all identified and investigated misconduct cases" (page 134).

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed under the Minimum Disclosure Requirement MDR-T rather than as a numbered disclosure requirement. G1-3 became a standalone targets DR only in the 2025/2026 ESRS; this statement was prepared under the 2023 ESRS (page 56).

Sanoma sets no business conduct targets and says so explicitly. Under the heading "Minimum Disclosure Requirement MDR-T": "Sanoma has not set any ESRS-aligned measurable time-bound outcome-oriented targets related to business conduct, and does not have plans to implement such targets. However, it tracks the effectiveness of business conduct-related policies and actions through monitoring the completion rate of the Code of Conduct trainings" (page 133).

Consistent with MDR-T's alternative limb, effectiveness tracking is described in place of targets:

• The entity-specific Code of Conduct training metric: annual reminder e-learning completion 99% (2024: 97%) and new employee introduction e-learning completion 88% (2024: 78%) (page 133).
• Anti-corruption training coverage of the functions identified as most at risk: "60% of the functions-at-risk... were specifically trained for anti-corruption and bribery in 2025 (2024: 0%)" (page 134).
• Culture measurement: "Sanoma, for example, asks about employees' ability to speak up about ethics and compliance concerns in the annual Employee Engagement Survey. In addition, the CoC trainings' completion rate is monitored annually and the number of gifts and hospitality requests are reported to the Sustainability and Ethics Working Group. The number of investigated misconduct cases is reported to the Sustainability and Ethics Working Group and Board of Directors' Audit Committee. Trends in reported misconduct help assess the effectiveness of measures taken to raise awareness" (page 133).
• Governance cadence: the Ethics and Compliance Programme "is reviewed by the Audit Committee twice a year" (page 60).

No base year, target value or target year is disclosed for any business conduct measure.

Incidents of corruption or bribery

Reference: page 135.

Confirmed incidents of corruption or bribery (page 135):

"No actions were taken to address breaches in procedures and standards of anti-corruption and anti-bribery as no reported incidents occurred. Sanoma did not have any public legal cases regarding corruption or bribery during the reporting period" (page 135).

This is a complete nil return across all five G1-4 datapoints for both years. It should be read alongside the detection and investigation arrangements described under G1-3: independent investigation by Internal Audit separately from the management chain, an independent Controlling Board in Italy, reporting of all identified and investigated misconduct cases to the Audit Committee, and the KYC screening of suppliers for bribery and corruption flags (page 134). Discrimination and harassment incidents, which are reported through the same channels, are disclosed separately under S1-17 at 8 incidents in 2025 (page 116).

Political influence and lobbying activities

Reference: page 135.

Accountability and contributions. "Sanoma's President and CEO is responsible for the oversight of political influence and lobbying activities. Sanoma's Donations and Sponsorship Policy prohibits Sanoma from making any donations for political purposes. In 2025, Sanoma did not have any financial or in-kind political contributions (2024: EUR 0)" (page 135).

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" (page 135).

Revolving door. "One member of Sanoma's administrative, management and supervisory bodies has held a comparable position in public administration in the two years preceding such appointment in the reporting period" (page 135).

Main lobbying topics, each mapped to a material IRO (page 135):

• Improving learning outcomes, linked to the impact of access to high-quality and inclusive learning products: promoting the use of professionally produced education materials, increasing education investment per student, and strong copyright protection for using education materials in training AI.
• Supporting the media's operating conditions, linked to the freedom of expression impact: "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, linked to the IPR risk: strong copyright protection, fair terms for using audiovisual content, and direct licensing as the primary licensing form.
• Reforming the Finnish gambling legislation, linked to the responsible advertising impact: "Sanoma promotes responsible advertising related to the opening up of gambling advertising in Finnish media".