Solar

Solar operates a two-tier governance system in which the Board of Directors (tier one) and the Executive Board (tier two) together form the administrative, management and supervisory bodies (page 30). The Board of Directors comprises six members elected by the Annual General Meeting and three elected by employees; board members elected at the AGM stand for election each year while employee representatives serve four-year terms. The Executive Board consists of the CEO and CFO. Relevant board experience is described on page 35. Solar reports two executive members and nine non-executive members, with female members at 27.3% and a board gender diversity ratio of 0.38; independent board members represent 44.4% (page 33). Three board members are independent under ESRS, and 66.7% of members are elected by the AGM. The Board sets strategy and monitors and approves sustainability reporting under CSRD and ESRS, supported by Audit, Remuneration and Nomination Committees. The Board annually determines the expertise needed, including sustainability and green transition knowledge (page 31).

Solar reports how sustainability matters are provided to and addressed by its administrative, management and supervisory bodies (page 31). In 2023-24, Solar prepared for CSRD and ESRS requirements, with the double materiality assessment (DMA) and IRO as key elements of its due diligence process. The Head of Sustainability presented methodology, process, progress and performance for CSRD, ESRS, DMA, IRO and targets at Audit Committee meetings, the Board of Directors' conference and board meetings. The DMA and IRO are included on pages 44-46 and have been presented to and addressed by the Audit Committee and the Board of Directors. Sustainability matters and IRO are an integral part of Solar's Solve strategy, and impact, risk and opportunity assessment is a standard part of major investment and project decisions. From 2025, the annual cycle for the Board and Audit Committee will address material sustainability matters at every ordinary meeting, with the due diligence process evaluated annually. In 2024, eight board meetings and one board conference were held; the Audit Committee held five meetings. The Sustainability Steering Committee meets at least quarterly.

Solar reports on the integration of sustainability-related performance in incentive schemes (page 32). Members of the Executive Board are entitled to annual remuneration under the remuneration policy, which may include fixed remuneration, employee benefits, variable remuneration with non-share-based incentives, share-based incentives for the long term, and extraordinary incentives. The remuneration policy was amended at the 2024 Annual General Meeting to include ESG targets in variable remuneration and to introduce long-term targets for share-based incentives, replacing restricted shares with performance share units. Under the current policy the Board may allocate share-based incentives such as performance share units, where vesting depends on achievement of long-term targets, valued at 50% of annual fixed remuneration per member. In 2024 the Board granted performance share units in line with the policy, with vesting based partly on Solution Sales and EBITDA margin and 7-15% based on CO2 reduction within scope 1 and 2 targets (65% reduction by 2026 versus a 2020 baseline). There are no incentive schemes for members of the Board of Directors. The share of variable remuneration dependent on sustainability-related targets is reported as 7-15% (page 33). E1-related incentive detail also appears at page 32 and in the E1 section.

Solar provides a statement on sustainability due diligence (page 90). A table maps the core elements of due diligence to the sections of the sustainability statement where information can be found. The elements are: (a) embedding due diligence in governance, strategy and business model (Governance information, pages 84-85); (b) engaging with affected stakeholders in all key steps of the due diligence process (General information page 43; Social information pages 76-77 and 84-85); (c) identifying and assessing adverse impacts (Social information pages 76-78 and 81-82; Governance information pages 84-85); (d) taking actions to address those adverse impacts (Social information pages 77 and 82; Governance information pages 84-85); and (e) tracking the effectiveness of these efforts and communicating to stakeholders (Social information pages 77 and 82; Governance information pages 84-85). Solar states that the table outlines where in the sustainability statement readers can find information on how the company implements the main aspects and steps of its due diligence process.

Solar reports on risk management and internal controls over sustainability reporting (pages 32-33). Its risk management, sustainability processes, procedures and controls are organised according to a three lines of defence model that structures roles and responsibilities for managing IRO, decision-making and control. The first line comprises those responsible for implementing sustainability targets, policies, procedures and processes in their area. The second line is the Sustainability Steering Committee, established by the Executive Board and chaired by CFO Michael H. Jeppesen, comprising four members of senior management and the Head of Sustainability; it advises the Executive Board on sustainability ambitions, facilitates IRO identification, establishes policies and frameworks, and monitors progress toward targets, meeting at least quarterly. The third line is Solar's Internal Audit team, which tests, validates and assesses the efficiency of the sustainability processes. Solar has implemented internal control systems and conducts an annual risk assessment to identify potential material misstatements in financial and sustainability reporting, considering materiality, process complexity and likelihood of errors. Financial reports are audited by an independent firm, while sustainability data undergoes limited assurance by the same auditor. In 2025 Solar plans to evaluate processes in all material areas.

Solar reports its strategy, business model and value chain (Management review pages 11-15 and Sustainability statement page 47). Sustainability is embedded in the Group strategy and business model and is considered a strategic enabler. Solar has three strategic sustainability focus areas: climate impact, sustainable supply chain, and diversity, equity and inclusion, each with underlying actions and targets corresponding to its material impacts, risks and opportunities. These support its ambition to deliver climate and energy solutions such as heat pumps and solar panels and to advance the green transition. Stated priorities include net-zero in own operations by 2030, a 25% reduction in supply chain (scope 3) emissions by 2030, conversion to an EV fleet by 2030, transition to circular resource use, respecting human rights and labour across the value chain, 25% women in senior management by 2026, conducting supplier risk management due diligence of 82% of spend by 2026, and having 95% of spend covered by a signed Supplier Code of Conduct by 2026. Solar is a sourcing and services company serving the business-to-business market. Related detail is cross-referenced to the ESRS topical sections (page 42).

Solar reports on the interests and views of stakeholders (page 43). Engaging with affected stakeholders helps the company understand their expectations and respond accordingly, and insight gained from regular engagement supports general due diligence and serves as a source of information for the double materiality assessment. Guided by its Employee Code of Conduct and the UN Global Compact ten principles, Solar maintains open communication with external stakeholders. A table sets out how Solar engages with employees, customers, suppliers, investors, industry associations, civic and non-profit organisations, and local communities, together with the purpose and outcome examples for each. Engagement methods include surveys and workplace assessments, customer support and Solar School training, supplier dialogue and due diligence, investor calls and capital market days, and partnerships with NGOs. Solar states that the views and interests of affected stakeholders on sustainability are communicated to the Sustainability Steering Committee. In the S2 section (page 43 cross-reference), Solar notes that insights from understanding value chain workers' interests, views and rights are used as input into its strategy and business model.

Solar reports its material impacts, risks and opportunities and their interaction with strategy and business model (pages 44-48). The DMA identified impacts on the environment and society (impact materiality) and sustainability-related risks (financial materiality). Seven of the ten ESRS topical standards are material, with 22 sustainability sub-topics identified as material. E3 Water and Marine Resources, S3 Affected Communities, and S4 Consumers and end-users were omitted due to the nature of Solar's business as a local sourcing and services company serving the business-to-business market. The sub-topic E1 Energy is described as the most material topic, and one entity-specific topic was identified: E1 sales of renewable energy products and solutions enhancing the shift to renewable energy, which is financially material. IROs are classified as impact-material, financially material or double-material. Impacts are assessed for own operations and the value chain, with negative upstream impacts largely concentrated outside Europe in raw-material extraction and manufacturing (page 47). Actions addressing material IROs have not changed Solar's strategy and business model, and no impact is foreseen during the 2024-2026 strategy period (page 48). Material topics span E1, E2, E4, E5, S1, S2 and G1.

Solar describes its process to identify and assess material impacts, risks and opportunities (pages 53-54). The methodology was developed with reference to the draft ESRS principles and 2023 guidelines, refined in 2024. The ten ESRS topics were analysed; E3, S3 and S4 were omitted due to the nature of the business. Solar defined four core process steps for both impact and financial materiality: scoping, stakeholder engagement, materiality scoring and findings, and management review and conclusion. The impact assessment (inside-out) came first, followed by a financial assessment (outside-in). A Solar DMA core team of the Sustainability Director and three subject-matter experts was established. A stakeholder engagement analysis was conducted; in 2023, four stakeholder groups were identified and interviews were held with 18 external stakeholders and more than 25 employees, engaging B2B customers and tier one suppliers. Impacts were assessed as actual (primary data) or potential (secondary data), scored on scale, scope, irremediable character and likelihood. Financial risks were scored 0 to 5 using the Enterprise Risk Management methodology. The materiality threshold was set at 3 by Executive Management and the DMA core team; matters scoring 3 or above are deemed material. Going forward the Sustainability Steering Committee will hold decision-making responsibilities for materiality governance.

Solar reports the disclosure requirements in ESRS covered by its sustainability statement (pages 87-89). An index table lists the ESRS 2 general disclosure requirements and the seven topical standards material to Solar, together with the section and page where each is addressed, and identifies data points incorporated by reference to the management review or financial statement. Solar states that it has omitted the disclosure requirements in the topical standards E3, S3 and S4 due to the nature of its business. The seven material topical standards are E1 Climate change, E2 Pollution, E4 Biodiversity and ecosystems, E5 Resource use and circular economy, S1 Own workforce, S2 Workers in the value chain, and G1 Business conduct. The tables map disclosure requirements such as GOV-1 (pages 30-37), GOV-2 (page 31), GOV-3 (page 32), GOV-4 (page 90), GOV-5 (pages 32-33), BP-1 and BP-2 (page 41), SBM-1 (pages 11-15, 47), SBM-2 (page 43), SBM-3 (pages 44-48) and IRO-1 (pages 53-54). Where Solar does not yet have information for a specific disclosure requirement, no reference is made.

Solar A/S reports a transition plan for climate change mitigation (p. 61) based on a science-based approach aligned with the Paris Agreement 1.5 degrees C goal. It covers scope 1, 2 and 3 GHG emissions towards 2030 from a 2020 baseline. Solar reports a 50% reduction in scope 1 and 2 CO2e emissions versus 2020. Decarbonisation levers include transition to a 100% EV fleet, switching to renewable electricity (procured or self-generated), phasing out fossil fuels such as gas heating, and changing the product mix. Own operations account for less than 1% of emissions; over 99% derive from the value chain, mostly sourced products and use of sold products (category 11 alone is more than 90%). Planned reductions are 100% in scope 1 and 2 and 25% in scope 3. The plan is financed through the annual business and financial planning process, with the CFO chairing the Sustainability Steering Committee. It is approved by the Executive Board and Board of Directors (see Management Review p. 11-15). Operational and capital funding is detailed in the EU Taxonomy section (p. 56-60).

Solar A/S reports policies related to climate change mitigation and adaptation (p. 62). Its Sustainability Policy and Environmental Policy define and communicate how the company works with climate change mitigation and sustainability, including a commitment to reduce scope 1, 2 and 3 emissions by 2030 and an ambition of 100% renewable energy (electricity) and energy optimisation. Covering all emission scopes, the Sustainability Policy applies to emissions from own operations and the upstream and downstream value chain. The Sustainable Procurement Policy sets demands for suppliers, requesting them to disclose emissions, report to EcoVadis and sign the Supplier Code of Conduct, with decarbonisation and environmental protection central to supplier relationships. Both policies apply to all employees and suppliers, aim to minimise environmental impact, and are available on Solar's employee intranet and website. Accountability lies with the Executive Board; Group Sustainability has overall responsibility, ensures alignment with legislation, and reviews the policies annually.

Solar A/S reports actions and resources in relation to climate change policies (p. 62-63). In own operations, it is reducing scope 1 emissions by phasing out fossil fuels such as gas with renewable alternatives like heat pumps and transitioning to a 100% EV fleet by 2030. Scope 2 actions include switching to renewable electricity (purchased or generated, including a solar panel field at the Vejen head office in Denmark planned for 2025), upgrading to energy-efficient LED lighting, and installing sensors and building management systems. A new warehouse in Sweden built to BREEAM Excellent will replace two existing warehouses and is expected in use in 2026, benefiting scope 1 and 2. The Group Sustainability function was strengthened with three local Sustainability Managers and a Sustainable Procurement Manager. Supply chain actions include establishing Solar Industrial Solutions for turnkey climate and energy solutions, requiring suppliers to commit to renewable energy (meeting a 2024 target of 93% of spend covered by the Supplier Code of Conduct), risk assessment due diligence (80% of spend by end of 2024), and on-site third-party audits.

Solar A/S reports targets related to climate change mitigation (p. 63), all measured against a 2020 base year using SBTi methodology. For scope 1 and 2, its official SBTi commitment is a 42% reduction by 2030, with a mid-term target of 65% reduction by 2026, and its own more ambitious target of net-zero/0 emissions by 2030. Solar reports it has already superseded the 42% commitment. Market-based scope 1 and 2 emissions fell from a 4,326 tCO2e baseline (2020) to 1,815 tCO2e in 2024, a 42% reduction. Scope 1 and 2 emissions (per the E1-4 chart) declined from 7,140 tCO2e in 2020 to 3,560 tCO2e in 2024, targeting 2,499 tCO2e in 2026. For scope 3, the target is a 25% total reduction by 2030 in category 1 (purchased products and services) and category 11 (use of sold products); these categories total 3,205,348 tCO2e in the 2020 baseline versus 2,404,011 tCO2e targeted for 2030. Solar also targets 100% renewable energy (electricity) by 2026 (88% in 2024). Scope 3 was recalculated with a new methodology, not requiring SBTi resubmission.

Solar A/S reports energy consumption and mix for 2024 (p. 65). Total energy consumption was 29,250 MWh, split between total fossil energy consumption of 14,859 MWh (51% share) and total renewable energy consumption of 14,391 MWh (49% share). Fossil sources comprised natural gas of 2,898 MWh, other fossil sources of 10,279 MWh, and purchased electricity, heat, steam and cooling from fossil sources of 1,682 MWh; coal and crude oil/petroleum consumption were both 0 MWh. Consumption from nuclear sources was 0 MWh (0% share). Renewable energy comprised consumption of purchased or acquired electricity, heat, steam and cooling from renewable sources of 12,858 MWh and self-generated non-fuel renewable energy of 1,533 MWh; fuel consumption from renewable sources including biomass was 0 MWh. Procured renewable electricity is documented through guarantees of origin (GO). The share of renewable energy (electricity) reached 88% in 2024, and 100% for sites owned by Solar.

Solar A/S reports gross scopes 1, 2, 3 and total GHG emissions for 2024 (p. 66-68). Total gross scope 1 emissions were 1,745 tCO2e (2023: 2,150; 2020 base year: 2,814), comprising fleet 1,189, natural gas 530, and fuel oil 26 tCO2e. Scope 2 market-based emissions were 1,815 tCO2e and location-based were 3,722 tCO2e (2020 base year: 4,326). Total scope 1 and 2 emissions were 3,560 tCO2e. Total gross scope 3 emissions were 3,499,615 tCO2e (2023: 3,309,423; 2020 base: 3,275,651), up 6%, dominated by C11 use of sold products at 3,116,332 tCO2e and C1 purchased products and services at 312,588 tCO2e. Other scope 3 categories include C9 downstream transportation 60,730, C7 employee commuting 3,659, C12 end-of-life 4,097, C6 business travel 1,415, and C3 fuel and energy-related activities 794 tCO2e. Total GHG emissions scope 1, 2 and 3 market-based were 3,503,175 tCO2e and location-based were 3,505,082 tCO2e. Market-based GHG intensity was 286.605 tCO2e per DKKm net revenue (net revenue DKK 12,223m). Scope 3 primary data share was 0.14%.

Solar's Environmental Policy communicates the company's environmental performance and states that Solar undertakes all work related to the handling of pollution and is committed to complying with applicable laws and regulations. The policy states that Solar wants to improve its processes to prevent pollution, but it does not contain information on mitigating actions regarding water and soil in the event an incident occurs to limit the negative impact on people and the environment. It does not address substituting and minimising the use of substances of concern or phasing out substances of very high concern. The policy applies to all employees and is available on Solar's intranet and website. No environmental issues or incidents were reported in 2024 or previous years. For own operations, a future action plan will be grounded in Solar's Environmental Management System. Accountability for implementing the policy lies with the Executive Board and ultimately the CEO. For the upstream value chain, pollution is addressed in the Supplier Code of Conduct and the Sustainable Procurement Policy. (page 69)

Solar states that pollution can take place through indirect or direct water contamination and leakage, soil pollution in surrounding areas, operations in the upstream value chain, and in its own operation. Solar strives to enhance its environmental performance by implementing effective pollution mitigation and adaptation strategies to support creating a positive impact where possible. The actions apply to all operations within Solar and its upstream value chain. Due to a history of not having identified any incidents, water and soil pollution is considered low risk. In own operations, pollution-related matters come under the Environmental Management System, which is frequently audited by third-party consultants. Current and future actions include tracking potential pollution incidents related to water and soil in own operations through daily operation, continuing to address water and soil pollution with suppliers through the Supplier Engagement Programme, aligning the Environmental Policy in 2025 to also cover water and soil pollution, and aligning the Environmental Management System framework in 2025 according to the standards of ESRS E2. (page 69)

Due to the nature of Solar's business and its history, no targets related to pollution have been set. Solar will conduct an assessment to better understand the full scope of its pollution-related impacts, risks, and opportunities in order to identify potential future targets and the resources required. Pollution-related targets that are mandatory by law will be implemented during 2025. For this reporting year, Solar did not identify any incidents in its own operations, nor does it possess the methodology and data on the amounts of pollutants or the changes over time. (page 69)

Solar has identified pollution of water and soil to have a negative impact in the upstream value chain and its own operation. The full process and methodology applied to identifying pollution-related material impact is set out in the General information section. Solar complies with national and internal regulations, and through its ISO 14001 process monitor it screens for potential negative impacts. In case a severe incident occurs, Solar will engage local authorities and affected communities. For the upstream value chain, pollution is addressed in the Supplier Code of Conduct and the Sustainable Procurement Policy. At this time, Solar does not have data on emissions and pollutants related to the two negative impacts identified through its IRO analysis: water and soil. Through daily operation, Solar tracks potential pollution incidents related to water and soil in own operations, and it will continue to address water and soil pollution with suppliers as part of its Supplier Engagement Programme. (page 69)

Solar reports that no financial implications of pollution-related risks and opportunities have been identified. The company states that it will allocate potential additional resources or funds to the extent needed. (page 69)

Solar states that continuously assessing and enhancing the resilience of its business model and strategy to biodiversity and ecosystems-related risks is essential for long-term sustainability, and that the company depends on diverse and healthy ecosystems to support climate change reductions. Due to its business model, Solar believes it has integrated the necessary resilience to physical, transition and systemic risks within this topic in both its own operations and the upstream value chain, and therefore has no separate transition plan. Solar acknowledges that raw material extraction for manufacturing the products it sells, as well as energy resources and transportation, may cause significant harm and negative impact on people and the environment. Solar engages with suppliers through its Supplier Engagement Programme and performs regular risk assessments. Because it primarily operates with suppliers from European markets with legislative requirements, Solar believes its current strategy and business model hold the necessary resilience to limit the negative impact, and it has not performed any further resilience analysis. Solar has engaged with relevant stakeholders from its own operations and upstream value chain to assess its impact on biodiversity. (page 70)

Solar does not have a biodiversity and ecosystem policy relating to the material impacts and risks identified. Its related policies, such as the Environment Policy, Sustainability Policy, Sustainable Procurement Policy, and Environmental Policy, define the company's commitment to biodiversity and ecosystems. The Sustainable Procurement Policy addresses responsible sourcing throughout the value chain and the protection of people and nature, with traceability in the form of country of origin identified in the product documentation. Solar seeks to inspire its suppliers by demanding that they sign its Supplier Code of Conduct, which emphasizes the protection of people and the environment. (page 70)

Solar adheres to national and local regulations and procedures for the protection of biodiversity and ecosystems, which are supervised by authorities; therefore the material impact is considered limited. In its own operation, biodiversity and ecosystems is anchored in operations, and any incidents shall be reported to a management team member and to the EMS team. For the upstream value chain, pollution is addressed in the Supplier Code of Conduct under the chapter Environment, Pollution Prevention, and Resource Conservation, as well as in the Sustainable Procurement Policy. Ongoing and future actions include: further aligning policies towards the demands of the ESRS standards and other applicable international standards; continuing to mitigate negative impacts and risks through SBTi targets; continuing the development of afforestation projects, with more details to be made available in the coming reporting period; and continuing to monitor and follow up on suppliers via targets for risk assessment and signing of the Supplier Code of Conduct. (page 70)

Solar has no direct targets in relation to biodiversity and ecosystems. For its own operations, Solar tracks and follows the progress of its afforestation projects. Signing its Supplier Code of Conduct, which contains several environmental elements, is an indirect target showing suppliers' commitment to this subject. (page 71)

Solar reports that no financial implications from biodiversity and ecosystems risks and opportunities have been identified. The company states that it will allocate potential additional resources or funds to the extent needed and refers readers to the Taxonomy section for further information. (page 71)

Solar reports its policies related to resource use and circular economy (E5-1, page 72). Solar's Environmental Policy covers areas such as waste management and environmentally friendly packaging. As Solar is ISO 14001 certified, it is committed to ensuring that guidelines relating to the management of waste, as well as hazardous waste and materials, are strictly followed. As outlined in its Supplier Code of Conduct, Solar also engages with suppliers to ensure that the use of natural resources, including water, fossil fuels, minerals, and virgin forest products, is conserved through practices such as modifying production, maintenance and facility processes, materials substitution, reuse, conservation, recycling, or other means. The company frames circular economy practices as increasingly important within its own production and across its industry, and states it wants to become part of the long-term solution while noting that reuse and waste sorting challenges must be resolved to achieve a fully implemented circular economy culture.

Solar reports actions and resources related to resource use and circular economy (E5-2, page 72). In its own operation, waste is anchored in the Operations department, which monitors waste and recycling processes. Historically and during the year under review, Solar focused on the following activities: reporting monthly on all waste fractions relevant to its business model, with help from waste management providers and through external audits; running several pilot projects with the objective of recycling products used across its value chain; striving to source 100% certified recycled cardboard packaging materials for use with customers; and constantly seeking new processes and projects to create a positive impact on resource and circular economy within its value chain. Waste in Solar's operations and value chain mainly consists of packaging waste from inbound product supply and outbound distribution. Solar complies with national and internal regulations and continuously evaluates its methods to improve waste sorting for optimised recycling, collecting data on all relevant waste fractions.

Solar reports targets related to resource use and circular economy (E5-3, page 72). In relation to resource inflows, specifically cardboard packaging, Solar has a target of 100% recycled cardboard but without any timeline. Solar states it does not have targets for waste management. However, it manages waste according to national standards and requirements and closely monitors any updates in this regard. The company endeavours to manage waste in a manner that does not harm the environment by continuously improving its waste management programmes in collaboration with its waste managers. Solar states it will work towards setting targets in 2025.

Solar reports resource inflows (E5-4, page 72). Companies that manufacture electrical equipment rely heavily on resources such as metals, which require mining, posing significant environmental threats as they must be sourced from different parts of the world. Almost all resources used in Solar's supply chain derive from the extraction of raw materials, including the energy resources and transport involved. It is likely that products in the supply chain have been produced from virgin materials extracted from mines or natural areas, and extraction can have a significant negative impact on people and the environment. Through its Supplier Engagement Programme, Solar maintains dialogue with suppliers to reuse and recycle through circularity levers. Although relatively small, Solar depends on virgin resources in its packaging and distribution materials in its own operation, such as paper, pulp, and natural gas/crude oil for plastics. Dependence can be reduced, for example by switching to recycled packaging materials and optimising packing methods, but it is not possible to reduce dependency completely at this stage.

Solar reports resource outflows (E5-5, pages 73-74). Due to the nature of its business, waste streams mainly consist of packaging waste (paper, cardboard, plastics, wood etc.) and electronic waste (minerals from batteries and other electronic devices, as well as metal and plastics from cables etc.) deriving from damaged or returned products. Solar complies with the Waste Electrical and Electronic directive. Electronic waste is a significant waste stream in the industry, as many products sold are still not designed with circularity in mind (durability, repair, reuse, disassembly, and recycling), generating general waste and e-waste that potentially causes indirect or direct harm to nature. Waste data is actual data collected and reported monthly by those responsible, with accountability lying with Operations, and is provided for most locations subdivided by material type, equivalent waste management type and weight. Waste treatment volumes are reported in absolute tonnage (in kg). All data is third-party data; the first three quarters of 2024 are actual data, while Q4 is estimated based on the average of the previous three quarters.

Solar's E5-5 waste table (page 74) reports total waste generated in 2024 of 3,961,694 kg. Total hazardous waste diverted from disposal was 26,226 kg, all due to recycling (0 kg for preparation for reuse and 0 kg for other recovery). Total non-hazardous waste diverted from disposal was 3,020,955 kg, comprising 2,911,297 kg due to recycling, 109,658 kg due to other recovery operations, and 0 kg due to preparation for reuse. Total hazardous waste directed to disposal was 6,505 kg, all by incineration (0 kg landfilling, 0 kg other). Total non-hazardous waste directed to disposal was 908,008 kg, comprising 881,067 kg by incineration and 26,941 kg by landfilling (0 kg other). The total weight of non-recycled waste was 914,513 kg, representing a total non-recycled waste percentage of 23%. Waste treatment volumes are reported per final treatment in absolute tonnage (in kg).

Solar discloses policies related to its own workforce (page 76). The company states it will continue to focus on fostering a workplace and culture that promotes diversity, equity, and inclusion, respects human rights, and does not accept any form of discrimination or harassment. Policies are aligned with applicable ILO standards and address the safety of workers, precarious work, human trafficking, and forced or child labour. Solar has implemented a Sexual Harassment Policy intended to contribute to a work environment that is sound in terms of safety and health, where all employees thrive and feel safe. Accountability for well-being and the mitigation of negative impacts lies with Group HR. Violations are reported back to either the Board of Directors or the Executive Board, with accountability held by Group HR. The Inclusion and Diversity Policy aims to ensure that all employees are treated equally and to advance diversity and inclusion in general.

Solar describes its processes for engaging with its own workers and workers' representatives about impacts (page 77). Overall accountability for engagement lies with the Executive Board. The company conducts engagement surveys to gain insight into employees' well-being, commitment, perception of influence, development opportunities, work-life balance, collaboration with colleagues, and how Solar's leaders are perceived. The survey runs every two to three years, with accountability held by HR; in 2024 it also included questions on diversity, inclusion, and equality. Results are presented to all managers with employee responsibility so they can engage with staff and take action, and are published on Solar's intranet. Group HR monitors and tracks the effectiveness of managers' engagement through the HR system (People Portal). Employees can also voice opinions via the whistleblower portal, works councils, employee representatives, and performance appraisals. Solar has three employee-elected members on its Board of Directors. See Stakeholder engagement on page 43 for further information.

Solar reports on processes to remediate negative impacts and channels for own workers to raise concerns (page 77). Employees are encouraged to speak up if they experience any irregularities or illegalities on Solar's part. Access to remediation helps ensure a just and fair workplace, protects employees, and underpins the ambition for a diverse, equal, and inclusive work culture. Employees with a grievance or complaint can report the incident via the whistleblower portal, which is accessible on Solar's intranet or websites, or can seek support from their line manager or HR. Should these channels be unsuitable, all stakeholders, both internal and external, can raise a complaint directly with the Executive Board. Solar's Internal Audit team tracks and monitors all issues raised through any means. The company takes proactive steps to ensure awareness of acceptable standards of behaviour by regularly running information campaigns on the intranet, having all employees sign the Code of Conduct, and making the Employee Handbook available on the intranet.

Solar reports on actions taken on material impacts on its own workforce (pages 77). Starting from two negative impacts identified in its double materiality assessment, the company focuses on two areas: diversity, equity, and inclusion; and health, safety, and well-being. Solar believes that following its policies and structured engagement contributes to a positive impact, and currently has no other actions planned beyond those described. Effectiveness is tracked through employee engagement surveys and KPIs relating to retention, employee turnover, sick leave, and number of accidents. On diversity, Solar will continue to increase the proportion of women at senior management level and in entry-level positions, maintain communities supporting diversity, provide equal opportunities, and has embarked on ISO 27001 implementation to mitigate data protection impacts. On health and safety, it introduced a Safety Flash tool to register serious incidents and accidents, analyse root causes, and set actions; it organises prevention campaigns such as emergency drills and safety training, offers seminars on psychological safety, and supports work-life balance through flexible and remote working.

Solar discloses targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities (page 78). Targets for diversity are set and tracked by the Executive Board in collaboration with HR and the Danish Management Team, and communicated in the Annual Report. Solar is committed to promoting gender diversity and has set a target of 25% women in senior management and 40% women at entry level by 2026, calculated according to the Danish Financial Act section 99b. For women in senior management, the 2024 result was 21% (up from 15% in 2023) against the 25% target. For entry level, all employees, women, the 2024 result was 34% (up from 31% in 2023) against the 40% target. Targets are tracked annually. Solar acknowledges the target may be challenging given its legacy and the traditionally low representation of women in its industry, meaning most employees and managers are currently male. To support progress it conducts unbiased recruitment training, updated recruitment processes and job advertisements, and implemented a Recruitment Policy.

Solar discloses the characteristics of its employees (page 79; see note 2.3 Staff costs, page 111). Total headcount at year-end 2024 was 3,009 (2023: 3,059), and total FTE was 2,895 (average 2,990 in 2023). Headcount by country: Denmark 926, Sweden 583, Norway 387, the Netherlands 637, Poland 369, and Others 107. By gender, there were 2,107 men and 902 women, with 0 categorised as other and 0 not reported. By contract type, of 3,009 total employees, 2,830 were permanent (1,985 men, 845 women), 123 temporary (84 men, 39 women), and 56 non-guaranteed hours employees (38 men, 18 women). Permanent employees by region: Denmark 888, Sweden 553, Norway 380, the Netherlands 570, Poland 340, Others 99. Employee turnover in 2024 was 513 (headcount), giving an employee turnover rate of 17.8%. Number of employees is measured as headcount and FTE at the end of the reporting period, with gender categorised as male, female, or other.

Solar reports diversity metrics (page 80). For gender distribution in top management, there were 11 men and 3 women in 2024 (2023: 11 men and 2 women), equating to 79% men and 21% women in 2024, compared with 85% men and 15% women in 2023. Top management includes management levels 1 and 2 of the organisation; level 1 is the executive board and managers at the same organisational level, and level 2 includes managers with staff responsibility reporting directly to level 1 management, defined per the Danish Financial Statements Act section 99b. For age distribution of employees in 2024, 373 were under 30 years, 1,482 were between 30 and 50 years, and 1,154 were over 50 years, for a total of 3,009 employees (headcount).

Solar discloses health and safety metrics for 2024 (page 80). The share of employees covered by a health and safety management system based on legal requirements was reported as 0%. There were 0 fatalities in the own workforce as a result of work-related injuries and work-related ill health, and 0 fatalities among other workers working on the undertaking's sites. Solar recorded 33 recordable work-related accidents, with a recordable work-related accidents rate of 5.75%. There were 0 cases of recordable work-related ill health of employees. Days lost to work-related injuries and fatalities from work-related accidents, work-related ill health, and fatalities from ill health related to employees totalled 417. Work-related accidents are defined as arising from exposure to hazards at work, including when travelling for work purposes; when working from home, accidents directly related to the performance of work are included.

Solar reports remuneration metrics (page 80). The gender pay gap for 2024 was 23.9% (not reported for 2023). Based on data for all employees, the gender pay gap is defined as the difference in average gross hourly pay levels between male and female employees, expressed as a percentage of the average gross hourly pay level of male employees. The annual total remuneration ratio for 2024 was 22.8 times, down from 25.4 times in 2023. This ratio is defined as the annual total remuneration of the highest-paid individual (the CEO) to the median annual total remuneration for all employees excluding the highest-paid individual. Annual total remuneration to the own workforce includes salary, bonus, stock awards, option awards, non-equity incentive plan compensation, change in pension value, and non-qualified deferred compensation earnings provided over the course of a year.

Solar states that it aims to ensure decent jobs across its industry and to provide adequate wages, decent working conditions, freedom of association, no child or forced labour, secure employment, health and safety, and a working environment where workers can freely express their views and concerns (page 81). Its commitment to uphold human and labour rights is outlined in its Human Rights Policy, whose objective is to reduce the risk of negative impact on workers across the value chain, as well as in the Sustainable Procurement Policy and Supplier Code of Conduct. The company reports operating in a low-risk market and, based on its history, regards it as low risk that direct (tier one) suppliers will breach labour and human rights. Solar has over 4,000 direct material suppliers, of which 2,500 are strategic or preferred suppliers. Data from 2024 shows that 98.5% of Solar's spend is within the EU/EES/GB region and 91% is from countries where Solar is present.

Solar describes how it engages with value chain workers about impacts (page 81). Through frequent dealings with business partners and the people it is in direct contact with, the company engages indirectly with the workforce across its value chain, thereby gaining insight into general labour conditions. Through its Supplier Engagement Programme, Solar assesses supplier commitment to human rights and labour, covering labour and human rights, ethics, and sustainable procurement, with results verified by a third-party specialist in supplier assessment and risk management due diligence. Overall accountability for supplier engagement lies within the organisation, and the company states that severe human rights issues and incidents connected to its upstream and downstream value chain must be disclosed where applicable. During the year Solar also conducted on-site audits in collaboration with a third-party provider for selected high-risk suppliers. Where a supplier fails to meet thresholds in the Sustainable Procurement Policy, a corrective action plan is initiated and a reassessment conducted, a training programme is assigned to suppliers scoring below the human rights and labour threshold, and continued non-compliance can ultimately lead to termination.

Solar describes its processes to remediate negative impacts and the channels for value chain workers to raise concerns (page 81). Due to the nature of its business and operating in a low-risk zone, the company reports it has not been made aware of any incidents that have caused or contributed to a negative impact. Employees and external stakeholders are encouraged to speak up if they experience concerns, irregularities, or illegalities on Solar's part or within the value chain. Solar's whistleblower portal is hosted by an external partner and is accessible from its website, allowing value chain stakeholders to anonymously report breaches without risk of retaliation and ensuring confidential access to Solar's Executive Board. All submitted cases are registered and presented to the Board of Directors and the Executive Board for resolution under the Whistleblower Policy. Solar states it is committed to engaging with the workforce across its value chain and, through its Supplier Engagement Programme, will maintain focus on suppliers' own grievance mechanisms for workers and stakeholders alongside its whistleblower portal. Further detail is provided in section G1 Business Conduct.

Solar describes the actions taken on material impacts on value chain workers (pages 81-82). By following its policies and Code of Conduct and through regular, structured engagement with contact persons in the value chain, the company monitors potential risks. Working conditions, equal treatment and opportunities, and child and forced labour are integrated into its supplier risk assessment due diligence, which also applies to the selection of new suppliers. Where an incident occurs, it is handled and tracked via the Supplier Engagement Programme, and Solar reports no record of any material risks. Planned actions include continuing to promote awareness of its grievance mechanism to the supply chain workforce, providing suppliers with capacity to make a positive impact on human rights issues, tracking and measuring its targets and engagement, and maintaining collaboration with industry and trade organisations in the countries it operates in to influence a just and inclusive workforce. Members of the Senior Management Team are assigned appropriate resources to manage and operationalise material impacts through daily management. Solar reports no record of any severe human rights issues and incidents connected to its upstream and downstream value chain.

Solar reports two entity-specific targets set in 2024 based on the outcome of its double materiality assessment, supporting its Sustainable Procurement Policy and helping it better understand how suppliers operate and contribute to a positive work-related human rights and labour impact for supply chain workers (page 82). The targets are set and defined by the Executive Board in collaboration with Commercial Market and Sourcing Management, who are operationally responsible, and are tracked quarterly using data from the contract system and risk assessment platform, with progress overseen by the Executive Board. The first target relates to spend undergoing risk assessment, which reached 80% in 2024 (up from 68% in 2023 and 50% in 2022), with a 2026 target of 82% at group level. The second relates to spend covered by a signed Supplier Code of Conduct, which reached 93% in 2024 (up from 91% in 2023 and 85% in 2022), with a 2026 target of 95%. More than 1,300 documents were signed, covering 93% of strategic/preferred supplier spend.

Solar describes its business conduct policies under ESRS 2 MDR-P (page 84). The policies include a Whistleblower Policy, which encourages stakeholders in the value chain and own operation to report unethical breaches and practices without fear of retaliation; a Fraud Policy, which facilitates controls for detecting and preventing fraud in the value chain and own operation while promoting consistent behaviour through guidelines and assigned responsibilities; a Data Ethics Policy, which outlines Solar's data ethics principles and processing methods and commits the company to protecting data to the highest ethical standards; and a Tax Policy, which manages Solar's tax efficiently, ensures compliance with laws, and conducts business activities ethically and in a socially responsible manner. Accountability for implementing the policies lies with the Executive Board and ultimately the CEO. Solar takes proactive steps to ensure awareness by providing internal information on its intranet and making its whistleblower portal available on its websites. The whistleblower portal is hosted by an external partner, allows employees and external stakeholders to anonymously report breaches without risk of retaliation, and offers confidential access to the Executive Board.

Solar reports on confirmed incidents of corruption or bribery under G1-4 (page 84). The company has identified confirmed incidents of corruption or bribery as having a negative impact primarily in the value chain but also in its own operation, with the full process and methodology for identifying confirmed incidents set out in the General information section. For 2024, Solar reports a table showing zero results across both measured indicators. The number of convictions for violation of anti-corruption and anti-bribery laws was 0 in 2024 (and 0 in 2023). The amount of fines for violation of anti-corruption and anti-bribery laws was 0 in 2024 (and 0 in 2023).