SSAB

The role of the administrative, management and supervisory bodies

The Board's responsibility for sustainability work

(GOV-1 § 22 c & d, GOV-2 § 26 a) SSAB's Board of Directors is ultimately responsible for the company's sustainability work, which includes, among other things, conducting business responsibly and managing risks and opportunities related to sustainability at a strategic level (for more information on identified impacts, risks and opportunities in the area of sustainability, see the Sustainability Report, section Process for assessment of material impacts, risks and opportunities (IRO-1)). For example, the Board approves the Code of Conduct, the sustainability strategy and the strategy and investments related to the transformation to fossil-free steel production.

At Group Executive Committee meetings the development of SSAB's sustainability work is regularly reported to the CEO by the members of the Group Executive Committee in accordance with their respective areas of responsibility (for more information, see section The Group Executive Committee's responsibility for sustainability work), which is consolidated and reported to the Board of Directors. The board is informed, if deemed necessary, in the event of changes to group directives and instructions due to, for example, regulatory changes or based on internal evaluations.

The Board of Directors is updated at least quarterly about the development of SSAB's sustainability work in the company's material areas. The Board is updated through information in internal reports or other documents and presentations that are provided ahead of and presented at Board meetings. For the areas that have set targets, the Board is presented with the current outcome in relation to the set targets. Information about the Group's safety work and SSAB's transformation to fossil-free steel production is given at each ordinary meeting.

Since sustainability and climate issues, especially the transformation to fossil-free operations, are an integral part of SSAB's business strategy, the Board does not have a separate sustainability committee. The Sustainability Report is processed in the Audit Committee as part of the Annual Report.

The Board of Directors follows the views of the most important stakeholders in relation to SSAB's sustainability work, for example employee representatives are included in the Board of Directors which gives the employees agency in questions discussed by the Board. Furthermore, the Board also has contact with, for example, shareholders, especially in connection with the Annual General Meeting, as well as authorities and politicians. Otherwise, the Board has delegated stakeholder dialogs to members of the Group Executive Committee, within their respective areas of responsibility (for more information on the Group Executive Committee's areas of responsibility, see section The Group Executive Committee's responsibility for sustainability work. The Board of Directors is informed as required or if major changes are made.

Rules of procedure of the Board

(GOV-1 § 22b) Each year, the Board adopts the rules of procedure, including instructions to the CEO, which, among other things, govern the allocation of work between the Board and the CEO. The rules of procedure further regulate the frequency of Board meetings and the allocation of work among the Board's committees. The rules of procedure state that there must be a Remuneration Committee and an Audit Committee. Ahead of each Board meeting, the directors receive a written agenda and full documentation to serve as the basis for decisions. Each Board meeting conducts a review of the Group's safety statistics, sustainability objectives – including significant impacts, risks and opportunities related to sustainability matters, the current state of the business, the Group's results, financial position and the business (for more information on the Board's and the Group Executive Committee's responsibility in sustainability work, see section The Board's responsibility for sustainability work and The Group Executive Committee's responsibility for sustainability work). Other issues addressed include competition and the market situation.

Audit Committee

Duties

(GOV-1 § 22 b) The Audit Committee elects a Chair from among its members. Members of the Audit Committee are elected from directors who are not employees of the company. At least one of the members must be competent in accounting or auditing matters.

The duties of the Audit Committee are stated in the Board's rules of procedure. The Chair of the Committee is responsible for ensuring that the entire Board is kept regularly informed of the Committee's work and, where necessary, for submitting matters to the Board for decision.

The main duty of the Audit Committee is to support the Board in its work to ensure the quality of the financial and sustainability reporting.

Remuneration Committee

Duties

(GOV-1 § 22 b) In addition to the Chair of the Board of Directors, the Remuneration Committee comprises one or more directors elected by the general meeting who must be independent both of the company and of the company's top management. The Committee members must possess the required knowledge and experience of remuneration matters relating to senior executives. The Committee's duties are stated in the Board's rules of procedure. The CEO attends the Committee meetings to report on matters.

Work of the Board in 2024

(GOV-1 § 21, GOV-2 § 26 b & c) In 2024, the Board of Directors held 12 meetings at which minutes were taken and the Board was quorate at all times. SSAB's General Counsel, who is not a director, served as a secretary to the Board. During the financial year 2024, the Board of Directors consisted of seven members elected by the Annual General Meeting during the period January 1–April 24, 2024, nine directors elected by the Annual General Meeting during the period April 24–October 28, 2024 and eight directors elected by the Annual General Meeting during the period October 28–December 31, 2024. As at December 31, 2024, the Board of Directors consisted of four women and four men (corresponding to a ratio of 50%/50% for female/male directors). In addition, the Board during the financial year 2024 consisted of three employee representatives and three deputies. All of the directors elected by the Annual General Meeting during the financial year 2024 were non-executive directors, with the exception of Martin Lindqvist, who was an executive director in the capacity of President and CEO during the period January 1–October 28, 2024. All (100%) of the non-executive directors of the Board of Directors are deemed to be independent in relation to both the company and the company's management, as well as the company's major shareholders.

The Board's experience and expertise in the company's sectors, products and geographical locations and sustainability

(GOV-1 § 23) The Board of Directors is evaluated annually to ensure that it has the required combined experience and competence for SSAB's operations, which includes the company's products, the sectors and geographical locations in which SSAB operates as well as material sustainability areas. The evaluation for 2024 was conducted by an external party and consisted of an extensive questionnaire that was answered by each director individually as well as individual interviews with the directors. The questionnaire mainly related to the Board's efficiency and collective competence to handle its responsibilities in relation to important areas for the company. The responses were consolidated and reported anonymously to the Board of Directors and to the Nomination Committee prior to their preparation of proposals for the election of directors (for more information on the Nomination Committee's work, see section Nomination Committee). The conclusion from the Board evaluation carried out in 2024 was that the directors were deemed to have appropriate experience and competence for the company's operations.

A special sustainability focus for the Board evaluation was to ensure that the Board has the necessary competence for the implementation of the company's transition to fossil-free steel production, which included competence and experience in the heavy processing industry, international marketing and sales, major investment projects, finance, IT and digitalization as well as corporate social responsibility.

In addition to the competence that the Board possesses in the area of sustainability, the Board also has access to additional competence when necessary, primarily through specialized employees within the Group.

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

Information provided to the Board on sustainability matters

(GOV-2 § 26 a) At Group Executive Committee meetings the development of SSAB's sustainability work is regularly reported to the CEO by the members of the Group Executive Committee in accordance with their respective areas of responsibility (for more information, see section The Group Executive Committee's responsibility for sustainability work), which is consolidated and reported to the Board of Directors. The board is informed, if deemed necessary, in the event of changes to group directives and instructions due to, for example, regulatory changes or based on internal evaluations.

The Board of Directors is updated at least quarterly about the development of SSAB's sustainability work in the company's material areas. The Board is updated through information in internal reports or other documents and presentations that are provided ahead of and presented at Board meetings. For the areas that have set targets, the Board is presented with the current outcome in relation to the set targets. Information about the Group's safety work and SSAB's transformation to fossil-free steel production is given at each ordinary meeting.

Each Board meeting conducts a review of the Group's safety statistics, sustainability objectives – including significant impacts, risks and opportunities related to sustainability matters, the current state of the business, the Group's results, financial position and the business (for more information on the Board's and the Group Executive Committee's responsibility in sustainability work, see section The Board's responsibility for sustainability work and The Group Executive Committee's responsibility for sustainability work). Other issues addressed include competition and the market situation.

Sustainability matters specifically addressed by the Board in 2024

(GOV-2 § 26 b & c) During the year, the Board of Directors specifically dealt with the following sustainability issues: • Transformation of operations to fossil-free steelmaking. • Safety work in the Group.

The Board of Directors has spent considerable time on topics related to the transformation to fossil-free steel production and has during the year visited SSAB's sites in Luleå, Sweden and Raahe, Finland. The company's material impacts, risks and opportunities related to sustainability are communicated to the Board in connection with the annual strategy and risk review and are a central part of the basis that the Board has taken into account in strategic decisions and considerations during the financial year, such as the Board of Directors' decision to proceed with the next step in SSAB's transition by building a state-of-the-art steel mill in Luleå for the production of premium steel with low CO2 emissions.

Integration of sustainability-related performance in incentive schemes

Roles covered

Sustainability-related performance is integrated into incentive schemes for:

• The CEO
• Other members of the Group Executive Committee
• All employees who have short-term variable compensation in accordance with global instructions (approximately 2,100 employees)

Short-term incentive (STI) programme

CEO - Performance period 2024

The STI program has been measured during the full year 2024 and is capped at 75 percent of the fixed salary 2024.

Performance criteria:

The CEO's STI consists of 100% Group objectives. There are three Group objectives:

1. EBITDA margin compared to peer group (60% of Group objectives minimum)
2. Operating cash flow in relation to adjusted operating result before depreciation and amortization
3. A sustainability objective measuring the injury frequency with lost time which lead to absence of more than one day (LTIF)

2024 Outcomes:

Total STI outcome for CEO:

Prerequisite for STI payment: The Group must show a positive adjusted operating result (excluding items affecting comparability). This threshold was reached for 2024.

Other senior executives

For senior executives with clear own profit responsibility, STI shall consist of:

• At least 45% unit objectives
• Remaining part of group objectives

For other senior executives, STI shall consist of:

• At least 70% Group objectives
• Remaining part of unit objectives

STI outcomes for Group Executive Committee members (excluding CEO):

In 2024, the outcomes of the short-term variable compensation in relation to base pay were on average 60.2% (49.0% in 2023) for other Group Executive Committee members.

Maximum STI levels:

• CEO: Maximum 75% of fixed annual cash salary
• Other senior executives: Maximum 50% of fixed annual cash salary

Long-term incentive (LTI) programme

CEO - Performance period 2022-2024

The LTI program is cash-based and has been measured over a period of three years (2022–2024). The outcome is capped to maximum 35 percent of the base salary as per December 31, 2021.

Performance criteria:

The CEO's LTI is linked to:

• Total return on the company shares (TSR) for the financial years 2022, 2023 and 2024 in relation to a reference value which consists of:
  • 70% average total shareholder return of a benchmark group (ArcelorMittal, JFE, Nucor, Salzgitter, ThyssenKrupp, U.S. Steel and Voestalpine)
  • 30% OMX 30 index

2022-2024 Outcome:

SSAB outperformed the reference value by 70.4 percentage points which corresponds to a maximum outcome.

LTI payout for CEO:

Active LTI programmes

Sustainability link: The LTI programs 2023-2025 and 2024-2026 include a target for "Total sales of emission free products" / "Total sales of steel without fossil carbon dioxide emissions".

Broader employee coverage

Regarding sustainability topics linked to compensation (GOV-4), all employees who have short-term variable compensation in accordance with global instructions (approximately 2,100 employees) are covered by the group goal of sustainability with a focus on safety. In addition, divisions and subsidiaries may have additional sustainability targets at the unit level.

Rationale for performance criteria

The performance criteria for the CEO's variable remuneration have been selected to deliver the company's strategy and to encourage behavior which is in the long-term interest of the company. In the selection of performance criteria, the strategic objectives and short-term and long-term business priorities have been taken into account. The non-financial performance criteria further contribute to alignment with sustainability as well as the company values.

SSAB's stated objective is to become the safest steel company in the world to work in, and shall in addition adhere to high environmental standards.

Current status on GHG reduction targets in LTI

SSAB currently has no direct link between compensation programs and targets for reducing greenhouse gas emissions, as the major effects of the transformation plan are not expected to occur until some years from now. In the currently active long-term incentive programs, one of the targets is the sale of emission-free products.

Verification and governance

Before the payment of variable cash compensation is effected, the Board of Directors must verify that the objectives linked to the remuneration have been met and that the remuneration has been calculated correctly.

Following a proposal from the Remuneration Committee, the Board of Directors is responsible for the evaluation of variable remuneration to the CEO. For variable cash remuneration to other senior executives, the Remuneration Committee is responsible for the evaluation in consultation with the CEO.

Strategy, business model and value chain

This is SSAB

SSAB is a Nordic and US-based steel company that builds a stronger, lighter and more sustainable world through value added steel products and services. SSAB has employees in over 50 countries and production facilities in Sweden, Finland and the USA. SSAB is listed on Nasdaq Stockholm and Nasdaq Helsinki.

SSAB is organized across five business segments consisting of three divisions: SSAB Special Steels, SSAB Europe and SSAB Americas, and the fully-owned subsidiaries: Tibnor and Ruukki Construction.

SSAB Special Steels

has global responsibility for sales of SSAB's quenched and tempered (Q&T) steels and advanced high-strength steels (AHSS) as well as for the production sites in Oxelösund, Sweden, and in Mobile, USA.

SSAB Europe

is responsible for sales of strip, heavy plate and tubular products in Europe, the global business in the Automotive customer segment (AHSS) and for the production sites in Raahe and Hämeenlinna, Finland, and in Luleå and Borlänge, Sweden.

SSAB Americas

is responsible for sales of heavy plate in North America and for the production site Montpelier, USA.

Tibnor

is the Group's distributor of a full range of steel and non-ferrous metals in the Nordics and Baltics. Tibnor buys and sells materials produced both by SSAB and other suppliers.

Ruukki Construction

produces and sells energy-efficient building solutions, with a focus on northern and eastern Europe.

SSAB's home markets

SSAB's home markets are the Nordics (heavy plate, strip and tubular products) and North America (heavy plate). High-strength and quenched and tempered steels are sold worldwide. Our production plants are in Sweden, Finland and the USA and have an annual crude steel production capacity of 8.8 million tonnes.

Strategy - Building an even stronger steel company

SSAB's strategy is to deliver sustainable, industry-leading profitability by strengthening and innovating products that increase added value for customers.

Leading position in home markets

SSAB is the market leader on our home markets – flat steels and tubular products in the Nordics and heavy plate in North America. A proximity to customers has built up partnerships through the years. These partnerships continue to evolve. It is key for customers to receive top-quality steel with good delivery accuracy and short lead times. SSAB's competitive edge is that production is relatively close to customers, which also facilitates product development. This leading position on our home markets creates a stable platform from which to further develop SSAB' offering.

Global leadership in special and premium steels

SSAB has a wide range of premium steels and is the global market leader in quenched and tempered (Q&T) steels and advanced high-strength steels (AHSS). These steels create great value for SSAB's customers, for example through longer product lifespan, lighter products that consume less energy in use and higher productivity. SSAB's unique special products have higher margins and more stable earnings than standard steel over business cycles. The strategy is to continue to increase sales of special and premium steels by upgrading customers from standard steels to high-strength premium alternatives, and to enter new markets and segments. Combining the growth of these products with a more stable development of standard products will improve SSAB's product mix.

Leading the green transformation of the steel industry

Many of SSAB's customers and other market actors, not least in the mobility, construction and construction machinery industries, have set ambitious goals to reduce their climate impact from materials. In many cases, steel accounts for a significant share of CO2 emissions related to materials and manufacture of these products. By offering these customers steel with lower CO2 emissions, SSAB helps them to reach their climate goals and in turn sell products and applications with a lower carbon footprint. This shows how the development of steel with lower climate impact creates great value for our customers and adds a further dimension to SSAB's range of premium products. Back in 2023, we introduced a unique steel, SSAB Zero, based on recycled steel scrap and fossil-free energy. SSAB's flexible production system means that we can offer SSAB Zero in most product categories and on many markets in Europe and North America.

Customer segments

The customer segments include heavy transport, construction and infrastructure, automotive, industrial applications, construction and construction machinery (including lifting cranes) and energy and material handling (including mining). In the Nordic and North American home markets, standard steel is sold to a certain extent via service centers and distributors. SSAB has its own sales channels in 50 countries.

SSAB's customer segments

Share of total shipments in 2024: • Heavy transport, 13% • Construction, 10% • Automotive, 12% • Industrial applications, 12% • Construction machinery, 5% • Energy, 5% • Material handling, 4% • Service centers, 38% • Others, 2%

Market segment

SSAB operates in the so-called flat carbon steel market (steel with a certain carbon content) that is rolled into sheets of varying thickness. With an annual production capacity of approximately 8.8 million tonnes of crude steel, SSAB is a smaller player on the global market, but has leading positions in four segments: Special steel (Advanced High-Strength Steel, AHSS, and toughened steel), premium steel for vehicles (AHSS), flat steel and tubular products in the Nordic region and heavy plate in North America. SSAB is also a retailer of steel and other metals via the subsidiary Tibnor and offers steel-based construction products via the subsidiary Ruukki Construction.

SSAB's transformation enables increased premium product range

SSAB has decided on an ambitious agenda to increase and strengthen its leadership in strategic areas. SSAB plans to invest in modern, cost-effective and almost emission-free production technology at a number of our sites. These investments will allow us to expand our range of premium products and increase sales of steel with a low climate footprint. The transformation will also strengthen SSAB's competitiveness by lowering costs, converting fixed costs into variable costs and not least avoid the future costs of CO2 emissions resulting from the phasing out of free allocations to for example the steel industry under the EU Emission Trading System (EU ETS).

Strategy for profitable growth

SSAB's strategy is to grow in special products and premium steels, areas where we can stand out from the competition and deliver unique value to the customer. We will strengthen this focus, which will permeate all our business areas as we develop new products and services.

The focus is key to reaching our financial target – to be the most profitable steel company. Our planned investments combined with our dedicated employees give us the tools we need.

Interests and views of stakeholders

Stakeholder engagement overview

SSAB has regular contact with stakeholders and works for an open dialogue to increase understanding of their perspective. The stakeholder dialogues are adapted to meet the stakeholders' needs, and can take place, for example, through individual or public meetings.

Stakeholder dialogues take place to a large extent at local level in connection with production facilities, for example with residents in the immediate area and the rest of the local community, but depending on issues also at Group level. The board and Group Executive Committee are informed annually about the views and interests of important stakeholders with regard to SSAB's sustainability impact. Other decision-makers within SSAB are informed of the results of relevant stakeholder dialogues and these are taken into account for both daily and strategic issues.

Key stakeholder groups and engagement methods

Integration of stakeholder views into strategy

The views of stakeholders can influence the strategic direction, as for example until 2022, when SSAB's Board decided to advance the transformation of the Nordic production system as a result of high demand from customers for emission-free steel. Stakeholder dialogues were held as an integral part of the assessment of SSAB's material areas. SSAB assesses that stakeholders support both the analysis of the important areas and the company's strategy and transformation.

Distinction between affected stakeholders and users of sustainability information

SSAB's employees are an important stakeholder group and their views are an important part of SSAB's Code of Conduct and other Group policy documents. SSAB has regular meetings with employees to inform them about the planned transformation of SSAB's plants and to provide them with an opportunity to ask questions. SSAB is also in dialogue with trade union representatives concerning skills development in conjunction with the transformation and the employees' health and safety environment.

Employees in SSAB's value chain, especially contractors who perform work at SSAB's sites, are an important stakeholder group and their interests and views are an important part of SSAB's Code of Conduct and other relevant Group policy documents.

Workers in the value chain relates mainly to contractors who perform work at SSAB's sites, employees upstream in the value chain in, for example, iron ore and coal mining, and employees downstream in the value chain in, for example, logistics and transport used by SSAB. SSAB assesses these groups to have the highest risk of negative impact concerning health and safety and human rights.

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

Sustainability strategy

SSAB is a member of the UN Global Compact and stands behind the ten principles in human rights, labor law, environment and anti-corruption. SSAB has also committed to conducting operations in line with the UN's global goals for sustainable development and the Paris Agreement.

SSAB also supports the International Bill of Human Rights, the International Labour Organization's (ILO's) core conventions, the OECD's guidelines for multinational companies and the UN's guiding principles for business and human rights. SSAB has regular contact with stakeholders (see SBM-2).

SSAB's sustainability work is integrated into the business strategy and covers all divisions and subsidiaries. The sustainability strategy is based on the materiality analysis (refer to SBM-3) and also includes the fossil-free customer offer. SSAB wants to be a leader in sustainability, which includes the ambition to become the world's safest steel company and to largely remove carbon dioxide emissions from its own operations by around 2030. This means that SSAB intends to change the entire product portfolio to products with a low carbon footprint.

SSAB's overall sustainability targets:

• Greenhouse gas emissions: 48% reduction by 2033 compared to 2018
• Safety: Accident rate (LTIF) below 1.0 and total recordable injury rate below 5.5 (for 2024)
• Deliveries of emission-free steel (SSAB Zero): Deliveries of 100,000 tonnes of SSAB Zero steel by 2025

Sustainable offering

SSAB's offer to customers includes sustainability aspects. Some examples are:

• SSAB's blast furnace-based production is already among the most CO2 efficient in the world and thus reduces the carbon footprint from SSAB's own products as well as in customers' products.
• SSAB is a world leader in high-strength steel, which helps customers upgrade their products and use stronger steel to save weight and material.
• SSAB Zero, a steel produced with recycled steel scrap and fossil-free energy, was launched in 2023. SSAB's customers from, for example, the mining and transport industries already use SSAB Zero in their products.
• SSAB has launched the world's first steel powder without fossil carbon emissions for commercial deliveries. The powder combines the properties of SSAB's high-strength steel with the light structures that are possible with 3D printing.
• Pilot deliveries of steel produced with fossil-free sponge iron as raw material continue. The fossil-free sponge iron is developed with HYBRIT technology, which is currently being produced at a pilot scale in Hybrit Development AB's facility in Luleå.
• SSAB's partnership with customers and deliveries of emission-free steel are mainly to industrial customers in the Nordic and US home markets.

Material impacts, risks and opportunities

Material sustainability topics

SSAB's material sustainability topics, and their scope in the value chain as well as the respective ESRS standard that is used for disclosures:

Time horizon

SSAB's transformation to fossil-free steelmaking production is planned to take place over the next ten years, and will significantly reduce SSAB's CO2 and other emissions. SSAB's employees will be given relevant competence development and training in connection with the transformation. It is assessed that other sustainability areas will need to be addressed on an ongoing basis as a consequence of the business in the foreseeable future.

Resilience analysis of strategy and business model

SSAB believes that the company's strategy and business model not only deal with the various material risks related to sustainability, but also directly address the core of the climate problem, especially the high emissions from blast furnace-based steelmaking.

This is why SSAB believes that the strategy and business model adequately and resiliently address critical sustainability issues. SSAB's sustainability strategy and reporting are based on areas where the company has a major impact on people, the environment and/or areas with major financial impact on SSAB, either where this impact is already occurring or is very likely to occur.

Sustainability impact

In terms of climate, SSAB wants to tackle the root of the problem of high CO2 emissions in the steel industry, namely the use of coke in the reduction of the raw material iron ore. Other important areas of sustainability largely follow from the fact that SSAB is a company in heavy industry (for example, safety issues and gender equality), and has a global value chain (for example, work with business ethics, anti-corruption and sustainability in the supply chain). Today, through its operations, SSAB has a negative impact on people and the environment, but through the direction decided by the Board towards fossil-free steelmaking, the environmental impact can be significantly reduced and also drive the rest of the steel industry in a more environmentally friendly direction. The continuous work with other areas of sustainability can also have positive long-term effects in, for example, the working environment and gender equality.

Financial impact

Climate is the area that overall has the greatest financial impact on SSAB, as the free allocation of emission allowances is gradually phased out and planned to end in the middle of the next decade. Read more about SSAB's consumption of and costs for emission allowances in note C.1. At the same time, SSAB is investing in transforming to fossil-free steel production. Read more in section E1 as well as the capital expenditure plan included in the section Disclosures according to EU Taxonomy. SSAB intends to finance the transformation through its own balance sheet and, for example, a new framework for green and sustainability-linked bonds published in 2024. In 2023, SSAB launched the unique steel SSAB Zero, which has less than 0.05 kg of carbon dioxide equivalents per kg of steel. The product is sold at a higher market price compared to conventionally manufactured steel, as it adds value by supporting customers' efforts to reduce the carbon footprint of their products. Other areas of sustainability are currently not judged to have a significant impact on SSAB's financial position, investments or operating costs.

Examples of climate-related risks and opportunities (medium-long term, 1-5 years)

Operational risks

The main operational risks, including sustainability risks:

Board and Group Executive Committee work on material impacts, risks and opportunities

The company's material impacts, risks and opportunities related to sustainability at a strategic level are communicated to the Board in connection with the annual strategy and risk review and are a central part of the basis that the Board has taken into account in strategic decisions and considerations during the financial year. The Board approves the Code of Conduct, the sustainability strategy and the strategy and investments related to the transformation to fossil-free steel production.

At Group Executive Committee meetings the development of SSAB's sustainability work is regularly reported to the CEO by the members of the Group Executive Committee in accordance with their respective areas of responsibility, which is consolidated and reported to the Board of Directors. The Board is updated at least quarterly about the development of SSAB's sustainability work in the company's material areas.

Each Board meeting conducts a review of the Group's safety statistics, sustainability objectives – including significant impacts, risks and opportunities related to sustainability matters, the current state of the business, the Group's results, financial position and the business.

Integration into financial reporting

The transformation to fossil-free steelmaking will impact SSAB's financial reporting. The remaining useful lives of the assets in Sweden and Finland that will be replaced in the transformation are reviewed regularly. In April, 2024, SSAB's Board of Directors made a decision to proceed with SSAB's transformation, and to build a state-of-the-art mini-mill in Luleå, Sweden. When completed, SSAB will close the current blast furnace-based production system. Startup of the new mill is planned at the end of 2028 with full capacity one year later. Consequently, SSAB revised the remaining useful life estimates for the assets that will be replaced and become obsolete by the new production system so that these assets will be depreciated to their residual values by the end of 2028. As of April, 2024 the change increased SSAB's annual depreciation by approximately SEK 300 million.

Regarding value-in-use calculations for impairment testing, climate risks have been taken into account to the extent they could be estimated. Future capital expenditure and other cash flows regarding the transformation to fossil-free steelmaking have not been included in the calculations.

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

Methodology

SSAB's assessment of material impacts, risks and opportunities regarding people and the environment is based primarily on the estimates of SSAB's internal experts. These estimates are built on various assumptions, for example that it is possible to rank different types of sustainability impacts on the same scale.

Both assessments (impact materiality and financial materiality) are done in conjunction with the annual strategy and risk process. All divisions and the subsidiaries Tibnor and Ruukki do their own assessments, which are then included in a Group-wide assessment. This is validated by the Head of Sustainability, the CFO, and the Head of Strategy as well as by internal experts at the Group level. The assessment is reported to the Board in conjunction with the annual strategy and risk review.

The process is intended to identify risks at the Group level and to provide a basis for SSAB's strategic priorities and sustainability reporting.

The assessments have been made both for SSAB's own business and for the Group impact through business relationships with suppliers and customers. The assessments have not focused on any particular activities or geographical areas. The greatest focus has been on assessing existing and future adverse material impacts of operations.

Inputs to the assessment

Internal sources:

• SSAB's internal experts provide estimates and assessments
• Internal workshops, including risk assessments and management
• Divisions and subsidiaries (SSAB Special Steels, SSAB Europe, SSAB Americas, Tibnor, Ruukki) conduct their own assessments
• Internal experts at Group level validate assessments
• Head of Sustainability, CFO, and Head of Strategy validate assessments

External sources:

• External stakeholder dialogues (see SBM-2)
• Stakeholder consultation: various stakeholder groups including shareholders, customers and trade union representatives had an opportunity to give their views in various meetings
• Methodology in accordance with ESRS 1 3-5
• For climate-related physical risks: External expert assessments obtained as appropriate (e.g., in 2022, SSAB commissioned SMHI (Swedish Meteorological and Hydrological Institute) to analyze potential physical climate risks at SSAB's production sites from two different climate scenarios)

Scoring criteria for impact materiality

SSAB has developed an internal sustainability impact index where impacts are assessed based on:

• Scope (both severity and general impact)
• Possibility of restoration (irremediable character)
• Likelihood of occurrence

Scoring criteria for financial materiality

Assessment of financial effects from sustainability-related impacts, risks and opportunities has been done in accordance with an internal scale measuring:

• Financial effects in SEK
• Likelihood (the likelihood scale is the same as in the assessment of sustainability-related risks)

In the process, SSAB has in particular taken into account the connectivity between SSAB's impact on people and the environment and the financial impact on SSAB of these issues, which is clearly shown in the area of climate change.

Validation and approval

The result has been validated through stakeholder engagement. SSAB assesses that stakeholders share SSAB's analysis of the material areas and there were no views put forward to change the materiality assessment. The ambition has been that the result as a whole should be in line with SSAB's and stakeholders' understanding. The result has agreed with that of various stakeholder groups including shareholders, customers and trade union representatives.

Frequency and last review

The assessment is done in conjunction with the annual strategy and risk process.

The process of assessment of sustainability risks (risk for negative impact on environment and people) is new for 2024. The financial and/or reputational impact from sustainability factors has for several years been integrated into the ERM-process and is assessed by all divisions.

Use of value chain mapping

The assessments have been made both for SSAB's own business and for the Group impact through business relationships with suppliers and customers.

SSAB has no specific process to assess the impact on people and the environment as a consequence of greenhouse gas emissions from steelmaking.

Upstream value chain: SSAB's purchases are mainly from Sweden, Finland and other European countries (59% of purchases are from Europe), but also the USA (31%). Only a smaller proportion comes from other countries, and then mainly Australia. During 2024, SSAB purchased products, materials and services worth approximately SEK 77 billion. Iron ore is the largest purchasing category, followed by coal and coke and scrap.

Downstream value chain: SSAB's customers include companies in heavy transport, the construction industry, the automotive industry and construction and mining equipment. SSAB also distributes steel and other metals via Tibnor and offers steel-based construction products via Ruukki Construction.

Specific processes for climate-related matters

Process for climate-related physical risks:

Assessment of climate-related physical risks for the next three years is included in the annual Group-wide risk process for financial effects. Other assessments, which may be longer term, are currently done by obtaining various expert assessments as appropriate. For example, in 2022, SSAB commissioned SMHI (Swedish Meteorological and Hydrological Institute) to analyze potential physical climate risks at SSAB's production sites from two different climate scenarios.

At a local level, any physical climate risks are reviewed continuously, for example through downpour mapping. These are taken into account both in maintenance planning and in the implementation of new construction. At a local level, a more detailed analysis of specific climate factors has been conducted.

Assessment of climate-related physical risks in the value chain is managed by the responsible division as appropriate (SSAB has no Group-wide process).

Process for transformation risks and opportunities:

Assessment of the transformation risks and opportunities for the next three years is primarily done in the annual strategy and risk process but also on an ongoing basis in divisions and subsidiaries. SSAB began work on developing fossil-free steelmaking back in 2016 following an assessment of increased transformation risks through, for example, increased regulation and costs of carbon emissions as well as increased demand for fossil-free products.

SSAB's strategy to transform to fossil-free steelmaking is under continuous development. For example, in early 2022, SSAB's Board took a policy decision to bring forward the transformation of the Nordic production system by around 15 years, thanks to increased customer demand for products with a low carbon footprint.

SSAB has no Group-wide process to assess climate-related transformation risks in the value chain and the matter is dealt with as appropriate by the division responsible.

SSAB has no separate process for identifying sustainability-related opportunities and the assessment of these is part of both the ordinary strategy process and ongoing operations. SSAB's sustainability-related business opportunities lie mainly in the climate area, for example by reducing the carbon footprint of customers' products and in fossil-free steel partnerships.

Climate scenario analysis

SSAB has conducted scenario analysis to assess the resilience of its strategy. The two scenarios are based on the IPCC's climate scenarios RCP 2.6 and RCP 8.5, and descriptions in SSP1 and SSP5. The time horizon is motivated by an estimation of the steelmaking plants' lifetimes.

SSAB also commissioned SMHI to analyze the potential physical impacts of future climate changes at SSAB's largest steel production plants. The physical climate analysis included the climate factors that SSAB considered to be the most material: temperature, precipitation, wind strength and water supply. A total of 10 different indicators were analyzed. The analysis used three different time periods: short-term (until 2040), medium-term (2040–2070) and long-term (2070–2100).

Regardless of the climate scenario, a warmer climate with higher precipitation at SSAB's sites is expected, especially in the Nordics. The overall risk of a changed climate is assessed to be low for the Group as a whole for the next three years.

The conclusion was that SSAB's strategy to transform to fossil-free steelmaking and to shut down the blast furnaces in Sweden and Finland, and to be the first steel company to launch fossil-free steel onto the market is well positioned in these two climate scenarios. Regardless of the scenario, it is thought that there is a market for steel with a low carbon footprint even if the margins will vary.

Transition plan for climate change mitigation

Scope of the plan

SSAB's transformation plan covers:

• Entities and geographies: Nordic production system (Sweden and Finland), including all blast furnace-based production sites
• Value chain segments: Core operations (hot-rolling and upstream), downstream operations after hot rolling, and parts of Scope 3 (purchased goods and services, fuel and energy-related activities, upstream transport and distribution)
• Production sites: SSAB Raahe, SSAB Luleå, SSAB Oxelösund (Sweden and Finland)

Target year(s) for net zero / carbon neutral

• Net zero target: SSAB commits to reaching net zero greenhouse gas emissions throughout the value chain by 2045
• Long-term target: SSAB commits to reducing absolute greenhouse gas emissions in Scope 1, 2 and 3 by 93% by 2045 compared to the base year 2018

Scope 1, 2, 3 reduction milestones with baseline years

Base year: 2018

Short-term target (by 2033):

• SSAB commits to reduce absolute Scope 1, 2 and 3 (categories: purchased goods and services, fuel and energy-related activities and upstream transport and distribution) GHG emissions by 47.9% by 2033 compared to the base year 2018
• Sub-target: Reduction of Scope 1, 2 and 3 for core operations by 55.1% by 2033
• Sub-target: Reduction of Scope 1 and 2 outside core operations by 63.0% by 2033
• Sub-target: Reduction of Scope 3 outside core operations by 37.5% by 2033
• Intensity target: Reduce emissions by 56.8% per tonne of hot-rolled steel

Annual trajectory to 2033:

Alignment with 1.5°C / SBTi validation status

• Validation status: In 2024, SSAB's updated targets to reduce greenhouse gas emissions were approved by the Science Based Targets initiative (SBTi)
• 1.5°C alignment: The targets are validated as consistent with SBTi Criteria and Recommendations (Criteria version 5.1) and SBTi Corporate Net Zero Standard. SSAB's climate target is in line with the Paris Agreement's ambition of 1.5°C both for the net zero target (Scope 1, 2 and 3) and the near-term target (Scope 1 and 2)
• Well below 2°C: The target for other indirect emissions (Scope 3) is in line with the ambition level of "well below 2°C" for the target year 2033
• SSAB applies a sectoral decarbonization pathway for emissions within the system boundary of core operations in accordance with SBTi's steel guidance

Key levers / decarbonization pillars

Process transformation:

• Phase out traditional blast furnace-based steelmaking where coal and coke are used as reducing agents
• Replace five blast furnaces in Nordic steelmaking with electric arc furnaces
• Around 90% of SSAB's direct carbon dioxide emissions are derived from the blast furnaces
• Use a mix of fossil-free sponge iron and recycled steel scrap as raw material in new mini-mills

Energy:

• Electrification of processes
• Where electrification is not feasible, SSAB will strive to use renewable fossil-free fuels
• Remaining 10% of direct emissions from fossil fuels will be reduced by process electrification and using fossil-free fuels like biogas
• Systematic work on energy efficiency and recovery at all sites
• Electricity generation from process gases at steel mills

Product:

• Delivered around 50,000 tonnes of SSAB Zero steel in 2024, made using recycled steel and fossil-free energy, produced at Montpelier, USA
• Pilot deliveries continued of fossil-free steel based on fossil-free sponge iron produced with HYBRIT technology
• Customer demand for products with low fossil emissions is a main driver for transformation

Supply chain:

• Use of high-grade iron ore pellets
• SSAB's Supplier Code of Conduct encourages suppliers to take measures to reduce environmental impact

CapEx / investment commitments

Luleå investment (April 2024):

• State-of-the-art mini-mill with annual capacity of 2.5 million tonnes
• Two electric arc furnaces, advanced secondary metallurgy, direct strip rolling mill
• Cold rolling and galvanizing complex
• Investment amount: EUR 4.5 billion
• Will reduce SSAB's carbon dioxide emissions (Scope 1) by up to 3 million tonnes when completed

Oxelösund conversion:

• Electric arc furnace expected to start operating in late 2026
• Investment amount: SEK 6.2 billion (excluding power line)
• Will reduce SSAB's carbon dioxide emissions (Scope 1) by up to 1.5 million tonnes
• Capital expenditure in 2024: SEK 1,648 million

Overall capital expenditure:

• 2024: SEK 5,375 million total, of which SEK 2,601 million were strategic investments
• 2025 estimate: Around SEK 10 billion (increase mainly due to Luleå investment)

Financing:

• SSAB intends to finance the transformation of its Nordic production system through its own balance sheet
• Launched new combined Green and Sustainability-Linked Finance Framework to support transformation
• Framework includes climate targets validated by SBTi

Locked-in emissions and stranded asset analysis

Avoidance of locking-in effects:

• Implementation of SSAB's transformation is necessary for climate targets to be reached and to avoid the locking-in of greenhouse gas emissions
• If SSAB is unable to carry out its transformation, it will result in:
  • Continued operation of the blast furnace-based system
  • Increased costs in the form of emission allowances
  • Continued greenhouse gas emissions at current levels
  • Need for costly blast furnace and coke plant maintenance investments in the long term

Use of carbon credits / removals

Not explicitly disclosed in the provided excerpts.

Policies and governing documents

• Group Directive and instruction for environmental management: Includes SSAB's commitment to work with continuous improvements in the environmental subtopic, including greenhouse gas emissions. States that SSAB's environmental work must be conducted in accordance with ISO 14001
• Group Directive and instruction for energy: Includes SSAB's commitment to work with continuous improvements in energy efficiency and to support efforts to reduce greenhouse gas emissions by using fossil-free energy. Prioritizes electrification of processes
• Both directives are decided by SSAB's Group Executive Committee and reviewed at least annually
• Policy documents are available on SSAB's website
• Supplier Code of Conduct: Encourages suppliers to take measures to reduce environmental impact

Climate scenario analysis

SSAB has conducted climate scenario analysis based on:

• IPCC scenarios: RCP 2.6 (low future emissions) and RCP 8.5 (high future emissions)
• Time horizon: Medium-term perspective (approximately 2050), motivated by estimation of steelmaking plants' lifetimes
• Physical climate analysis: Commissioned Swedish Meteorological and Hydrological Institute (SMHI) to analyze potential physical impacts at largest steel production plants, including temperature, precipitation, wind strength and water supply

Scenario 1 (Low future emissions - ~2050):

• Global temperature rise limited to below 2°C
• Large steel companies have switched to fossil-free or low CO2 production
• Steel with low CO2 footprint becomes the new normal
• Fossil-free steel can probably justify higher added value during transitional period

Scenario 2 (High future emissions - ~2050):

• Global temperature rise of 4°C by end of century
• Many steel producers continue carbon-intensive production
• Small number assume niche position with low CO2 steel
• Demand for fossil-free steel exists but to lesser extent than Scenario 1
• Price premium for fossil-free steel not as distinct

Governance

• SSAB's plans to transform to fossil-free steelmaking, including the investment framework, are decided by the Board
• The Board follows up the plans at each meeting
• The transformation to fossil-free steelmaking is progressing to plan

Policies related to climate change mitigation and adaptation

SSAB's work on managing climate issues is governed by two main policy documents that address climate change mitigation and adaptation:

Group Directive and Instruction - Environmental Management

• Policy name: Group Directive and instruction for environmental management
• Scope: SSAB's operations and work with these issues together with suppliers and customers
• Approval and oversight: Decided by SSAB's Group Executive Committee; reviewed at least annually
• Key content/principles: Includes SSAB's commitment to work with continuous improvements in the environmental subtopic, including greenhouse gas emissions and other ways to address and limit the effects of climate change. States that SSAB's environmental work must be conducted in accordance with ISO 14001
• Stakeholder engagement: Stakeholder views have been taken into account within the scope of the materiality assessment but had no direct involvement in the development of policy documents
• Monitoring: The policy documents contain no target formulations and targets are developed for each respective area in a separate process

Group Directive and Instruction regarding Energy

• Policy name: Group Directive and instruction regarding energy
• Scope: SSAB's operations and work with these issues together with suppliers and customers
• Approval and oversight: Decided by SSAB's Group Executive Committee; reviewed at least annually
• Key content/principles: Includes SSAB's commitment to work with continuous improvements in the energy subtopic and in turn to improve the Group's energy efficiency and to support efforts to reduce greenhouse gas emissions by using fossil-free energy. The Instruction specifies prioritizing the electrification of processes. Where electrification is not feasible, SSAB will strive to use renewable fossil-free fuels
• Stakeholder engagement: Stakeholder views have been taken into account within the scope of the materiality assessment but had no direct involvement in the development of policy documents
• Monitoring: The policy documents contain no target formulations and targets are developed for each respective area in a separate process

Climate Policy Engagement

SSAB has also adopted a Climate Policy Engagement policy:

• Policy name: Climate policy engagement
• Approval and oversight: Adopted by the CEO
• Key content/principles: Based on the corporate strategy, the Code of Conduct and SSAB's support for the goals in the Paris Agreement. SSAB supports the European Green Deal and Climate Law, including the target of a 55% reduction in greenhouse gas emissions by 2030 and climate neutrality by 2050. The policy addresses issues related to climate policy, energy policy, industrial policy, public funding, and industry competitiveness
• International standards: SSAB's support for the goals in the Paris Agreement is explicitly referenced
• Public availability: For lobbying activities in the EU, SSAB is registered in the EU Transparency Register
• Memberships: SSAB participates in various industry associations including Energy Transitions Commission (ETC), First Movers Coalition, Eurofer, European Corporate Leadership Group (CLG Europe), Jernkontoret, Confederation of Swedish Enterprise, Fossil Free Sweden, and others

Actions and resources in relation to climate change policies

Main transformation action: Phase-out of blast furnace-based steelmaking

Description and scope: The main key actions planned by SSAB are to phase out traditional blast furnace-based steelmaking where coal and coke are used as reducing agents in making crude iron from iron ore. Around 90% of SSAB's direct carbon dioxide emissions are derived from the total of five blast furnaces in Nordic steelmaking. The plans are to replace the blast furnaces with electric arc furnaces. This makes the transformation to fossil-free steelmaking with the decommissioning of blast furnaces and coke plants alike the main activities to reach the climate targets.

Technology focus:

• Hydrogen-based direct reduction (DRI) in ironmaking, being developed by Hybrit Development AB, based on fossil-free electricity
• Electric arc furnaces (EAF) in steelmaking
• Shift to fossil-free energy sources throughout SSAB's operations
• Technology development that can accelerate the global transformation across the entire steel industry

Value chain scope: Own operations (Nordic steelmaking operations in Sweden and Finland)

Time horizon:

• Near-term target year: 2033 (47.9% reduction in Scope 1, 2 and 3)
• Long-term target year: 2045 (93% reduction in Scope 1, 2 and 3; net zero across value chain)
• The road towards reaching the climate targets will follow a stepwise reduction pathway, with the transformation of blast furnace-based steelmaking in Sweden and Finland contributing the most to meeting the targets

Resources allocated:

• SSAB's capex consists of the planned investments in Oxelösund and Luleå
• SSAB has obtained third party verification confirming potential taxonomy compatibility for both mills
• Since the plants are under construction, climate change adaptation actions have not yet been implemented in full
• Since completion of the mills is at the end of the defined five-year period, SSAB has for now not included operating expenditure in the plan as this is difficult to assess
• No specific quantified capex or opex amounts are disclosed in the excerpts provided

Funding: During the year, SSAB published an updated framework for green and sustainability-linked bonds. No bonds were issued under the framework during 2024.

Expected outcomes:

• Meet the Paris Agreement ambition of 1.5°C for net zero target (Scope 1, 2 and 3) and near-term target (Scope 1 and 2)
• Meet political ambitions communicated both globally and in countries where SSAB has steelmaking operations
• Make a major contribution to national climate targets in Finland and Sweden

Link to targets: This transformation directly supports SSAB's SBTi-validated climate targets:

• Near-term: 47.9% absolute reduction in Scope 1, 2 and 3 by 2033
• Long-term: 93% absolute reduction in Scope 1, 2 and 3 by 2045
• Net zero: Net zero greenhouse gas emissions throughout the value chain by 2045

Supply chain actions

Work with climate issues in the supply chain is covered by SSAB's Supplier Code of Conduct, which is described more fully under Business Conduct, disclosure G1-2.

Targets related to climate change mitigation and adaptation

Overview

SSAB's climate targets were approved by the Science Based Targets initiative (SBTi) in 2024, validated as consistent with SBTi Criteria and Recommendations (Criteria version 5.1) and SBTi Corporate Net Zero Standard. The targets are in line with the ambition of the Paris Agreement to limit global warming to 1.5°C.

Near-term target (Scope 1, 2 and 3)

Target metric: Absolute greenhouse gas emissions in Scope 1, 2 and 3

Target value: 47.9% reduction

Target year: 2033

Baseline year: 2018

Baseline value: 21,130 thousand tonnes CO₂e (overall); comprising:

• Core operations (Scope 1, 2, 3): 12,201 thousand tonnes
• Outside core operations (Scope 1, 2): 222 thousand tonnes
• Scope 3 outside core operations: 8,707 thousand tonnes

Scope:

• Scope 1, 2 and 3 (categories: purchased goods and services, fuel and energy-related activities, and upstream transport and distribution)
• Covers SSAB's own operations and parts of value chain

Type: Absolute target (with sub-targets as follows):

• Core operations (Scope 1, 2, 3): 55.1% reduction
• Outside core operations (Scope 1, 2): 63.0% reduction
• Scope 3 outside core operations: 37.5% reduction
• Intensity target: 56.8% reduction per tonne of hot-rolled steel (with maximum 63% scrap permitted)

Validation: Science-based, validated by SBTi (2024)

Progress to date (2024):

• Actual emissions: 19.6 million tonnes CO₂e
• Reduction vs baseline: 7.1% (1.5 million tonnes)
• Emissions per tonne hot-rolled steel: reduced by 1.1%
• Percentage of scrap across Group: 39%

Target trajectory:

Long-term target (Scope 1, 2 and 3)

Target metric: Absolute greenhouse gas emissions in Scope 1, 2 and 3

Target value: 93% reduction

Target year: 2045

Baseline year: 2018

Baseline value: 22,821 thousand tonnes CO₂e

Scope: Scope 1, 2 and 3 (including category 10: Processing of sold products)

Type: Absolute target

Validation: Science-based, validated by SBTi

Progress to date: Not currently reported (methodology development ongoing for Scope 3 category 10)

Net zero target

Target metric: Net zero greenhouse gas emissions throughout the value chain

Target value: Net zero

Target year: 2045

Baseline year: 2018

Baseline value: 22,821 thousand tonnes CO₂e

Scope: Entire value chain (Scope 1, 2 and 3)

Type: Absolute target (net zero)

Validation: Science-based, validated by SBTi

Progress to date: Not currently reported

Methodological notes

• The near-term target applies a sectoral decarbonization pathway for emissions within the system boundary of core operations in accordance with SBTi's steel guidance
• For emissions outside this boundary, the absolute contraction approach is used
• The targets are in line with the 1.5°C requirement level, so the reference target value for 1.5°C is the same as SSAB's target value
• The transformation to fossil-free steelmaking, including closing blast furnaces in Sweden and Finland and replacing them with electric arc furnaces, is the main pathway to achieve these targets

Alignment with Paris Agreement

SSAB's climate targets are validated by SBTi as being in line with the Paris Agreement's ambition to limit global warming to 1.5°C for:

• Net zero target (Scope 1, 2 and 3): 1.5°C aligned
• Near-term target (Scope 1 and 2): 1.5°C aligned
• Near-term target for other indirect emissions (Scope 3): "well below 2°C" for target year 2033

Energy consumption and mix

Total energy consumption

Total energy consumption (including electricity, purchased fuels and purchased heat) was 8,927 GWh (2024), 9,142 GWh (2023), 8,961 GWh (2022), 9,375 GWh (2021), and 9,082 GWh (2020).

Energy intensity amounted to 1,215 kWh/tonne crude steel (2024), compared to 1,175 kWh/tonne crude steel (2023).

Energy consumption and mix (GRI 302-1)

Electricity consumption by energy source (2024)

The report includes a pie chart showing the breakdown of electricity consumption:

• Fossil energy: 20%
• Nuclear power: 26%
• Renewable energy: 34%
• Own process gases: 21%

Energy consumption by region (2024)

Scope and methodology

The energy disclosures cover the use of electricity, purchased fuels and purchased heat. The use of electricity includes external companies within the industrial areas.

Electricity is the largest energy source, accounting for approximately 50% of total energy consumption. Electricity is used primarily to power the electric arc furnaces at the US sites. Natural gas, propane and fuel oil are mainly used for various heating and heat treatment processes.

In Finland and Sweden, SSAB purchases some fossil-free electricity verified by guarantees of origin. At the Montpelier, USA site, the electricity supplier gives local industrial customers priority for renewable, mainly wind power, electricity.

Gross Scopes 1, 2, 3 and Total GHG emissions

SSAB reports GHG emissions in accordance with GRI Standards (GRI 305-1, 305-2, 305-3, 305-4) and has applied the phase-in option for ESRS E1-6. Below are the metrics disclosed in the 2024 Annual Report.

Scope 1 GHG emissions

Scope 1 emissions cover SSAB's direct emissions from steelmaking operations, primarily from blast furnaces and coke plants. No sub-breakdown by emission source (stationary combustion, mobile combustion, process emissions, fugitive emissions) was disclosed.

Scope 2 GHG emissions

Scope 2 emissions relate to purchased electricity and energy. The report does not separately disclose location-based and market-based figures for Scope 2.

Scope 3 GHG emissions

SSAB has not disclosed Scope 3 emissions by GHG Protocol category in this report. The company has applied the phase-in opportunity under ESRS E1-6.

Total GHG emissions

No total GHG emissions figure (Scope 1 + 2 + 3) was disclosed for 2024.

GHG intensity

No GHG intensity metric (e.g., tCO₂eq per unit of revenue or per tonne of steel) was disclosed.

Biogenic CO₂

No separate disclosure of biogenic CO₂ emissions was provided.

Regulated emissions (EU ETS)

The report references SSAB's participation in the EU Emissions Trading System (EU ETS) and notes that the company has been purchasing allowances since 2018. However, no quantitative metric for regulated emissions under EU ETS was disclosed.

Methodology and scope notes

• Reporting boundary: Environmental data includes production sites in Sweden (Oxelösund, Virsbo, Luleå, Borlänge, Finspång, Köping), Finland (Raahe, Hämeenlinna, Kankaanpää, Oulainen, Pulkkila, Toijala), USA (Mobile, Montpelier), and Poland (Oborniki). Unless otherwise stated, associated companies, joint ventures, and subcontractors are not included.
• Standards: SSAB reports under GRI Standards (GRI 305) for emissions. The company has applied the phase-in option for ESRS E1-6 (formerly E1-8) and has not disclosed Scope 3 emissions by category.
• Baseline and targets: The report references a baseline year of 2018 for GHG reduction targets, with a target of 47.9% reduction by 2033 (Scope 1, 2, and selected Scope 3 categories). For 2024, emissions decreased by 7.1% compared to 2018 levels.
• SSAB Zero: SSAB launched a low-emission steel product (SSAB Zero) with less than 0.05 kg CO₂e per kg of steel, produced using recycled scrap and fossil-free energy. Over 50,000 tonnes were delivered in 2024.

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

Phase-in exemption applied

SSAB has chosen not to report on E1-9 for 2024. The disclosure requirements table indicates that ESRS E1-9 and its specific requirements (66, 66a, 66c, 67c, 69) are "Not included (phase-in opportunity)".

Limited financial information provided

While SSAB has not provided comprehensive E1-9 disclosures, the company states that:

"financial information linked to climate is described in notes A.2. and C.1. Price hedges of electricity consumption in the Nordic region by financial instrument and physical delivery are described in note D.1. Electricity prices in the USA are regulated in each state."

Asset useful life implications

SSAB notes one specific financial effect related to the transformation:

"The change in the useful life of assets that will be replaced in the new production system in conjunction with the transformation is an example of a decision taken as a result of such an evaluation."

This relates to existing blast furnace assets that will be replaced as part of the fossil-free steel transformation.

Time horizons used in scenario analysis

For climate scenario analysis purposes (not E1-9 quantification), SSAB uses:

• Short-term: until 2040
• Medium-term: 2040–2070
• Long-term: 2070–2100

These time horizons are longer than those normally included in SSAB's strategic and financial planning and differ from those indicated in ESRS 1 because long time horizons are required to model climate changes.

Policies related to own workforce

SSAB discloses several policies related to its own workforce under ESRS S1-1.

Code of Conduct

Policy name: Code of Conduct

Scope: All employees across SSAB's operations globally

Approval and oversight:

• Reviewed at least once a year
• Decided by the Board of Directors
• The Board approves the Code of Conduct as part of the Board's responsibility for sustainability work

Key content and principles:

• Sets out SSAB's principles for business conduct and serves as the Group's ethical compass
• Covers areas such as health and safety, the environment, human rights and business ethics
• States that SSAB recognizes and respects employees' right to freedom of association and collective bargaining
• Complies with applicable laws, industry standards and collective agreements on working hours, including overtime and overtime pay
• Ensures sufficient time for rest and free time and commits to paying fair wages
• Does not tolerate any form of discrimination
• Zero tolerance for harassment and no forms of child labor, forced labor, slave labor or illegal labor, including trafficking and other forms of modern slavery

Link to international standards:

• Based on SSAB's support for UN Global Compact principles
• International Bill of Human Rights
• Core conventions of the International Labour Organization (ILO)
• OECD Guidelines for Multinational Enterprises
• UN Guiding Principles on Business and Human Rights
• SSAB has committed to implementing processes to prevent, identify and address adverse impacts on human rights

Public availability: Available on the SSAB website. The Code is supplemented by a guide to further clarify SSAB's fundamental principles.

Monitoring and implementation:

• Mandatory training on the Code of Conduct for all employees, including working conditions and human rights
• Training module available in ten languages and must be completed every three years
• During 2024, 85% of new employees completed training in the Code of Conduct
• Violations can be reported through reporting and whistleblowing channels, including the Ethics Line
• Each HR department monitors compliance in consultation with management teams and trade unions in accordance with valid collective agreements
• Annual employee survey is an important instrument for following up that the policy is promoted

Group Directive and instruction - Health and Safety

Policy name: Group Directive and instruction regarding health and safety

Scope: All SSAB's employees and contractors at SSAB's sites

Approval and oversight:

• Decided by the Group Executive Committee
• Reviewed at least annually

Key content and principles:

• Includes SSAB's goal to be the world's safest steel company, to have zero workplace accidents and diseases
• Emphasizes the importance of uncompromising safety performance and individual responsibility for working safely
• Safety work is a part of the integrated management system
• Subcontractors have the same right to a safe workplace as SSAB's own workers
• SSAB's ambition is to prevent all accidents and occupational diseases
• Based on principles that all accidents and occupational diseases can and must be prevented; employee engagement and education are required for successful safety work; safe working is a requirement for employment at SSAB; good work in health and safety also delivers good business results; health and safety issues must be integrated into the business process

Public availability: Available on SSAB's website

Monitoring and implementation:

• Safety management system meets the requirements of ISO 45001 and has been implemented at all SSAB sites
• All SSAB's employees and contractors are included in safety work and have both an opportunity and duty to report deviations, incidents and potential hazards at the workplace
• Employees take part in safety rounds to identify risks and improve health and safety
• Root causes of incidents are identified to prevent a recurrence
• All employees and contractors have access to instructions, training and equipment necessary to ensure safe working
• Divisions and subsidiaries are responsible for safety work and lead many activities and projects related to the area
• Targets set for LTIF (Lost Time Injury Frequency) below 1.0 and TRIF (Total Recordable Injury Frequency) below 5.5 for 2024

Group Directive and instruction - Inclusion and Diversity

Policy name: Group Directive and instruction for inclusion and diversity

Scope: SSAB's business (all employees)

Approval and oversight:

• Decided by the Group Executive Committee
• Reviewed at least once a year

Key content and principles:

• Serves as a framework for how SSAB works to create an inclusive workplace where all employees have equal possibilities to participate and be involved in SSAB's business
• Ensures similar conditions for all employees
• Addresses discrimination on nine grounds: gender, transgender identity or expression, ethnic or national affiliation, religion, disability, age, sexual orientation, marital or parental status, political opinion or trade union membership
• Zero tolerance for discrimination and harassment
• Promotes a non-discriminatory corporate culture

Public availability: Not explicitly stated in the excerpts, though described as part of Group-level policy documents

Monitoring and implementation:

• Supplemented by an employee handbook and various training events
• Inclusion and diversity and a non-discriminatory corporate culture are part of the mandatory training on the Code of Conduct
• SSAB's whistleblowing scheme, Ethics Line, is an important channel to ensure zero tolerance for discrimination
• Employee survey is an important instrument for following up that the policy and work on inclusion and diversity are promoted in general
• Target set for share of women in line manager positions: 24% by 2025

Group Directive and instruction - Environmental Management

Policy name: Group Directive and instruction - Environmental Management

Scope: SSAB's operations (all employees with relevant responsibilities)

Approval and oversight:

• Decided and reviewed by SSAB's Group Executive Committee at least annually

Key content and principles:

• Includes SSAB's commitment to work systematically with continuous improvements on the environmental front
• Commitment to reduce the Group's environmental impact in terms of emissions to air and water
• Includes SSAB's environmental work being conducted in compliance with ISO 14001
• Each division and subsidiary has a dedicated environmental function responsible for monitoring laws and requirements, processing permit applications and for measuring and reporting emissions

Public availability: Available on the SSAB website

Monitoring and implementation:

• The environmental management system covers all SSAB's operations and all production plants are certified according to ISO 14001
• Group Executive Committee is ultimately responsible for ensuring that divisions and subsidiaries operate in line with Group directives and instructions
• Divisions and subsidiaries are responsible for ensuring that emissions are kept within the framework of discharge conditions and other requirements from the environmental authorities

Policy document for just transition

Policy name: Code of Conduct (applied to just transition)

Scope: Personnel matters linked to the strategic transformation to fossil-free steelmaking

Key content and principles:

• The Code of Conduct serves as the starting point for personnel matters linked to the strategic transformation
• Addresses how the transformation to fossil-free steelmaking can involve a change in tasks at sites
• SSAB is actively working on development of new core competences and training in new work practices with regard to employees affected

Monitoring and implementation:

• SSAB has regular meetings with employees to inform them about the planned transformation and to provide them with an opportunity to ask questions
• Dialogue with trade union representatives concerning skills development in conjunction with the transformation

Taking action on material impacts on own workforce

Safety

In SSAB's operations employees and contractors are at risk of accident and injury, primarily at the production sites. The most common types of accidents are wounds, sprains, strains, fractures and concussion.

All employees and contractors are encouraged to make suggestions on how practices can be improved to enable a safer work environment. All employees and contractors have access to instructions, training and equipment necessary to ensure safe working.

Divisions and subsidiaries are responsible for safety work and lead many activities and projects related to the area.

Scope: Own operations (employees and contractors at production sites) Time horizon: Not specified Resources allocated: Not quantified Expected outcomes: Reduction in accidents and injuries, monitored through LTIF and TRIF targets

Inclusion and Diversity

SSAB continues to participate in several different networks aimed at increasing diversity in the steel industry:

• Female Leader Engineer (Sweden)
• Tekniksprånget (Sweden)
• Women in Tech (Finland)
• Inklusiiv (Finland)
• Association of Women in the Metal Industries (USA)

The HR function at Group level is responsible for Group-wide policy of inclusion and diversity and for developing targets and definitions. SSAB continued to work with internal and external communications to strengthen knowledge about inclusion and diversity.

Divisions and subsidiaries are responsible for developing appropriate actions and initiatives at local level:

• SSAB Special Steels: Activities to counteract unconscious bias with regard to recruitment
• SSAB Americas: Training to managers on how to support and develop an inclusive work environment
• Luleå mill transformation: Design of new production plant aims to improve work environment, e.g. avoiding heavy lifts

Scope: Own operations (all divisions and subsidiaries) Time horizon: Long term Resources allocated: Not quantified Expected outcomes: Improved gender balance and diversity; share of females in management tracked as KPI

Just Transition (Skills Development)

SSAB Academy (Luleå): SSAB has received support from the EU's Just Transition Fund for skills development in line with the company's needs arising from transformation to fossil-free steelmaking.

Training initiatives implemented during the year:

• Education for industrial electricians
• Leadership training
• Pilot training in automation for electricians
• Training initiatives to strengthen knowledge about Luleå's transformation

Employee-initiated training: Training where employees themselves take the initiative, aimed at skills development and contributing to SSAB's transformation. This has led to several training initiatives in maintenance, material science, loading and unloading.

A survey of skills needs is carried out prior to the start of new training courses, including dialogues with participants and people with skills in the relevant area. Trade unions are included in the SSAB Academy steering group.

Scope: Own operations (focus on Luleå site) Time horizon: Not specified (linked to transformation timeline) Resources allocated: EU Just Transition Fund support (amount not specified); SSAB Academy works with Group-wide HR organization Expected outcomes: New core competences and new practices for fossil-free steelmaking; no specific targets disclosed Link to policy: Addresses just transition in context of transformation to fossil-free steelmaking

Training and Skills Development

Several internal development programs:

• Internal business development program
• Training module for middle managers
• Trainee programs (focus on technology and leadership)

Annual Talks: Key element of skills development with focus on employee's individual development plan. 92% of office workers had Annual Talks in 2024.

Scope: Own operations (all employees) Time horizon: Ongoing Resources allocated: Not quantified Expected outcomes: Employees have right conditions for skills development; 92% Annual Talks participation for office workers

Targets related to own workforce

Safety

SSAB primarily monitors safety work through lost time injury frequency (LTIF) and total recordable injury frequency (TRIF) per million hours worked.

Target characteristics:

• Metric: Lost time injury frequency (LTIF) and total recordable injury frequency (TRIF) per million hours worked
• Scope: Own workers and contractors
• Governance: Group targets are decided by the Group Executive Committee. All divisions and subsidiaries have annual LTIF and TRIF targets
• Reporting: Outcome is reported monthly to the Group Executive Committee
• Stakeholder involvement: Employee and contractor representatives are involved in the target setting process, which also includes an assessment of earlier outcomes and targets
• Target values: Not disclosed in the excerpts
• Baseline year and value: Not disclosed in the excerpts
• Target year: Annual targets mentioned, but specific target year not disclosed

Note: The policy documents contain no target formulations and targets are developed for each respective area in a separate process.

Inclusion and diversity

Work in the area of inclusion and diversity is monitored by several key performance indicators, of which the share of females in management is presented in the note section.

Target characteristics:

• Metric: Share of females in management (among other KPIs)
• Target values: Not disclosed in the excerpts
• Baseline year and value: Not disclosed
• Target year: Not disclosed
• Note: The excerpts state that "Work on inclusion and diversity is long term and given the gender imbalance in the industry, it will take time before the activities are effective."

Skills development

Work to develop worker skills in conjunction with SSAB's transformation is not covered by any targets.

Characteristics of the undertaking's employees

Total headcount and FTE

Total workforce:

Permanent employees at year-end:

Note: The key figures section states "Employees1)" with footnote "1) Permanent employees at year end."

Headcount by gender

Permanent employees:

Total workforce:

Temporary employees:

Full-time employees:

Headcount by country/region

Permanent employees by country:

Temporary employees by country:

Full-time employees by country:

Total workforce by region (key figures):

Headcount by employment contract type

Contract type (as % of total workforce):

Absolute numbers:

• Permanent employees: 14,618 (2024), 14,565 (2023), 14,568 (2022)
• Temporary employees: 645 (2024), 561 (2023), 758 (2022)

Note: No disclosure of non-guaranteed hours contracts.

Headcount by employment type (full-time/part-time)

Employment type (as % of total workforce):

Absolute numbers:

• Full-time employees: 14,811 (2024), 14,715 (2023), 14,921 (2022)

Employee turnover

Total employee turnover rate:

Employee turnover by country:

Employee turnover by gender:

Note: Employee turnover comprises permanent employees and is calculated by the total number of employees who left the company divided by the average number of employees during the year (at each quarter).

New employee hires

Total new employee hires:

New employee hires by country:

New employee hires by gender:

Note: New employee hires relates to the number of new permanently employed employees during the year.

Accounting principles

Total workforce relates to the total number of employees at year end and includes both permanent and temporary employees.

Temporary employees comprises various fixed-term employments such as holiday substitutes and students. Relates to year end.

Part-time employees comprises employees who work less than 100%. Relates to year end.

New employee hires relates to the number of new permanently employed employees during the year.

Employee turnover comprises permanent employees and is calculated by the total number of employees who left the company divided by the average number of employees during the year (at each quarter).

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

Non-employee workforce overview

SSAB uses different contractors, partners and external consultants across all parts of the organization and in different work areas including cleaning of premises, maintenance work at production sites and various IT services. SSAB does not have a central follow-up of different external resources; this is managed at a local level.

Safety metrics including contractors

SSAB includes contractors in safety monitoring and reporting:

Lost time injury frequency (LTIF) and Total recordable injury frequency (TRIF) including contractors:

Contractor-specific safety data (2024):

Contractor safety data (historical):

Methodology

Counting approach: Hours worked by contractors are tracked separately from employees. LTIF relates to the number of injuries resulting in an absence of more than one day per million working hours. TRIF relates to total recordable injuries per million hours worked, including lost time injuries, medical treatment injuries, and restricted work injuries. For contractors in the USA, medical treatment injuries and restricted work injuries are not included in TRIF.

Scope: Contractors included in safety metrics are those performing work at SSAB's sites. All contractors' employees must undergo both general and local safety training courses for the specific site where they will be working.

Collective bargaining coverage and social dialogue

Collective bargaining coverage

All SSAB's employees in Finland and Sweden are covered by collective agreements that are consistent with internationally recognized instruments and regulate, for example, wages, working hours and other employee terms and conditions. Different arrangements are in place for employees in the USA and other countries in accordance with national practice and legislation.

Employees covered by collective bargaining agreements, %

Works council and social dialogue arrangements

SSAB has established several social dialogue bodies:

Group Works Council: Members of the Group Executive Committee meet employee representatives of employees in Finland and Sweden on a quarterly basis.

Division Works Council: Divisional management meets employee representatives eight times a year.

Local Works Council: Management at each site meets local employee representatives.

European Works Council: SSAB has a European Works Council, which is regulated by a special agreement. This involves employee representatives from SSAB's operations (with more than 75 employees) in all countries in Europe meeting SSAB's management once a year.

Employee representation

Most employees in Finland and Sweden are represented by trade unions. Agreements with trade unions ensure that engagement and exchange of information take place in a structural way.

Diversity metrics

Board of Directors

Members appointed by the employees (6) are not included.

Group Executive Committee

All employees

Frontline workers

Office employees

Additional disclosures

• Share of women in line management: 22%
• Board of Directors' members who are women (Group-wide): 17% (16% in 2023)
• Board of Directors' members who are women (parent company): 44% (43% in 2023)
• Share of women in management groups (including Presidents) in the Group: 20% (22% in 2023)

Social protection

Disclosure Status

EDRS S1-11 is reported as not included (not material) in SSAB's sustainability statement.

Pension Coverage Information

While S1-11 is not formally disclosed, the following pension information is available from the financial statements:

Sweden:

• Blue collar employees: Covered by SAF/LO plan (defined contribution)
• White-collar employees: Covered by ITP plan (defined contribution and defined benefit)
  • ITP1 plan: Employees born 1979 or later (defined contribution)
  • ITP2 plan: Employees born before 1979 (defined benefit)
  • Part of ITP2 covered through insurance with Alecta

Finland:

• Rautaruukki's Finnish pension scheme (A-säätiö) - defined benefit plan

Norway:

• CCB Pensionskasse - defined benefit plan

USA and Canada:

• Smaller pension plans exist

President and Group Executive Committee:

• President: Retirement age 65, pension based on contributions covered by insurance, cost 30% of fixed salary in 2024
• Other GEC members: Minimum retirement age 62, pensions based on contributions
• Exception: Olavi Huhtala covered by benefit-based pension via Rautaruukin Eläkesäätiö (possible retirement age 60)
• Exception: Charles Schmitt's pension scheme in line with US legislation and practice

Pension Expenses (SEK millions)

Expected fees in 2025 for ITP2 insurances with Alecta: SEK 54 million

Persons with disabilities

ESRS S1-12 is listed as Not included (not material) in SSAB's disclosure index.

No data on the percentage of employees with disabilities, methodology, or country exclusions has been disclosed.

Training and skills development metrics

Annual Talks (Performance Reviews)

Office workers with Annual Talks: 92% (2024), 92% (2023)

Training Programs

SSAB has several internal development programs for different levels of the organization, such as an internal business development program and a training module for middle managers. SSAB also has trainee programs, for example with a focus on technology and leadership.

One key element of skills development is the Annual Talks, where there is focus on the employee's individual development plan. Depending on SSAB's strategy and future needs, upskilling initiatives to ensure that employees have the right conditions for skills development.

Skills Development in Transformation

SSAB's transformation to fossil-free steelmaking can involve a change in tasks at the sites when, for example, the blast furnaces and coke plants are shut down. SSAB is actively working on the development of new core competences and training in new work practices with regard to those employees affected, for example in Luleå.

Data Limitations

Average training hours per employee (overall, by gender, or by employee category) are not disclosed. Total investment in training (€) is not disclosed.

Health and safety metrics

Coverage by health and safety management system

100% of SSAB's employees and contractors are covered by the company's health and safety management system. The safety management system meets the requirements of ISO 45001 and has been implemented at all SSAB sites.

Work-related injuries and fatalities

Metrics definitions:

• LTIF (Lost time injury frequency): Number of injuries resulting in an absence of more than one day per million hours worked
• TRIF (Total recordable injury frequency): Total recordable injuries per million hours worked, including lost time injuries, medical treatment injuries and restricted work injuries
• High consequence LTI: Injury that the employee cannot or is not expected to recover from within 6 months
• TRIF for contractors excludes medical treatment injuries and restricted work injuries in the USA

Work-related ill health

SSAB has no structured reporting of work-related ill-health. Information in the report concerns only work-related injuries.

Days lost

No disclosure of number of days lost or absentee rate.

Compensation metrics

Pay gap

SSAB does not currently disclose gender pay gaps at Group level. Work is underway to define the concept of pay gap and to develop qualitative input taking into account the EU Pay Transparency Directive, which will apply from 2026.

Remuneration ratio

The annual total remuneration of the highest paid individual and the average of annual total remuneration for all employees are shown in the Remuneration Report.

Remuneration and company performance in the reported financial year

Methodology

The CEO total remuneration includes Johnny Sjöström from October 28 to December 31, 2024 and Martin Lindqvist from January 1 to October 27, 2024. The average remuneration relates to employees of the parent company excluding members of the Group Executive Committee.

Incidents, complaints and severe human rights impacts

Complaints and incidents

The number of complaints submitted through reporting and whistleblowing channels is shown in G1-1. No complaints were reported through the OECD National Contact Points for Multinational Enterprises, nor were any sanctions or damages awarded. No detected cases of severe human rights impacts and incidents occurred during the period.

Discrimination cases

No discrimination cases concerning gender, ethnicity, nationality, religion or belief, or disability were reported. No reports of human rights violations were received.

Ethics Line reports

According to G1-1 disclosures: cases are still under investigation and 28 cases were considered not to be within the scope of whistleblowing cases and the persons reporting were referred to other reporting channels. The number of reports in the Ethics Line shows that employees are aware of and trust the reporting structures.

Sanctions and fines

Nor were any sanctions or damages imposed for cases reported to the Ethics Line.

Human trafficking and forced labour

SSAB supports and respects internationally recognized human rights and has taken several measures to prevent child labor, forced labor, slavery and human trafficking from occurring in the supply chain. These measures include updating SSAB's Supplier Code of Conduct, risk assessments and audits, and training SSAB's employees.

No conflict minerals (gold, tin, tungsten, wolfram and tantalum) are used by SSAB.

Incidents of corruption or bribery

Confirmed incidents

SSAB reports that there were no incidents of corruption to report in accordance with current regulations during 2024.

Convictions and fines

No convictions or fines related to corruption or bribery are disclosed for the reporting period.

Disciplinary actions

No specific information is provided regarding employees dismissed or disciplined due to corruption or bribery incidents during 2024.

Contracts terminated

No information is provided regarding contracts with business partners terminated or not renewed due to corruption or bribery.

Investigation procedures and speak-up mechanisms

Reporting channels

SSAB operates a global whistleblowing system called Ethics Line, which is available in almost all countries where SSAB operates and supports 13 languages. The system allows anonymous reporting 24/7 either online or by telephone. Both internal and external stakeholders can submit reports through this channel.

Reports are forwarded to an internal steering group consisting of SSAB's head of Internal Audit, head of Ethics & Compliance, and head of HR Compliance. The steering group ensures that cases (including any corruption and bribery offenses) are investigated promptly, independently, and objectively.

Protection against retaliation

SSAB's Code of Conduct explicitly states that no person who reports irregularities on reasonable grounds may be subjected to reprisals or harassment. The whistleblowing system instructions mandate that whistleblowers must not be subject to retaliation for reporting.

2024 reporting statistics

In 2024, 37 incidents (39 in 2023) were reported via the Ethics Line. After investigation:

• 5 cases were considered to be within the scope of whistleblowing cases
• Action was taken in 2 cases (related to compliance with rules)
• 4 cases were still under investigation
• 28 cases were not within the scope of whistleblowing cases

No discrimination cases concerning gender, ethnicity, nationality, religion or belief, or disability were reported. No reports of human rights violations were received. No sanctions or damages were imposed for cases reported to the Ethics Line.

Internal audits

During 2024, internal audit conducted audits of subsidiaries where risks concerning fraud and corruption were part of the audit scope. The audits did not reveal any concrete irregularities; however, opportunities to reduce risks were identified and addressed through established action plans.

Training

SSAB conducts regular training on business conduct, anti-corruption, and competition law, aimed primarily at managers and employees in sales and purchasing who are at greater risk of being exposed to corruption. At year-end 2024:

• 97% (94% in 2023) of the target group had completed training in competition law
• 94% (90% in 2023) had completed training on anti-corruption
• 85% of new employees completed training in the Code of Conduct

All members of the Group Executive Committee have completed this training.

Political influence and lobbying activities

Disclosure statement

SSAB has assessed ESRS G1-5 (Political influence and lobbying activities) as not material and therefore does not provide detailed disclosures on political contributions, lobbying expenditure, or trade association membership fees.

According to the ESRS index on page 84 of the Annual Report:

• ESRS G1-5: Not included (not material)
• ESRS G1-6: Not included (not material)

Climate policy engagement

While detailed G1-5 disclosures are not provided, SSAB describes its climate policy engagement approach on page 121:

Political engagement approach: SSAB's collaboration with political decision-makers, on a global, European and national level, aims to inform about opportunities and challenges associated with the decarbonization of the steel industry. Climate policy, energy policy and industrial policy are areas of specific interest for SSAB, as well as issues related to public funding and efficient permit processes.

Ethical standards and guidelines: SSAB's climate policy engagement is adopted by the CEO and is based on the corporate strategy, the Code of Conduct and SSAB's support for the goals in the Paris Agreement.

EU Transparency Register: For lobbying activities in the EU, SSAB is registered in the EU Transparency Register (no ID provided).

Focus areas

SSAB is pursuing the following issues:

• Climate policy: SSAB supports the European Green Deal and Climate Law, including the target of a 55% reduction in greenhouse gas emissions by 2030 and climate neutrality by 2050.
• Energy policy: Access to fossil-free electricity at competitive and predictable prices, and well-functioning electricity markets and transmission grids are important issues for SSAB.
• EU ETS and CBAM: SSAB supports effective implementation of the revised EU ETS and the new Carbon Border Adjustment Mechanism.
• Public funding: SSAB advocates caution regarding state aid, which can easily distort the EU's internal market. If used, subsidies should focus on research and development and the scaling up of new technologies.
• Industry and competitiveness: It is important to ensure a level playing field on the EU internal market, and internationally. There is a need for clear standards and definitions that support steel market transformation.

Membership of organizations and advocacy organizations

Alignment assessment: SSAB has carried out an assessment to ensure that the member organizations SSAB belongs to stands behind and/or are in line with the goals in the Paris Agreement. The assessment shows that all member organizations meet SSAB's expectations.

Quantitative data

No quantitative data on political contributions, lobbying expenditure, or trade association membership fees is disclosed.

Payment practices

Payment terms and practices

The range of payment terms for purchase invoices part of supply chain finance program is 60–90 days while the terms for purchase invoices is typically 30 days.

Supply chain financing arrangements

The amount of purchase invoice amount under supply chain financing program on December 31, 2024 was SEK 3,425 million, out of which SEK 3,011 million had already been paid to the suppliers.

Materiality statement

ESRS G1-6 is reported as "Not included (not material)" in SSAB's materiality assessment.