Technoprobe

Governance roles

Reference: pages 27-30. In the ESRS content index under ESRS 2 and again under G1 (index pages 57 and 61).

Corporate bodies are the Shareholders' Meeting, the Board of Directors with its committees, and the Board of Statutory Auditors. The statutory audit is entrusted to PricewaterhouseCoopers S.p.A. (page 27).

Composition (page 28). A replacement director was appointed on 29 April 2025 and an additional director on 10 July 2025, taking the Board "from 9 to 10" members. The text states the Board "consists of 10 members, of whom 3 have executive ... and 7 6 non-executive positions. Of these, 5 members are independent", and that female representation is "equal to 20% of the total (women number two compared to eight men, representing a 25% ratio)". The two percentages and the executive split are inconsistent as printed.

Committees (pages 28-29). Control, Risk and Sustainability Committee, Nomination and Remuneration Committee, Related-Parties Committee, each with 3 members; Board of Statutory Auditors with 3 members and 2 alternates.

Oversight (page 29). Supervision sits with the Board; operational management of IROs is delegated to Top Management (CEO, CCO, CTO, CFO, HR Director, Corporate Manufacturing Director, Chief Supply Chain & Procurement Officer). "The Board of Directors of Technoprobe does not include members representing employees or other workers".

Information flows to the board

Reference: page 30. Listed in the ESRS content index (page 57) under "ESRS 2 General Disclosures - 1.2 Governance".

The Board of Directors and the Board of Statutory Auditors "receive regular updates on issues related to impacts, risks and opportunities relevant to the Group". Information is prepared by the competent departments, which collect and analyse the needs arising from the Group's activities, the actions taken or planned and the related results. For particularly critical topics, "extraordinary sessions or dedicated workshops can be organized to ensure adequate in-depth study".

Material IROs are described as integrated into strategic planning and key decisions, and the Board "takes these aspects into account when evaluating relevant transactions, such as acquisitions, investments or significant strategic changes".

For the list of material impacts, risks and opportunities addressed by the bodies during 2025, the disclosure cross-refers to ESRS 2 SBM-3 (pages 42-45). It does not state how often sustainability matters were tabled during 2025, nor which matters were addressed at which meetings.

Sustainability in incentive schemes

Reference: pages 30-31. In the ESRS content index under ESRS 2 and under the European Taxonomy block (page 57), and again under E1 (page 58).

Sustainability metrics carry a weighting of 10% in both the 2025 annual variable component (STI) and the 2025-2027 Performance Share Plan (LTI) (page 30).

2025 STI ESG objective (page 30), three components:

• 5% reduction in waste collected (tonnes) relative to revenue versus 2024, Group level;
• 2% reduction in energy consumption (MWh) relative to revenue versus 2024, Group level;
• 1% increase in energy from renewable sources (MWh) versus 2024, Group level.

"In 2025, the ESG objective was achieved across all three of its components" (page 31).

LTI ESG objective: "Completion of the first People Probe Survey, to be conducted during 2027" (page 31).

Climate-specific (E1 - GOV-3, page 31). Two of the three STI components are climate-related, and "both elements that make up the ESG objective related to climate change targets were achieved". Page 31 prints this paragraph twice, once in Italian and once in English. No monetary value or payout attributable to the ESG component is disclosed.

Due diligence mapping

Reference: pages 31-32. Listed in the ESRS content index (page 57) and carried in the Appendix B datapoint table (page 62).

The disclosure is a mapping table only. It "illustrates in which sections of the Sustainability Statement the application of the main aspects and phases of the due diligence process is treated", and states plainly that "A structured process and a formal policy on the subject will be structured subsequently" (page 31).

The five core elements are mapped as follows:

• (a) Embedding due diligence in governance, strategy and business model: GOV-1, GOV-2, SBM-1.
• (b) Engaging with affected stakeholders: SBM-2, IRO-1 and the engagement processes in S1, S2, S3 and S4.
• (c) Identifying and assessing adverse impacts: SBM-3 and IRO-1.
• (d) Taking actions to address adverse impacts: the actions disclosures in E1, E5, S1, S2, S3 and S4.
• (e) Tracking effectiveness and communicating: the targets disclosures in E1, E5, S1, S2, S3 and S4.

The mapping is a signpost rather than a description of an operating due diligence process, and the company says as much.

Internal control over sustainability reporting

Reference: pages 32-34. Listed in the ESRS content index (page 57).

During 2025 the Group continued building the Internal Control of Sustainability Reporting (ICSR) begun in 2024, through the Dirigente Preposto (Group CFO) and a newly introduced Sustainability Manager role and dedicated function (page 32).

2025 activities (pages 32-33): updating the methodology for determining relevant DRs via a contribution analysis ("scoping"); extending control formalisation over the reporting preparation process and over data collection for the scoped DRs, including for the most relevant foreign subsidiaries; and monitoring the operating effectiveness of those controls. A footnote records that "During the 2025 financial year, the activities involved the subsidiary Technoprobe Taiwan".

System components (page 33): a documented reporting procedure; Risk and Control Matrices; DR-level matrices for Technoprobe and for one subsidiary; an internal attestation process to the Dirigente Preposto; and external attestation under Article 154-bis, paragraph 5-ter of Legislative Decree 58/1998.

Risks (page 34): "lack of accuracy and completeness of data ... as well as the risk of non-compliance with the assertions and principles governing sustainability reporting". Controls are "mainly manual". Monitoring results go to the Board and the Committee at least annually.

Business model and value chain

Reference: pages 34-39. Listed in the ESRS content index (page 57).

Founded in 1996 by Giuseppe Crippa, Technoprobe designs and manufactures Probe Cards, electro-mechanical interfaces used for semiconductor testing, and is "present through its subsidiaries in 10 countries" (page 34). Since 2007 it has specialised in probe cards for non-memory chips at wafer test, with proprietary Vertical MEMS and TPEG MEMS technology; the 2024 DIS acquisition took it into final testing, and during 2025 it "further expanded its product portfolio in wafer-level testing through the development of Probe Cards for memory chips" (page 35).

Scale (page 35). Revenues of 628 million euro. The page states the Group "had 3,238 employees, of which 1,782 in Europe, 156 in the United States and 1,390 in Asia"; those components sum to 3,328, the figure reported under S1-6, so the headline appears to be a transposition error.

Value chain (pages 37-39). Upstream: mining by indirect suppliers with conflict-minerals engagement, direct procurement of PCBs, metal alloys, silicon, chemicals, machinery, services and outsourced processing. Own operations in Italy, France, the United States, Taiwan, Korea, the Philippines and Singapore. Downstream: chip manufacturers and end-users, with end of life managed by the customer because "no part of the probe card can be reused".

Stakeholder engagement

Reference: pages 39-41. Listed in the ESRS content index under ESRS 2 and under S1, S2, S3 and S4 (pages 57-61); footnote 14 on page 39 confirms the paragraph also serves the topical SBM-2 disclosures.

Internal stakeholders are employees and collaborators; external stakeholders are customers, suppliers, investors and local community entities including schools and non-profits.

• Own workforce (page 39): intranet, whistleblowing, events, training, feedback sessions and focus groups, plus "in 2025 a company climate survey was conducted at Group level".
• Customers (page 40): key account engagement, periodic commercial, technical and quality meetings, technical reviews and "defined escalation channels for the most significant programmes".
• Suppliers (page 40): a dedicated whistleblowing channel under the Supplier Code of Conduct, and long-term partnerships with key suppliers.
• Financial stakeholders (page 40): Investor Relations met "approximately 300 analysts and investors" during the year, and the Company "hosted its first Capital Market Day" on 29 April 2025.
• Schools, universities and local communities (page 41): orientation and training programmes, site visits, hiring days, donations and sponsorships.

Executives and a sample of external stakeholders were involved in the 2025 Double Materiality Assessment, and the main topics arising "are periodically reported to the members of the Board of Directors".

Material IROs

Reference: pages 42-47, repeated per topic at pages 83, 96, 109, 111 and 113.

The tables set out 28 impacts, 8 risks and 2 opportunities. Each impact is tagged actual or potential, positive or negative, with a time horizon and value chain position; risks and opportunities carry dependencies instead of a topic column.

Impacts (pages 42-44). E1 three, all actual negative: Scope 3 emissions, Scope 1 and 2 emissions, energy consumption. E5 two: depletion of natural resources, waste. G1 four. S1 twelve, covering training, well-being, equal treatment, workforce data, injuries, diversity, remuneration, growth expectations and union relations. S2 three, S3 one, S4 three.

Risks (page 44): climate transition risks; three "unethical behaviour" risks; corruption cases; inadequate working conditions; product non-conformities; loss of customer data. Opportunities (page 45): staff training; customer service.

Changes versus 2024 (pages 45-47). "Pollution" is no longer material, including substances of concern and SVHCs, because the Group "operates in the assembly of micro-components and precision mechanics". "Water and marine resources" is no longer material because the business "does not involve water-intensive production processes". Newly material are the S1 sub-sub-topics on disability inclusion, harassment, and diversity.

No entity-specific IROs were identified and no current financial effects are reported (page 47).

Double materiality process

Reference: pages 47-56. Listed in the ESRS content index under ESRS 2, E1, E5 and G1.

Four phases, following EFRAG IG 1 (pages 47-48): understanding the context; building a long list of IROs at ESRS 1 granularity; assessment, with impacts scored by executives and a sample of stakeholders and risks and opportunities scored by the Finance function then validated by risk owners; and consolidation, with results reviewed by the Control, Risk and Sustainability Committee and approved by the Board.

Impact materiality (page 49). Severity or benefit is scored 1 to 5 on scale, scope and, for negative impacts, irremediability, multiplied by likelihood, on an inherent basis. Stakeholders scored only severity. "the Group prioritised the assessment provided by external stakeholders" where internal and external views diverged, which brought nine further impacts into scope.

Financial materiality (pages 51-53). Magnitude is scored across economic/financial, operational, reputational and compliance drivers, anchored to EBITDA bands (marginal below 0.5%, critical above 15%), multiplied by likelihood at the maximum of the three horizons.

Limits (page 54). The Group states it operates "In the absence of a structured Enterprise Risk Management (ERM) process", using a Risk Register that incorporates ESG risks. The next review is scheduled for 2026. Topic-level IRO-1 sections at pages 54-56 explain why E2, E3 and E4 are not material.

ESRS content index

Reference: pages 57-61, with the Appendix B datapoint table at pages 62-70.

The report prints a genuine ESRS content index, "IRO-2 - Disclosure requirements in ESRS covered by the undertaking's corporate sustainability statement", mapping each covered disclosure requirement to a named section rather than a page number. Its introductory line refers to "the Technoprobe Group's 2024 Sustainability Reporting", a carry-over from the prior year.

Coverage. ESRS 2 BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2, with MDR-P, MDR-A, MDR-M and MDR-T signposted to the topical chapters; EU Taxonomy Article 8; E1 SBM-3, IRO-1 and E1-1 to E1-9; E5 IRO-1 and E5-1 to E5-6; S1 SBM-2, SBM-3 and S1-1 to S1-17; S2, S3 and S4 SBM-2, SBM-3 and DRs 1 to 5; G1 GOV-1, IRO-1 and G1-1 to G1-4. E2, E3 and E4 appear only through their topic-level IRO-1 immateriality explanations. G1-5 and G1-6 do not appear.

Phase-in. Four DRs carry the note "Being subject to a transitional provision, Technoprobe has decided to use the phase-in provided for the information prescribed by this DR": E1-9, E5-6, S1-7 and S1-13 (pages 58-59).

Appendix B (pages 62-70) cites page numbers that do not match this year's document (S1 SBM-3 is cited to "Page 82" while the S1 chapter begins at page 96) and still carries E3-1, E3-4 and E2-4 rows although water and pollution are not material for 2025.

Transition plan

Reference: page 83. Listed in the ESRS content index under E1 ("E1 Climate change - 2.2.1 Strategy", index page 58).

The disclosure is a nil return. In full: "The Group recognises the crucial role of companies in the fight against climate change and, although it has not currently defined a transition plan for climate change mitigation, the definition of a first decarbonisation plan is being assessed in the medium term."

There is therefore no GHG reduction target, no decarbonisation lever quantification, no capex plan, no locked-in emissions assessment and no statement of alignment with a 1.5C pathway attached to E1-1. Nothing is said about approval of a plan by an administrative or management body, because no plan exists to approve.

Adjacent content that exists elsewhere in the statement, but is not presented as a transition plan: the two climate objectives in the 2025 short-term incentive (a 2% cut in energy intensity and a 1% rise in the renewable share, both achieved, pages 30-31 and 84), the mitigation initiatives grouped "by decarbonisation levers" at page 84, and the emissions and energy data at pages 84-91. The EU Taxonomy section reports no aligned activities at all, "not having a formalized analysis of its exposure to physical climate risks" (page 74).

This is unchanged in substance from FY2024, when the Group also reported no transition plan.

Climate risk identification

Back-filled from ESRS 2 IRO-1 (E1 section, page 55) and the SBM-3 risk table (page 44). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Scenario analysis: none performed. "With regard to climate-related risks and opportunities, the Group has not yet formalized a comprehensive and granular analysis that includes specific scenario analyses in the short, medium, and long term" (page 54). No high-emission scenario, no 1.5C-aligned scenario and no temperature projection is named. Under E1 paragraph 17 those datapoints apply only where scenario analysis was used, so the absence of the analysis is the finding.

Risk identification (page 55). Within the Double Materiality Assessment "the Group analyzed its exposure to physical and transition climate risks", considering "both its own operations and the activities of the main actors along the value chain". No site-level exposure or sensitivity screening is disclosed.

Classification (page 44). One climate risk is carried in the material IRO tables, "Climate transition risks", covering "Technological, regulatory, market, and reputational transition risks", long-term, own operations. No material physical risk is carried.

The Taxonomy section confirms the gap: the DNSH criterion for climate adaptation fails because "Technoprobe has not currently carried out assessments of exposure to physical climate risks" (page 73).

Climate resilience

Back-filled from ESRS 2 SBM-3 (page 47) and the E1 SBM-3 section (page 83), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

No resilience analysis has been performed. The E1 section states: "At present, Technoprobe has not yet formalized an analysis of the resilience of its strategy and business model with respect to climate change" (page 83). The cross-cutting SBM-3 says the same for all topics: "To date, a quantitative analysis of the resilience of the strategy and business model with respect to the undertaking's ability to address material impacts and risks and to seize material opportunities has not yet been formalised" (page 47).

Intended next steps (page 83). The assessment "has represented the starting point for the launch of a structured pathway aimed at implementing an analysis of climate-related risks, both physical and transition-related, and the subsequent definition of a resilience plan". No date, scope or method is attached.

None of the E1-3 elements is therefore present: no results, no implications for strategy or business model, no link between scenario effects and the response, no areas of uncertainty, and no assessment of the capacity to adjust or adapt. The report is explicit about this rather than silent.

Climate policies

Reference: page 83. Listed in the ESRS content index as "E1-2, MDR-P Policies related to climate change mitigation and adaptation" (index page 58).

A nil return. "The Group has not adopted specific formalized policies regarding climate change mitigation and adaptation, as the definition of a Group decarbonization plan is currently under evaluation. This plan is expected to include specific actions related to the IROs associated with climate change topics."

What is offered in place of a policy is a compliance statement: the Group "operates in compliance with applicable local regulations, works to obtain and maintain all required environmental authorizations, and proactively implements actions to control its processes, aligning them with the best internationally recognized standards".

None of the MDR-P content elements is therefore present: no policy scope, no most senior level accountable for the policy, no reference to third-party standards or initiatives, no consideration of stakeholder interests, and no statement of how the policy is made available. The position is unchanged from FY2024, where the Group also reported no formalised climate policy.

Climate actions

Reference: page 84. Listed in the ESRS content index as "E1-3, MDR-A Actions and resources in relation to climate change policies" (index page 58).

The section gives "a summary of the main initiatives related to climate change mitigation implemented by the Group during the year, divided by decarbonisation levers":

• Renewable self-generation. "The Group operates renewable energy generation plants installed at its Italian sites in Cernusco Lombardone and Osnago, as well as in San Jose, California." Self-generated renewable output rose from 751 MWh in 2024 to 883 MWh in 2025, an 18% increase (pages 85-86).
• Sustainable mobility. Technoprobe "encourages its workforce to use local public transport by ... reimbursement of annual railway transport passes and by making shuttle services available". More than 500 public transport subscriptions were reimbursed in 2025 (page 101).
• Energy monitoring. During 2025 the Group "strengthened the monitoring and control of energy consumption of its foreign legal entities through semi-annual analyses and on-site visits. This process will help lay the foundations for identifying the most energy-intensive drivers."

Resources. "The total investment in 2025 is below the predefined threshold reported in the ESRS 2, BP-1 section", which BP-1 sets at 500,000 euro (page 26). No expected GHG reduction is quantified for any action, and none is tied to a target.

Climate targets

Reference: page 84. Listed in the ESRS content index as "E1-4, MDR-T Targets related to climate change mitigation and adaptation" (index page 58).

No GHG emission reduction target is set. "At present, the Technoprobe Group has not yet implemented a climate strategy for climate change mitigation."

What is disclosed instead are two energy objectives set within the 2025 short-term incentive plan and drawn from the Remuneration Policy:

• a 2% reduction in the Group's energy intensity (MWh per unit of revenue) compared to 2024;
• a 1% increase in the share of energy from renewable sources at Group level compared to 2024.

Both were achieved in 2025 (page 31). Measured performance is consistent: energy intensity for high climate impact activities fell from 0.10 to 0.09 MWh per thousand euro, and the renewable share of total energy rose from 1.6% to 1.9% (pages 85-86).

Neither objective is a GHG target. There is no base year for emissions, no 2030 or 2050 milestone, no gross versus net split, no science-based validation and no separate mitigation and adaptation targets. Total GHG emissions rose 18% location-based and 19% market-based over the year (page 88), so the two energy objectives were met while the absolute footprint grew.

Energy consumption and mix

Reference: pages 84-86. Listed in the ESRS content index (index page 58).

Totals (MWh). Total energy consumption 45,595 in 2024 and 47,344 in 2025. From fossil sources 44,844 to 46,461; from nuclear sources nil in both years; from renewable sources 751 to 883. Fossil share 98.4% to 98.1%; renewable share 1.6% to 1.9%.

Fossil breakdown 2025 (page 85). Crude oil and petroleum products 828 MWh (from 602); natural gas 6,203 (from 6,328); purchased electricity, heat, steam or cooling 39,430 (from 37,914); coal nil.

Renewables. All 883 MWh is "self-generated renewable energy without the use of fuels"; purchased renewable energy is nil. Footnote 21 applies a prudential approach under AR 32(j): purchased energy counts as renewable only where the origin is contractually evidenced.

Intensity (page 86). Energy intensity of activities in high climate impact sectors fell from 0.10 to 0.09 MWh per thousand euro, on consumption of 45,574 MWh (from 43,046) and net revenues of 524 million euro (from 442).

Drivers (pages 84-85). The 4% rise in fossil consumption is attributed to the full-year consolidation of DIS, expansion of production in Taiwan including a new facility, and greater use of company vehicles. The 2024 fossil figure was restated from 49,583 to 44,844 MWh (footnote 20). The conversion factor table on page 86 is corrupted: the petrol and LPG rows repeat the energy intensity values instead of factors.

GHG emissions

Reference: pages 86-91. Listed in the ESRS content index (index page 58).

Headline (tCO2e, 2024 to 2025). Scope 1 1,378 to 1,583 (+15%), with no emissions from regulated emission trading systems. Scope 2 location-based 22,976 to 20,809 (-9%); market-based 24,188 to 23,853 (-1%). Scope 3 82,475 to 103,379 (+25%). Total location-based 106,829 to 125,771 (+18%); total market-based 108,041 to 128,815 (+19%). Emission intensity is 0.20 tCO2e per thousand euro in both years, on net revenue of 543 then 628 million euro (page 88).

Scope 3 by category, 2025. Cat 1 purchased goods and services 47,777 (+55%); Cat 2 capital goods 34,978; Cat 3 fuel and energy related 4,630; Cat 4 upstream transport 6,241; Cat 5 waste 860; Cat 6 business travel 4,637 (+28%); Cat 7 commuting 2,927; Cat 9 downstream transport 1,329. Scope 3 is 80% of the market-based total. The trend column shows "-10%" for Cat 3 although the figure rises from 4,206 to 4,630.

Method (pages 90-91). Cat 1 uses the average-data method with LCA, EPD and Ecoinvent 3.9 factors for goods and spend-based for services; Cat 2, 4 and 6 spend-based; Cat 3 average-data; Cat 5 waste-type specific; Cat 7 distance-based, extrapolated from the Italian perimeter. Categories 8 and 10 to 15 are excluded with reasons at footnote 40.

Gap: page 91 states "for Category 1, the use of primary (specific) data amounts to xx%", an unfilled placeholder in the published report.

Removals and carbon credits

Reference: page 91. Listed in the ESRS content index (index page 58).

A complete nil return: "The Group does not participate in GHG removal and storage activities and does not purchase carbon credits to offset its carbon footprint."

Nothing is therefore disclosed under the removals limb (removals and storage in own operations or the upstream and downstream value chain, in tCO2e) or the carbon credits limb (credits cancelled in the reporting year, credits planned to be cancelled, the share from removal versus reduction projects, the recognised quality standard, and the share of corresponding adjustments). No net-zero claim is made anywhere in the statement, so the paragraph 60 disclosure on the relationship between a net-zero target and gross reductions does not arise.

The nil return is consistent with the rest of the E1 chapter: the Group has no transition plan (page 83) and no GHG target (page 84), so there is no offsetting architecture to describe.

Internal carbon pricing

Reference: page 91. Listed in the ESRS content index (index page 58).

A one-line nil return: "The Group has not adopted internal carbon pricing systems."

Because no internal carbon price is applied, the supporting datapoints do not arise: the type of scheme (shadow price, internal fee or implicit price), the scope of application, the price per tonne of CO2e and how it was set, and the share of emissions covered by the scheme within each scope.

The statement is consistent with the absence of a transition plan (page 83), of climate policies (page 83) and of GHG targets (page 84), and with the Group's report that it has "not yet implemented a climate strategy for climate change mitigation" (page 84). It also aligns with the Taxonomy disclosure, where no capital expenditure is Taxonomy-aligned and no shadow price is applied to investment decisions (pages 73-74).

Circular economy policies

Reference: page 92. Listed in the ESRS content index as "E5-1, MDR-P Policies related to resource use and circular economy" (index page 58).

A qualified nil return: "Having formalized its environmental commitment within the Code of Business Conduct, the Group has not adopted specific formalized policies on resources and circular economy. However, the Group monitors the volumes of incoming materials and the waste generated, adopting identification and labeling procedures and using appropriate technologies to limit risks to the environment."

So the only policy instrument is the general environmental commitment in the Code of Business Conduct, first issued in October 2015 and last updated in December 2022, approved by the Vice-Chairman and reflecting Responsible Business Alliance standards (page 117). No dedicated circular economy policy exists.

None of the MDR-P elements is provided for E5: no policy scope or exclusions, no most senior level accountable, no third-party standard, no stakeholder consideration and no availability statement. The two material E5 impacts, "Depletion of natural resources" and "Generation of waste" (page 42), are therefore managed without a topic-level policy.

Circular economy actions

Reference: page 92. Listed in the ESRS content index as "E5-2, MDR-A Actions and resources related to resource use and circular economy" (index page 58).

The section opens with a qualified nil: "In the absence of formalized policies on resources and the circular economy, the Group has not adopted specific actions but has promoted initiatives aimed at reducing waste generation and encouraging its recovery and reuse."

Initiatives described:

• Municipal waste at the workplace "is collected separately", with "continuous awareness initiatives ... promoted among the workforce".
• Special production waste "is managed using the best available technologies, and wherever possible, material or energy recovery operations are preferred over disposal". Temporary storage areas at production sites "have been designed to prevent any form of soil or groundwater contamination", under cover on paved surfaces with spill safeguards.
• Sites carrying out design, customer support or repair "do not generate industrial waste" and handle mainly packaging, paper and cardboard, "where possible, implement[ing] recycling and reuse processes for materials such as boxes and foam fillers".
• Industrial waste disposal runs through authorised third parties.

Resources. "The total investment in 2025 is below the predefined threshold reported in the ESRS 2 section", which BP-1 sets at 500,000 euro (page 26). No expected resource saving is quantified for any initiative.

Circular economy targets

Reference: page 92. Listed in the ESRS content index as "E5-3, MDR-T Targets related to resource use and circular economy" (index page 58).

"At present, the Technoprobe Group has not yet implemented a strategy to mitigate negative externalities related to resource use and the circular economy. However, with reference to objectives related to resource use and the circular economy, during 2025 the Group set a target to reduce the intensity of waste generated (tonnes/revenue) by 5% compared to 2024."

That objective is the waste component of the 2025 short-term incentive ESG objective, weighted within the 10% ESG element of the STI, and page 31 records that "the ESG objective was achieved across all three of its components" (pages 30-31).

The target is intensity-based rather than absolute, covers waste only, and does not address the other material E5 impact, depletion of natural resources. No target is set for resource inflows, for recycled or secondary content, or for resource outflows. No base year beyond 2024, no interim milestones and no target year beyond the incentive period are given, and no method or stakeholder involvement in setting the target is described.

Resource inflows

Reference: pages 92-93. Listed in the ESRS content index (index page 58).

Materials named (page 92). The Group "primarily purchases the following types of raw materials: printed circuit boards (PCBs), metal alloys, electronic components, silicon, and process solutions for surface chemical treatments". Auxiliary materials include "chemicals, pastes, resins, soldering wires and technical gases", plus packaging.

Quantities (page 93). Total weight of products and materials used fell from 933 tonnes in 2024 to 399 tonnes in 2025. Biological materials are nil in both years. Total weight of reused or recycled materials or components is 0.23 in 2024 and 0.42 in 2025; the percentage row is left blank.

Explanation of the fall (page 93). The Group "introduced several changes to an internal process related to the processing of a material relevant to its production activities", which "led to a redefinition of procurement methods, resulting in a reduction in purchased volumes". The affected area also "underwent an operational reorganization", including "the closure of a plant that used these materials", so some remaining material "was disposed of, resulting in their reclassification under indicator E5-5".

Method. Weights are built from purchase orders per material, with estimates from piece counts and prior-year data where weights were unavailable. The 2024 figure was restated from 1,016 to 933 tonnes (footnote 41).

Resource outflows: products and materials

Reference: page 93, with the waste tables at pages 94-95. Listed in the ESRS content index (index page 58).

Durability and repairability. "The Probe Card is a device designed based on the technical specifications of the chip to be tested; these specifications determine its durability, which therefore varies depending on the characteristics of the chip itself." Durability is driven by the market segment served (Consumer, Automotive, Industrial and Artificial Intelligence) and the supported technology.

No durability metric is given, and the company explains why: "These intrinsic characteristics make it difficult to identify reference indicators or comparable benchmarks, also considering the absence, at sector level, of shared metrics defining an average durability for this type of product."

Repair. "In order to extend the useful life of its products, the Group is able, upon customer request, to carry out maintenance activities such as the replacement of probe card needles and probes." The Group "is engaged in internal studies and analyses on the topics of durability, repairability and recyclability of its products".

No rates of recyclable content in products or packaging are reported. End of life is managed by the customer, and SBM-1 states that probe cards "are considered consumables ... no part of the probe card can be reused" (page 39).

Waste

Reference: pages 94-95. Listed in the ESRS content index within E5-5 (index page 58), and in the Appendix B table as SFDR indicators for non-recycled and hazardous waste (page 66).

Totals (page 94). In 2025 the Group generated 2,251 tonnes of waste, of which 688 tonnes hazardous, "a 21% decrease and a 22% increase compared to 2024" respectively. Waste not sent for recycling is 2,180 tonnes, up 2%. The Group "has not produced radioactive waste" (footnote 42).

Destination, total column, 2025 (2024 in brackets). Diverted from disposal 389 (470), of which reuse 2 (1), recycling 70 (130) and other recovery 317 (339). Directed to disposal 1,862 (2,373), of which incineration 67 (56), landfill 35 (59) and other disposal 1,760 (2,258). The hazardous and non-hazardous column headings do not line up with the 688 tonne hazardous figure in the narrative, so the split should be read from the narrative.

Composition (page 94). Hazardous special waste is mainly "galvanic solutions, pickling acids and bases, solvents, empty contaminated packaging, and rags"; non-hazardous includes condensate or washing water, filter-pressed sludge, packaging, ferrous metal shavings and wood.

Method (pages 94-95). Italian sites classify under Legislative Decree 152/2006, foreign sites under local rules. 2025 data for DIS Tech America (Santa Clara, closed April 2025, and Fremont) were "partially estimated". 2024 totals were restated from 2,871 to 2,843 tonnes (footnote 43).

Own workforce policies

Reference: pages 96-97. Listed in the ESRS content index as "S1-1, MDR-P Policies related to own workforce" (index page 59).

Three instruments are named: the Code of Business Conduct, the Health and Safety Management System and the Information Security Policy (page 96).

Code of Business Conduct commitments (pages 96-97), in four blocks: professional development, career continuity and fair treatment; respect for the individual, diversity and inclusion, committing to "maintaining a workplace free from discrimination, coercion and harassment"; well-being, health and safety, extending to "measures to promote psychological well-being and work-life balance"; and protection of personal data.

Health and safety (page 97). An OHS Management System covers "all Italian sites, which has not been certified by a third-party body", aligned with Article 30 of Legislative Decree 81/2008 and ISO 45001. Technoprobe Taiwan and Korea hold third-party certified ISO 45001 systems; other companies use local standards.

Information security (page 97). The Information Security Policy applies to all Group companies and was approved by Management in April 2023, committing the Group to GDPR and equivalent rules. The paragraph is printed twice, once in English and once in Italian.

No commitment to the UN Guiding Principles, the ILO declaration or the OECD Guidelines appears in the S1-1 text itself.

Worker engagement

Reference: pages 97-98. Listed in the ESRS content index (index page 59).

The People Probe Survey. "During 2025, the Group adopted a structured process for engaging the workforce regarding impacts, represented by the People Probe Survey ... aimed at analysing the perception of employee engagement." Areas covered are "the employee experience, development, confidence in the future, management effectiveness, and innovation". Based on the responses "the Group initiated dedicated discussion forums ... committing to implement improvement actions across the organization". Completion of the first survey is the ESG objective of the 2025-2027 LTI plan (page 31).

Other channels are "periodic meetings, informal meetings with management, and internal questionnaires".

Health and safety representation (page 98). Technoprobe "promotes the election of workers' safety representatives", who participate in risk assessment and prevention, receive information on hazardous substances, machinery, accidents and emergency management, and are involved annually in verifying preventive measures.

Industrial relations. Technoprobe participates in forums including the Equal Opportunities Committee, and "Since 2019 ... has regularly signed a second-level company collective agreement together with the Social Partners", supplementing the national CCNL. No global framework agreement is reported.

Remediation and grievance channels

Reference: pages 98-99. Listed in the ESRS content index (index page 59), and carried in the Appendix B datapoint table as the SFDR grievance mechanism datapoint (page 67).

The instruments named are the Code of Business Conduct, the Organizational Model 231, the Global Whistleblowing Policy and internal reporting systems, the Health and Safety Management System, and the related communication and training (page 98).

The Global Whistleblowing Policy is adopted "in compliance with the provisions of Legislative Decree 2023/24 and Directive (EU) 2019/1937", and a whistleblowing reporting channel is "available to all employees". In addition, "if a member of the workforce believes that the working environment does not reflect the principles described in the Code of Business Conduct, they may also submit a report, including anonymously, to the Human Resources function".

"These channels ensure confidentiality, anonymity and protection for individuals who submit reports, safeguarding them from the risk of retaliation" (page 99).

What is not disclosed: no measure of worker awareness of, or trust in, the channels; no description of how remedies are provided or how the Group tracks whether an issue was resolved; and no third-party mechanism. Volume data appear separately under S1-17, which reports no incidents or complaints in 2025 (page 108).

Actions on own workforce

Reference: pages 99-104. In the ESRS content index as "S1-4, MDR-A" (page 59).

Talent attraction (pages 99-100). Career Days and Open Days, a Technoprobe Hiring Day at Cernusco Lombardone for graduates in Engineering, Physics and Materials Science, plus PCTO programmes and internships.

Training (pages 99-101). Three goals: technological innovation, with courses on design, specialist software (Prometeo, Windchill, Cadence, Ansys) and AI applied to chip testing; productivity and process quality, including SAP and on-the-job training; and collaboration and leadership.

Performance and pay (page 101). A performance management system "was launched at Technoprobe in December 2025 and will subsequently be extended across the Group in 2026". Ahead of the EU Pay Transparency Directive, a remuneration project mapping role families and job levelling was launched in January 2026.

Welfare (page 101). Bonus conversion with "an additional 30% increase provided by Technoprobe"; 58% of employees opted for full or partial conversion.

Inclusion (pages 101-102). Under Article 14 of Law 68/1999, the Ciclofficina Project and ForMe - A bridge to employment, which "involved ten participants" in 2025.

Health and data (pages 102-104). An audit plan, an adverse events procedure, health seminars, a 1,000 euro new-birth bonus and a Group cybersecurity campaign. Total 2025 investment was below the 500,000 euro threshold.

Own workforce targets

Reference: page 104. Listed in the ESRS content index as "S1-5, MDR-T Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities" (index page 59).

A nil return, in full: "The Group, while recognising the importance of the issue, has not adopted specific formalised targets regarding its own workforce."

No target is therefore set for any of the twelve material S1 impacts identified in SBM-3 (pages 42-43), which include well-being, equal treatment and equal opportunities, diversity in governing bodies and across the workforce, work-related injuries, remuneration, career development, discrimination, workforce data protection and relations with trade unions, nor for the material S1 risk (inadequate working conditions) or opportunity (staff training) at pages 44-45.

None of the MDR-T elements arises: no measurable outcome-oriented target, no base year, no target year, no methodology, and no statement of whether workers or their representatives were involved in setting targets. The only quantified workforce-related objective anywhere in the statement is the LTI ESG objective, "Completion of the first People Probe Survey, to be conducted during 2027" (page 31), which is an activity milestone rather than an outcome target and is not presented under S1-5.

Employee characteristics

Reference: pages 104-105. Listed in the ESRS content index (index page 59).

Headcount. At 31 December 2025 the Group employed 3,328 people, "a slight decrease of 1% compared to 2024" (3,355). Permanent contracts are "equal to 90% of the total" and full-time "equal to 99% of the total", both slightly down on 2024.

By gender (page 105). 2,111 male and 1,217 female; the "other" and "not reported" columns are nil.

By country (page 105). Italy 1,752; Taiwan 595; Philippines 360; other countries 621. The Philippines appears separately for the first time in 2025, having been inside "rest of the world" in 2024 (footnote 49). Significant employment means 50 or more employees representing at least 10% of the total (footnote 48).

By contract type (page 105). Permanent 2,983 (1,905 male, 1,078 female); temporary 344; non-guaranteed hours 1. Full-time 3,285; part-time 43.

Turnover. 21% in 2025, "corresponding to 699 departures", against 14% and 477 in 2024. The increase "is also attributable to the reorganization operations previously mentioned, which particularly affected Technoprobe Asia Pte. Ltd. (Singapore), Technoprobe America Inc., and DIS Tech America Inc.". Turnover is calculated as leavers over closing headcount (footnote 47).

2024 comparatives were restated: permanent employees from 3,273 to 3,113 and fixed-term from 82 to 242 (footnote 46).

Collective bargaining and social dialogue

Reference: page 106. Listed in the ESRS content index (index page 59).

"At the European Economic Area (EEA) level, the percentage of the Group's employees covered by both collective bargaining agreements and workers' representatives amounts to 99.7%, in line with what was reported in the previous Sustainability Report."

Footnote 50 gives the exception: "employees of Technoprobe Germany GmbH are not covered by collective bargaining agreements or trade union agreements".

On European-level representation: "Within the Group, there are no agreements with employees for representation through a European Works Council (EWC), a Works Council of a European Company (SE), or a Works Council of a European Cooperative Society (SCE)."

Two limits are worth noting. The coverage figure is given for the EEA only, so no rate is disclosed for the Group's employees in Taiwan, the Philippines, Korea, Singapore, Japan, China or the United States, which together account for roughly half the workforce (page 105). And no breakdown by country or by region outside the EEA is provided, nor any statement of the working conditions determined by non-EEA collective agreements. S1-2 adds that Technoprobe "has regularly signed a second-level company collective agreement together with the Social Partners" since 2019 in Italy (page 98).

Diversity metrics

Reference: page 106. Listed in the ESRS content index (index page 59).

Top management. "As of 31 December 2025, the Group's Top Management consists of 7 male members (100%)." Top Management is defined at GOV-1 as the CEO, CCO, CTO, CFO, HR Director, Corporate Manufacturing Director and Chief Supply Chain & Procurement Officer (footnote 5, page 29). Footnote 51 notes that Top Management is the only S1-9 datapoint compared with 2024.

By category and gender (page 106). Executives 48 (39 male, 9 female); managers 156 (118 male, 38 female); white collar 1,608; blue collar 1,516. "the most represented professional categories are employees and blue-collar workers, which together account for 94% of the workforce."

By age. The table gives, for men, 860 under 30, 984 aged 30 to 50 and 267 over 50, and for women 447, 650 and 120, totalling 3,328. The narrative above the table states that employees are concentrated "under 30, which includes 1,127 employees, and between 30 and 50 years old, which includes 1,431 employees". Those narrative figures do not reconcile to the table, whose corresponding sums are 1,307 and 1,634. The table sums correctly to the S1-6 headcount, so the narrative appears to be the erroneous line.

Board-level gender diversity is reported separately under GOV-1 (page 28) and in the Appendix B table (page 62).

Adequate wages

Reference: page 106. Listed in the ESRS content index (index page 59).

The disclosure is a single sentence: "In accordance with the Code of Business Conduct or, where applicable, collective bargaining agreements or local regulations, all Group employees receive an adequate salary."

This is presented as a full-coverage statement rather than a percentage: the Group asserts that 100% of employees are paid an adequate wage. The benchmark used is the applicable collective agreement or local regulation, with the Code of Business Conduct as the fallback where neither applies.

What is not disclosed: no reference to an external adequate-wage benchmark such as the EU minimum wage adequacy criteria or an applicable living wage standard; no identification of the countries where employees earn below the applicable benchmark, or a statement that there are none; and no percentage of employees paid at or above the benchmark by country.

Related content sits elsewhere: S1-16 reports a 27% gender pay gap and average gross hourly pay of 19.56 euro for men and 14.26 euro for women (page 107); S1-4 describes a compensation benchmarking practice and the pay transparency project launched in January 2026 (page 101); and SBM-3 carries a material impact on remuneration expectations and a material risk from "unfair remuneration or excessive working hours" (pages 43-44).

Social protection

Reference: page 106. Listed in the ESRS content index (index page 59). Footnote 51 records that this metric "was not reported in the previous financial year", so no 2024 comparative is presented.

Coverage is reported against the ESRS major life events:

• Sickness, workplace accidents and acquired disability: 100% of the Group's employees are covered.
• Parental leave: 97%. Footnote 52 explains that "under local regulations in Taiwan, foreign employees are excluded from national parental leave", and that in North Carolina the rule "does not apply to companies with fewer than 50 employees".
• Unemployment from the start of employment: 95%. Footnote 53 notes that in Taiwan and Singapore foreign employees are excluded from national unemployment protection, and that "Korean executives, who are not legally classified as employees, are excluded".
• Retirement: 94%. Footnote 54 notes the exclusion of foreign employees in Taiwan and that in Singapore "national regulations provide that employees rely on an individual-funded pension scheme".

Coverage is stated through public schemes and local statutory entitlement rather than through employer-provided benefits, and no country-by-country breakdown of the uncovered share is given.

Persons with disabilities

Reference: pages 106-107. Listed in the ESRS content index (index page 59). Footnote 51 records that this datapoint was "identified as material following the refinement and update of the double materiality assessment", so no 2024 comparative is presented.

"Within the Group, 2% of the total workforce consists of persons with disabilities." Footnote 55 gives the split: "the share of employees with disabilities amounts to 1.3% among men and 1.9% among women, respectively". Applied to the reported headcount of 2,111 men and 1,217 women, those two rates imply a Group figure closer to 1.5% than 2%, so the headline and the footnote do not reconcile exactly.

Method and limits (page 107). "the identification of disabilities has been carried out in accordance with national regulations and in compliance with the privacy requirements applicable in the various countries, considering that in some jurisdictions such information is left to the discretion of the individual." The Group therefore acknowledges that the figure is subject to legal restrictions and self-declaration, as ESRS S1-12 anticipates.

The corresponding action content sits under S1-4, which describes the Ciclofficina and ForMe placement projects run under Article 14 of Law 68/1999, the latter involving ten participants in 2025 (pages 101-102). "Employment and inclusion of persons with disabilities" is one of the sub-sub-topics newly assessed as material for 2025 (page 46).

Health and safety metrics

Reference: page 107. Listed in the ESRS content index (index page 59), and carried in the Appendix B datapoint table as the SFDR accident and lost-days datapoints (page 67).

Coverage. "Within the Group, 71.6% of employees, corresponding to 2,382 people, are covered by a Health and Safety Management System, representing an increase of 8.8% compared to the previous year." The 2024 figure was restated from 53% to 62.8% (footnote 56). Technoprobe, Technoprobe Korea and Technoprobe Taiwan run UNI ISO 45001 systems covering all their employees, the Korean and Taiwanese ones third-party certified; Technoprobe Singapore and Philippines run systems "aligned with the requirements of the Responsible Business Alliance (RBA)".

Incidents. "During 2025, the Group recorded a total of 6 workplace accidents and an injury rate of 1.00, showing a reduction of 33% (9 accidents) and 40% (injury rate of 1.65) respectively compared to the previous year." The rate is accidents per 1,000,000 hours worked (footnote 57), and the improvement is attributed to the ISO 45001 systems.

Fatalities. "during the year no fatalities due to workplace accidents or occupational diseases occurred, either among the Group's workforce or among other workers operating at company sites."

Days lost to injuries, accidents, fatalities or illness, and the number of cases of recordable work-related ill health, are not reported.

Work-life balance metrics

Reference: page 107. Listed in the ESRS content index (index page 59). Footnote 51 records that this metric "was not reported in the previous financial year", so no 2024 comparative is given.

Entitlement. "99.7% of the Group's employees are entitled to family leave, in accordance with the regulations applicable in the various jurisdictions where the Group operates."

Take-up. "During the year, 12.4% of eligible employees made use of family leave. The gender breakdown shows 9.9% utilization among men and 16.6% among women."

Exclusion explained. "This percentage does not include the entire Technoprobe population, as in one jurisdiction where the Group operates local legislation provides that family leave is mandatory only for sites with at least 50 employees. Since the entity operating in that area currently does not reach this threshold, the mandatory regulation does not apply." The Group adds that the site nonetheless evaluates leave requests "on an individual, case-by-case basis".

The jurisdiction is not named in the S1-15 text, although footnote 52 under S1-11 identifies North Carolina as the location where the 50-employee threshold applies to parental leave. Supporting parental benefits, including the 1,000 euro new-birth bonus, summer camp contributions and nursery school benefits, are described under S1-4 (page 103).

Pay gap and total compensation

Reference: pages 107-108. Listed in the ESRS content index (index page 59).

Gender pay gap. "At Group level, the gender pay gap stands at 27%, representing a reduction of 2 percentage points compared to the previous reporting period."

Hourly pay. "In 2025, the average gross hourly remuneration amounts to 19.56 euro for men and 14.26 euro for women, representing a decrease of 5% and 3% respectively compared to the previous year."

Explanation given (page 107). The year-on-year movement is attributed "both to departures concentrated in North America, where salary levels are generally higher than in European and Asian markets, and to the path undertaken by the Group towards greater pay equity". The structural driver is stated as the STEM skills base: "these fields show a gender imbalance in favour of men, and in some geographical areas where the Group operates this still contributes to the gender pay gap".

Total compensation ratio (page 108). "The ratio between the total annual remuneration of the highest-paid individual and the median total annual remuneration of all employees (excluding the highest-paid individual) amounts to 92.84 (69.11 in 2024)." Footnote 58 attributes the increase to "higher overall remuneration in relation to the Group's overperformance in the results achieved". The ratio therefore rose by roughly a third in a year in which average hourly pay fell for both men and women.

Incidents and complaints

Reference: page 108. Listed in the ESRS content index (index page 59).

A complete nil return for the reporting year: "During 2025, in continuity with 2024, no companies within the Group recorded incidents of discrimination or serious incidents or severe human rights impacts related to the workforce. Consequently, no complaints were filed through the Group's reporting channels or through the OECD National Contact Points for Multinational Enterprises. The total amount of fines, penalties and compensation recorded was 0 euro."

The nil return covers all three limbs of S1-17: discrimination incidents including harassment, complaints filed through channels and through OECD National Contact Points, and severe human rights incidents connected with the own workforce, together with the associated financial consequences.

Corroborating statements elsewhere: the Taxonomy minimum safeguards assessment records that the Parent Company and its subsidiaries "have not received court convictions relating to issues related to human rights, corruption, bribery, taxation or fair competition" and have not been "the subject of cases handled by an OECD National Contact Point (NCP)" (page 75). S2-1 reports no cases of non-compliance with the UNGPs, the ILO declaration or the OECD Guidelines involving value chain workers (page 110), and G1-4 reports no convictions or fines for corruption (page 120).

Value chain worker policies

Reference: pages 109-110. In the ESRS content index as "S2-1, MDR-P" (page 60).

The instrument is the Supplier Code of Conduct, adopted in March 2023, "applicable to all Group companies and approved by the Vice President of Technoprobe" (page 109).

Standards referenced (page 110). The Code "is based on the United Nations Guiding Principles on Business and Human Rights and has been prepared in accordance with internationally recognized standards, including the ILO Declaration on Fundamental Principles and Rights at Work".

Content. Suppliers must comply with "the respect and promotion of human rights, the guarantee of a workplace free from discrimination, the respect of workers' rights to participate in trade union activities, compliance with health and safety regulations, and privacy protection", and "must not use forced labour or child labour". Technoprobe "periodically verifies the compliance of its suppliers with the principles and standards set out in the Code".

Outcome for the year. "During 2025, no cases of non-compliance with the United Nations Guiding Principles on Business and Human Rights, the ILO Declaration ... or the OECD Guidelines for Multinational Enterprises involving workers in the value chain were reported."

The strategy section notes the Group "does not maintain direct business relationships" with the upstream extraction companies where the risk concentrates (page 109).

Engagement with value chain workers

Reference: page 110. Listed in the ESRS content index (index page 60).

A candid nil return: "There is currently no structured Group-wide process for engaging value chain workers regarding impacts; however, the most appropriate method of engagement is assessed on a case-by-case basis in order to capture their perspectives and expectations."

None of the supporting S2-2 datapoints therefore arises: no statement of whether engagement occurs directly with workers or through credible proxies such as trade unions or workers' representatives, no stage or frequency of engagement, no function or role with operational responsibility for it, no assessment of the effectiveness of engagement, and no specific approach for workers who may be particularly vulnerable to impacts.

The gap is material in context. SBM-3 identifies two negative S2 impacts, human rights violations covering "instances of child labour, forced or compulsory labour, collective bargaining, freedom of association, and social dialogue", and "Inadequate working conditions in the value chain", both upstream and downstream (page 43). S2 SBM-3 states the upstream chain "may be exposed to significant critical issues" concentrated "in the early stages of extraction and processing of raw materials ... in geographical areas characterized by high levels of risk" (page 109).

Remediation and channels for value chain workers

Reference: page 110. Listed in the ESRS content index (index page 60).

The instruments named are the Code of Business Conduct, the Supplier Code of Conduct and the Global Whistleblowing Policy, described as "tools aimed at engaging, raising awareness among and holding its suppliers accountable".

The Group's own channel. "In compliance with Legislative Decree 2023/24 and Directive (EU) 2019/1937, the Group has adopted a Global Whistleblowing Policy and a reporting channel available to suppliers and their workers, which specifically governs the reporting of unlawful conduct."

Requirements passed down the chain. "Through the Supplier Code of Conduct, the Group requires its suppliers to ensure appropriate reporting channels that allow their employees to report any violations of the principles set out in the Code, including anonymously", guaranteeing "confidentiality, privacy, anonymity and protection" and "processes protecting whistleblowers from retaliation".

Not disclosed: whether value chain workers are aware of or trust these channels, whether any grievances were received during 2025, how remedy is provided, and whether the Group uses any third-party grievance mechanism. S2-1 records no non-compliance cases in 2025 (page 110).

Actions on value chain workers

Reference: page 110. Listed in the ESRS content index as "S2-4, MDR-A" (index page 60).

A one-line nil return: "While recognizing the importance of the topic, the Group has not adopted specific actions regarding workers in the value chain."

No action, resource allocation or effectiveness tracking is therefore disclosed for the two material S2 negative impacts identified in SBM-3, human rights violations and inadequate working conditions among value chain workers, both located upstream and downstream (page 43), nor for the positive impact "Strengthening relationships with key partners".

What exists in place of actions is contractual and monitoring language elsewhere in the statement: the Supplier Code of Conduct is a condition of all procurement contracts (page 119), Technoprobe "periodically verifies the compliance of its suppliers with the principles and standards set out in the Code" (page 110), and G1-2 describes supplier criticality analysis, evolving control methodologies and dynamic review of risk profiles, with ESG criteria embedded in three procurement procedures inside the ISO 9001 quality system (pages 118-119). None of that is presented under S2-4, and no severe human rights issue or incident response process is described.

Value chain worker targets

Reference: page 110. Listed in the ESRS content index as "S2-5, MDR-T" (index page 60).

A one-line nil return: "While acknowledging the relevance of the topic, the Group has not adopted specific formalized targets regarding workers in the value chain."

No measurable outcome-oriented target is therefore set for either material S2 negative impact, human rights violations and inadequate working conditions among value chain workers (page 43), nor for the positive impact on relationships with key partners. None of the MDR-T elements is present: no base year, no target year, no methodology or assumptions, no milestones, and no statement of whether value chain workers or their representatives were involved in setting or reviewing targets.

The absence is consistent across the S2 chapter, which reports no structured engagement process (page 110) and no specific actions (page 110). The only forward-looking supplier commitment anywhere in the statement is in G1-2, where "The integration of sustainability parameters into this strategy, currently underway, aims to ensure a resilient value chain" (page 119), which is a direction of travel rather than a target with a date and a measure.

Community policies

Reference: page 111. Listed in the ESRS content index as "S3-1, MDR-P Policies related to affected communities" (index page 60).

A qualified nil return: "The Group has not adopted specific policies regarding affected communities, but addresses its commitment through the principles and values contained in the Code of Business Conduct."

The relevant Code commitments named are "the development of strong relationships at the local level with governments and communities, aimed at building trust and supporting balanced decision-making processes, as well as the commitment to respect local specificities and facilitate integration within business activities".

The S3 strategy section adds that the affected communities considered "include those who live and work near the Group's operational sites, as well as those located along the Group's value chain", and that upstream communities "may be exposed to significant critical issues ... particularly in the early stages of extraction and processing of raw materials" in high-risk geographies, where the Group has no direct commercial relationship (page 111). The Group's stated principle is "acting as a community of people", expressed through training initiatives for young people and local educational institutions.

No policy addresses human rights commitments to affected communities specifically, and no reference is made to the UN Guiding Principles, the ILO declaration or the OECD Guidelines within S3-1.

Engagement with affected communities

Reference: page 111. Listed in the ESRS content index (index page 60).

A qualified nil return: "There is currently no structured Group-wide process for engaging local communities regarding impacts; however, the most appropriate method of engagement is assessed on a case-by-case basis in order to capture perspectives and expectations."

One concrete instance is given: "In line with CSRD requirements, Technoprobe actively involved a representative from the non-profit sector in the Double Materiality assessment process", cross-referred to IRO-1. SBM-2 confirms that the 2025 assessment involved "non-profit organisations, and academic and technical institutions" among external stakeholders (page 41), and the E2 and E3 IRO-1 sections record that "a sample of local community stakeholders was involved through a questionnaire to assess their perspective on the long list of impacts generated by the Group" (page 55).

Not disclosed: the stage and frequency of engagement outside the materiality exercise, the function or role with operational responsibility for it, how the Group assesses the effectiveness of engagement, and any specific approach for communities that may be particularly vulnerable or marginalised. The single material S3 impact is positive, "Creation of jobs and contribution to youth employment" (page 43), and community engagement is otherwise described under SBM-2 as donations, sponsorships and school partnerships (page 41).

Remediation and community channels

Reference: page 112. Listed in the ESRS content index (index page 60).

The disclosure is brief: "The Group is committed to assessing and monitoring its impacts on communities, as well as ensuring the effective management of any negative impacts that it may directly or indirectly cause. In compliance with Legislative Decree 2023/24 and Directive (EU) 2019/1937, the Group has adopted a Global Whistleblowing Policy and a reporting channel available to third parties."

The channel is therefore the same Group whistleblowing platform used for employees, suppliers and customers, accessible from the corporate website, with reports handled by a Whistleblowing Officer, confidentially or anonymously, and with protection from retaliation (pages 98 and 118). No community-specific grievance mechanism exists.

What is not disclosed: whether affected communities are aware of the channel or trust it, whether any community grievance was received during 2025, how remedy would be provided, and whether the Group participates in or funds any third-party or state-based grievance mechanism. The single material S3 impact identified in the DMA is positive (job creation and youth employment, page 43), and SBM-3 notes that the impact "Financial support to associations within the local community" was identified as material by stakeholders "but for which no specific actions by the Group were identified" (page 50).

Actions on affected communities

Reference: page 112. Listed in the ESRS content index as "S3-4, MDR-A" (index page 60).

Two initiatives are described, both aimed at the material positive impact on youth employment.

Physics Teaching School "Federico Cesi". Technoprobe took part in the second edition, "promoted by the Territorial School Office of Lecco and the Province of Lecco", whose objective is "to stimulate in-depth reflection on physics education and to offer secondary school teachers a structured professional development programme". Technoprobe assigned professionals in engineering physics to deliver workshops, and seven training days were organised at Cernusco Lombardone "focusing on topics such as probe resistance and the use of artificial intelligence".

IFTS post-diploma programme. Launched in 2025 with the Lombardy Higher Technical Institute Foundation (ITS) and Gi Group, "aimed at creating one-year post-diploma training programmes". It "combines classroom training and company internships and includes the signing of an apprenticeship contract", and is intended "to prepare profiles that can be immediately employable in companies operating in the semiconductor, electronics and chip and circuit design software sectors".

Resources. "The total investment in 2025 remained below the predefined threshold reported in the ESRS 2, BP-1 section", that is under 500,000 euro. No participant numbers or outcome measures are given.

Community targets

Reference: page 112. Listed in the ESRS content index as "S3-5, MDR-T" (index page 60).

A one-line nil return: "While recognizing the importance of the topic, the Group has not adopted specific formalized targets related to affected communities."

No target is therefore attached to the single material S3 impact, "Creation of jobs and contribution to youth employment", an actual positive impact in own operations with a short, medium and long-term horizon (page 43). None of the MDR-T elements is present: no measurable outcome, no base year or target year, no methodology, and no statement of whether affected communities or their representatives were involved in setting or tracking targets.

The two community initiatives described under S3-4, the Federico Cesi physics teaching school and the IFTS post-diploma programme (page 112), are therefore reported without any quantified objective or measure of effectiveness. SBM-3 also records that the stakeholder-identified impact "Financial support to associations within the local community" was material to stakeholders but that "no specific actions by the Group were identified" for it (page 50), and that although the related risk "emerged as not material, the sub-topic 'Economic, social, and cultural rights of communities' remains material from an impact materiality perspective" (page 46).

Consumer and end-user policies

Reference: page 113. Listed in the ESRS content index as "S4-1, MDR-P Policies related to consumers and end-users" (index page 61).

Two instruments are named. The Code of Business Conduct commitments towards customers cover "product quality, service quality and customer satisfaction, which form the basis of the Group's values and commercial strategies", with a stated commitment to "maintaining a high level of product innovation, quality and safety, through continuous listening to customer needs and expectations, also taking into account sustainability aspects and product content restrictions".

The Information Security Policy, "approved by the Vice-Chairman of the Board of Directors in April 2023", exists "In order to prevent unintentional behaviours that could cause issues or threats to the security of the Group's data and equipment". Its principle is that data accessed during work "must be considered confidential and must not be communicated or disclosed without the company's specific authorization".

A third instrument is the internal procedure "Confidential Information Management", aimed at raising workforce awareness of confidential information "while also ensuring the same level of protection for third-party know-how received by Technoprobe".

The policies address the two material negative S4 impacts (page 44). No reference to the UN Guiding Principles or the OECD Guidelines appears within S4-1.

Engagement with consumers and end-users

Reference: page 114. Listed in the ESRS content index (index page 61).

Engagement is "structured and dedicated", with the commercial management and sales functions as "the main interface between the Group and its customers", responsible for listening to and collecting requests about products and the company.

Four named channels (page 114): periodic visits to headquarters covering annual forecasts and commercial conditions; Technical Review Meetings to update customers on technological progress and share development roadmaps; Continuous Improvement Meetings generating "shared action plans aimed at maintaining consistent quality standards"; and Commercial Working Groups covering forecasts, planning, supply chain stability and risk management, and also "safety and sustainability ... and long-term operational resilience".

Events. In 2025 the Group ran a panel on chiplet testing at the European Test Symposium in Estonia and attended the International Test Conference in San Diego and the Chiplet Summit in California.

Materiality input. "the Parent Company actively involved a sample of customers in the Double Materiality Assessment, collecting information on the significance of the impacts generated by the Group."

No function with operational responsibility for engagement is named beyond the sales organisation, and no effectiveness assessment is disclosed.

Remediation and customer channels

Reference: pages 114-115. Listed in the ESRS content index (index page 61).

Non-conformity management. Technoprobe "pays constant attention to customer satisfaction through continuous monitoring of product non-conformities and of the sustainability expectations expressed by customers", through the Procedure for the Management of Non-Conformities and Improvement Actions, which covers "the lifecycle of the products and services offered by the company". Its aims are to "prevent the supply of products with defects" and to "prevent the recurrence of behaviours or processes that may lead to product or process non-conformities". It "defines the responsibilities and methods for the issuance, management and assessment of the effectiveness of corrective and preventive actions".

Whistleblowing and complaints. The Global Whistleblowing Policy channel is available to third parties under Legislative Decree 24/2023 and Directive (EU) 2019/1937. Separately, "for complaint management the Group has implemented an internal database in which received complaints are recorded and assigned to a responsible owner, who performs an analysis to identify root causes and define the related corrective actions".

No number of complaints received is disclosed, although S4-4 records that "During the year, no complaints relating to customer data breaches were received" (page 116).

Actions on consumers and end-users

Reference: pages 115-116. Listed in the ESRS content index as "S4-4, MDR-A" (index page 61).

No structured action programme. "considering the highly customized nature of its products, the Group adopts an equally tailored approach to customer relationship management ... For this reason, no specific structured action programmes have been defined."

Product quality (page 115). Products are made to customer requirements and internal procedures, with continuous improvement "including through the systematic analysis of customer feedback". Quality is assured through "inspections throughout the various stages of production and a rigorous final control process", under ISO 9001 certified systems at Technoprobe, Technoprobe Asia, Taiwan, Korea and France.

External recognition (pages 115-116). In 2025 the Group received Intel's EPIC Supplier Award and was recognised by Samsung Electronics as an Excellent Partner Company.

Data protection (page 116). A Vulnerability Assessment and Penetration Test runs annually across the Group perimeter. Data centre services are outsourced to a provider certified to UNI ISO 27017 and 27018, and Technoprobe "renewed the certification of its Information Security Management System in accordance with UNI ISO 27001:2022". "During the year, no complaints relating to customer data breaches were received."

No resources are quantified and no effectiveness measure is attached.

Consumer and end-user targets

Reference: page 116. Listed in the ESRS content index as "S4-5, MDR-T" (index page 61).

A one-line nil return that ties the absence of targets to the absence of actions: "As the Group has not established specific structured action programmes, while recognising the importance of the topic, it has not adopted formalised targets relating to consumers and end-users."

No target is therefore set for any of the three material S4 impacts, the positive impact from "Offering safe, high-quality, and durable products" and the negative impacts from "Failure to meet customer satisfaction and expectations" and "Violation and loss of customer data" (pages 43-44), nor for the two material S4 risks (product non-conformities and loss of customer data) or the material S4 opportunity (customer service management) at pages 44-45.

None of the MDR-T elements is present: no measurable outcome, no base year or target year, no methodology, no milestones, and no statement of whether consumers and end-users were involved in setting targets or tracking performance. The disclosure also carries no metric of its own, so customer satisfaction, complaint volumes and non-conformity rates are described qualitatively under S4-3 and S4-4 but never quantified, other than the statement that no customer data breach complaints were received during the year (page 116).

Business conduct policies

Reference: pages 117-118. In the ESRS content index as "G1-1, MDR-P Business conduct policies and corporate culture" (page 61).

Code of Business Conduct. The Code "provides guidelines for activities carried out within Technoprobe and its subsidiaries, and to which the workforce and suppliers are required to adhere", covering "quality, ethics, respect for working conditions ... environmental protection and responsible sourcing", and "reflects the standards of the Responsible Business Alliance (RBA)". First issued October 2015, last updated December 2022, approved by the Vice-Chairman. It is published on the website and intranet and given to new hires, with compliance "subject to periodic verification by the competent functions".

Model 231. An Organisational, Management and Control Model under Legislative Decree 231/2001 aims "to prevent the commission of offences, including unlawful data processing, environmental crimes and other offences related to human rights violations". The Board updates it, while "the Supervisory Body (OdV) continuously monitors its effectiveness and compliance".

Whistleblowing (page 118). A Global Whistleblowing Policy, approved by the Board and part of the Model, with an appointed Whistleblowing Officer and an online platform; oral reports are possible on request. In 2025, 18% of employees in Italy (313 employees) completed the "Whistleblowing" training course, for a total of 313 training hours.

Supplier relationships

Reference: pages 118-119. In the ESRS content index (page 61).

Approach. "Supplier relationship management is based on a systematic analysis that correlates the strategic impact of each supplier with the associated supply risk", built on three principles: supplier criticality analysis, focused on suppliers "identified as essential for maintaining core business operations"; evolution of control methodologies, with criteria "subject to continuous and progressive updates"; and dynamic review of risk profiles, "ensuring that monitoring resources are allocated proportionally to each supplier's actual business criticality".

"The integration of sustainability parameters into this strategy, currently underway, aims to ensure a resilient value chain."

Instruments (page 119). A Supplier Code of Conduct and a Global Procurement Policy apply Group-wide. "All procurement contracts are conditional upon acceptance of the Supplier Code of Conduct." Three procedures incorporate ESG criteria: supplier qualification, supplier product qualification, and purchasing. These "form part of the Quality Management System certified according to UNI ISO 9001:2015".

Selection criteria. Environmental (resource management, emissions reduction, eco-friendly materials), social (safety, fair wages, prohibition of child labour) and business conduct.

No payment practices data is given; G1-6 is absent from the content index.

Anti-corruption

Reference: pages 119-120. In the content index (page 61).

Policy. "The Group does not tolerate any form of corruption or bribery, either directly or through third parties", through a Global Anti-Corruption Compliance Policy "applicable to processes considered particularly sensitive". It was "updated in December 2022 and approved by Technoprobe's Board of Directors", and applies to "directors, officers, employees, agents, representatives and other individuals acting on behalf of the Group, including external collaborators, distributors and commercial partners".

Prohibition. Recipients "may not offer or provide any benefit, including gifts, hospitality or representation activities, with the aim of obtaining or maintaining an improper business advantage."

Investigation independence (page 120). "Technoprobe ensures the separation of investigative personnel from the management chain involved, and the results of investigations are promptly communicated to the relevant governance bodies".

Training. "In 2025, 15% of employees received training on these topics. In particular, in Italy 9% of employees (151) attended the 'EMS Training' course, for a total of 151 training hours, representing an increase of 4% compared to 2024." Footnote 66 records that other at-risk employees were trained in 2022 and 2023 and that "Training was not provided to the members of the Board of Directors."

No breakdown of at-risk functions is given.

Business conduct targets and effectiveness tracking

Reference: pages 117-120. This is a standalone DR only from the 2025/2026 ESRS; the statement was prepared under the 2023 ESRS, where business conduct targets fell under MDR-T. The ESRS content index lists only G1-1 to G1-4 under G1, with no MDR-T entry (page 61).

No target is stated. No quantified or dated business conduct objective appears in the G1 chapter, and the ESG components of the 2025 incentive plans are environmental and social rather than governance (pages 30-31).

Effectiveness is tracked, which is MDR-T's other limb. The mechanisms disclosed are:

• periodic verification of Code of Business Conduct compliance "by the competent functions" (page 117);
• the Supervisory Body (OdV), which "continuously monitors its effectiveness and compliance" for the Model 231 (page 117);
• controls "carried out by the Internal Audit function" over business conduct policies (page 118);
• employees who "must certify in writing that they have read and accepted" the anti-corruption policy (page 120);
• measured training completion: 18% of Italian employees on whistleblowing (313 employees, 313 hours) and 15% of Group employees on anti-corruption, 9% in Italy (151 employees, 151 hours), up 4% on 2024 (pages 118 and 120);
• incident review through G1-4, which reports no convictions or fines in 2025 (page 120).

The tracking is activity-based, and no baseline or improvement objective is attached.

Confirmed incidents

Reference: page 120. In the ESRS content index (page 61).

A nil return for the year, in full: "During 2025, and in line with the previous year, the Group did not receive any convictions and/or fines for violations of laws against active and passive corruption."

The statement covers the convictions and fines limb of G1-4. It does not separately report the number of confirmed incidents of corruption or bribery, the number of confirmed incidents in which own workers were dismissed or disciplined, the number relating to contracts with business partners being terminated or not renewed, or details of public legal cases regarding corruption or bribery brought against the undertaking or its own workers.

Corroborating statements elsewhere in the statement: the Taxonomy minimum safeguards assessment records that the Parent Company and its subsidiaries "have not received court convictions relating to issues related to human rights, corruption, bribery, taxation or fair competition" and have not been "the subject of cases handled by an OECD National Contact Point (NCP)" (page 75), and S1-17 reports no incidents, complaints or fines relating to the workforce, with a total of 0 euro in fines, penalties and compensation (page 108).

"Incidents of corruption and anti-competitive practices" is a material potential negative impact spanning upstream, own operations and downstream (page 42), and "Corruption cases" is a material risk (page 44).