Tecnotree Corporation

Under the heading Corporate Governance Framework (tagged ESRS 2, GOV-1, GOV-3, page 57), Tecnotree describes the role of its administrative, management and supervisory bodies. The Board of Directors, comprising non-executive members and supported by four Board Committees (Audit, Nomination, Remuneration and Strategy), is responsible for the Company's corporate governance and for effective oversight of operations. A Management Board sits alongside the Board Committees in the governance structure. The Company states it has established a corporate governance structure and undertakes regular risk assessments to identify and mitigate potential ethical and compliance risks, and that it does not engage in lobbying activities across its global operations. The material topics linked to this section are Business Ethics and Compliance and Bribery and Corruption. Readers are directed to the Corporate Governance Statement of the Annual Report for further detail on Board and Management Board members, the roles of the Board Committees, and Board independence and diversity. The disclosure is high-level and points to the separate governance statement for specifics.

GOV-2 covers information provided to, and sustainability matters addressed by, the undertaking's administrative, management and supervisory bodies. In the ESRS Disclosure Index (page 61), Tecnotree maps GOV-2 to the section titled Board of Directors and Management Board. The narrative sustainability report does not contain a dedicated, detailed GOV-2 discussion of how sustainability matters were reported to and considered by these bodies during the reporting period. The report indicates that the Board of Directors and its four Committees (Audit, Nomination, Remuneration and Strategy) provide oversight of operations, and it directs readers to the Corporate Governance Statement of the Annual Report for information on the Board and Management Board. As this is Tecnotree's inaugural CSRD-aligned report and first double materiality assessment, the treatment of GOV-2 in the sustainability statement is brief and largely handled through the disclosure index cross-reference rather than a standalone account of matters addressed by the bodies.

GOV-3 concerns the integration of sustainability-related performance into incentive schemes. In a dedicated section titled Integration of Sustainability-related Performance in Incentive Schemes (tagged ESRS 2 GOV-3, page 43), Tecnotree states that climate-related considerations are not yet explicitly linked to the remuneration of the members of its administrative, management and supervisory bodies. The Company acknowledges the importance of embedding sustainability into its KPIs and business objectives and, to accelerate progress and strengthen credibility, intends to introduce sustainability-linked incentive programs within the next two years. The topic is also referenced under the Corporate Governance Framework heading (ESRS 2, GOV-1, GOV-3) and the Board's Commitment to Sustainability heading (GOV-3, GOV-4, GOV-5, G1-5). Elsewhere the report mentions that 5% of leadership incentives are tied to ESG. The disclosure is honest about the current absence of formal sustainability-linked remuneration and frames it as a planned future development, consistent with this being a first-year reporter.

GOV-4 requires a statement on due diligence. Under the heading Board's Commitment to Sustainability (tagged GOV-3, GOV-4, GOV-5, G1-5, page 57), Tecnotree states that it is committed to embedding due diligence as a core element of its governance, strategy and business model to ensure alignment with the Corporate Sustainability Due Diligence Directive (CSDDD). To strengthen this commitment, the Company reports that it has proactively initiated the EcoVadis assessment process, which it says will provide a comprehensive framework for evaluating and enhancing its sustainability and corporate social responsibility efforts. It adds that the results of this assessment will be transparently shared in the Company's upcoming report. In the ESRS Disclosure Index (page 61), GOV-4 is mapped to the Board's commitment to sustainability section. The statement is brief and forward-looking, describing an intention to align with the CSDDD and an initiated EcoVadis process rather than presenting a completed due diligence mapping across the value chain, which is consistent with Tecnotree's first year of ESRS reporting.

GOV-5 covers risk management and internal controls over sustainability reporting. Tecnotree addresses this under the Board's Commitment to Sustainability heading (tagged GOV-3, GOV-4, GOV-5, G1-5, page 57), and the ESRS Disclosure Index (page 61) maps GOV-5 to that same section. The report frames strong governance as underpinning long-term success through tight risk management and continuous improvement, and states that the Company undertakes regular risk assessments to identify and mitigate potential ethical and compliance risks. Related material describes a comprehensive governance framework of business conduct policies, including a Business Continuity and Disaster Recovery Policy aligned with ISO/IEC 27001, an Information Security Management System, a Data Loss Prevention Policy and a Quality Management System aligned with ISO 9001:2015. The financial materiality assessment is noted as aligning with the Company's enterprise risk management (ERM) framework. The disclosure does not provide a detailed description of internal controls specific to the sustainability reporting process itself, addressing GOV-5 mainly through broader governance and risk-management commitments.

SBM-1 addresses strategy, business model and value chain. In the section Tecnotree's Sustainable Business Strategy (tagged SBM-1, SBM-3, E1-4, pages 32-33) the Company presents its Strategic Sustainability Priorities organised under three pillars: Environmental Stewardship, Social Responsibility and Governance. Environmental Stewardship covers focus areas of Energy Management, GHG Emissions and climate and environmental responsibility, with efforts such as a Green Cloud Initiative, energy efficiency and infrastructure optimization, and going paperless. Social Responsibility covers Digital Inclusion and Diversity, addressing the digital divide, workplace equity and inclusion, and human capital development, alongside customer relationship management and community impact. Reported progress figures include Scope 1 emissions of 3.11 tCO2e, Scope 2 emissions of 145.68 tCO2e, 30% women employees, an employee satisfaction score of 8.1, average training hours per employee of 6.12, and a customer satisfaction score of 4.08. The ESRS Disclosure Index (page 61) maps SBM-1 to the section Our strategy. The disclosure describes value creation across operations and the value chain but is presented largely through a priorities-and-targets table rather than a detailed value-chain map.

SBM-2 concerns the interests and views of stakeholders. Under the heading Engaging with Stakeholders (tagged SBM-2, page 35) Tecnotree states that creating value for stakeholders is at the core of its mission and purpose, and that by listening to and addressing their needs the Company navigates social, environmental and economic challenges. It sets out a six-step Stakeholder Engagement Approach: identify stakeholders; understand their needs and expectations; analyse their influence on Tecnotree; engage with the identified stakeholders; track and analyse the results of the engagement; and undertake relevant changes and improvements to the engagement strategy. A Methods of Engagement table describes engagement with consumers, suppliers and employees, listing topics of engagement, measures in place to meet stakeholder needs (such as steering group reviews, quality control, contract reviews, reward and recognition programmes and training academies), engagement modes (surveys, grievance mechanisms, customer and supplier meets, townhalls, emails) and frequency (annual, ongoing or demand-based). SBM-2 is also tagged in the workforce and customer sections (ESRS 2 SBM-2, page 61 index), linking stakeholder views to material topics for own workforce and consumers.

SBM-3 covers material impacts, risks and opportunities and their interaction with strategy and business model. Tecnotree addresses this within the Double Materiality Assessment section (tagged IRO-1, IRO-2, SBM-3, pages 36-41) and links it to the Sustainable Business Strategy (SBM-1, SBM-3, E1-4). The Company presents a Double Materiality Matrix plotting impact materiality against financial materiality for topics including Business Ethics and Compliance, Data Privacy and Cybersecurity, Diversity Equity and Inclusion, Employee Health Safety and Well-Being, Community Impact and Engagement, Sustainable Innovation Management, Human Rights, Human Capital Development, Energy Management, GHG emissions, Clean Technology, Customer Relationship Management, Responsible Supply Chain, Waste Management, Water Management and Environmental Policy and Management. An Impacts, Risks and Opportunities table sets out, for each material topic, potential risks or opportunities, measures taken by Tecnotree, and actual impact during the year. SBM-3 is further tagged in the E1, S1 and S4 sections (page 61 index). The material topical standards emerging from this maiden assessment are E1, S1, S4 and G1.

IRO-1 describes the processes to identify and assess material impacts, risks and opportunities. In the Double Materiality Assessment section (tagged IRO-1, IRO-2, SBM-3, pages 36-38) Tecnotree explains that during 2024 it conducted its maiden double materiality assessment in accordance with the CSRD and ESRS, considering both impact materiality (the impacts of the Company's business on environment and people) and financial materiality (how sustainability topics prompt material financial effects on the business). The process followed several steps: Sectoral and Peer Analysis to identify relevant topics from sector standards and peer priorities; building a Universe of Material Topics categorised into E, S and G with overlapping topics merged; Management Discussions in which subject matter experts and senior leadership assessed impacts, risks and opportunities; and a Materiality Survey of nearly 10% of the internal workforce and external stakeholders (sample suppliers and vendors) rating magnitude and time horizon on a three-point scale. The financial materiality assessment aligns with the enterprise risk management (ERM) framework, extends time horizons and evaluates risks before mitigation, consistent with ESRS 1. The output was a comprehensive list of material topics and a materiality matrix.

IRO-2 concerns the disclosure requirements in ESRS covered by the undertaking's sustainability statement. Tecnotree addresses this within the Double Materiality Assessment section (tagged IRO-1, IRO-2, SBM-3), and the ESRS Disclosure Index (page 61) maps IRO-2 to that section. The most substantive IRO-2 content is the ESRS Disclosure Index (Annexure, pages 60-61 onward), which lists the disclosure requirements the Company reports against, their descriptions, the section of the report where each is covered and, where shown, page numbers. The index is organised by ESRS 2 General Disclosures (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2) followed by topical standards ESRS E1 Climate Change, S1 Own Workforce, S4 Consumers and End-users, and G1 Business Conduct, reflecting the material topical standards identified in the maiden double materiality assessment. Each entry cross-references the relevant report section, providing the mapping of covered disclosure requirements to their location in the statement.

Tecnotree reports a transition plan for climate change mitigation that is still under development (p. 43). The Company states it is actively working on a comprehensive transition plan set for adoption by CY 2027, with objectives for reducing Scope 1, Scope 2 and Scope 3 emissions and interim milestones to ensure accountability and measurable progress. As a first-year reporter, the disclosure is early-stage and qualitative rather than a finalised, quantified plan. Pending formal adoption, the Company says it is embedding climate-conscious practices across operations, including reducing emissions through data-driven strategies, adopting renewable energy and low-carbon technologies, and improving energy efficiency. It also plans to integrate climate resilience by assessing and mitigating physical and transition risks. No specific reduction percentages or capital allocation figures are provided for the transition plan itself.

Tecnotree describes policies related to climate change mitigation and adaptation (p. 43). The Company states it is committed to advancing sustainability and addressing climate change through a formalized climate action policy framework. As part of this initiative it is assessing its operational footprint while aligning with industry best practices to establish measurable, low-carbon initiatives. Key actions cited include transitioning to green data centers as a cornerstone of its low-carbon strategy, with plans to strengthen energy efficiency and environmental stewardship targets by 2026. The disclosure is qualitative and reflects a first-year reporter whose policy framework is still being formalised. No detailed policy scope, thresholds or governance ownership of the policies are quantified in the text.

Under the heading Prioritising Climate Change Mitigation, Tecnotree describes actions and resources for climate mitigation (p. 43). It states it is integrating cleaner solutions into operations, with a key initiative promoting green cloud infrastructure to optimize energy efficiency while reducing environmental impact. The Company notes its Certify solution advances clean technology and strengthens trust and governance in Artificial Intelligence, aligning with frameworks such as the EU AI Act, CSRD standards and privacy policies. Related actions described elsewhere in the E1 narrative include running roughly 30% of data centers as green and carbon-neutral (including the Mysuru facility), a commitment to transition to 100% green data centers over the long term, investing in LEED-certified buildings, and monitoring energy consumption using OpenTelemetry (p. 42). The disclosure is qualitative and does not quantify the financial resources allocated to these actions.

Tecnotree discloses early-stage climate targets within its energy and GHG narratives (pp. 43-45). For emissions, the Company states it is working towards a net-zero target by CY 2040, with defined reduction pathways for Scope 1, 2 and 3 from a baseline year. A specific focus is Scope 3 Category 7 (employee commuting), with a target to reduce emission intensity from employee commuting by 10% per employee per kilometer each year. It aims to align reduction efforts with the Science-Based Targets initiative (SBTi) framework. For energy, the Company reports a long-term goal of achieving 100% climate-neutral data centers by 2030 as part of the Climate Neutral Data Center Pact, and plans to strengthen energy efficiency and environmental stewardship targets by 2026. As a first-year reporter, most targets are directional and interim milestones and the baseline year are not yet fully specified.

Tecnotree reports energy consumption for CY 2024 (p. 43 narrative; ESG data pack p. 63). The narrative states total energy consumption of 212,068.74 kWh with an energy intensity of 12.05 kWh per 1,000 EUR for its India operations. The ESG data pack (E1-5 Energy consumption and mix) breaks this down as purchased grid electricity of 200,389 kWh and diesel of 1,164 liters, giving a total of 200,389.15 kWh, equivalent to 763.44 GJ. The Company describes optimizing energy use through a pay-as-you-go model for public cloud services, automated virtual machine shutdown during off-peak hours, and increased use of renewable energy across locations. In India, leased office premises are managed by the property operator, who monitors and reports monthly energy consumption via sensors on floors and in meeting rooms.

Tecnotree reports gross GHG emissions for CY 2024 for the first time, covering Scopes 1, 2 and 3 (p. 44 narrative; ESG data pack p. 63). Scope 1 emissions were 3.11 tCO2e, from diesel generator sets at the Bengaluru office. Scope 2 (location-based) emissions were 145.68 tCO2e, from grid electricity at the Bengaluru office, for India operations. Scope 3 emissions were screened for India operations and reported by category: Category 1 Purchased goods and services 2.2 tCO2e (spend-based method); Category 3 Fuel- and energy-related activities 55.88 tCO2e (average data method); Category 6 Business travel 39.85 tCO2e (Finland air, car and hotel data); and Category 7 Employee commuting 50.91 tCO2e (based on a survey of 223 employees, about 30% of the 742 workforce). The Company applies the GHG Protocol Corporate Standard and the Scope 3 Value Chain Standard.

Tecnotree describes its policies for employee well-being (page 52), all approved by the Board of Directors and applicable to employees, contractors and suppliers. The Code of Conduct requires integrity, accountability and respect, with mandatory annual review and a comprehension test, and offers a Direct reporting channel for misconduct without retaliation. The Human Rights Policy adheres to the UN Guiding Principles on Business and Human Rights, EU directives, ILO conventions, the Modern Slavery Act 2015 and the Universal Declaration of Human Rights, overseen by the Board, CFO and CEO. An Anti-harassment Policy sets zero tolerance and complies with the Occupational Safety and Health Act, Equality Act and Non-discrimination Act. A Prevention of Sexual Harassment (POSH) Policy mandates training with annual refreshers. A Diversity and Equity Plan aligns with the Finnish Non-discrimination Act and Act on Equality, features measurable goals, regular monitoring and biennial updates starting in 2025, and is promoted by a DEI Committee.

Tecnotree reports engagement with its own workforce (page 53) through an Employee Communication Model designed to foster transparent, meaningful and consistent engagement. The Company achieved an employee satisfaction score of 8.1 out of 10 during the year. The model sets out defined engagement types, frequencies, key topics and modes: quarterly CEO communication by email and webinar covering quarterly goals and organisation performance; Vice President/Regional Head communication once every two months covering regional goals, products, challenges and new initiatives; business unit engagement once every two months covering function updates, customer feedback and rewards and recognition; monthly one-to-one meetings between team members and their immediate managers covering business development, employee appreciation, two-way feedback and learning and development needs; and Marketing/CFO communication of public releases as released. New employee communication (monthly) includes goal setting, skip-level meetings with the Core Management Board, an HR pulse check and probation review, while monthly HR communication covers company policies.

Tecnotree reports channels for its own workforce to raise concerns (pages 52 to 53). Under the Code of Conduct the Company provides a Direct reporting channel for reporting misconduct, with a dedicated team that investigates reports and takes appropriate action up to legal measures, and it prohibits retaliation against those who report. The Anti-harassment Policy encourages employees to report harassment immediately and strictly prohibits retaliation against people who report. As part of employee engagement, Tecnotree operates a two-step exit interview process in which departing employees complete an exit questionnaire followed by a confidential face-to-face interview with an HR Business Partner; feedback is reviewed with the management team and Business Unit Head while maintaining confidentiality, and actionable steps are implemented to support continuous improvement. Monthly one-to-one meetings between employees and managers also provide two-way constructive feedback.

Under the heading Prioritising Employee Well-being (page 50), Tecnotree describes actions taken to manage impacts on its own workforce. It offers a comprehensive range of benefits including provision for remote work, a lunch benefit per local practices, parental leaves and allowances as good as or better than local regulations across all locations, and regular sports, leisure and employee engagement activities. An Occupational Safety and Health Program includes a Safety Action Plan and an OHS Committee, OSH Manager and elected delegates meeting twice a year, with a General Safety and Action Guide for Finland offices. An Early Support Model applicable to all Tecnotree Oyj employees ensures timely responses to threats to work, safety and well-being, covering deterioration in performance, burnout and recurrent sickness. A Crisis Management Framework, led by a Crisis Manager and a dedicated Crisis Management Team, prioritises employee and contractor safety during internal or external crises.

Tecnotree reports on targets related to managing its workforce (pages 52 to 53). Its Diversity and Equity Plan, aligned with the Finnish Non-discrimination Act and Act on Equality, features measurable goals, regular monitoring and biennial updates starting in 2025, implemented by the management board, HR, managers and the occupational safety and health team, with a DEI Committee promoting diversity, equity and inclusion across recruitment, performance management and employee engagement at Tecnotree Oyj. The Company uses a top-down annual target-setting process, with Board-approved goals set at the start of the year and cascaded to Business Units, teams and individual employees. The disclosure references an employee satisfaction score of 8.1 out of 10 achieved during the year as a measure of engagement. As a first-year reporter, Tecnotree does not present a full quantified set of time-bound social targets.

Tecnotree reports characteristics of its employees (pages 47 and 64). It currently employs 742 permanent employees across Dubai, Finland, India and Nigeria (excluding other locations), of which 522 are male and 220 are female. Employee turnover for the reporting year was 10.91%. The ESG data pack gives headcount by location: Dubai 33 (27 male, 6 female), Finland 22 (18 male, 4 female), India 660 (452 male, 208 female) and Nigeria 27 (25 male, 2 female). By share of workforce, India accounts for 89%, with Dubai, Finland and Nigeria each around 3 to 4%. The overall gender split is 70% male and 30% female. In line with the European General Data Protection Regulation (GDPR), Tecnotree does not collect personal information about its employees across its operations.

Tecnotree reports characteristics of non-employees in its own workforce (pages 47, 49 and 65). It collaborates with 175 non-employees through various contractual arrangements including direct contractors, fixed-bid contractors, third-party contractors and interns. The ESG data pack gives non-employee headcount by region: Dubai 5, India 156, Finland 4 and Nigeria 10. By gender, non-employees comprise 115 male (66%) and 60 female (34%, shown as 44% female in one chart), with India split 100 male and 56 female, Dubai 5 male, Finland 4 male and Nigeria 6 male and 4 female. As a first-year reporter, Tecnotree presents headcount by region and gender rather than a fuller breakdown of non-employee categories.

Tecnotree reports on collective bargaining coverage and social dialogue for its own workforce (page 54). The Company respects the rights of its Finnish employees to freely associate, participate and engage in collective bargaining in accordance with the law. In calendar year 2024, 100% of Tecnotree's employees in Finland were covered by collective bargaining agreements. Collective bargaining does not apply to its employees in India, Dubai and Nigeria. As a first-year reporter, the disclosure focuses on the Finnish workforce, where collective bargaining is legally established, and does not present a fuller quantitative breakdown of workplace representation across all locations.

Tecnotree reports diversity metrics for its own workforce (page 47). Across its permanent workforce of 742 employees, 522 (70%) are male and 220 (30%) are female. Location-wise gender diversity is disclosed: Dubai 27 male and 6 female, Finland 18 male and 4 female, India 452 male and 208 female, and Nigeria 25 male and 2 female. New hires during the year skewed young, with 60% of the 82 new hires below 30 years of age. As a first-year reporter, Tecnotree presents gender distribution by location but notes that, in line with GDPR, it does not collect broader personal information about employees, so certain diversity dimensions such as management-level gender split are not quantified.

Under Prioritising Employee Well-being (pages 50 to 51), Tecnotree addresses adequate wages and related conditions for its own workforce. It offers a comprehensive range of benefits to support well-being and growth, including provision for remote work, a lunch benefit according to local practices, and parental leaves and allowances as good as or better than local regulations in all Tecnotree locations. Employees are covered by various types of insurance in Finland, including employee pension, accident, life, unemployment and travel insurance. The Company follows a 5-day work week across its offices with remote, hybrid and office-based working models by location. As a first-year reporter, Tecnotree describes benefits and working conditions qualitatively rather than presenting a quantified adequate-wage benchmark.

Tecnotree addresses social protection for its own workforce within its well-being disclosures (pages 50 to 51). In Finland the Company provides various types of insurance such as employee pension, accident insurance, life insurance, unemployment insurance and travel insurance. Healthcare benefits in Finland include a pre-employment medical examination, a fixed-term medical examination every three years for employees over 50 years of age, mandatory medical examination for postings abroad, and a Substance Abuse Program to maintain a substance-free, healthy and safe working environment. All employees are entitled to parental leave as good as or better than local regulations. As a first-year reporter, Tecnotree describes these protections qualitatively, with the most detailed coverage relating to its Finland operations.

Tecnotree references persons with disabilities within its workforce disclosures (page 47) as part of its overall workforce and diversity reporting. The tag for this disclosure requirement appears alongside the workforce characteristics section that reports 742 permanent employees split 522 male and 220 female across Dubai, Finland, India and Nigeria. The Company notes that, in line with the European General Data Protection Regulation (GDPR), it does not collect personal information about its employees across its operations. As a first-year reporter, Tecnotree does not present a quantified disability employment rate; the topic is covered through its Diversity and Equity Plan and Non-discrimination commitments rather than a separate metric.

Tecnotree reports training and skills development metrics (pages 54 and 66). It invests in tailored learning pathways, leadership development programs and workshops on emerging technologies, alongside reward and recognition programmes and defined Way of Working (WoW) practices. For employees, average training was 6.12 hours per employee, 5.8 hours per male employee and 6.8 hours per female employee. For non-employees, average training was 24.99 hours overall, 21.82 hours per male non-employee and 31 hours per female non-employee. The data pack shows total employee training hours by location: Dubai 171.5, Finland 232, India 4,050.50 and Nigeria 90.5, with per-employee averages of 5.2, 10.55, 6.14 and 3.35 hours respectively. All Tecnotree employees participated in performance and career development reviews through biannual goal evaluation discussions including a mid-year review and an annual appraisal.

Tecnotree reports on health and safety for its own workforce (page 50). Its Occupational Safety and Health Program is built on a Safety Action Plan that fosters a healthy work environment by encouraging employee cooperation and safety concern reporting. An OHS Committee, OSH Manager and elected delegates meet twice a year to address OSH issues, collaborating with employees and healthcare providers to ensure workplace safety. For Finland offices, a General Safety and Action Guide ensures employee safety through emergency preparedness and clear action steps. A Crisis Management Framework prioritises employee and contractor safety and health during extraordinary internal or external crises, activating a dedicated Crisis Management Team led by a Crisis Manager to reduce risks and ensure business continuity. As a first-year reporter, Tecnotree describes its health and safety management qualitatively without presenting quantified injury or coverage rates.

Tecnotree reports work-life balance metrics (pages 51 and 66). All employees are entitled to parental leave as good as or better than local regulations, supported by a Get Fit model offering a Selfcare Day-off for employees who complete 20 hours of monthly exercise. Working models vary by location: remote in Espoo and hybrid in Tampere (Finland), and hybrid in India, Dubai and Nigeria, on a 5-day work week. The parental leave data pack shows employees entitled to leave and those who took it: in Finland 3 paternity and 10 maternity, and in India 19 paternity leaves taken, with essentially no uptake recorded in Dubai and Nigeria. Return-to-work rate for employees that took parental leave was 100% in Finland (paternity) and 100% in India (both maternity and paternity), with retention rates of employees who took leave of 33% and 80% in Finland and 79% in India.

Tecnotree references remuneration and compensation matters for its own workforce within its well-being and policy disclosures (pages 50 to 52). The Company offers benefits including a lunch benefit according to local practices, parental leaves and allowances as good as or better than local regulations, and various insurance provisions in Finland. Its Diversity and Equity Plan aligns with the Finnish Non-discrimination Act and Act on Equality and features measurable goals, regular monitoring and biennial updates starting in 2025 to promote equity across recruitment and performance management. As a first-year reporter, Tecnotree does not disclose a quantified gender pay gap figure or CEO-to-median pay ratio; the topic is addressed through equal-treatment commitments and its DEI governance rather than a specific compensation metric.

Tecnotree addresses incidents, complaints and human rights impacts affecting its own workforce through its policies (pages 50 to 52). The Anti-harassment Policy sets a zero-tolerance stance towards harassment in all work settings, encourages immediate reporting and strictly prohibits retaliation, complying with the Occupational Safety and Health Act, Equality Act and Non-discrimination Act. The Prevention of Sexual Harassment (POSH) Policy prohibits all forms of sexual harassment and retaliation, with mandatory training including annual refreshers. The Code of Conduct provides a Direct reporting channel, with a dedicated team investigating reports and taking action up to legal measures without retaliation. On the related anti-corruption topic, no incidents of corruption or bribery were detected in 2024. As a first-year reporter, Tecnotree describes its complaint mechanisms and protections qualitatively without reporting a specific count of workforce discrimination or harassment incidents.

Tecnotree reports its policies related to customers under the heading Policies related to Customers (pages 55-56), drawing on ESRS SBM-2 and SBM-3. The Company states it places customers at the centre of its business and works to align its solutions with their evolving needs and expectations. To strengthen customer relationships, the Strategy Committee participates in customer meetings and events and provides clarity on strategic direction. The disclosure reports customer outcome measures rather than a standalone consumer policy document: Tecnotree achieved a customer satisfaction score of 4.08 out of 5 during the year. In 2023 it recorded a Net Promoter Score in the medium range of 0 to 30, with 20 percent of respondents being promoters, and it notes the NPS was under evaluation for 2024. Related data protection and security commitments that protect end users are described elsewhere in the governance section. The narrative is brief and framed around customer-centricity, satisfaction tracking and strategic engagement rather than a formally codified consumer rights policy.

Under Engaging with customers (page 56, tagged S4-2 and S4-5), Tecnotree describes the processes it uses to engage consumers and end users of its telecom software. Engagement and support run through a 24/7 global technical team that delivers prompt solutions across all time zones to enhance customer satisfaction. The Company monitors service-level agreements, with rigorous SLA monitoring and regular project reviews conducted by the Project Steering Group to ensure compliance and proactive risk management. Delivery issues are managed through weekly delivery dashboard reviews, daily escalation meetings, Project Steering Groups and Change Requests focused on issue resolution and project velocity. Quality Control and System Integration teams carry out comprehensive product and service testing before releases, using defect triage and a shared known defects list to maintain transparency. The Company also notes strategic engagement, with the Strategy Committee joining customer meetings and events. It highlights leveraging AI in the CRM space as an opportunity to improve customer service efficiency, personalization and responsiveness.

Tecnotree describes its approach to addressing customer grievances under the Engaging with customers section (page 56). The Company provides customer support and grievance handling through its 24/7 global technical team, which delivers prompt and efficient solutions across all time zones. It commits to safeguarding customer data with robust security protocols to prevent breaches, and states that in the unlikely event of a data leak it notifies affected customers within 48 hours, swiftly removes the compromised element from the network and keeps relevant stakeholders informed. Grievances tied to delivery and contractual performance are handled through SLA monitoring and regular project reviews by the Project Steering Group. Where issues arise, delivery reviews are initiated and actions are monitored and tracked by the COO's office to ensure timely resolution and maintain customer trust. Delays are managed through weekly delivery dashboard reviews, daily escalation meetings and Project Steering Group reviews. The disclosure focuses on support channels, data breach notification and delivery escalation rather than a dedicated consumer complaints mechanism.

Actions taken on material impacts affecting consumers and end users are set out in the Engaging with customers and Addressing customer grievances content (page 56). Tecnotree identifies risks relating to breaches of contractual or SLA requirements, data privacy breaches, and delivery challenges caused by environmental or political reasons. Current controls include rigorous SLA monitoring and regular project reviews by the Project Steering Group. To mitigate the risk of releasing defective products or services, Quality Control and System Integration teams run comprehensive testing before any release, apply defect triage to prioritize issues, and share a known defects list to manage customer expectations. To manage delivery delays and delays in customer response, the Company conducts weekly delivery dashboard reviews, daily escalation meetings and reviews through Project Steering Groups and Change Requests, with an action plan to hold periodic Project Steering Committee meetings. On data protection, Tecnotree commits to notifying affected customers within 48 hours of a data leak and removing the compromised element. It also frames AI adoption in CRM as an action to improve service efficiency and customer experience.

Targets related to consumers and end users are reported within the Engaging with customers section (page 56, tagged S4-2 and S4-5). Tecnotree does not present a formal set of quantified, time-bound consumer targets. Instead it discloses the outcome metrics it tracks: a customer satisfaction score of 4.08 out of 5 for the year, and a 2023 Net Promoter Score in the medium range of 0 to 30 with 20 percent of respondents being promoters, noting that the NPS was under evaluation for 2024. The Company frames continuous improvement through mechanisms such as SLA monitoring, Project Steering Group reviews, comprehensive product and service testing, and escalation routines aimed at timely delivery and customer trust. It also identifies leveraging AI in the CRM domain as a forward-looking opportunity to bring greater efficiency to customer service, optimize deliveries and improve overall customer experience. As a first-year reporter, the disclosure reflects satisfaction tracking and process improvement rather than measurable numeric targets.

Business conduct policies and corporate culture are described under that heading (pages 58-59, tagged G1-1). Tecnotree states that its comprehensive governance framework encompasses policies guiding its management of material business conduct impacts, risks and opportunities. Policies described include a Business Continuity and Disaster Recovery policy aligned with ISO/IEC 27001 and reviewed annually, an Information Security Policy under an ISMS aligned with ISO/IEC 27001:2013, a Data Loss Prevention Policy, a Data Backup Policy, an IT Policy, and a Privacy Breach Handling Procedure aligned with GDPR. The Company describes GDPR alignment with Articles 33 and 34, notifying the supervisory authority and affected data subjects within 72 hours of a breach where feasible. India's Quality Management System aligns with ISO 9001:2015. On whistleblowing, Tecnotree provides accessible channels to report behaviour contradicting its Code of Conduct, through management, HR or a dedicated email, with a designated team investigating and actions ranging from disciplinary measures to legal action. It prohibits retaliation against whistleblowers and plans to establish a Whistleblower Policy by CY 2026. A Cooperation Committee supports management-personnel collaboration.

Management of relationships with suppliers is disclosed under Doing ethical business with suppliers (pages 59-60, tagged G1-2 and G1-6). Tecnotree states that it prioritizes ethical sourcing, supplier diversity and open communication, ensuring commitment to responsible business practices throughout its supply chain. A Supplier Security Policy sets stringent requirements for all third parties, mandating non-disclosure agreements, security evaluations and risk assessments, and contractual security obligations, including compliance with Tecnotree's security policies and provisions for audits, breach reporting and business continuity. The procurement process is defined by thresholds: purchase orders are not required for purchases under EUR 1,000 annually per vendor, purchases over EUR 1,000 require three quotes, and the Purchase Committee approves purchases over EUR 25,000. Single-source and final price approvals, and all advance payments, require CFO consent. Regional procurement committees include the Controller alongside the HR and Delivery Head in India or the Tech Head in Finland. The disclosure describes structured, tiered procurement controls and supplier security requirements as the basis for managing supplier relationships.

Prevention and detection of corruption and bribery is disclosed under the Anti-bribery and Anti-Corruption Policy (page 52, tagged G1-3 and G1-4) and the Responsible Business Conduct section. Tecnotree's anti-corruption and anti-bribery policy is aligned with the UN Convention against Corruption and prohibits all forms of bribery and corruption. Employees in Finland, India, Dubai and Nigeria receive mandatory training on the policy. Bribery and Corruption is identified as a material topic under Business Ethics and Compliance (page 57). Tecnotree states that it has established a corporate governance structure and undertakes regular risk assessments to identify and mitigate potential ethical and compliance risks. Governance oversight sits with the non-executive Board of Directors, supported by four Board Committees (Audit, Nomination, Remuneration and Strategy) and the Management Board. The disclosure frames prevention through policy, mandatory geographically targeted training, and periodic risk assessment rather than a dedicated separation of duties description.

Incidents of corruption or bribery are reported under the Anti-bribery and Anti-Corruption Policy (page 52, tagged G1-3 and G1-4). Tecnotree states plainly that no incidents of corruption or bribery were detected in 2024. This confirmed nil figure is the substantive quantitative disclosure for G1-4. The Company situates this within its broader anti-corruption framework: a policy aligned with the UN Convention against Corruption that prohibits all forms of bribery and corruption, supported by mandatory training for employees in Finland, India, Dubai and Nigeria. Bribery and Corruption is listed among Tecnotree's material governance topics, and the Company undertakes regular risk assessments to identify and mitigate potential ethical and compliance risks. As a first-year ESRS reporter, the disclosure is brief, reporting zero detected incidents for the year without further breakdown of confirmed cases, fines or sanctions.

Political influence and lobbying activities are addressed under the Board's Commitment to Sustainability section (pages 57-58, tagged with GOV-3, GOV-4, GOV-5 and G1-5). Tecnotree states clearly that the Company does not engage in lobbying activities across its global operations. This is the core G1-5 disclosure. No financial or in-kind political contributions are reported, consistent with the stated absence of lobbying. The surrounding governance narrative describes Tecnotree's commitment to embedding due diligence as a core element of its governance, strategy and business model to align with the Corporate Sustainability Due Diligence Directive, and notes that the Company has proactively initiated the EcoVadis assessment process to provide a framework for evaluating and enhancing its sustainability and CSR efforts, with results to be shared transparently in an upcoming report. The disclosure is concise, resting mainly on the declared absence of any lobbying activity.

Payment practices are disclosed under Doing ethical business with suppliers (page 60, tagged G1-2 and G1-6). Tecnotree states that it pays suppliers upon invoice receipt and measures payment time from the contractual or statutory due date. It reports average supplier invoice payment times by location: 90 days in Dubai, 85 days in Finland, 150 days in India and 30 days in Nigeria. These figures are the substantive quantitative disclosure for G1-6. The payment practices sit within the Company's broader procurement framework, which sets approval thresholds (no purchase order required under EUR 1,000 per vendor annually, three quotes required over EUR 1,000, Purchase Committee approval over EUR 25,000) and requires CFO consent for single-source approvals, final price approvals and all advance payments. Regional procurement committees include the Controller alongside functional heads in India and Finland. The disclosure does not report standard payment terms as a policy figure or the proportion of on-time payments, but it does give location-level average payment times.