TKH

Governance roles

Reference: pages 84-85; composition datapoints incorporated by reference to Members of the Executive Board (page 41), Members of the Supervisory Board (page 42) and Report of the Supervisory Board (page 44).

TKH Group N.V. has a two-tier board: an Executive Board of three members and a Supervisory Board of five non-executive members. A six-member Management Board (three Executive Board members plus Jacqueline Lenterman, Gertjan Sleeking and Derk Postma) sits below it (page 85).

Allocation of responsibility (page 84):

• "The overall ownership of sustainability is with the CEO."
• The Executive Board is responsible for strategic risk management, for identifying IROs through the double materiality analysis, for all assessments of and changes to sustainability aspects in strategy and business model, and for approving targets and sustainability-related policies.
• "The Audit Committee of the Supervisory Board is responsible for overseeing sustainability reporting."
• The Director Sustainability, who reports to the CEO and is a member of the Management Board, sets targets, monitors and reports performance, manages IROs and develops policies (pages 84-85).

Board members "have sufficient/advanced knowledge, skills, and experience in the area of sustainability" and follow internal sustainability training; deep-dive sessions since 2023 have covered the CSRD and the DMA process and outcomes (page 84).

Diversity (page 84): Supervisory Board 2 male / 3 female (60.0% female, target 33.3%); Executive Board 3 male / 0 female (0% female against a 33.3% target); 100% of Supervisory Board members are independent.

Information provided to and matters addressed by the bodies

Reference: pages 84-85.

"The Executive Board is informed about relevant sustainability matters during each Management Board meeting, and quarterly through our internal sustainability reporting. This includes communication regarding our annual reporting, impact, risk, and opportunity (IRO) identification from the double materiality assessment (DMA), reporting requirements based on IROs, and our quarterly sustainability performance" (page 84).

The Executive Board discusses sustainability strategy, policy implementation, KPIs and progress with the operating companies at least once a quarter, based on financial and non-financial reports covering all material sustainability matters. Each month it receives an update from the Director Sustainability and evaluates progress within the sustainability program; each quarter it receives a performance update on sustainability-related KPIs (page 85).

"Sustainability is frequently on the agenda of the Supervisory Board meetings" (page 84). Topics covered in deep-dive sessions include the CSRD, the double materiality assessment process and outcomes including material IROs, other upcoming sustainability laws and regulations, cyber-security, and bribery and corruption. "The outcome of the DMA, including the material sustainability-related IROs, is discussed and approved by the boards. The KPIs connected to the IROs are part of the quarterly sustainability reporting, and are discussed within the Executive and Supervisory Board" (page 84). Cybersecurity is a recurring agenda item in Executive Board and Audit Committee meetings (page 130).

Sustainability-related performance in incentive schemes

Reference: pages 85-86; detail incorporated by reference to the Remuneration report, pages 53-56.

"Members of the Supervisory Board do not receive variable remuneration or incentives based on the financial or sustainability-related performance of TKH" (page 85). Executive Board variable pay has two parts, both carrying sustainability measures:

Short-term incentive (STI), 2025 targets (page 85):

• Employee satisfaction, weight 10% of STI, target 7.8
• LTIFR safety performance, weight 10% of STI, target 0.70

Long-term incentive (LTI), 2025 targets (page 85):

• Diversity, weight 10% of LTI, target 22.2%
• CO2 reduction scope 1 and 2, weight 10% of LTI, target 73.3%

So sustainability measures carry 20% of the STI and 20% of the LTI. The Supervisory Board sets the targets and criteria in advance of the reporting year on the recommendation of the Remuneration Committee, and determines the bonus after year end (page 85). Under the share plan, Executive Board members receive shares only on condition that they personally invest in the same number of shares, "a significant amount of money in a way that prudently manages risk" (page 85). The incorporation-by-reference table (page 83) points to the sustainability performance paragraphs, the STI 2025 table and the performance multiplier on CO2 footprint reduction and diversity in the LTI 2025 table.

Statement on due diligence

Reference: page 86.

TKH gives the ESRS 2 GOV-4 mapping table, cross-referencing each core element of due diligence to the paragraphs of the statement that address it (page 86):

• Embedding due diligence in governance, strategy and business model to: Administrative, management and supervisory bodies; Policies, action plans, metrics and targets; Risk management and internal controls over sustainability reporting; Strategy, business model and value chain; Process to identify, assess and prioritize material IROs; Material impacts, risks and opportunities.
• Engaging with affected stakeholders in all key steps to: Interests and views of stakeholders; Administrative, management and supervisory bodies; the IRO process; Policies, action plans, metrics and targets.
• Identifying and assessing adverse impacts to: the IRO process; Material impacts, risks and opportunities.
• Taking actions to address adverse impacts to the Actions sections of E1, E2, E3, E5, Sustainable innovation, S1 Diversity, S1 Health and safety, S2, S4, G1 and AI and algorithm ethics.
• Tracking effectiveness and communicating to the Environmental, Social and Governance information sections as a whole.

The statement adds that "At least once a year, the Executive Board and the Supervisory Board will be informed by the Director Sustainability about the material IROs, the implementation of due diligence, and the results and effectiveness of policies, action plans, and the adopted targets" (page 86).

Risk management and internal controls over sustainability reporting

Reference: page 87.

"Controls are in place to ensure reliable reporting on sustainability-related metrics." Processes and definitions are formalised in the Sustainability Reporting Manual, which covers collection, consolidation and reporting; data is reviewed by responsible company officers using the financial reporting model and validated by the group sustainability department. "For most of the reported datapoints, differences greater than 10% compared with the previous year have been investigated." Because the reporting scope has broadened since 2024, "we have established a wider range of internal controls, deemed appropriate and adequate, following an ongoing evaluation of the risks related to data accuracy and completeness" (page 87).

Internal Audit performs sustainability audits on processes and data accuracy as a permanent part of its work program; reports go to the Executive Board and material findings to the Audit Committee. In 2025 it reviewed selected non-financial KPIs and operating companies. "No material deficiencies or findings were identified." The 2025 findings covered "completeness of waste reporting and classification of waste treatment, minor reconciliation differences in sustainability reporting, including documentation, and consistency in ways of working regarding sustainability reporting, partly as a result of the decentralized organizational structure." In 2026 TKH will continue to develop review activities "with the ambition of including all CSRD-related quantitative datapoints in the scope of internal audit over time" (page 87).

Strategy, business model and value chain

Reference: pages 88-91; background incorporated by reference to Long-term value creation, pages 28-29.

TKH "has offices and production sites in 34 countries and serves customers in over 90 countries". Until 2025 operations were grouped into three segments; from 2026 TKH moves to Automation and Electrification following the Capitalize & Execute 2028 strategy announced at the Capital Markets Day of September 2025, with a planned separation of Electrification (pages 81, 88).

2025 turnover €1,761.2 million (2024: €1,712.7 million) and 6,538 employees (2024: 6,665), split as (page 88):

• Smart Vision systems (NACE C26): €522.6m, 2,219 employees
• Smart Manufacturing systems (NACE C28): €522.6m, 1,713 employees
• Smart Connectivity systems (NACE C27): €728.8m, 2,436 employees

TKH states its NACE codes C26, C27 and C28 are "activities in high climate impact sectors" under Annex I to Regulation (EC) No 1893/2006 (page 88).

Three value chain maps are given: Vision Technologies (page 89), Tire Building (page 90) and Electrification and Digitalization (page 91). Dependencies are disclosed: no significant key-supplier or customer dependency in Smart Vision; in Smart Manufacturing "There is a dependency on one particular supplier, because customers prescribe this supplier as their factory automation system"; in Smart Connectivity "There is a dependency on suppliers of raw materials (copper and aluminum), due to the limited numbers of global suppliers" (pages 89-91).

Interests and views of stakeholders

Reference: pages 92-93.

"TKH's Stakeholder Engagement Policy, published on our website, outlines how we include the interests of relevant stakeholders in the definition and further development of the sustainability strategy." The CEO is responsible for implementation. Key stakeholders are defined as employees, shareholders, customers, suppliers, analysts, banks, public bodies, education and knowledge institutions, and community and sectoral organisations including NGOs (page 92).

If the works council is a participant in a stakeholder dialogue, "the chair of the works council will be invited to participate". The Executive Board decides whether a dialogue is collective or bilateral, and "The main outcomes of the stakeholder dialogues are discussed with the Executive and Supervisory Board" (page 92).

"Representatives from these key stakeholder groups have been consulted on sustainability-related impacts, risks, and opportunities. We prioritize the input from stakeholders based on frequency..., severity... and alignment..." (page 92). A full table on page 93 sets out, per stakeholder group, the relevance and purpose, engagement channels (including a "Survey on material IROs" for most groups), key engagement topics and the relevant strategy elements.

Limits are disclosed elsewhere: stakeholders "are not directly involved in policy and target setting" for pollution (page 104), key stakeholder interests are not specifically considered when setting the water policy (page 106), and consumers and end-users "are not directly involved in target setting" (page 128).

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

Reference: page 94; per-topic IRO boxes on pages 98, 104, 106, 108, 111, 119, 122, 124, 128, 133, 136, 138 and 140.

The overview table on page 94 lists 13 material topic rows, each tagged with its IRO type (positive impact, negative impact, risk, opportunity), value chain position (own operations, upstream, downstream), time horizon and page:

• E1 Climate change - GHG emissions, energy efficiency and consumption (S M L, page 98)
• E2 Pollution - Pollution of air, soil and water (S M L, page 104)
• E3 Water and marine resources - Water consumption (S M L, page 106)
• E5 Resource use and circular economy - Resource inflows, waste and waste recycling (S M L, page 108)
• Entity-specific - Sustainable innovation, the only positive impact and the only opportunity (S M L, page 111)
• S1 Own workforce - Diversity (page 119) and Health and safety (page 122)
• S2 Workers in the value chain - Child / forced labor, and health and safety, upstream only (M L, page 124)
• S4 Consumers and/or end-users - Privacy (cybersecurity) (S M, page 128)
• G1 Business conduct - Corporate culture (page 133), Management of relationships with suppliers (page 136), Corruption and bribery (page 138)
• Entity-specific - AI and algorithm ethics (page 140)

Every topic row carries a risk marker as well as an impact marker. E4 Biodiversity and S3 Affected communities do not appear. Climate-specific risk identification is also presented under E1-2 (2025 ESRS numbering).

Processes to identify and assess material impacts, risks and opportunities

Reference: page 95; climate-specific process on pages 96-97.

"In 2024, TKH identified material sustainability topics by following the double materiality assessment (DMA) approach", using the sustainability matters in ESRS 1 application requirement 16 including biodiversity and ecosystem matters. From those, "we defined a comprehensive longlist of 131 potentially relevant sustainability topics. This longlist was narrowed down to a shortlist of 67 sustainability topics by scoping out sustainability topics that are not relevant due to the nature of our business and value chain." Each of the 67 was assessed for IROs over short (<1 year), medium (1-5 years) and long (>5 years) horizons (page 95).

Thresholds are quantified (page 95). Financial size runs on a five-point scale expressed as a percentage of EBITA: very low <5%, low 5-10%, medium 10-20%, high 20-40%, critical >40%. Likelihood: rare <20%, unlikely 20-40%, possible 40-60%, likely 60-80%, almost certain >80%. Scale, scope and irremediable character each use a five-point scale, scope running operating company / local / country / regional / global and irremediable character immediate / 0-1 year / 1-5 years / 5-20 years / >20 years.

For 2025 the DMA was not rerun. "For 2025, we did not identify changed material facts and circumstances (i.e., triggers)... we concluded that the outcome of the prior reporting period's materiality assessment is still relevant at the reporting date. We performed a validation assessment on the existing identified IROs, including benchmark analysis." TKH will update the DMA in 2026, "especially in view of the intended separation of our Electrification segment", and "will also assess how we can improve the DMA process further to mitigate the risk that certain sustainability topics are wrongly classified as non-material" (page 95).

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

Reference: page 79 ("Disclosure Requirements covered by the sustainability statements"); pages 150-154 (Datapoints derived from other EU regulation); page 145 (Other sustainability-related topics, not material).

TKH prints a full ESRS content index on page 79, listing each covered disclosure requirement with page references. Covered: ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2, MDR); E1 (E1-GOV-3, E1-SBM-3, E1-IRO-1, E1-1 to E1-6); E2 (E2-IRO-1, E2-1 to E2-4); E3 (E3-IRO-1, E3-1 to E3-4); E5 (E5-IRO-1, E5-1 to E5-4); S1 (S1-SBM-2, S1-SBM-3, S1-1 to S1-6, S1-9, S1-14); S2 (S2-SBM-2, S2-SBM-3, S2-1 to S2-5); S4 (S4-SBM-2, S4-SBM-3, S4-1 to S4-5); G1 (G1-GOV-1, G1-IRO-1, G1-1 to G1-4). ESRS E4 appears nowhere in the index.

Basis of preparation: "Although there is not yet a formal statutory requirement to report in accordance with the CSRD, due to the delayed implementation, TKH prepared its 2025 sustainability statements based on the CSRD on a voluntary basis, as we did for 2024. In addition, we obtained a voluntary assurance on the sustainability statements" (page 82).

Phase-in and omissions: "All material datapoints are reported on, other than those that are voluntary or subject to phase-in" (page 82). "No relevant pieces of information were omitted for reasons related to classified and sensitive information and information on intellectual property. TKH did not use any exemptions provided under Article 19a and 29a of Directive 2013/34" (page 82). The Appendix B table (pages 150-154) marks E1-7, all E1-9 datapoints, E4 datapoints and E3-1 sustainable oceans as "not-relevant"; S1-16, S1-17, S3-1 and S3-4 datapoints as "not-material"; and S1-14 days lost as "phased-in".

Transition plan for climate change mitigation

Reference: page 98 (transition plan and targets), pages 99-100 (levers), page 101 (investments).

"Since 2024, we further developed our existing transition plan, including by further developing the scope 3 GHG emissions inventory and targets." TKH provided a framework for all companies to calculate scope 1, 2 and 3 emissions under the GHG Protocol and identified emissions hotspots, "which highlighted the operating companies and business segments with the highest emissions. Due to their size and global footprint, these are Smart Manufacturing systems (VMI - tire building machines) and Smart Connectivity systems (TKF - cable production company)." Mitigation levers were then identified through portfolio-shift assessment, technological options and peer benchmarking, business cases were developed for prioritised initiatives, and scope 1 and 2 targets were set in alignment with the SBTi. Enabling mechanisms "include awareness campaigns and the integration of sustainability into our annual strategic plan and budget process" (page 98).

Approval and ownership: "The transition plan has been approved by the Executive and Supervisory Board, and the CEO is responsible for its implementation, with support from the Director of Sustainability" (page 98).

Targets: SBTi-aligned scope 1 and 2 reduction of 42.0% by 2030 from a 2023 base year, and the Capital Markets Day carbon-neutral market-based target of 100% by 2030 from a 2019 base year, reconfirmed at the CMD of 25 September 2025; net-zero carbon by 2050 (pages 81, 98).

Investments: "No capital expenditures (capex) have been made related to coal-, oil-, or gas-related economic activities." Identified environmental capex is €7.8 million over the coming five years, mainly gas-to-heat-pump replacement, solar and PV panels and energy reduction, plus €8.3 million of opex for ESG programs, both based on operating company plans for 2026-2030 and to be re-examined in 2026. "These investments are not planned to align our economic activities... with the criteria established in Commission Delegated Regulation" (page 101).

TKH "is not excluded from any EU Paris-aligned benchmarks because we do not meet any of the exclusion criteria stated in Articles 12.1 (d) through (g) of Commission Delegated Regulation (EU) 2020/1818" (page 98).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1-SBM-3 / E1-IRO-1 climate sections, where this content is disclosed in the FY2025 report (pages 96-98). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

No scenario analysis was performed. "Our climate risk and opportunity assessment follows the TCFD framework, integrating key risk categories into our sustainability strategy. This high-level assessment primarily focuses on physical (acute) risks and transition risks. The assessment performed is based on TKH's current situation, and does not yet include a climate scenario analysis. In the coming years, we will formally identify and assess transition risks as part of an expanded scenario analysis" (page 96). Because no scenario analysis was used, ESRS E1 paragraph 17 does not apply and its absence is not a gap.

Classification of risks (¶15). Risks are split into physical and transition. "Due to the locations of our production facilities, the physical (acute) risk is considered to be low. However, we consider physical (acute) climate change risks when making business decisions, for example when changing locations, expanding our facilities, or increasing activities" (page 96). Four transition risk areas are named (page 97): regulatory (future CO2 taxation or pricing raising operational and compliance costs), technology (high investment costs to meet demand for reduced-emission products), market demand and market change (failure to meet stakeholder expectations on climate reporting), and resource scarcity (volatility in the price and availability of raw materials). Four opportunity areas are also listed: efficient production, renewable energy use, R&D and innovation, and renewable energy programs in the value chain.

Methodology and scope (¶16). Coverage extends upstream: "We have also assessed the exposure of our strategic suppliers (suppliers with an annual purchase volume above €1 million) to any material first- and second-order physical climate change impacts. This assessment includes impacts indirectly caused by the physical effects of climate change, such as significant economic crises resulting from physical damage to businesses or human migration due to flooding" (page 97).

Gap the company states itself: "we have not yet explicitly defined these time horizons for specific climate-related risks and opportunities" (page 96).

Resilience in relation to climate change

Back-filled from the E1 climate-related risks and opportunities section, where this content is disclosed in the FY2025 report (pages 96-97). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

TKH states plainly that it has not performed a resilience analysis as the ESRS define it. "We are planning to conduct a comprehensive resilience analysis in accordance with the full requirements of the CSRD. These include defining time horizons for climate-related risks and opportunities, evaluating exposure of assets and business activities to transition risks (likelihood, magnitude, and duration), and integrating scenario analysis" (page 96). And again on page 97: "While we have not yet conducted a full resilience analysis, we are actively implementing mitigation strategies such as electrification, energy efficiency improvements, and supplier engagement. Future scenario analyses will help refine our adaptation strategies to ensure resilience against climate risks."

What is disclosed instead (¶19(a)(iii)). "Our strategy already integrates climate-related considerations through our transition plan, decarbonization roadmap, and sustainability-linked incentive schemes for executives" (page 97). The 100% carbon-neutral 2030 target and the SBTi-aligned 42% target were reconfirmed at the Capital Markets Day in September 2025 (pages 81, 98).

Uncertainty (¶19(b)). "The realization of the target is partly dependent on available and affordable low-carbon technologies and green certificates until 2030. This may pose a challenge for some of the countries in which we operate. Replacing gas-based systems with electric heat pumps in older buildings is challenging, and may lead to locked-in emissions if replacements cannot be made" (page 100).

Timing. "A European integrated framework for climate resilience is expected by the end of 2026" (pages 81, 96), which TKH gives as the reason for waiting. Under AR 9 a resilience analysis need not be annual, but here none has yet been performed at all.

Policies related to climate change mitigation and adaptation

Reference: page 98 ("Our approach and policies").

TKH discloses a decentralised policy structure and an explicit gap at group level: "We have integrated environmental policies per operating company as part of the health, safety, and environmental (HSE) policy..., focusing on various environmental-related topics such as climate and energy, waste, transportation, and supply chain. These policies also address our local compliance with environmental laws and continuous improvement of our practices."

"We do not currently have a group-level environmental policy. However, we are considering an environmental policy that would involve the whole group" (page 98).

The HSE policy is summarised in the standard policy table used throughout the statement (pages 106, 110, 122): it describes how each operating company deals with environmental, health and safety issues including instructions and procedures; it is applicable to all production sites and, where relevant, other locations; the managing director of the operating company is responsible for implementation; it is based on the ISO 14001 standard (ISO 14001/45001 in the health and safety version); and it is published on operating company intranets and forms part of local procedures and handbooks.

Supporting certification: "Our operating production companies have implemented internationally recognized ISO standards that support our sustainability goals, including the ISO 14001 environmental management system and the EN-16247 energy audit system, the latter of which is related to the European Energy Efficiency Directive" (page 96).

Paris alignment is stated in the same section: TKH "is not excluded from any EU Paris-aligned benchmarks" under Articles 12.1(d) to (g) of Delegated Regulation (EU) 2020/1818 (page 98).

Actions and resources in relation to climate change policies

Reference: pages 99-100 (levers and key actions), page 101 (resources).

Scope 1 and 2 levers, quantified as shares of the planned reduction (page 99):

• Electrification, 16.5% of the overall reduction. "we aim to replace 100% our fleet with electric cars by 2030. In the coming years, we have also scheduled the replacement of several gas-powered heating systems with electric heat pumps."
• Energy efficiency, 8.9% of the overall reduction.
• Renewable energy, 34.1% of the overall reduction, through solar panels on buildings and parking areas, purchased renewable energy and green certificates.

"We expect the planned actions to further reduce our scope 1 and 2 emissions by 59.6% between 2026 and 2030. Compared to the 2023 base year, we expect to decarbonize our scope 1 and 2 emissions by 80.7%", against the 100% carbon-neutral target, leaving "The remaining expected reduction of 19.3%" to be investigated (pages 99-100).

Ten levers with key actions are tabulated on page 100, adding to the three above: business model innovation (new and extended service programs); product and service design (EcoDesign principles, product use-phase energy efficiency, recyclability of materials in sold products); supply chain and circularity (increase recycled content in purchased copper, carbon reduction criteria in procurement, joint emission reduction targets with strategic suppliers, supplier training and programs); customer engagement (recycling incentives, training on reducing carbon footprints); waste management; transportation ("Reduce/eliminate use of air freight", green transport procurement); and travel (online meetings, public transport, bicycle plans in the employee benefit budget).

Resources (page 101): €7.8 million capex and €8.3 million opex identified for 2026-2030, the capex "mainly related to replacements of gas systems with electric heat pumps, installation of solar and photovoltaic panels, and other investments to reduce energy consumption". For scope 3, "In 2025, we started to work on the implementation of our scope 3 decarbonization strategy... by developing detailed plans for each decarbonization lever" (page 102).

Targets related to climate change mitigation and adaptation

Reference: pages 98-99; group target table page 81; progress chart page 103.

Two scope 1 and 2 targets are disclosed side by side (page 98):

"The reduction target values are in absolute terms as % of the base year." The 2019 base year "represents TKH's activities prior to the COVID-19 pandemic". "As these CMD targets are more ambitious than the SBTI-aligned targets, they are also aligned with the Paris Agreement and the 1.5˚C scenario. At our CMD at September 25, 2025 we reconfirmed this 2030 target." The SBTi-aligned target is "based on net-zero science-based targets, meaning they exclude carbon credits and include neutralization", calculated using "the SBTi's cross-sector absolute contraction methodology, using 2023 as a base year", and includes "a forward-looking ambition (FLA) adjustment" (pages 98-99). TKH also "committed ourselves to be net-zero carbon by 2050" (page 81).

No scope 3 target exists. "In 2025, we started to work on the implementation of our scope 3 decarbonization strategy... Our aim is to set a target for the reduction of scope 3 emissions by 2026" (page 102), and the 2026 outlook names "a target setting on scope 3 emissions and related SBTi-alignment" as an important focus area (page 81). Scope 3 was 2,928,029 tCO2e in 2025, so the targeted perimeter covers under 1% of the total footprint.

Progress: 76.3% reduction in scope 1 and 2 market-based emissions against the 2019 base year (2024: 70.3%; 2023: 64.3%; 2022: 42.7%) against the 100% by 2030 objective (pages 81, 103).

Energy consumption and mix

Reference: page 103.

Full ESRS energy table, in MWh (2025 against 2024):

• Fuel from crude oil and petroleum products 7,894 (9,799), down 19.4%
• Fuel from natural gas 16,629 (16,710), down 0.5%
• Purchased electricity, heat, steam and cooling from fossil sources 7,650 (15,837), down 51.7%
• Total fossil energy consumption 32,173 (42,346), down 24.0%; share of total 34.0% (2024: 43.1%)
• Consumption from nuclear sources 340 (336); share 0.4% (0.3%)
• Purchased renewable electricity, heat, steam and cooling 60,169 (53,852), up 11.7%
• Self-generated non-fuel renewable energy 2,016 (1,658), up 21.6%
• Total renewable energy consumption 62,185 (55,510), up 12.0%; share of total 65.7% (2024: 56.5%)
• Total energy consumption 94,698 (98,192), down 3.6%
• Energy intensity rate for high climate impact sectors 53.8 MWh per €m turnover (2024: 57.3), down 6.2%

A footnote records that "The 2024 crude oil and petroleum products consumption has been adjusted by including fleet consumption" (page 103).

TKH is a high climate impact sector reporter on its own analysis (NACE C26, C27, C28, page 88), which is why the intensity rate is given. The turnover used as the denominator "is reconciled with the total turnover included in note 22 of the consolidated financial statements" and is IFRS 15 based. "We have not used contractual instruments for the sale and purchase of energy bundled with attributes about the energy generation. Approximately 71% of the electricity consumption is covered by green certificates (unbundled energy attribute claim)" (page 101).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 101-103; methodology pages 142-144.

Scope 1 and 2, tCO2e (page 101):

• Gross scope 1 4,943 (2024: 5,049; 2023 base: 6,285), down 2.1%
• Gross scope 2 location-based 30,302 (31,009; 55,677), down 2.3%
• Gross scope 2 market-based 4,869 (7,245; 8,496), down 32.8%
• Total scope 1 and 2 location-based 35,245 (36,058; 61,962)
• Total scope 1 and 2 market-based 9,812 (12,294; 14,781), down 20.2%
• 2030 target values are printed alongside: 3,645 scope 1, 4,928 scope 2, 8,573 total, each at 42.0% of the 2023 base

Scope 3, tCO2e (page 102), total 2,928,029 (2024: 3,175,447), down 7.8%. Category 1 purchased goods and services 462,276 (15.8% of scope 3, up 10.0%); category 11 use of sold products 2,330,240 (79.6%, down 11.1%); category 12 end-of-life 74,436 (2.6%); category 7 employee commuting 12,223; category 4 upstream transport 10,199 (up 112.3%); category 3 fuel- and energy-related 8,485; category 6 business travel 5,719; category 5 waste 5,247; category 9 downstream transport 3,360; category 2 capital goods 15,464. Categories 8, 10, 13, 14 and 15 are declared not applicable with a reason for each (page 102).

Totals (page 102): total GHG location-based 2,963,274 (down 7.7%); total market-based 2,937,841 (down 7.8%); intensity 1,683 location-based and 1,668 market-based tCO2e per €m turnover, both down about 10%.

Boundaries follow the GHG Protocol; consolidation matches the financial statements and minority holdings are excluded for lack of operational control. "The percentage of scope 1 GHG emissions from regulated emission trading schemes is zero" (page 101). Scope 3 covers "approximately 97% of turnover" (page 142). In 2025 scope 2 was recalculated on Ecoinvent 3.11 with country-specific factors; 2024 location-based figures were restated but "2024 scope 1 and scope 2 market-based emissions remain unadjusted, as the methodological differences make recalculation impracticable" (pages 83, 99).

Policies related to pollution

Reference: pages 104-105.

"We manage our impact on pollution using our Health, Safety & Environment (HSE) policy. All operating companies to whom the HSE policy is relevant have established and implemented it, incorporating a clear commitment to preventing pollution and minimizing health risks. Stakeholders are not directly involved in policy and target setting" (page 104).

The HSE policy table on page 105 records: it describes how the operating company deals with health and safety issues including safety instructions and procedures; applicable for all production sites and, if relevant, other locations; the managing director of the operating company is responsible for implementation; based on the ISO 14001 standard; published on operating company intranets and part of local procedures and handbooks.

A group-level policy was considered and rejected with a reason: "In 2025, we reviewed whether it is necessary to develop a group-wide pollution policy to ensure a consistent approach across all operations. We concluded that this topic is sufficiently incorporated into the existing Health, safety and environmental (HSE) policy (at the operating company level)" (page 105).

Implementation is described in detail: "we conduct structured screenings of our site locations and business activities. These assessments evaluate both actual and potential pollution-related impacts within our operations. The methodologies, assumptions, and tools used in this process include ISO 14001-certified environmental management systems at all production locations. Each relevant cable production company has established internal awareness programs and procedural safeguards designed to minimize pellet loss and prevent contamination", including "filtering dust from the factories' chimneys and purifying the chimney gases" (page 104).

Actions and resources related to pollution

Reference: page 105.

"We record all environmental incidents, breaches, and fines, with voluntary targets of zero environmental breaches and fines related to our own operations. The target is based on compliance with regulatory requirements. An environmental incident is an incident that has an environmental impact. An environmental breach occurs when there is a failure to comply with an environmental legislative obligation" (page 105).

2025 events are disclosed rather than summarised away. "In 2025, one environmental breach was reported (no fines). The reported breach is the result of several findings notified during an onsite environmental audit at one of our cable production sites by the local regional environmental agency. The audit resulted in six observations, which we will follow up in 2026. Also, ten environmental incidents were reported, compared with five in 2024." Each incident is assessed for whether additional controls are needed, an external researcher may be appointed to ensure independence, and "The reported 2025 environmental incidents are related to minor incidents, for example small oil leakages from machines or during transportation. Therefore, we concluded that no further action was deemed necessary, as all remediation actions were addressed directly upon detection" (page 105).

Planned actions: "In 2026, we plan to complete the inventory of relevant emissions at our cable production sites, supported by (laboratory) measurement reports where relevant... Also, we will follow up on the environmental breach reported at the end of 2025" (page 105).

Resources: "Due to the nature of the actions, the resources needed for these actions are opex-related and do not require any significant capex. The opex-related resources are also not additional, since these initiatives are embedded into ongoing environmental management efforts" (page 105).

Targets related to pollution

Reference: page 105.

TKH discloses two pollution targets, both compliance-anchored and both voluntary:

1. Zero environmental breaches and zero fines in its own operations. "We record all environmental incidents, breaches, and fines, with voluntary targets of zero environmental breaches and fines related to our own operations. The target is based on compliance with regulatory requirements" (page 105).
2. No exceedance of E-PRTR threshold values. "Our target is that the listed thresholds for the relevant pollutants should not be exceeded" (page 105), referring to the pollutants and threshold values in Annex II of Regulation (EC) No 166/2006.

Performance against them, from the Environmental compliance table (page 105):

Both the breach target and the incident target were missed in 2025, and the report says so rather than presenting the year as a success. Stakeholders "are not directly involved in policy and target setting" for this topic (page 104). No quantified reduction target is set for any individual pollutant.

Pollution of air, water and soil

Reference: page 105; estimation uncertainty also page 83.

"The inventory of pollution to air, soil, and water is based on the list of pollutants and related threshold values specified in Annex II of Regulation (EC) No 166/2006" (the E-PRTR Regulation), the datapoint the Appendix B table maps to pages 104-105 (page 152).

The disclosure is a threshold statement rather than a table of tonnages. "In 2025, we further expanded the number of measurements of pollutants. For most of the pollutants, we have determined, on the basis of (laboratory) measurement reports and reports from external sources, that the listed threshold values were not exceeded in 2025. For the pollutants that are not measured through (laboratory) measurements, we used estimates based on reports provided by external parties. These estimates are calculated by internal technical engineers and the health, safety, and environmental department" (page 105).

Uncertainty is disclosed and quantified in nature if not in amount. "Due to the use of estimates and own calculations, there is a degree of uncertainty in the outcome of the assessment. We will further optimize the process in 2026, including by having more measurements carried out by external experts for the remaining relevant pollutants. This will further substantiate the assertion that the listed thresholds for the relevant pollutants have not been exceeded" (page 105). The basis of preparation section flags the same point: "Part of the inventory of pollution to air, soil, and water... is based on estimates and own calculations, resulting in uncertainty about the outcome" (page 83).

Monitoring is aimed at cable production, "particularly for cable degassing, isolation, and printing operations", where NOx and SOx emissions arise (pages 104-105). The auditor's emphasis of matter on measurement uncertainty covers metrics of this kind (page 218).

Policies related to water and marine resources

Reference: pages 106-107; Appendix B maps ESRS E3-1 paragraph 9 to pages 106-107 and paragraph 13 (dedicated policy) to page 106 (page 152).

TKH has a group-level Water policy, one of the few group policies it holds. "At TKH, our water policy focuses on reducing our operational impact on water consumption and quality. The interests of key stakeholders are not specifically considered when we set our policy. Our primary focus is on operational water efficiency, compliance with environmental standards, and responsible water management within our production facilities" (page 106).

The policy table (page 106) records: it describes how TKH strives to reduce its water impact, "defining goals, implementing actions, and monitoring results"; applicable for all operating companies; "Not based on a specific framework or set of guidelines"; the managing director of the operating company is responsible for implementation; provided to managing directors and available to all functions with access to the Cognos reporting system.

Commitments in the policy text: "In line with global reporting standards, including CDP Water and ISO 14001 Environmental Management, we commit to transparently disclosing relevant water management indicators. We measure and monitor water-related risks and stress, using internationally accepted methodologies, and we mitigate risks through efficient water management, conservation, and protection." TKH also states it ensures "that all our workplaces globally have adequate water, sanitation, and hygiene facilities", reduces consumption "by using efficient equipment or technology", minimises it "by reusing water", promotes "industrial closed-loop water processes" and concentrates effort "at our sites in water-scarce areas" (pages 106-107).

Appendix B marks the E3-1 sustainable oceans and seas datapoint (paragraph 14) as "not-relevant" (page 152).

Actions and resources related to water and marine resources

Reference: page 107.

Site-level risk screening and response. "Among our production sites, one location has been identified as being exposed to substantive financial and strategic risks related to water. This site is situated in China, in an area with extremely high water stress. In response, we assessed and defined our risk exposure, anticipated potential losses, and implemented proactive measures to mitigate business interruption. Important production sites are flexible, allowing us to shift production capacity from areas with high water stress to other locations. Additionally, we have offices in areas with high water stress. We assessed these locations and concluded that the anticipated potential losses and business interruption are limited" (page 107).

Closed-loop reuse in cable production, quantified. "In our cable production activities, water is reused in a closed system for the cooling of our extrusion lines. At our largest cable production company, water circulates around 154 times before it completely evaporates. In 2025, 14,438 m3 of water was recycled and reused in this way" (page 107).

Screening tools. TKH performs "an annual assessment of our operational sites to address potential water-related risks", using "publicly accessible tools, such as the Aqueduct Water Risk Atlas by WRI and WWF Water Risk Filter" (page 106).

Planned actions and resources. "In 2026, we will investigate whether diversified water sourcing could be a solution to further reduce our water risk. In addition, we will continue to reassess our operational resilience on a yearly basis by analyzing potential scenarios for adjusting production planning, including shifting production to other sites in the event of severe water scarcity. The implementation of defined actions may result in limited investments in research and technical assessments, such as collaboration with environmental experts or water resource specialists" (page 107).

Targets related to water and marine resources

Reference: page 107; the target is also flagged as new for the year on pages 6, 8 and 80.

TKH set its first water target in 2025: "We have the ambition to reduce our water intensity ratio by 5% annually, on average over the 5-years period 2026-2030" (page 80). The Water metrics table on page 107 states it as "Water intensity ratio average yearly reduction target (2026-2030): 5.0%".

Baseline and current performance: "The 2025 water intensity ratio was 64.9 (m3/€m turnover). This figure is 4.9% lower than the previous year and close to the average yearly reduction target of 5.0% (2026-2030), which we defined in 2025" (page 107). The 2024 ratio was 68.2.

Basis: "The water intensity ratio is calculated by dividing total water consumption (in m3) by the total turnover, with the total turnover included in note 22 of the consolidated financial statements" (page 107).

Two features are worth noting for a reader. First, the target is expressed as an intensity target, not an absolute reduction, so it can be met through turnover growth. Second, the target period begins in 2026, so 2025 is a baseline year rather than a performance year against it. No separate target is set for water withdrawal, for water discharge or for the site in an area of extremely high water stress identified on page 107; the water reduction ambition applies group-wide. Stakeholder interests "are not specifically considered when we set our policy" and, by extension, the targets derived from it (page 106).

Water consumption

Reference: page 107; Appendix B maps E3-4 paragraph 28(c) and paragraph 29 to page 107 (page 152).

Water metrics table (page 107), 2025 against 2024:

"The total water consumption in 2025 is 114,242 m3, a 2.2% decrease compared to 2024. This decrease is a combination of relocating production activities to other locations, divestment, and less water consumption at some locations" (page 107). Water consumption in areas of high water stress fell 20.0%, and recycled and reused water rose 33.2%.

Measurement basis: "Reported water consumption is based on measurements taken directly from water meters and water invoices, both of which are stored locally at the operating companies" (page 107). This puts water among the better-evidenced metrics in the statement, in contrast to the pollution inventory and scope 3 emissions, which rely on estimates (pages 83, 105).

Context for the numbers: water at TKH "is essential for cooling and is also used for drinking and sanitary purposes at our factories and offices" (page 106), and the reuse figure comes from the closed cooling system on the extrusion lines at the largest cable production company (page 107).

Policies related to resource use and circular economy

Reference: pages 108-109.

"Sustainable business practices include the sustainable management of resources. Through our operational excellence program, we focus on production efficiency while maintaining close attention to key issues, such as reducing our energy consumption and the use of raw materials. From the design stage onward, we aim to select raw materials and other input materials that have a minimal environmental impact. We do this at all our manufacturing sites" (page 108).

Two stated approaches (page 108):

• "Reducing waste at source: We aim to use raw materials as efficiently as possible and therefore increase material efficiency. Our operational excellence programs focus on right-first-time production to minimize waste in our own operations."
• "Minimizing the impact of waste: We aim to maximize the use of recycled materials and optimize waste treatment through greater cooperation across the value chain."

The governing policy is again the operating-company HSE policy based on ISO 14001, tabulated on page 109. "ISO 14001 certification: All TKH production sites comply with ISO 14001 environmental standards, ensuring responsible disposal and recycling of electronic waste" (page 108). TKH and parts of certain operating companies also participate in third-party assessments by EcoVadis, CDP and Sustainalytics (page 108).

Stakeholder involvement is stronger here than for pollution or water. "We actively incorporate stakeholder perspectives into the development of policies related to resource use and the circular economy", through regular sustainability meetings, supplier dialogue, ESG reporting and industry working groups; policies are communicated through the intranet and handbooks, through supplier contracts, procurement guidelines and the Code of Supply, publicly through the report and website, and are "subject to internal audits, external assessments, and compliance reviews" (page 109).

A gap is disclosed: "In 2026, we will continue to assess the need for a group-wide procurement policy, aimed at reducing the use of virgin material, increasing recycled content, and promoting sustainable sourcing" (page 110).

Actions and resources related to resource use and circular economy

Reference: page 110.

Environmental product declarations at scale. "In 2025, TKF made more than 200 self-declared environmental product declarations (SD-EPDs) available to customers. An EPD is a transparent, standardized profile of a product's environmental impact throughout its entire life cycle: from raw material sourcing and production to transportation, use, and end-of-life disposal. The results are based on a life cycle assessment (LCA). TKF's LCA and EPD tool, ALCAS, was critically examined and successfully verified by independent third parties. This ensures that customers receive consistent, verifiable data for specifications, tenders, procurement, and project documentation, including a strong substantiation of sustainable material choices" (page 110).

Recycling routes for the main production materials. "Our copper suppliers re-process pure copper waste into fully usable copper. This means that our copper waste is 100% recycled. This also applies to aluminum and steel. Plastics that become unusable during the cable production process but are suitable for recycling are offered to waste processing companies to be converted into new raw materials." TKH is also "exploring the possibility of completely recycling" odd-length cables, and "considering the same approach for plastics used in insulation and sheathing material" (page 110).

Planned action. "In 2026, we will continue to assess the need for a group-wide procurement policy, aimed at reducing the use of virgin material, increasing recycled content, and promoting sustainable sourcing" (page 110).

Resources. "We revisit actions related to the circular economy every year and these actions are integrated into activities at the operating company level. Due to the nature of these actions, the required resources are primarily operating expenditure (opex)-related and do not require any significant capital expenditure (capex). The opex costs are also not additional, since these initiatives are an integral part of our day-to-day expenses and procurement activities" (page 110). Circularity also appears as decarbonisation lever 6 in the climate chapter, with actions to increase recycled copper content and set joint reduction targets with suppliers (page 100).

Targets related to resource use and circular economy

Reference: pages 88, 109-110.

Two group targets are stated for the main production raw materials, copper, aluminium and plastics used in cable production:

• Maximum 5% waste of total relevant material volume consumed. TKH's business model section states the goal as "limiting waste of key production raw materials such as copper, aluminum and plastics to no more than 5%" (page 88).
• At least 80% recycling of the most relevant production raw material waste (page 88).

Both were missed in 2025, and the report says so with the reason. "Total waste from the most relevant raw materials used in cable production, compared to total relevant material consumption, was 12.2% of total material volume consumed in the year under review. This is higher compared with the previous year - which was 5.4% - and also higher than our target for a maximum of 5% waste. The increase is mainly the result of our start-up activities, in particular related to our new subsea cable production facility in Eemshaven and our new fibre optic cable production facility in Poland. Establishing new activities and production sites results in more waste, for example, from testing and commissioning machines and cable type approvals" (page 109).

"Although the waste percentage is relatively high, the recycling percentage in 2025 was 75% (recycling of copper, aluminum, and plastics related to our cable production activities), with copper being fully recycled" (page 110), against the 80% ambition.

The Eemshaven ramp-up is also flagged in the year in review: "The start-up and ramp-up of the production facility resulted in additional usage of materials and related waste... This resulted in relatively more material usage and waste in 2025" (page 80). No target is set for resource inflows or for recycled content in purchased materials.

Resource inflows

Reference: page 109; listed in the ESRS content index as "E5-4 Resource use and circular economy metrics" (page 79).

Resource inflows table (page 109), in tonnes:

The recycled share fell year on year, from 4.2% to 3.3%, and the report does not present it otherwise.

Named materials. "At TKH, the primary raw materials we use are copper, aluminum, and plastics, which are essential parts of our Smart Connectivity systems supply chain. Within Smart Manufacturing and Smart Vision systems, the primary raw materials we use are steel, aluminum, and electronic components. Other materials mainly used are packaging materials, such as wood, paper, board, and plastic foils" (page 108).

Recycled copper. "approximately 21% of the copper we purchase comes from secondary reused or recycled sources, meaning that 21% of the copper we purchase contains recycled content. This percentage is calculated based on information provided to us by our suppliers as well as publicly available information on recycled content" (page 109).

Method. "We calculate our resource inflow based on recorded purchases during the reporting year. We determine the weight of our materials using the weights recorded on purchase orders, purchase invoices, or transportation documents. If weight data cannot be obtained, the weight is estimated based on the estimated proportion of the material in the total product weight. To avoid double counting, we exclude intercompany shipments, ensuring only external material purchases are accounted for" (page 109).

Waste

Reference: pages 109-110. The ESRS content index on page 79 folds this into "E5-4 Resource use and circular economy metrics", but the Appendix B table of datapoints derived from other EU legislation names the requirement directly, mapping "ESRS E5-5 Non-recycled waste paragraph 37 (d)" and "ESRS E5-5 Hazardous waste and radioactive waste paragraph 39" to page 110 (page 152).

Waste from own operations, tonnes (page 110):

Treatment (page 110). Hazardous waste 166 t: incineration 160 (96.5%), landfill 1, recycling 4, other 1. Non-hazardous waste 14,015 t: incineration 2,523 (18.0%), landfill 2,367 (16.9%), recycling 8,137 (58.1%), other disposal 987 (7.0%). Total non-recycled waste 6,039 t, 42.6% of total waste (2024: 4,663 t, 40.5%).

"Most of the waste we produce is classified as non-hazardous, which accounts for 98.8% of our total waste" and "TKH does not produce any radioactive waste" (pages 108, 110). Approximately 58% of waste relates to copper, aluminium, steel and plastics.

Method and its limits. "We determine the weight and treatment method of the waste using data recorded and reported by external recycling and waste processing companies. In case weight data cannot be obtained, the weight is estimated... If the treatment method cannot be obtained, we assume that the waste has been incinerated" (page 110). Internal Audit's 2025 findings included "completeness of waste reporting and classification of waste treatment" (page 87).

Policies related to own workforce

Reference: pages 115-118, 119, 122-123; Appendix B maps S1-1 paragraphs 20, 21, 22 to pages 115-118 and paragraph 23 to pages 122-123 (page 153).

Human rights commitments. "We have included provisions regarding the respect and protection of human rights in our Code of Conduct for our employees. Our policy is based on the UN Guiding Principles on Business and Human Rights and we do not tolerate any human rights violations. We use the OECD Guidelines and ILO Declaration on Fundamental Principles and Rights at Work as a reference framework to enable us to quickly identify potential risks. Since 2024, we have endorsed the guidelines provided in the UN Global Compact. In the event of human rights violations, we investigate and implement ways to remediate impacts" (page 116).

Discrimination. "At TKH, we have a strict policy of equal treatment for all our employees, regardless of race, nationality, ethnic background, color, age, religion, gender, sexual orientation, political opinion, or disability... We do not differentiate between the base salaries of male and female employees and apply market-based remuneration. However, there may be differences between countries, depending on local market practices, as well as tax and social security structures" (page 116).

Coverage and scope. "We have identified potential material negative impacts on the overall health and wellbeing of our own workforce. These impacts apply to all members of our own workforce and are not related to individual incidents. Therefore, our policies to manage material impacts, risks, and opportunities apply to all members of our own workforce. We have no operations that are at significant risk of forced, child, or compulsory labor... However, production activities may be at greater risk due to health and safety issues... We did not identify any material impacts on workers that could result from transition plans... There are no material positive impacts" (page 115).

Policy tables for the Code of Conduct and the whistleblower procedure (based on EU Whistleblower Directive 2019/1937) are on page 118; the HSE policy based on ISO 14001/45001 on page 122.

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

Reference: pages 116-117.

"We gain insight into the perspectives of our own workforce - including those who may be particularly vulnerable - via direct engagements, meetings with Works Councils, employee satisfaction surveys, and annual performance reviews. The Executive Board maintains direct contact with employees throughout the organization by attending employee presentations, participating in project meetings, or taking part in informal gatherings" (page 116).

Formal representation. "Employee interests are represented at the operating company level by the local Works Councils, and at the TKH group level by the Central Works Council. These councils ensure ongoing employee representation under the terms of the Works Councils Act (or 'Wet op de Ondernemings-raden' in Dutch). This year, the Executive Board and the Central Works Council held four informal meetings. The CEO attended on behalf of the Executive Board, as the most senior TKH executive with operational responsibility for ensuring engagement and incorporating the outcomes of these meetings into TKH's approach" (page 116). The eight named members of the Central Works Council, drawn from VMI, TKF, Intronics and TKH Security, are listed on page 117.

"Topics discussed included performance on non-financial KPIs compared to the targets. These KPIs include sustainability-related matters such as diversity and health and safety. To strengthen the ties between the various Works Councils of our Dutch operating companies and to promote the exchange of knowledge and experience, we hold an annual Works Council day" (page 117).

Board-level engagement. "at least one regular Supervisory Board meeting is held annually at the location of a TKH operating company. These company visits allow the Supervisory Board to meet with local management and employees... The Supervisory Board is updated on local developments and possible challenges faced by local management" (page 116).

The employee satisfaction survey reached 3,713 employees, 57% of total headcount, across the 2022 to 2025 cycle (page 117).

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

Reference: pages 117-118; Appendix B maps S1-3 paragraph 32(c) to pages 116-117 (page 153).

"At TKH, we are committed to an open culture in which employees can discuss any concerns, problems, or abuses openly. We encourage our employees to report such matters to their direct manager or supervisor. Employees can report matters confidentially, and they will not suffer any detriment for doing so. We have also established a whistleblower procedure to provide employees with a clear course of action when they wish to raise issues or concerns. This procedure is for reporting possible criminal offenses or violations of the law, such as bribery, disclosure of confidential information, dishonesty, and unethical behavior, including discrimination, sexual harassment, and bullying. It also covers tax-related issues" (page 117).

Protection against retaliation and handling. "TKH has implemented specific measures to prevent any form of retaliation, and remains vigilant in safeguarding the anonymity and protection of whistleblowers. Reports are reviewed and investigated by the local confidential officer and/or the Group Compliance Officer. Depending on the topic, an external researcher may be appointed to ensure independence and objectivity. If deemed necessary, disciplinary and corrective measures are taken. We track and monitor the issues raised by ensuring that all received reports are recorded, investigated, and closed" (page 117).

Effectiveness tracking. "We evaluate the effectiveness of the procedure by engaging with our own workforce through employee surveys and performance reviews. TKH promotes awareness of the whistleblower procedure through internal training and various communication channels, such as shared folders" (page 117).

2025 outcome: "In 2025, no reports were received through the whistleblower procedure. Also, no violations of the Code of Conduct were reported through the internal reporting procedure" (page 134), against 0 whistleblower reports and 3 internal reports in 2024 (page 135).

Feedback loops also run through satisfaction surveys and performance reviews, whose findings "are included in the relevant operating company's HR plans", with follow-up surveys measuring the effect of improvements (page 117). In 2025, 74% of all employees received a performance review, up from 63% in 2024 (page 117).

Taking action on material impacts on own workforce

Reference: pages 115-123.

Diversity actions (pages 120-121). "we have initiated specific programs to recruit women, including a trainee program for young women. Through this program, female employees have the opportunity to work in different technical and technological positions, combined with a specific development program to develop their other skills, including management and personal development skills. We have also established specific working groups to promote women within our organizations." TKH "maintains close contact with business schools and universities", offers "internships, graduation projects, and short courses", and uses "targeted programs to attract more female students with limited or lower levels of education - such as those in vocational training". Referral recruitment is used increasingly for external female candidates. "In 2026, we will continue with targeted programs to attract more female students. Also, we will strengthen our development programs to improve skills... to enable women to be promoted to senior and executive positions" (page 121).

Health and safety actions (pages 122-123). Health and safety policies, a safety management system and awareness programs are implemented "within all of our operating companies"; manufacturing companies are certified to ISO 45001; "We conduct regular risk assessments to identify potential safety risks. In some cases, this has resulted in the relocation of machinery or material storage to eliminate the risk. Employees performing activities with a higher safety risk must first complete a special safety course. As part of an ongoing safety learning program, we ask our employees safety-related questions on a weekly basis." Since 2024 the cable production company holds Safety Culture Ladder certification (level 3) alongside ISO 45001. "In 2026, we will continue implementing safety awareness programs to reduce the number of incidents that occur" (page 123).

Resources. For both diversity and health and safety, "the resources needed are opex-related and do not require any significant capex. These operating expenses are also not additional, since these initiatives are an integral part of our day-to-day expenses and HR activities" (pages 121, 123).

Targets related to own workforce

Reference: pages 81, 117, 119, 123.

Four own-workforce targets are disclosed, three of them in the group key sustainability targets table on page 81:

• Female executive and senior management: >25% by 2030. Set in 2021 "based on the 2020 figure of 16.8%, as well as through benchmarking with other technical companies and engagement with various stakeholders". 2025 outcome 20.5%, down from 21.6% in 2024 (page 119).
• Employee satisfaction score: >8.0 (CMD 2028 target). "In 2025, as part of our CMD 2028 targets, we raised our target score for the employee satisfaction survey from >7.8 to >8.0 because our performance in 2024 equaled the original target. Our 2025 employee satisfaction score was 7.8" (page 117).
• Lost Time Injury Frequency Rate: <0.70. "In 2025, we adjusted our LTIFR target from <1.0 to <0.7, to demonstrate the importance of safety and our commitment to improving it." 2025 outcome 0.41, from 0.67 in 2024, so the target was met (page 123).
• Illness rate: maximum 4.0%. "In 2025, the illness rate was 4.11%, slightly above the previous year's rate of 3.97% and slightly above the maximum target rate of 4.0%. Flu-related illnesses had the greatest impact on the small increase" (page 123).

Two further zero-tolerance targets sit in the health and safety table: zero fatalities from work-related injuries and ill health among own employees, and zero among other workers on TKH sites, both achieved (page 123).

Targets are set by the Executive Board; "Tracking effectiveness is part of our quarterly sustainability reporting, including metrics", and where no quantitative measure exists TKH reports qualitatively (page 86). Two of these targets, employee satisfaction and LTIFR, also carry 10% weightings each in the Executive Board short-term incentive, and diversity carries 10% of the long-term incentive (page 85).

Characteristics of the undertaking's employees

Reference: pages 117-118.

"The total number of employees (head count) as of December 31, 2025, was 6,538. The total average number of employees (head count), during 2025 was 6,615. The total number of full-time equivalent (FTE) employees was 6,304 and aligns with the FTE number in note 22 of the consolidated financial statements. A total of 853 employees left TKH in 2025. The employee turnover rate was 12.8%", calculated on leavers in 2025 divided by headcount at 31 December 2024 (page 117).

By region, headcount (page 118): Netherlands 2,390 (2024: 2,375); Germany 1,074 (1,153); Europe other 1,455 (1,475); China 717 (762); Asia other 89 (86); North America 546 (565); Other 267 (249). Total 6,538 (6,665).

By contract type (page 118): permanent 5,859 (2024: 5,834); temporary 584 (705); non-guaranteed hours 95 (126). The same split is given per region and by gender: permanent 4,466 male / 1,393 female; temporary 411 / 173; non-guaranteed 61 / 34.

By gender (page 118): male 4,938 (2024: 5,095), female 1,600 (1,569), other 0 (1).

By age (page 120): under 30 998 (15.3%); 30 to 50 3,523 (53.9%); over 50 2,017 (30.8%).

"In the year under review, 111 FTEs were employees with disadvantages in the labor market, compared to 125 FTEs in 2024" (page 118).

Basis: "The tables include head count of employees at the end of the reporting period (December 31, 2025). HR data is obtained every quarter. This data is derived from the HR accounts held by TKH's operating companies. The table showing employees per country (>10% of employees) and region is based on the location of the operating company with which the employee is contracted. An employee's nationality or actual place of work or residence is irrelevant for this breakdown" (page 118).

Diversity metrics

Reference: pages 119-121; board diversity also page 84.

Workforce and management (page 120):

"In 2025, the proportion of women in our total workforce increased slightly, from 23.6% in 2024 to 24.5%. The male-to-female ratio remained relatively high, reflecting the gender composition of the available labor market... The proportion of female executive and senior management employees decreased from 21.6% in 2024 to 20.5% in 2025" (page 119), against the >25% by 2030 target.

Age distribution (page 120): under 30 998 (15.3%); 30 to 50 3,523 (53.9%); over 50 2,017 (30.8%).

Definitions are given (page 119): "Executive management: statutory management director level (reporting directly to the Executive Board). Senior management: includes managers who are members of the operating company's management team and are responsible for specific business units or departments (e.g., finance, human resources, sales, marketing, legal, R&D, QHSE, supply chain, and operations)."

Board-level targets are one-third female and one-third male for the Executive, Management and Supervisory Boards; the Supervisory Board meets it at 60% female, the Executive Board does not at 0% (pages 84, 120). "TKH will strive to ensure that new appointments to the Executive Board, Management Board, and Supervisory Board are made with the aim of having of at least one-third female and one-third male members" (page 120).

Health and safety metrics

Reference: page 123; Appendix B maps S1-14 paragraph 88(b) and (c) to page 123 and marks paragraph 88(e) days lost as "phased-in" (page 153).

Health and safety metrics, own employees (page 123):

"52.8% of our own workers are covered by our health and safety management system, which is based on recognized standards. This percentage is calculated based on the total number of our own workers and includes both production sites and office locations. In 2025, 100% of our own workforce at our production sites was covered by the ISO 45001 standard" (page 123).

"TKH defines its Lost Time Injury Frequency Rate (LTIFR) as the number of incidents resulting in at least one day's absence from work, with no possibility of any replacement, per million hours worked."

Limitations are stated candidly. "Reportable incidents are based on actual occurrences and are never extrapolated or estimated. Despite a range of measures and an open safety culture, there is an inherent risk of under-reporting accidents, because accidents are self-reported in most cases. Reported hours are measured, calculated, or estimated. The absolute number of serious accidents reported includes all employees on TKH's payroll, excluding third-party contractor employees. Our LTIFR is reported at the group level and is not specified by region or gender" (page 123).

Illness rate was 4.11% in 2025 against a maximum target of 4.0% (2024: 3.97%).

Policies related to value chain workers

Reference: pages 124-125; Appendix B maps S2-1 paragraphs 17, 18 and 19 to pages 124-127 (pages 153-154).

The governing instrument is the Code of Supply. "To manage potential negative impacts, we have implemented a Code of Supply. We perform desktop reviews and on-site assessments of our strategic tier-1 suppliers (with an annual purchase volume of more than €1 million) and measure effectiveness through targets and KPIs. By signing our Code of Supply, our strategic tier-1 suppliers agree to respect and comply with the fundamental rights granted to all employees under applicable national statutes. Furthermore, we expect our strategic tier-1 suppliers to fully recognize the labor standards issued by the International Labour Organization (ILO)" (page 124).

Content of the Code (page 124), each item introduced as an expectation: employment freely chosen in accordance with the Universal Declaration of Human Rights; prohibition of "human trafficking, forced labor, compulsory labor, or child labor"; equal opportunities and equal treatment; prohibition of discrimination in recruitment, promotion or selection for training on grounds including "gender, age, ethnicity, nationality, sexual orientation, disability, union membership, political affiliation, or religious conviction"; respect for "collective bargaining and freedom of association"; compliance with national statutes on working time; compensation in line with national statutes; a safe working environment and compliance with health and safety statutes; "an appropriate occupational health and safety management system that meets the requirements of ISO 45001 or the national equivalent"; protection of the health and safety of employees and contract labour; and consumer safety including products free of hazardous substances as defined in the RoHS Directive.

A gap is disclosed: "In 2025, we reviewed whether it is necessary to develop a supplemental policy for workers in the value chain, in addition to existing policies. We decided to first complete the new 2025 risk assessment, to identify all relevant risks in the value chain" (page 127). The group statement is blunter: "We currently have limited detailed policies and action plans in place for topics related to the value chain" (page 86).

Processes for engaging with value chain workers about impacts

Reference: pages 126-127.

TKH states the limit of its engagement first. "We do not engage directly with workers in the value chain. Consequently, they are not directly involved in setting targets either. We manage relationships with suppliers via meetings. We also perform desktop and on-site supplier assessments of our strategic suppliers to obtain information on the working conditions of value chain workers. Purchase departments within our operating companies are responsible for ensuring that engagement takes place, under the managing director's supervision" (page 126).

"The human rights section of these supplier assessments includes questions on child labor, forced and compulsory labor, working hours, minimum wages, freedom of association, discrimination, and harassment" (page 126).

Industry collaboration substitutes in part for direct engagement. "Since 2023, our largest cable production company TKF participates in the International Responsible Business Conduct (IRBC) agreement for the Renewable Energy Sector... By participating in this agreement, TKF is committed to collaborating with our stakeholders, as well as all others participating in the renewable energy agreement. We aim to identify and mitigate our own (including suppliers) risks and impacts on both society and the environment. We are also in continuous conversation with our main copper suppliers regarding a responsible supply chain. Our largest supplier in terms of purchase volume is part of The Copper Mark industry initiative" (page 125).

"In 2025, we performed a value chain assessment at our largest cable production company TKF in collaboration with one of our customers. Jointly conducting value chain research offers short- and long-term value for all parties involved" (page 125). "Through this assessment we covered 71.1% of our copper usage in 2025 (based on weight). In 2026, we will further enhance and extend the risk assessment. We will also engage with suppliers classified as high risk" (page 126).

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

Reference: pages 126-127.

"TKH is committed to an open culture in which people can openly discuss any concerns, problems, or abuses. External parties, such as suppliers or workers in the value chain, can report issues, either directly to the operating company via a complaint procedure, or directly to TKH. The whistleblower procedure establishes a clear course of action for employees or third parties who wish to raise issues or concerns, such as a possible criminal offense or violation of the law, bribery, disclosure of confidential information, dishonesty, or unethical behavior, such as discrimination, sexual harassment, or bullying" (page 126).

Protection from retaliation. "At TKH we are committed to protecting workers in the value chain from retaliation. Reports made in accordance with the established procedure will not negatively affect workers in the value chain" (page 126).

Handling and escalation. "Every complaint or report is investigated through the local complaint procedures. Reports received by TKH are reviewed and investigated by the Group Compliance Officer. If violations are found, ways to mitigate their impact on workers in the value chain will be investigated and implemented. If a supplier does not respond adequately, the business relationship with that supplier will be reevaluated. Existing policies and other measures to prevent this in the future will also be reviewed" (page 126).

2025 outcome: "In 2025, no severe human rights issues and incidents have been reported" (page 126), and "The assessments we have conducted with our suppliers have not revealed any material violations of human rights in our value chain" (page 127).

The whistleblower procedure is "Applicable for all employees and third parties" and is based on the EU Whistleblower Directive 2019/1937 (pages 118, 134). In 2025 TKH updated the procedure, to be implemented in early 2026 "together with a new online platform through which (anonymous) reports can be submitted", followed by "a new training program for staff receiving and managing whistleblower reports (confidential officers)" (page 135). TKH does not state whether value chain workers are aware of or trust these channels.

Taking action on material impacts on value chain workers

Reference: pages 125-127; Appendix B maps S2-4 paragraph 36 to pages 124-127 (page 154).

The copper value chain is mapped and assessed. "Copper is an important raw material for our cable production companies... The copper industry is global, spanning from mines in South America to refineries in Asia. The copper supply chain has several inherent risks, including health and safety (working conditions) and child/forced labor (work-related rights). We are at the end of the value chain, with tier 1, 2, and 3 suppliers in the upstream value chain. We purchase semi-fabricated copper products, such as copper wire, from our tier-1 suppliers. Our tier-2 suppliers are companies that smelt and refine copper purchased from tier-3 suppliers, which are copper mining companies" (page 125). A tier-3 to downstream diagram is printed on page 125.

New in 2025: a joint risk assessment. "In 2025, we performed a value chain assessment at our largest cable production company TKF in collaboration with one of our customers... The risk assessment includes social-related risk per county, focusing on forced labor & human trafficking, discrimination & gender, child labor, corruption, and government influence. Furthermore the environmental, health & safety risks per raw material and value chain position is included... Through this assessment we covered 71.1% of our copper usage in 2025 (based on weight)" (pages 125-126).

The Copper Mark. "Our largest supplier in terms of purchase volume is part of 'The Copper Mark' industry initiative... The Copper Mark covers the 32 sustainability criteria set out in the Responsible Minerals Initiative (RMI)'s Risk Readiness Assessment, and incorporates all major environmental, social, and governance (ESG) issues, such as child labor and occupational safety" (page 127).

Planned action and resources. "In 2026, we will further enhance and extend the risk assessment. We will also engage with suppliers classified as high risk to manage the identified potential risks, and to discuss the mitigation actions." Resources are "opex-related and do not require significant capex" and are "not additional" (page 127).

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

Reference: pages 126-127.

Code of Supply targets (page 126):

"The Code of Supply has been signed by 95.9% (2024: 89.4%) of all suppliers in scope. The annual target of 90% has been achieved, despite a longer lead time for new suppliers to sign the Code" (page 136). The two assessment percentages are governed by timing ambitions rather than annual percentage targets: "our ambition and goal is to conduct a desktop assessment of the supplier in question within two years of signing the Code of Supply and the on-site assessment within five years after signing" (page 136). Both rose sharply in 2025.

Tier-1 copper supplier targets (page 126):

Both copper metrics moved backwards year on year, and the report does not gloss over it: "Our target is to have at least 80% of our copper suppliers certified by The Copper Mark by 2030. In 2025, 54.9% of our tier-1 suppliers (based on purchased kilograms) were certified by The Copper Mark" (page 127).

Value chain workers are not involved in setting these targets: "We do not engage directly with workers in the value chain. Consequently, they are not directly involved in setting targets either" (page 126).

Policies related to consumers and end-users

Reference: pages 128-129; Appendix B maps S4-1 paragraphs 16 and 17 to pages 128-130 (page 154).

TKH opens by stating what it does not have. "We do not have a specific policy for consumers and/or end-users, nor are they directly involved in target setting. Our current policies do not include mechanisms or processes for monitoring compliance with the UNGC, ILO Declaration, or OECD Guidelines, nor do they include measures for remedying any negative impact on human rights. We will review the necessity of developing a specific policy for consumers and/or end users" (page 128).

What does apply: "We have included provisions regarding respect for and protection of human rights in our Code of Conduct. Based on the UN Guiding Principles on Business and Human Rights, our Code of Conduct does not tolerate any human rights violations. We use the OECD Guidelines and ILO Declaration on Fundamental Principles and Rights at Work as reference frameworks" (page 128).

The operative policies for the material sub-topic, privacy and cybersecurity, are two (page 129):

• IT and security policy - "Guidance on IT controls and information security, including security breach/incident reporting and intellectual property protection"; applicable for all operating companies; managing directors responsible for implementation; "Based on ISO 27001:2022 controls".
• Privacy policy - "Describes how we act as a company on privacy-related topics and how we want to protect personal employee data within our company"; applicable for all operating companies; "Based on the EU's GDPR".

"The IT and security policy covers important topics such as business continuity, operational IT controls, and guidelines on secure software development. IT audits are conducted at operating company level, and action plans are implemented to address identified vulnerabilities in IT systems" (page 128). GDPR compliance is supported by a processing register, and "In collaboration with the internal Legal Advisor (who is also the Data Privacy Officer), the Internal Audit team ensures the proper application of GDPR legislation" (page 129).

Processes for engaging with consumers and end-users about impacts

Reference: pages 129-130.

"We measure, monitor, and evaluate customer satisfaction by conducting comprehensive surveys every four years. These surveys cover predefined topics and provide the opportunity for customers to voice other concerns, such as those related to privacy or data protection. Based on the survey results, we can take specific action to address any data privacy issues that arise. The operating company's managing director is responsible for executing the survey and the implementing defined actions" (page 129).

Because all sales are business to business, engagement runs through customers rather than individuals: "All our sales transactions are business-to-business (B2B), and as a result, we have an indirect impact on consumers and end users" (page 128).

The limits are disclosed. "We do not specifically assess whether our consumers and/or end-users are aware of or trust these structures or processes for raising their concerns or needs" (page 129). And on affected individuals in a data incident: "The perspectives of affected individuals do not influence the management of actual GDPR incidents. However, with respect to potential impacts, individuals may contact the data controller (our customers) to exercise their GDPR rights and we will comply with such requests where applicable" (page 129).

Basis of the reported score. "The reported customer satisfaction score (on a scale of one to ten) is based on the outcome of the most recent surveys, conducted by an external research company. Each year, several operating companies conduct the survey. Each survey reflects the customer base of the respective operating company. The 2025 customer satisfaction score reflects survey results from the period 2022-2025 and is based on the weighted average of all responses from customers of selected operating companies during this period. For project-driven operating companies, we employ qualitative surveys and interviews to gain deeper insights" (page 130).

Consumers and end-users "are not directly involved in target setting" (page 128).

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

Reference: pages 129-130.

"At TKH, we are committed to fostering an open culture in which people can discuss concerns, problems, or abuses without fear of retaliation. Customers and other external parties can report issues to a particular operating company via the complaint procedure, or directly to TKH. We have established a whistleblower procedure to provide a clear course of action for employees or third parties who wish to raise issues or concerns. We fully investigate every complaint or report that we receive. Complaints reported to operating companies are investigated through the relevant local complaint procedures" (page 129).

Two KPIs track the channel itself. "We report on two KPIs related to this topic as part of our sustainability reporting: the number of received complaints and the number of complaints settled within five working days" (page 129).

Escalation and independence. "Reports received by TKH are reviewed and investigated by the Group Compliance Officer. Depending on the topic, we may appoint an external researcher to ensure independence and objectivity. If deemed necessary, disciplinary and corrective measures are taken" (page 129).

Data breach protocol. "Data leaks and cyber incidents require immediate corrective action to prevent escalation. Where an incident involves a GDPR breach that presents a risk to the affected individuals, we immediately inform the customer, and the incident is reported to the relevant local authority and the affected individuals" (page 129). For service failures: "We have established procedures to manage and mitigate system failure or downtime if a project experiences such issues. We act immediately to stop the incident and communicate with the affected customer, keeping them updated on the restoration of normal operations" (page 130).

Outcome and remaining gap. "The engagements have not revealed any material human rights violations. If violations do occur, the business relationship will be reconsidered. In addition, we will investigate and implement ways to remediate the impact on consumers and end users" (page 130). TKH does not assess whether consumers and end-users are aware of or trust these channels (page 129).

Taking action on material impacts on consumers and end-users, and approaches to managing material risks and opportunities

Reference: pages 128-130; Appendix B maps S4-4 paragraph 35 to page 130 (page 154).

The material sub-topic is privacy and cybersecurity. "Data leaks, cyber incidents involving GDPR-sensitive data, and the loss of business-sensitive information could have a potential negative impact on consumers' rights to data protection... Data protection is also relevant for our products that store customer data, such as portfolio and customer production data stored in our tire building machines and vision systems. Therefore, this topic covers the privacy and security of the products and services we sell as well as the cybersecurity of our organization" (page 128).

Actions taken in 2025:

• Phishing simulation and training. "We continuously train our employees to detect phishing attempts via email. To raise awareness and train detection skills, we regularly send fake phishing emails to employees. If they miss the signs of phishing and make a mistake, we inform them of the signs they should have noticed" (page 130).
• Penetration testing. "We perform penetration tests at select operating companies to evaluate their resilience against digital attacks, identify potential vulnerabilities, and assess their potential impact" (page 130).
• Regulatory preparation. "In 2025, we placed more emphasis on the EU NIS2 Directive... In addition, we began conducting assessments to implement the EU Cyber Resilience Act (CRA), which will impose reporting obligations regarding vulnerabilities and incidents starting in late 2026 and require full product compliance beginning in 2027" (page 130).
• Policy update. "At the end of 2025, we updated our IT and security policy, which will be implemented in 2026" (page 130).

Governance. "Cybersecurity is a recurring agenda item in Executive Board and Audit Committee meetings, and IT & Security is one of the Internal Audit team's immediate focus areas" (page 130).

Gaps the company states: "We did not identify any specific actions related to our own practices regarding product design, marketing, or sales. We also did not identify whether collaborative action with other relevant industry parties is required" (page 130). Resources are opex-related, not additional, and require no significant capex (page 130).

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

Reference: page 130.

Customers and end-users target table (page 130):

Cybersecurity. "Several minor and non-material security incidents occurred within our own operations during the year under review. These incidents reinforce the need to remain vigilant to IT security risks. In 2025, TKH experienced no cybersecurity incidents within its own operations that had a direct financial impact exceeding €100k" (page 130). The threshold-based target was met.

Customer satisfaction. "In 2025, as part of our CMD 2028 targets, we adjusted our customer satisfaction survey score target from >7.8 to >8.5 because our performance in 2024 exceeded the original target. Our average customer satisfaction survey score for 2025 was 8.6, compared to 8.6 in 2024" (page 130). The year in review adds that the score "is essential for our success and focus on customer-centricity as major strategic pillar" (page 80). The target is also listed in the group key sustainability targets table on page 81.

Improvement plan. "We aim to provide an even better customer experience through training and skills management and process standardization, as well as by improving our availability, information systems, and 24-hour service" (page 130).

Consumers and end-users are not involved in setting these targets: "We do not have a specific policy for consumers and/or end-users, nor are they directly involved in target setting" (page 128). No target is set on the two complaint-handling KPIs that TKH says it tracks, the number of complaints received and the number settled within five working days (page 129).

Business conduct policies and corporate culture

Reference: pages 131-135; Appendix B maps G1-1 paragraph 10(b) (UN Convention against Corruption) to pages 131-135 and paragraph 10(d) (protection of whistleblowers) to page 135 (page 154).

"TKH conducts its business according to the principles of honesty, integrity, accountability, and transparency... All employees are expected to be aware of the core values that underpin our actions and our risk profile, and to take responsibility for any potential risks. They are also expected to act in accordance with TKH's Code of Conduct" (page 133).

Governance of business conduct (page 132). "The Executive Board, led by the CEO, holds ultimate responsibility for defining, implementing, and monitoring business conduct policies across the organization." Policies "are developed by the Executive Board, reviewed by the Supervisory Board, and formalized in internal procedures"; the Director of Sustainability "is responsible for operational enforcement of compliance beyond reporting obligations"; Internal Audit "assesses governance risks related to business conduct". On training: "Board members and senior management undergo training on corporate ethics, business conduct, and compliance. Where no formal program exists, action plans will be developed to address this gap."

Code of Conduct. It "uses the OECD Guidelines as a reference framework, in addition to the guidelines provided in the UN Global Compact, which is endorsed by TKH", and covers "anti-bribery and anti-corruption, honest business conduct, conflicts of interest, health and safety, and human rights" with "a zero-tolerance policy regarding matters of principle, such as fraud, bribery, and corruption". Each employee receives and must sign it (page 133).

Signing rate, against target (page 133): "The Code of Conduct has been signed by 99.3% (2024: 98.9%) of all employees. The annual target of 100% has not been achieved, partly due to a longer-than-expected lead time for new employees to sign the Code." The four-year series is 99.3%, 98.9%, 96.5%, 97.7% (page 135).

2025 outcome: "no reports were received through the whistleblower procedure. Also, no violations of the Code of Conduct were reported through the internal reporting procedure. There are no incidents reported related to bribery, corruption, discrimination or harassment" (page 134).

Management of relationships with suppliers

Reference: pages 136-137.

"We expect our suppliers to adopt a zero-tolerance policy on issues that are material to us. Our principles and requirements are set out in our Code of Supply, which covers environmental, social, and governance topics such as human rights, environmental impact (such as policies, environmental management systems, and pollution prevention), occupational health and safety, compliance with law and regulations (including related to corruption and bribery), and ethical behavior. This set of environmental, social, and governance topics is part of our supplier selection criteria. In the case that the criteria are not met by the supplier, the business relationship will be reconsidered" (page 136).

Process and cadence. Strategic suppliers, those with annual purchase volume above €1 million, sign the Code of Supply, "This is followed by a desktop assessment and an on-site assessment", with the stated ambition "to conduct a desktop assessment of the supplier in question within two years of signing the Code of Supply and the on-site assessment within five years after signing the Code of Supply. Internal Audit has included the auditing of processes related to the Code of Supply in its work program" (page 136).

2025 performance (pages 136-137): Code of Supply signed by 95.9% of strategic suppliers against a >90% target (2024: 89.4%); desktop assessment completed for 69.3% (54.7%); on-site assessment for 46.4% (31.7%).

Supply security. "Situations where important raw materials such as copper, aluminum, steel, plastics, and technical (electronic) components have long delivery times, are unavailable, or are only available in limited quantities can put pressure on our profit margins... To mitigate these risks, we increase our inventory of critical raw materials and components where applicable. At the same time, we try to redesign products as much as possible to increase the use of alternative materials and components with better availability/pricing, in addition to the use of alternative suppliers" (page 137).

No payment practices disclosure accompanies this requirement.

Prevention and detection of corruption and bribery

Reference: pages 138-139.

"We do not approve of any form of corruption and bribery, or of any other form of unethical business practice. We have a Code of Conduct in place, covering various topics, including anti-corruption and anti-bribery. TKH has endorsed the ten principles of the United Nations Global Compact in the areas of human rights, labor, environment, and anti-corruption, which are aligned with the United Nations Convention against Corruption. We are committed to not only avoiding bribery, extortion, and other forms of corruption but also to proactively developing policies and concrete programs to address corruption internally and within our most important supply chains" (page 138).

Investigation independent of the management chain. "any violation of our anti-corruption or anti-bribery rules and procedures can be reported through our whistleblower or internal reporting procedure and is investigated by the Group Compliance Officer and/or an independent team, separate from the chain of management. Each report is submitted to the Executive Board and Supervisory Board through the Audit Committee" (page 138).

A named, located risk. "Based on the internal fraud risk assessments performed, we have identified a potential and inherent corruption/fraud risk in the value chain of our business segment Smart Manufacturing systems due to the use of third-party agents in serving a proportion of our end customers. We have implemented various measures to mitigate the risk, such as guidelines and template contracts to govern the working relationships with agents and intermediaries. We also provide training to our third-party agents" (page 139).

Training, and the gap in it. Efforts "specifically focus on functions at risk of corruption and bribery, which include procurement, sales, legal, financial administration, and senior and executive management". But the coverage metric is well short: 36.7% of at-risk employees covered by anti-corruption and anti-bribery training against a >90% target (2024: 27.5%) (page 139). "In 2025, we launched a group-wide e-learning platform for training programs. The new training program for functions at risk of corruption and bribery will be launched in 2026", and Executive and Supervisory Board members "will also participate" (page 139).

The Audit Committee "discusses the company's fraud risk assessment" at least annually (page 138).

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

TKH does set measurable annual business conduct targets, and reports against each of them:

The company reports the misses plainly. On the Code of Conduct: "The annual target of 100% has not been achieved, partly due to a longer-than-expected lead time for new employees to sign the Code. We are in close contact with the operating companies, and we are establishing clear rules to eliminate such delays" (page 133). The anti-corruption training figure, 36.7% against a >90% target, is the widest gap in the statement, and the remedy is stated as the new training program launching in 2026 on the group e-learning platform introduced in 2025 (page 139).

Target setting is compliance-driven, not stakeholder-driven: "Since the defined targets are derived from compliance requirements, key stakeholders are not directly involved in the target-setting process" (page 131). Targets are determined by the Executive Board, and "Tracking effectiveness is part of our quarterly sustainability reporting, including metrics" (page 86).

Incidents of corruption or bribery

Reference: page 139; Appendix B maps G1-4 paragraph 24(a) to page 139 and paragraph 24(b) to pages 138-139 (page 154).

A complete nil return for the year. "In 2025, no confirmed incidents of corruption or bribery were reported, and there were no convictions for the breach of such laws (annual target: no incidents or fines). In addition, there were no instances of employees being dismissed or disciplined for corrupt practices during the year" (page 139).

Incidents of corruption and bribery table (page 139):

Handling if an incident does occur. "Any incident of corruption or bribery is assessed to determine if additional internal control measures or other actions are needed. Each incident is investigated by the Group Compliance Officer. Depending on the topic, an external researcher may be appointed to ensure independence and objectivity in the investigation. If deemed necessary, disciplinary and corrective measures are taken. Each incident is reported to the Executive Board and Supervisory Board through the Audit Committee" (page 139).

The nil return is corroborated by the reporting channels: "In 2025, no reports were received through the whistleblower procedure. Also, no violations of the Code of Conduct were reported through the internal reporting procedure. There are no incidents reported related to bribery, corruption, discrimination or harassment" (page 134), against three internal reports in 2024 (page 135).

Read alongside G1-3, the nil return sits against 36.7% training coverage of at-risk functions and an inherent corruption risk identified in the Smart Manufacturing systems value chain arising from third-party agents (page 139), and against zero whistleblower reports in both years, which is itself worth weighing when judging detection capability.