Verkkokauppa.com

Reference: pages 14-15

Verkkokauppa.com's Board of Directors is the highest authority responsible for the Group's sustainability, approving strategy, the Code of Conduct, policies and guidelines and the objectives for responsible business. In 2025 the Board had seven members (four women, three men); 86% (6 people) were independent, and there is no employee representation on the Board or Management Team.

Board composition: Arja Talma (Chair), Robin Bade, Henrik Pankakoski, Kati Riikonen, Samuli Seppala, Irmeli Rytkonen, Enel Sintonen.

CEO and Management Team (8 members): Panu Porkka (CEO), Jesper Blomster (CFO), Tatu Kaleva, Pekka Litmanen, Jyrki Tulokas, Suvituuli Tuukkanen (Chief Marketing, Communications and Sustainability Officer), Satu Berlin, Anne-Mari Paapio (Chief Supply Chain Officer from 10 September 2025, succeeding Nina Anttila who left 28 August 2025).

Gender diversity (2025): Board of Directors 43% men / 57% women; Top management 62% men / 38% women, unchanged from 2024.

Reference: pages 15-16

As part of the 2025 double materiality analysis review, the Board of Directors and Management Team discussed and approved the identified impacts, risks and opportunities related to sustainability issues. Principles, actions and targets are reported to supervisory bodies whenever updated.

2025 topics discussed by the Board, Audit Committee and Remuneration Committee included: the double materiality analysis update and approval, approval of the Sustainability statement, an ESG review, updates to the Whistleblowing and Anti-bribery and corruption policies, and human resources and strategy matters.

Management Team topics included the Supplier Code of Conduct, the EU General Product Safety Regulation, circular economy services, the EcoVadis assessment, risk management, cybersecurity and data protection, eNPS results, and personnel matters such as occupational safety and diversity. The Sustainability Steering Group, chaired by the Chief Marketing, Communications and Sustainability Officer, prepares the Sustainability program; a separate CSRD Steering Group, chaired by the CFO, supports reporting.

Reference: page 16

For 2025, sustainability performance carried a 20% total weighting in the short-term remuneration model for management. Of this, 10 percentage points were assessed against keeping the product return rate below 1% annually for so-called "change of minds", supporting the company's principle of selling products based on genuine need while reducing returns and waste. The remaining 10 percentage points were assessed against implementation of the Compliance program.

The 2025 incentive system did not include targets directly related to greenhouse gas emissions. This differs from the return-rate-only 10% weighting disclosed for 2024, with a Compliance program component newly added for 2025.

The Remuneration Committee prepares the remuneration report for Board review; the Board approves it for the Annual General Meeting, where shareholders make an advisory decision.

Reference: page 16

Due diligence statement, mapped to the sustainability statement's own sections and page numbers:

Note that row (e) lists only E1, E2, E5, S1, S2 and S4 among the topical standards; G1 (business conduct) is not included among the topics with an MDR-T targets row.

Reference: page 16

Sustainability-reporting risks are identified, assessed and managed as part of the company's comprehensive risk management, based on the Board-approved risk management framework built on the ISO 31000 standard and run on an annual cycle. Risks are assessed by occurrence, probability and impact.

Sustainability reporting sits within external reporting, overseen by the CFO; preparation is the responsibility of the finance department and the sustainability unit, covering timelines and the availability and accuracy of background information. Reporting is carried out by people familiar with the subject who track applicable standards and legislation, and is supported by third-party assurance.

During 2025 the company established monitoring controls, including the work of the CSRD Steering Group, to further develop internal control of sustainability reporting. Progress and reporting-related observations were regularly reported to the Management Team, Audit Committee and Board.

Reference: pages 17-19

Verkkokauppa.com is a Finnish retail company specialising in consumer electronics and home and leisure products, operating primarily in Finland, with four stores (Helsinki, Pirkkala, Raisio, Oulu) and pick-up warehouses in Helsinki and Vantaa, plus consumer and wholesale sales in the EU/EEA. The product range covers over 60,000 products, including 2,800+ under private-label brands, across computers and peripherals, TV/video, mobile devices and home appliances, with installation, maintenance, recycling, trade-in and financing services.

2025 revenue was EUR 526.5 million (467.8), with net profit of EUR 12.4 million (-0.8). At year-end the company had 594 employees (615): 578 in Finland (597), 14 in China (15) and 2 in Hong Kong (3).

The value chain runs from raw material production and sourcing through the company's own operations (freight, warehousing, retail/circular-economy services) to end-of-life use, with significant production inputs including own workforce, supplier relationships, ERP/e-commerce systems, and brand and customer-data intangibles.

Reference: pages 20-21

Key stakeholders are customers, personnel, suppliers and other partners, owners and the capital market, plus workers in the value chain, whose interests, views and human rights aspects the company has separately assessed. Feedback is regularly reviewed by the Management Team and Board and feeds into the strategy process.

The company runs sustainability barometer surveys (2022 and 2024, each gathering over ten thousand responses on consumer electronics and online-store sustainability), used to update strategy, the double materiality analysis and Sustainability program targets.

The stakeholder engagement table covers channels and interests for each group, for example: customers via daily service contacts, surveys and the sustainability barometer; own workforce via personnel surveys, goal/development discussions and a diversity working group; suppliers via partner meetings, the Supplier Code of Conduct and audits; owners via the AGM, capital market days and investor reporting; and workers in the value chain via Amfori BSCI social responsibility audits including employee interviews.

Reference: pages 22-23

The company conducted its first double materiality analysis in early 2024 and updated it in 2025. Seven topics are material: E1 Climate change, E2 Pollution, E5 Resource use and circular economy, S1 Own workforce, S2 Workers in the value chain, S4 Consumers and end-users, and G1 Business conduct. S1 and S4 are material from both impact and financial perspectives; G1 is material from a financial perspective only; the rest are material from an impact perspective only. E3, E4 and S3 are not material.

The summary table of material IROs sets out subtopic, impact description, value-chain location and time horizon per topic, for example climate change mitigation impacts spanning the entire value chain (short-term) and S1 working-conditions/equal-treatment impacts concentrated in own operations. No material risks were identified requiring adjustment to the carrying amounts of assets or liabilities in the 2025 financial statements, though identified risks and opportunities may affect financial position and cash flows in the short and medium term.

Reference: page 24

In 2025 the company reassessed and refined its 2024 double materiality analysis based on a more detailed understanding of the materiality process. Two new negative impacts were identified, and material topics remained unchanged, but one new sub-theme, S4.2 Personal safety of consumers and end-users, was added. No changes were made to the identification and assessment process itself. The Board approved the updated analysis in autumn 2025.

Impacts scoring above 3.75 (on a 1-5 severity/likelihood scale) are material; the threshold is management-determined. As part of the update, the company deepened its climate resilience analysis and refined its scenario reporting (described under E1 Climate change). Biodiversity-related transition and systemic risks were identified in connection with logistics routes and supply chains, though the company's own sites are not in biodiversity-sensitive or high-water-risk areas. The company has not identified communities directly affected by its operations and has therefore not organised community consultations.

Reference: pages 25-27

The ESRS content index maps every disclosure requirement in the sustainability statement to a page reference or an explicit "Not material" / "Phase-in applied" marker, organised by topical standard (ESRS 2, E1, E2, E5, S1, S2, S4, G1).

Marked "Not material": E1-7 (GHG removals and carbon credits), E1-8 (internal carbon pricing), E2-4, E2-5, E2-6 (pollution of air/water/soil; substances of concern; anticipated financial effects), S1-12 (persons with disabilities), G1-5 (political influence and lobbying).

Marked "Phase-in applied": E1-9 (anticipated financial effects from climate risks and opportunities) and E5-6 (anticipated financial effects from resource use and circular economy).

E3 (water and marine resources) and S3 (affected communities) are absent from the index entirely, consistent with the SBM-3 materiality table marking them not material. A separate table (pages 28-32) lists cross-cutting datapoints derived from SFDR, Pillar 3, the Benchmark Regulation and the EU Climate Law, most marked not material to Verkkokauppa.com's business.

Reference: page 36

The company has not yet drawn up a formal transition plan. It states it has succeeded in its goal of reducing domestic own-operations emissions (Scope 1 and 2) to zero by the end of 2025, and therefore sees no immediate need for a transition plan on that front. A climate roadmap / transition plan for climate change mitigation is planned once the company has obtained SBTi validation of its climate targets confirming alignment with the Paris Agreement and EU climate targets; scope and implementation method will be assessed at that point, considering possible legislative changes.

In early 2025 the company committed to the Science Based Targets initiative (SBTi), and during the year prepared for the start of the target-validation process (E1-3, page 37). The company does not have significant greenhouse-gas- or energy-intensive assets that would create emissions lock-in or transition risk for its reduction targets (page 37).

Back-filled from ESRS 2 IRO-1 and the E1 climate-DMA subsection, where this content is disclosed in the FY2025 report (pages 24, 35-36). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

As part of the 2025 double materiality analysis update, the company assessed climate risks and its own-operations/value-chain resilience "from the perspective of the risks posed by the 1.5-degree climate scenario" (page 35), and classified identified risks as physical (acute or chronic) or transition risks (regulation, technology, markets, reputation), preparing a management practice for each.

Scope and timeframe: the entire value chain, over a 0-5 year horizon, consistent with the DMA (page 35). Physical risks (e.g. extreme weather disrupting the supply chain) concentrate at the beginning of the value chain; transition risks relate mainly to suppliers adapting to emission-reduction targets and regulation, both assessed not material given the company's low physical exposure and diverse supplier base (pages 35-36).

No named scenario model (SSP/RCP pathway, or a 1.5C-aligned model such as IEA NZE) or temperature projection is disclosed beyond "the 1.5-degree climate scenario"; risks "have been identified at a general level" without a separate identification method (page 35).

Back-filled from ESRS 2 SBM-3 and the E1 climate-DMA subsection, where this content is disclosed in the FY2025 report (pages 22-24, 35-36). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Based on its 1.5-degree-scenario assessment, the company states "no material financial climate risks have been identified" and sees no need to update its strategy (page 35); no material climate-related risks or opportunities are reported in its financial reporting.

Areas of uncertainty: the company "estimates that there are uncertainties associated with the identified risks and that conducting a broader climate scenario analysis could lead to the identification of potential new climate risks or a reassessment of the materiality of existing risks" (page 36); it reviews climate risks annually as part of the DMA and will reassess the scope of future resilience and scenario analyses considering legislative change.

Capacity to adjust: risk management includes preparedness for supply-chain disruption through securing alternative partners and transport routes (page 36); the broad, geographically spread supplier network is cited as a further source of resilience beyond the company's own low direct exposure (pages 35-36). No formal ESRS-defined resilience analysis with quantified short/medium/long-term outcomes is presented.

Reference: page 36

Climate-related principles sit in the Environmental Policy, covering own operations and the value chain: commitment to the international climate conference goals (1.5C), an annual carbon footprint calculation covering the entire value chain, and reducing own-operations emissions by investing in energy efficiency, purchasing renewable electricity/heating/cooling, and promoting renewable energy in leased properties. The company also commits to reducing logistics emissions with freight and distribution partners, minimising air freight, and switching to renewable transport fuels where possible.

Supplier-facing requirements on climate and energy were newly specified during the reporting year in the Supplier Code of Conduct: suppliers are encouraged to reduce emissions and improve emissions-data availability, with non-commitment able to affect supplier selection, continuation of cooperation, or contract renewal.

Climate change adaptation is not addressed in policy, as it has not been identified as a material topic. Policy scope, responsibility and availability are covered in the MDR-P section.

Reference: page 37

Actions table:

From summer 2025 all purchased electricity, district heating and cooling used in Finland is emission-free; electricity is EPD-certified renewable. During the year the company surveyed suppliers' SBTi commitment, built supplier/brand-level data capability, and updated its Supplier Code of Conduct with climate and energy requirements. No significant CapEx or OpEx was allocated to emission-reduction measures during the year; the company has not yet set an absolute Scope 3 reduction target, as calculations still rely largely on estimates.

Reference: page 38

Target 1 (Scope 1 and 2, own domestic operations): reduce to 0 tCO2 by end of 2025, versus a 2019 baseline. Result: Q1-Q2 2025 = 6 tCO2e, Q3-Q4 2025 = 0 tCO2e - the company states it succeeded in reaching zero in the second half of the year; full-year own emissions fell 79% year on year to 6 tCO2e, a 99% reduction versus 2019. The 2024 market-based own-operations figure was 581 tCO2e.

Target 2 (Scope 3 / value chain, global): 78% of suppliers and partners (by emissions) committed to SBTi targets by 2030 - an engagement target whose "formulation is preliminary" pending SBTi validation. 2025 progress not yet reported; KPI reporting is planned to start in 2026.

Critical assumptions note that growth in sales volumes will increase total emissions. Circular-economy targets (E5) are described as complementary, since extending product lifecycles reduces upstream manufacturing emissions.

Reference: page 39

Energy consumption and mix, 2025 vs 2024 (restated):

Reporting covers all locations except the two-employee Hong Kong office. The share of renewable sources rose from 79% to 95% as purchased electricity, district heating and cooling in Finland became fully emission-free from summer 2025. 2024 comparatives were adjusted retrospectively; the company will report a fossil-fuel-type breakdown for the first time in 2025.

Reference: page 40

Gross GHG emissions, tCO2eq:

Scope 3 growth was driven by category 1 Purchased goods and services (+26% to 183,370), category 11 Use of sold products (+10% to 25,565) and category 9 Downstream transportation (+9% to 2,234), against revenue growth of 12.5%. GHG intensity (market-based) rose slightly from 0.37 to 0.40 tCO2eq per thousand euros of revenue. Calculated per the GHG Protocol, on an operational-control basis, excluding the two-employee Hong Kong office; 99.78% of Scope 3 is calculated from primary data (sales volumes, supplier reports, internal systems).

Reference: page 43

Pollution principles sit in the Environmental Policy and Supplier Code of Conduct, both based on the Amfori BSCI Code of Conduct. The Environmental Policy addresses substitution and minimisation of substances of concern under EU chemical legislation, and managing/limiting pollution impacts at the beginning and end of the value chain (not the company's own operations, which the company states are not a source of pollution impacts).

The Supplier Code of Conduct requires suppliers to develop procedures for handling air, water and soil pollution, commit to Amfori BSCI environmental requirements, and consider environmental aspects in the supply chain, covering chemicals, hazardous substances, emissions and wastewater.

The company acknowledges a policy gap: its principles "do not specifically mention the elimination of substances of very high concern or the prevention of incidents and emergencies" and do not detail specific contaminants. Implementation of supplier environmental requirements is monitored through private-label supplier audits, which include an environmental-practice overview alongside social responsibility content.

Reference: pages 43-44

Actions table:

The company has not developed a pollution action plan and does not currently plan dedicated pollution-prevention actions, instead focusing resources on other environmental targets; no significant CapEx or OpEx was allocated. During 2025, WEEE guidelines were updated, online training on WEEE/hazardous-waste recycling was rolled out to personnel, and responsibilities were clarified, alongside acceptance of WEEE, batteries and accumulators beyond producer-responsibility requirements. Supplier-side monitoring runs through private-label social responsibility audits that include an environmental-practice overview (permits, water use, waste management).

Reference: page 44

The company has not set specific targets for preventing air, water or soil pollution in line with ESRS, and does not currently monitor the effectiveness of its pollution-related operating principles. It does not plan to set pollution targets for the 2024-2028 strategy period, citing the difficulty of measuring impacts that are concentrated at the beginning and end of the value chain, where the company has limited direct visibility.

The company states that progress on its climate change mitigation and circular economy goals is expected to indirectly deepen understanding of the downstream value chain and could support future pollution-target setting. In the meantime, management of pollution impacts relies on supplier Code of Conduct requirements, private-label supplier audits, and customer-facing recycling guidance for electronic waste, described under E2-1 and E2-2.

Reference: pages 45-46

Resource-use and circular-economy principles sit in the Environmental Policy and Supplier Code of Conduct, covering packaging and material choices, extending product life cycles, eco-design and waste minimisation/reuse.

Packaging: the company minimises packaging materials, avoids over-packaging, and prefers renewable and recycled materials to virgin/plastic materials. Recycled-plastic hierarchy: post-consumer recycled (primary), post-industrial recycled and pre-consumer recycled (secondary options). The company favours certified paper/cardboard, is reducing plastic shopping bags, and does not use PVC plastic; supplier packaging requirements are recorded in the Supplier Code of Conduct.

Circular economy: offering used/refurbished electronics, maintenance, repair and trade-in services extends product lifecycles, replacing primary with secondary resources - central to the company's "new normal for buying and owning" vision.

Eco-design: the company sets requirements for suppliers on eco-design and lifecycle thinking, targeting durability, repairability, energy efficiency and recyclability.

Reference: pages 46-47

Packaging: recycled content in packaging materials rose from 27% to 74% of total resource inflows in 2025; paper consumption fell 332 tonnes year on year following discontinuation of the printed advertising leaflet.

Circular economy: the "Vaihtokauppa" trade-in service, letting consumers resell used electronics for credit, covered phones, laptops, smartwatches and tablets in 2025, plus cameras/photographic equipment added as a new category; by year-end the service was unavailable except for cameras, due to a change of financing-service provider, with restoration planned. Maintenance services expanded: the TV maintenance line launched in 2024 moved to full scale, and preparation began for small-appliance maintenance (washing machines, dishwashers, dryers, phones, bicycles, scooters in Helsinki/Turku/Tampere).

Resourcing: one person-year was allocated to trade-in service development; no significant CapEx or OpEx was required for the year's measures.

Reference: page 47

Targets and 2025 results:

The circular-sales growth target was missed, slowed by refurbished-product productisation challenges, weak early-year outlet sales and the trade-in service's temporary closure following a corporate acquisition of the financing partner. The return-rate target was met (0.7%, flat versus 2024). A new service rate metric (0.1% in 2025) was introduced to separately track service cases going forward. Targets are voluntary, not science-based, and have no defined base year.

Reference: page 48

As a retailer without its own manufacturing, the company's material resource inflows are limited to packaging materials and advertising-leaflet paper.

Resource inflows by material, tonnes:

The steep drop in paper reflects discontinuation of the printed advertising leaflet. Recycled packaging materials rose from 159 tonnes (27% of total resource inflows) to 215 tonnes (74%); the proportion of recyclable raw materials in packaging was 100%, and FSC-certified packaging was 2% (3%), based on data from only one supplier reporting certification status.

Reference: page 48

As a retailer with no own manufacturing operations, the company does not treat the products it sells as resource outflows and does not report on their expected durability relative to industry averages, reparability, or recyclable-material content, since it does not manufacture them.

The company states it can only indirectly influence the lifecycle and repairability of the products it sells, through actions described under E5-2: offering used/refurbished electronics, trade-in and buy-back services, repair and spare-parts supply, extended warranties, and eco-design requirements placed on suppliers. Waste-related resource-outflow data (generated, diverted from and directed to disposal) is reported separately under the Waste breakout (E5-5-Waste, page 48).

Reference: page 48

Waste, metric tonnes (2024 / 2025):

Non-hazardous waste diverted from disposal rose to 1,808 tonnes (preparation for reuse 863, recycling 824, other recovery 121); hazardous waste diverted fell to 7 tonnes, entirely via other recovery options. Main streams are wood pallets, cardboard and WEEE. Waste data comes from external-operator portals and property-manager reports; no waste is sent to landfill, and the company does not handle radioactive waste.

Reference: page 51

Own-workforce principles sit in the Code of Conduct and Personnel policy, referencing the UN Universal Declaration of Human Rights, the Convention on the Rights of the Child, the ILO Convention on Fundamental Principles and Rights at Work, the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights.

The company does not tolerate human trafficking, child labour or forced labour, respects freedom of association and collective bargaining, and prohibits discrimination, harassment or unequal treatment on any of a long list of grounds (race, gender, disability, age, religion, etc.). No material impacts, risks or opportunities related to forced or child labour were identified, given operations are mainly Finland-based office/retail work with limited exposure outside Finland. Adequate rest, fair working conditions and compensation are upheld per policy.

Reference: pages 51-52

Engagement runs through daily interactions, an employee survey conducted 3-4 times a year, goal/development discussions, weekly newsletters, workplace communication channels, supervisor coaching, an internal idea box, and a diversity working group. Shop stewards and occupational safety representatives are present at each location, with quarterly discussions between the CEO, Chief HR Officer, selected Management Team members and employee representatives covering financial situation, workplace rules, workforce structure, skill development and well-being.

The company also holds a 2-4 times monthly status review between the HR manager and shop stewards, negotiates changes with employee representatives before implementation, and draws up an annual work community development plan with employee-representative input covering the whole workforce.

Reference: page 52

The primary contact for employee concerns is the immediate supervisor, with escalation available to the HR department or Management Team. Employees can also make anonymous reports through the reporting channel, and express views anonymously via employee surveys; separate channels exist for information-security and facility-security concerns.

The company supports reporting-channel use through mandatory annual training on the Code of Conduct and information security, plus supervisor-skills development, and has policies protecting users of reporting channels or complaint mechanisms from retaliation before any investigation begins. Mechanisms for identifying, reporting and investigating concerns are described more fully in the G1 Business conduct chapter (page 63), which the own-workforce channel also draws on.

Reference: pages 52-53

2025 actions: an occupational-safety campaign targeting a halved accident count; introduction of an accident-insurer near-miss reporting system; a new mental well-being programme (communication, webinars, supervisor training) alongside a work ability management system for supervisors supporting early response to reduced work capacity; a survey of harassment and inappropriate behaviour among customer-service staff, generating a follow-up action list; a language/cultural-competence survey assessing readiness to expand operating languages; and continued rollout of the job requirement classification system, now an established part of recruitment and performance management.

Resourcing equivalent to roughly one person-year supported skills development and diversity promotion, alongside continued equality and non-discrimination plan implementation and monthly diversity working group meetings. Effectiveness is monitored via personnel-survey KPIs and sick-leave/accident tracking.

Reference: pages 53-54

Targets (base year 2024, continuous annual monitoring unless noted):

All three KPIs declined and fell short of target in 2025. The company attributes this partly to the prior-year reorganisation and low store-operations staffing; well-being was affected despite increased supervisor support, and DEIB rose mid-year before falling in the final measurement. Targets are measured via the personnel survey and were set with employee-representative input; consistency with national/EU/international policy objectives was not specifically assessed.

Reference: page 54

Headcount by gender: men 429 (452), women 165 (163); total 594 (615).

Headcount by country: Finland 578 (597), China 16 (18) [combining mainland China and the Hong Kong office in the reported country table].

By contract type (2025): permanent 548, temporary 46; full-time 444, part-time 150; non-guaranteed-hours employees 0. All figures are numbers of persons at year-end, taken from a continuously maintained HR system; the decline versus 2024 reflects the overall headcount reduction from 615 to 594 employees.

Reference: page 54

At 31 December 2025 there were 237 non-employees (156 in 2024): 11 independent contractors (7) and 224 workers primarily from employment-activity companies (146), plus 2 interns (3). Temporary agency labour is used in supply chains, stores, and Customer Success/After Sales teams to cover sick leave and sudden workload increases, under practices agreed with employee representatives; the company's managerial responsibility for these workers follows the same practices and guidelines applied to its own employees. Figures come from a continuously updated HR system and do not vary significantly during the period.

Reference: page 54

Collective bargaining coverage for EEA employees (countries with over 50 employees representing more than 10% of total) falls in the 80-100% band, via the retail employers' association / service sector union agreement. As operations are Finland-only, no European Works Council, SE or SCE Works Council agreement was needed.

Turnover: 116 leavers in 2025 (162 in 2024), a turnover rate of 19.3% (25.5%). Fixed-term employment accounted for about 9% (9%) of the workforce, below the national level of 20% (21%, per Statistics Finland); main reasons for fixed-term contracts were seasonality (33%, 28%) and substitution (48%, 58%).

Reference: page 55

Top management by gender (unchanged both years): women 3 (37.5%), men 5 (62.5%).

Personnel by age group:

The workforce skews toward the 30-50 age band in both years, with a small shift toward the over-50 group and a decline in the under-30 share, consistent with the overall headcount reduction from 615 to 594 employees.

Reference: page 55

The company ensures all employees are paid wages meeting or exceeding the retail-sector collective agreement. This is delivered through company-specific practices: a 6.67% company-specific supplement above the table wage, uniform application of the capital-region salary level across all Finnish locations, and procedures favourable to employees regarding annual salary increases and training opportunities. No quantified adequacy benchmark (e.g. against a living-wage reference) beyond exceeding the sector's collective agreement is disclosed.

Reference: page 55

All of the company's employees are covered by social protection against income loss from major life events - illness, unemployment, work-related injury and disability, parental leave, and retirement - through a combination of public programmes and company-provided benefits. No gaps in coverage across the workforce are disclosed, and no breakdown by employment type or geography is provided beyond this blanket statement.

Reference: page 55

Average training hours per employee: women 7.5 (5.6 in 2024), men 7.9 (5.6) - training hours rose for both genders and the gender gap narrowed slightly. Hours are based partly on estimates and, where accurate data was unavailable, on an assumption of equal hours by gender.

Share of employees in regular performance/career development reviews: women 77% (88%), men 90% (94%) - both genders saw participation decline year on year. 2025 skill-development focus areas included work-life skills, supervisor training on employment-lifecycle processes, responsible recruitment, and a new work-life skills programme for knowledge workers.

Reference: pages 55-56

Fatalities: 0 (0). Occupational accidents: 18 (17), giving an accident frequency (all recorded accidents, per million hours worked) of 21.5 for 2025. The company separately reports an accident-frequency figure of 8.4 (10.3) covering only accidents resulting in sick leave, of which there were 7 in 2025; it notes the remaining accidents without absence were minor, requiring no first aid, doctor visit, work restriction or transfer.

Occupational disease cases: 0 (0). Workdays lost to work-related accidents: 18 (30). Employees covered by occupational health services: 100% (100%). China employees were included in the accident-frequency calculation for the first time in 2025.

Reference: page 55

Family-related leave entitlement: 100% (100%) of employees. Parental leave uptake among entitled employees: 16.4% (16.9%, restated). By gender: men who took family leave 16% (16%, restated from a previously reported 17.4%); women who took family leave 17% (19%, restated). The calculation method for the gender breakdown changed during the year, with comparative data updated accordingly to reflect the percentage of men/women who took leave out of all male/female employees.

Reference: page 55

Gender pay gap (Finland KPI): 1.8% (1.7%). The company separately discloses that the aggregated company-wide gap was 6.0% in 2025, which it says "does not reflect the actual situation" because it is distorted by the pay-level difference between Finland and China and the opposite gender balance between the two locations; the gap is mainly explained by specific individual roles.

Ratio of highest-paid individual to median employee remuneration: 10.7 (12.1) - a narrowing gap year on year. The 2024 pay-gap comparative carries noted uncertainty, as the calculation method was refined from Q3 2024 onward for closer ESRS alignment.

Reference: pages 55-56

No concerns were reported through the reporting channel in 2025 (2024: 0), by own workforce or other stakeholders. No serious human rights cases were identified (2024: 0), and no related fines, penalties or compensation were paid (2024: 0).

Some harassment cases not reported through the formal channel were handled through the company's normal processes during the year; the company states these were "not serious in nature" but does not disclose a count, as such cases are handled as part of normal HR work and are not included in reporting-channel statistics. All harassment, bullying and discrimination remain strictly prohibited under the Code of Conduct and Personnel policy, with confidential, impartial investigation procedures.

Reference: page 57

Value-chain-worker principles sit in the Code of Conduct and, in more detail, the Supplier Code of Conduct, built on the Amfori BSCI Code of Conduct (member since 2021). Coverage spans governance and supply-chain management, employee engagement and protection, the right to organise and negotiate, prohibition of discrimination/violence/harassment, fair wages, reasonable working hours, occupational health and safety, and prohibition of forced and child labour, with specific protections for young, migrant and seasonal workers.

The requirements guide operations toward the positive impacts and potential negative impacts the company has identified for value-chain workers, referencing the UN Universal Declaration of Human Rights, the Convention on the Rights of the Child, ILO conventions, OECD Guidelines and the UN Guiding Principles on Business and Human Rights, and apply to cooperation with partners in countries where labour and human rights protection is weaker.

Reference: page 58

Engagement with value-chain workers is indirect, through supplier representatives and, for suppliers manufacturing private-label products, third-party Amfori BSCI social responsibility audits that include employee interviews. Through audit observations and these interviews the company gathers information on employee rights and occupational safety, which under BSCI principles must be clearly communicated to workers in a language they understand.

The company's Chief Commercial Officer is responsible for ensuring this communication takes place and that results feed into company practice; operational responsibility for hearing value-chain workers via audit data sits with quality-assurance staff in the purchasing organisation, who are expected to maintain up-to-date expertise. The company does not specifically monitor value-chain workers' awareness of or trust in reporting channels.

Reference: page 58

Suppliers of private-label products in higher-risk countries (per Amfori BSCI risk classification and World Bank indicators) must provide evidence or consent to a BSCI audit or comparable third-party social responsibility audit before an order is placed, and prepare corrective action plans for significant findings; new orders are held until critical deficiencies are corrected. Amfori BSCI's grievance mechanism, required of suppliers and verified during audits, gives value-chain workers a route to raise concerns; suppliers must communicate it in a language employees understand.

Verkkokauppa.com's own reporting channel is also available to value-chain workers or their legal representatives, described in the Code of Conduct, with whistleblower-protection principles under the Whistleblowing policy. No zero-tolerance cases (e.g. child labour, forced labour, unsafe conditions) were identified through the Amfori BSCI programme during 2025.

Reference: page 59

Action: developing monitoring of supplier compliance (2024-2028, beginning of the value chain globally), aimed at ensuring purchases come from direct suppliers showing proof of adequate working conditions.

2025 activities: general procurement-process improvements (documentation, process descriptions), technical development of the supplier database, contract-management reform, defined performance evaluation and supplier-information identification; a new manager was recruited with responsibility for supply-chain regulatory and responsibility issues. This work did not require CapEx or significant OpEx. The company continued active supplier selection and evaluation, aiming to reduce supplier numbers to strengthen its ability to communicate and monitor sustainability goals, particularly for private-label and other direct-import value chains where its influence is greater.

Reference: page 59

Target: ensure purchases are made from suppliers providing proof of adequate working conditions (e.g. an approved social responsibility audit) - 100% of direct suppliers. 2025 result: not available; KPI reporting is planned to start in 2026, once technical development of the supplier database is complete.

The target wording was clarified in 2025 to require a valid, approved audit result be presented at the time of ordering. It is relative, scoped to direct suppliers at the beginning of the value chain, with no defined base year or value. Consistency with national, EU or international policy objectives was not specifically assessed.

Reference: page 60

Consumer policies sit in the Code of Conduct and, for privacy, the Data privacy statement / Information security policy, guided by internationally recognised consumer norms and the UN Guiding Principles on Business and Human Rights. The company treats and serves all customers equally and does not tolerate discrimination or harassment of customers; vulnerable persons are not specifically addressed in communications.

Data-protection compliance finding: in the reporting year the Helsinki Administrative Court upheld an administrative penalty imposed by the Data Protection Ombudsman, finding the company had failed to specify the retention period for online-store customer data as required under the EU Data Protection Regulation. The decision is not final; the company has applied for leave to appeal to the Supreme Administrative Court. Aside from this matter, the company was unaware of any adverse decisions on cases where UNGP/ILO/OECD standards were not followed.

Reference: pages 60-61

The company maintains constant, active direct interaction with consumers and end-users through customer service, social media, surveys and the sustainability barometer, feeding into strategy and target-setting (SBM-2). A year-end 2025 survey found 32% awareness among Finns of the company's one-hour deliveries.

Effectiveness of engagement is monitored through customer surveys, and customer-related incidents are tracked via customer-service contacts and the reporting channel, including any case where health or safety was compromised by a product-safety failure. The company continues developing delivery speed and accessibility (door-to-door and fast deliveries) as core engagement mechanisms promoting equal access across customer groups.

Reference: page 61

Consumers observing illegal activity or serious breaches of the Code of Conduct can contact company management directly or use the externally managed reporting channel, which allows confidential or anonymous reports in Finnish or English, under the misconduct-reporting policy and whistleblower-protection principles. The channel is not primarily intended for general consumer contact - customer service, social media and direct employee contact are the main low-threshold routes - but customer service is prepared to redirect a whistleblowing-type report there if needed. The company has not separately assessed how much consumers and end-users trust or are aware of the reporting channel.

Reference: pages 61-62

Actions table:

2025 work included completing an accessibility improvement project for the online store and support sites, based on a third-party accessibility assessment, and refining the compliance assurance process for private-label products (documentation review, third-party testing, shipment monitoring, self-monitoring, risk-based verification). Working time, OpEx and CapEx were allocated to fast-delivery and product-safety work, with additional resources in 2025.

Reference: page 62

Next-day delivery coverage: 80% of mainland Finnish households in 2025, against a 90% by 2028 target; the company assesses progress as on track, reflecting warehouse/order-processing speed and logistics-partner reach. The share of next-day-or-faster deliveries among all orders rose to 71% (65%).

Recalls: 0 (target: 0), achieved - no recalls of private-label or own-import products, and the company was unaware of any negligence in product-safety measures causing serious customer harm during the year. Neither target has a defined base year or value; stakeholder views fed into target-setting per the Stakeholder engagement table (SBM-2), though consumers were not specifically consulted.

Reference: page 63

The Code of Conduct, approved by the Board and applying to the entire workforce and management, sets principles on customer-oriented operations, communication, marketing, disclosure, personnel and corporate culture, partner cooperation, corruption/bribery prevention, human and labour rights, information security and privacy, environment, legal compliance, and the reporting channel; it is complemented by specific policies.

The company fosters a "bold, agile, and transparent" organisational culture, with culture-related targets and metrics tracked through regular employee surveys (reported under S1-5). It has not set separate results-oriented governance/control-structure targets under ESRS GOV-1.

Reporting channel: available via supervisor, HR, another appropriate contact, or an externally managed confidential/anonymous channel (Finnish or English); reports are handled by the CFO, HR Director and Legal Director, escalated to the CEO and Audit Committee, with a strict anti-retaliation policy.

Reference: page 64

Supplier collaboration practices are described in detail under S2 Workers in the value chain (due diligence in supplier selection, Supplier Code of Conduct, Amfori BSCI audits). For G1 specifically, the company states that environmental criteria were not a direct supplier-selection criterion in 2025, though it "recognises the importance of environmental criteria and plans to develop processes to better consider them in the medium term."

The company's procurement is described elsewhere (SBM-1) as decentralised, sourcing from well-known international electronics brands and wholesalers as well as smaller suppliers, none of which represents a significant share of any single supplier's annual production - a structure the company cites as limiting supply-chain concentration risk.

Reference: page 64

Corruption-prevention principles sit in the Code of Conduct and are specified in the Anti-corruption and anti-bribery policy, which the company states covers the key requirements of, and in its view complies with, the UN Convention against Corruption. The policy guides employees on accepting/giving gifts, hospitality, product loans and discounts, and participation in trips or sales competitions, and sets an approval process for these, alongside guidance on conflicts of interest and interactions with authorities.

Mandatory annual online Code of Conduct training covers 100% of functions identified as susceptible to corruption and bribery (procurement and corporate sales were identified as the most exposed functions); the Board did not receive this training. Corruption-related risks are additionally assessed annually by each department as part of risk management.

Back-filled from the G1 Business conduct chapter, where targets are addressed through MDR-T's effectiveness-tracking limb rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

The company discloses no measurable, outcome-oriented business-conduct target. The GOV-4 due diligence table (page 16) lists a "Targets (MDR-T, MDR-M)" row explicitly for E1, E2, E5, S1, S2 and S4 - G1 is not included, confirming no formal target-tracking structure exists for business conduct.

Consistent with MDR-T's alternative limb, effectiveness is tracked in the absence of a target: corruption-related risks are assessed annually by each department as part of risk management (page 64); mandatory annual Code of Conduct training covers 100% of functions identified as susceptible to corruption and bribery (page 64); and misconduct reports are centrally logged and escalated to the CEO and Audit Committee (page 63). Zero confirmed corruption cases were recorded in both 2024 and 2025 (G1-4, page 64), though a EUR 540,000 administrative fine for Anti-Money Laundering Act non-compliance was disclosed in 2025.

Reference: page 64

No cases, legal actions or investigations related to corruption were identified in 2025 (2024: none), and no lawsuits or judgments for violations of competition law, cartels or abuse of dominant market position were recorded (2024: none).

However, in 2025 the Regional State Administrative Agency for Southern Finland imposed an administrative fine of EUR 540,000 concerning the company's compliance with the Anti-Money Laundering Act for the period 1 September 2020 to 31 August 2023. Following the audit, the company states it has tightened its operating models and takes anti-money-laundering compliance "extremely seriously," actively participating in efforts to combat money laundering and the grey economy. This is a separate matter from the zero confirmed corruption/bribery incidents disclosed above.

Reference: page 64

Average time to pay an invoice: 47 days (57 days in 2024, restated from a previously reported 55 days) following a refinement in calculation principles that now bases the metric on invoices paid during the reporting year rather than by invoice date. The standard payment term in the company's general purchasing terms is 60 days net, assessed case by case for smaller suppliers, with specific payment dates and next-business-day payment when a due date falls on a weekend.

97% (95%) of payments were made within agreed terms, including invoices paid up to three days after the due date. The company treats all suppliers equally without distinct group categorisation, and had no pending legal proceedings related to late payments during the year.