E2 – Pollution

The BMW Group has implemented comprehensive policies related to pollution prevention and management across its operations and value chain.

Environmental Management Framework

Holistic Environmental Management

The BMW Group takes a comprehensive approach to environmental protection through robust environmental management systems and corporate responsibility practices that have upheld high standards for over fifty years. The Company pioneered sustainable business practices by appointing the first environmental officer in the German automotive industry over fifty years ago.

Site-Specific Policy Implementation

Environmental Assessment Requirements: All sites that require environmental assessment and approval under national law are subject to comprehensive pollution management policies, including:

• All production sites
• Component production facilities
• Research and Innovation Centre (FIZ)
• Test tracks
• Distribution centres

Risk-Based Approach: Sites with high risk and high level of damage potential are subject to specific measures to reduce potential environmental damage.

Pollution Prevention Policies

New Site Assessment

For new sites, the BMW Group implements systematic pollution prevention through:

• Environmental due diligence assessments
• Environmental impact analysis
• Climate risk assessments
• Baseline assessments of biodiversity (where required)

Risk mitigation measures derived from these assessments are implemented as required.

Existing Site Management

Certification and Monitoring: Sites with particular influence on business activities are subject to:

• Environmental impact assessments
• Case-by-case certification depending on risks involved
• Continuous monitoring and improvement measures

Technology and Process Policies

EfficientDynamics Integration: Environmental protection is integrated into product development through EfficientDynamics technologies that bring together:

• Highly efficient drivetrains
• Intelligent lightweight construction
• Optimised vehicle energy management systems

Air Quality Policies

Emissions Reduction

Fleet Emissions: Between 1995 and 2020, the BMW Group halved the CO₂ emissions of its new car fleet in Europe through commitment to efficiency technologies.

Advanced Fuel Support: Pollution reduction through support for cleaner fuels:

• B-series petrol engines approved for up to 25% ethanol (E25), reducing emissions by 20-45%
• B-diesel engines compatible with HVO100 fuel with 90% fewer carbon emissions
• 2025 pilot project: All diesel models produced in Germany filled with non-fossil HVO100

Technology Innovation

Electrification Strategy: Accelerating transition to zero local emission vehicles:

• 17.4% of 2024 deliveries were all-electric vehicles
• NEUE KLASSE development emphasizing efficiency and sustainability
• Planned hydrogen fuel cell variant for 2028

Water and Soil Protection Policies

Water Management

Material Topics Identified: The BMW Group's materiality assessment identified as material:

• Pollution of water
• Pollution of soil
• Microplastic pollution

Water Treatment Systems: The BMW Group is expanding water treatment systems to:

• Minimise fresh water usage
• Maximise efficiency
• Prevent water pollution through proper treatment of discharge

Soil Protection

Site Assessment: Environmental impact assessments include soil protection measures for all relevant facilities, with particular attention to:

• Manufacturing sites requiring permits under national environmental laws
• Sites with potential soil contamination risks
• Preventive measures for new construction projects

Supply Chain Pollution Prevention

Supplier Requirements

Due Diligence Enhancement: In 2024, responsibility for environmental due diligence in the supply chain was firmly embedded in purchasing strategy and strengthened through establishment of a dedicated department.

Supplier Code Compliance: The ↗ BMW Group Supplier Code of Conduct includes environmental protection requirements that suppliers must meet, including pollution prevention measures.

Raw Materials Management

Responsible Sourcing: The BMW Group's raw materials strategy includes pollution prevention considerations as part of responsible resource management integral to holistic corporate strategy.

Regulatory Compliance

Legal Framework Adherence

Pollution prevention policies ensure compliance with:

• Federal Immission Control Act (BIMSchG) in Germany
• Country-specific environmental assessment requirements
• Water Framework Directive 2000/60/EG and its guidelines
• National environmental permitting requirements

Environmental Statement

Comprehensive Assessment: The BMW Group Environmental Statement includes:

• Qualitative assessment of environmental impact of manufacturing technologies at various sites
• Assessment of other emissions topics where available
• List of material environmental effects for all technologies
• Indirect environmental effects (e.g., employee commuting)

Circular Economy and Waste Prevention

4R Principles

Pollution prevention through circular economy implementation following Re:think, Re:duce, Re:use, Re:cycle principles:

• Reducing consumption of virgin materials
• Minimising waste generation
• Closing material loops to prevent environmental releases
• Working with partners to integrate circularity into processes

Recycling Operations

Waste Management: Thousands of vehicles are dismantled and recycled using efficient methods annually at the BMW Group's recycling and dismantling centre, preventing pollution from improper disposal.

Monitoring and Continuous Improvement

Performance Tracking

Pollution prevention policies are monitored through:

• Regular environmental performance assessments
• Integration into sustainability reporting
• Board of Management oversight of environmental impacts, risks and opportunities
• Annual review and updating of environmental management systems

Innovation and Technology

Continuous Development: The BMW Group continuously invests in:

• Cleaner production technologies
• Advanced emission control systems
• Alternative materials and processes that reduce environmental impact
• Research partnerships for environmental innovation

These comprehensive pollution-related policies demonstrate the BMW Group's long-standing commitment to environmental protection across all aspects of its operations, from individual site management to global supply chain oversight, ensuring systematic prevention and management of pollution impacts throughout the value chain.

Pollution-Related Policies:

Danone has established comprehensive policies to address pollution prevention and management across its operations and value chain, integrated within its environmental management framework and Danone Impact Journey.

Environmental Protection Policies:

1. Operational Environmental Management:

• Strict environmental regulations compliance at all production sites
• Environmental standards implementation across 151 production facilities
• Energy use, water use, and waste management protocols
• Regular production site inspections for environmental protection

2. Air Quality Management:

• Emission reduction targets through renewable energy transition
• 50% renewable energy by 2030 reducing air pollution from fossil fuels
• Manufacturing process optimization to minimize air emissions
• Transportation efficiency improvements reducing logistics emissions

3. Water Pollution Prevention:

• Integrated water resources management programs
• Wastewater treatment standards at production facilities
• Water quality protection in watersheds where Danone operates
• Clean water access initiatives in communities

4. Soil Protection:

• Regenerative agriculture practices promoting soil health
• Chemical input reduction in farming systems
• Soil contamination prevention measures
• Support for organic and sustainable farming methods

Packaging and Waste Policies:

1. Circular Economy Approach:

• 100% circular packaging by 2030 (reusable, recyclable, or compostable)
• 30% reduction in virgin fossil-based packaging by 2030
• 4R strategy implementation (Reduce, Reuse, Recycle, Reclaim)
• Ellen MacArthur Foundation partnership on circular economy

2. Plastic Pollution Prevention:

• 21% reduction in virgin fossil-based plastic (2018-2024)
• Development of effective collection systems for plastic recovery
• Advocacy for UN Global Plastics Treaty with WWF
• Packaging design for pollution prevention

3. Waste Management:

• Production waste minimization programs
• Food waste reduction initiatives
• Packaging waste responsibility and management
• Recycling and recovery system development

Supply Chain Pollution Prevention:

1. Sustainable Sourcing Policy (SSP): Launched in 2024 with pollution prevention requirements:

• Environmental standards for suppliers
• Chemical use reduction in agricultural production
• Sustainable farming practice requirements
• Supply chain environmental performance monitoring

2. Agricultural Pollution Reduction:

• Support for regenerative agriculture reducing chemical inputs
• Farmer training on sustainable practices
• Integrated pest management promotion
• Biodiversity protection in agricultural systems

Chemical and Substance Management:

1. Product Safety Standards:

• Strict chemical safety protocols in product development
• Raw materials quality and safety requirements
• Packaging materials safety assessment
• Continuous monitoring of substance safety developments

2. Innovation for Pollution Prevention:

• Research & Innovation focused on cleaner technologies
• Alternative materials development reducing environmental impact
• Precision fermentation reducing resource intensity
• Biotech solutions for environmental performance

Regulatory Compliance:

1. Environmental Law Compliance:

• Comprehensive legal and regulatory monitoring
• Environmental permitting and authorization management
• Pollution control regulation adherence
• Proactive regulatory engagement on environmental standards

2. International Standards:

• ISO environmental management system implementation
• Global food safety initiative (GFSI) standards
• International environmental best practice adoption
• Third-party environmental certification participation

Stakeholder Engagement:

1. Community Relations:

• Environmental impact assessment and communication
• Local community engagement on environmental issues
• Transparency on environmental performance
• Collaborative environmental protection initiatives

2. Industry Collaboration:

• Industry partnerships for pollution prevention
• Best practice sharing and development
• Collective action on environmental challenges
• Research collaboration on pollution solutions

Policy Implementation:

• Environmental management systems at all facilities
• Regular environmental performance monitoring
• Continuous improvement programs
• Employee training and awareness programs
• Integration with business operations and strategy

Policies Related to Pollution

Pollution Prevention Policy Framework

GN has established policies to address pollution risks and impacts across its operations and value chain as part of its commitment to minimize negative environmental impact:

Product-Related Pollution Policies

Sustainable Design Policy:

• Focus on developing product designs that impact the experience of products, not the environment
• Integration of pollution prevention considerations into product development processes
• Compliance with growing product-related sustainability legislation
• Support for circular economy transition to minimize waste and pollution

Product Quality and Safety:

• Comprehensive quality management to ensure products operate without defects throughout lifecycle
• Centralized quality function enhances teamwork and ensures high-quality results
• Product security framework implementation to prevent environmental and safety risks

Manufacturing and Operations Pollution Policies

Manufacturing Standards:

• Implementation of pollution prevention measures across:
  • Central and regional manufacturing sites for hearing aids in Australia, China, Denmark, Japan, Malaysia, South Korea, Spain, and United States
  • Careful selection of manufacturers for enterprise and gaming products mainly in Asia
• Working with tier 1 manufacturers supported by more than 100 sub-suppliers on environmental standards

Supply Chain Environmental Standards:

• Integration of pollution prevention requirements into supplier selection and management
• Long-term strategic partnerships include environmental performance criteria
• Enhanced monitoring systems to track environmental performance across supply chain

Chemical and Material Management

Substances of Concern Management:

• Policies addressing substances of concern and substances of very high concern in products
• Compliance with chemical regulation requirements across global markets
• Material selection criteria incorporating pollution prevention considerations

Waste Management:

• Implementation of waste reduction and proper disposal practices
• Focus on resource efficiency and circular economy principles
• Balancing operations between different facilities to optimize environmental performance

Air, Water and Soil Protection

Emission Control:

• Policies to minimize air emissions from manufacturing and operations
• Integration with broader carbon reduction strategy achieving 58% reduction in scope 1 and 2 emissions
• Monitoring and control of industrial emissions across global facilities

Water and Soil Protection:

• Implementation of measures to prevent water and soil contamination
• Proper handling and disposal of potentially harmful substances
• Environmental management systems at key facilities

Regulatory Compliance

Multi-jurisdictional Compliance:

• Policies ensure compliance with pollution-related regulations across:
  • Global operations in 30+ countries with direct sales
  • Manufacturing locations across multiple continents
  • Distribution networks covering 100+ countries

Continuous Monitoring:

• Regular assessment of regulatory requirements and policy updates
• Integration of new pollution-related regulations into business processes
• Annual review of environmental policies and performance

Integration with Business Strategy

Strategic Integration:

• Pollution prevention integrated into existing business processes
• Board oversight through risk management framework
• Executive Leadership Team involvement in environmental policy decisions

Innovation and Development:

• DKK 1.9 billion R&D investment includes focus on sustainable technology development
• Research into cleaner production technologies and processes
• Development of products with reduced environmental impact throughout lifecycle

Stakeholder Engagement

Supply Chain Collaboration:

• Working with suppliers and manufacturing partners on pollution prevention
• Enhanced communication and problem-solving capabilities for environmental issues
• Integration of environmental requirements into partnership agreements

Customer and Community Engagement:

• Transparent communication about product environmental performance
• Response to growing stakeholder focus on environmental responsibility
• Sustainability-minded customer and employee attraction through environmental policies

These comprehensive pollution-related policies demonstrate GN's commitment to minimizing negative environmental impacts across its operations and value chain while maintaining compliance with global environmental regulations.

We follow strict criteria to mitigate pollution related environmental impacts and risks. Our focus areas for biodiversity management include pollution: We mitigate environmental impacts from pollution as required under the applicable environmental regulations.

Identifying chemical substances included in the various regulatory reporting schemes is becoming increasingly important. In 2024, we developed tools and data to manage the new EU Corporate Sustainability Reporting Directive (CSRD) requirements for reporting Substances of Concern. We also continued the work to ensure safe handling of chemicals at Neste to prevent hazardous exposure for workers.

Pollution Policies

Environmental Treatment Standards: We treat consumptive water, especially for active pharmaceutical ingredients in our manufacturing effluents, in compliance with all relevant regulations and pre-treatment standards, ensuring it returns to nature without harming the environment.

Regulatory Compliance: Reputational and legal fine/action risk due to non-compliance with water-related regulations or increased scrutiny on water usage affects the company's operations. We manage this through comprehensive compliance measures and monitoring systems.

Sustainable Product Development: Sustainable product innovations reduced waste and emissions across our value chain. We aim to minimise the impact of our products at every stage of their life cycle, contributing to pollution reduction.

Air Pollution Management: Pollution of air has been identified as one of our material environmental subtopics through our double materiality assessment, and we implement measures to address air quality impacts from our operations.

Our sodium-based SOLVAir® provides flue gas cleaning solutions that can remove up to around 99% of SOx, HF, and HCI emissions from exhausts in a range of sectors, including energy production and cement manufacturing. SOLVAir® Marine solution, designed for ships using heavy fuel oil, helps the marine industry reduce pollutant emissions, in line with international regulations.

Pollution-Related Policies:

Stora Enso has established comprehensive policies to prevent and minimize pollution across air, water, and soil:

Air Quality Management:

• Emission control policies for all production facilities
• Continuous monitoring of air emissions
• Investment in clean technologies to reduce particulate matter and other air pollutants
• Implementation of best available techniques (BAT) for emission control

Water Management:

• Water quality policies ensuring protection of water resources
• Wastewater treatment standards exceeding regulatory requirements
• Water efficiency programs to minimize water consumption
• Protection of aquatic ecosystems near operations

Soil Protection:

• Sustainable forest management practices preventing soil degradation
• Chemical management policies for forest operations
• Soil health monitoring in forest areas
• Restoration activities for disturbed areas

Chemical Management:

• Policies for safe handling and use of chemicals in production
• Substitution programs to replace hazardous substances
• Regular assessment of chemical risks
• Compliance with REACH and other chemical regulations

Waste Management:

• Circular economy principles to minimize waste generation
• Waste prevention and reduction policies
• Safe disposal and treatment of hazardous waste
• Material recovery and recycling programs

Implementation Framework:

• Environmental management systems at all sites
• Regular environmental monitoring and reporting
• Compliance with all applicable environmental regulations
• Integration with sustainability and climate policies
• Stakeholder engagement on environmental performance

Policies related to pollution

Pollution prevention commitment TKH is committed to minimizing pollution across our operations and value chain. We have implemented comprehensive policies to address air, water, and soil pollution risks.

Environmental management framework

• Operation in accordance with ISO 14001 environmental management standards
• Integration of environmental considerations in every business decision
• Regular assessment of pollution risks and impacts
• Implementation of prevention and mitigation measures

Pollution prevention policies

Air pollution

• Implementation of emission reduction programs across production facilities
• Investment in cleaner production technologies
• Monitoring and control of air emissions from manufacturing processes
• Regular assessment and optimization of emission sources

Water pollution

• Water consumption monitoring and management programs
• Implementation of water treatment and recycling systems where applicable
• Prevention of contamination in manufacturing processes
• Regular monitoring of water quality impacts

Soil pollution

• Assessment of soil impact risks at production facilities
• Implementation of prevention measures for soil contamination
• Proper handling and disposal of potentially harmful materials
• Regular environmental assessments at operational sites

Waste management and circular economy

• Waste reduction and recycling programs
• 75.2% recycling rate achieved in 2024
• Target: < 5% waste of most relevant raw materials (5.4% achieved in 2024)
• Design for recyclability and circular economy principles

Supply chain requirements

• Environmental standards for suppliers
• Assessment of pollution-related risks in supplier operations
• Active dialogue with strategic suppliers to improve environmental performance
• Integration of pollution prevention in procurement processes

Continuous improvement

• Regular review and enhancement of pollution prevention measures
• Investment in cleaner technologies and processes
• Monitoring and reporting of pollution-related performance
• External assurance on environmental reporting

Policies related to pollution

Air Quality Management Policy

Methane emissions reduction: TotalEnergies has implemented comprehensive policies to reduce methane emissions across four sources:

• Flaring reduction: Elimination of routine flaring by 2030, founding member of World Bank's "Zero Routine Flaring by 2030" initiative since 2014
• Vents management: Rerouting gas to export systems or flares, replacement of pneumatic equipment
• Stationary combustion optimization: Equipment efficiency improvements
• Fugitive emissions control: Continuous real-time detection systems and annual leak detection campaigns

Air emissions monitoring:

• OGMP 2.0 Gold Standard certification for 4th consecutive year
• AUSEA drone technology for methane detection and quantification
• Deployment of 13,000 sensors for continuous real-time detection by end 2025
• Regular emissions monitoring across all operated facilities

Water Protection Policies

Water management approach:

• Fresh water withdrawal monitoring: 92 Mm³ (ESRS perimeter)
• Implementation of water recycling and efficiency measures
• Protection of water resources in operational areas
• Discharge quality monitoring and treatment

Soil Protection and Waste Management

Circular economy initiatives:

• Priority given to waste and residues for biofuel production (>75% circular feedstocks)
• Used cooking oils and animal fats utilization avoiding first-generation biomass
• Refinery waste heat recovery projects (Le Havre district heating)
• Equipment recycling and modernization programs

Regulatory Compliance Framework

Environmental standards adherence:

• Compliance with local and international environmental regulations
• Proactive adoption of best available techniques
• Regular environmental impact assessments
• Continuous improvement approach to pollution prevention

"Our 5 Levers for a Sustainable Change" Initiative

Company-wide pollution reduction program:

1. Energy consumption minimization
2. Low-carbon operations deployment
3. Environmental discharges reduction
4. Community engagement
5. Employee care and commitment

Implementation approach:

• Engagement of all 102,887 employees
• Local action plans at 250 sites representing 94.4% of employees
• Workshop participation by more than 27,000 employees
• Site-specific objectives for 2025 achievement

Technology and Innovation for Pollution Reduction

R&D investment:

• 68% of $805 million R&D budget devoted to environmental solutions including methane, CCUS, water, and biodiversity
• Development of cleaner technologies and processes
• Digital solutions for environmental monitoring and optimization

Closed flare systems:

• Installation of closed flares to recover and treat waste gases
• First closed flare operational at Tempa Rossa facility in Italy
• Three additional projects approved in Angola and UK (160 kt CO2e/year reduction)

Industry Collaboration

Best practices sharing:

• Active participation in Oil & Gas Decarbonization Charter (OGDC)
• AUSEA technology sharing with 6 partners for methane detection
• Collaborate & Share program for pollution reduction solutions
• Support for industry-wide emission reduction standards

Actions and Resources for Pollution Management:

Danone has implemented comprehensive actions and allocated significant resources to address pollution prevention and management across its operations and value chain.

Operational Pollution Prevention Actions:

1. Production Facility Management:

• Regular inspections of 151 production sites for environmental compliance
• Implementation of strict environmental standards and protocols
• Waste management optimization across manufacturing operations
• Energy efficiency improvements reducing pollution emissions

2. Renewable Energy Transition:

• 50% renewable energy target by 2030 reducing air pollution
• Installation of renewable energy systems at production facilities
• Power purchase agreements for clean electricity
• Fossil fuel dependency reduction across operations

3. Water Management:

• Integrated water resources management in watersheds
• Wastewater treatment system improvements
• Water usage efficiency programs
• Water quality protection initiatives

Packaging Pollution Reduction Actions:

1. Plastic Reduction Achievements:

• 21% reduction in virgin fossil-based plastic (2018-2024)
• 11% total plastic packaging reduction (2018-2024)
• Alternative packaging material development and deployment
• Circular packaging design implementation

2. Collection and Recovery Systems:

• Development of effective collection systems for plastic recovery
• Partnership with recycling infrastructure providers
• Consumer education on proper disposal and recycling
• Extended producer responsibility program participation

3. Innovation in Packaging:

• Research & Innovation investment in sustainable packaging
• Biodegradable and compostable packaging development
• Recycled content integration in packaging materials
• Packaging optimization for reduced environmental impact

Agricultural Pollution Prevention:

1. Regenerative Agriculture Program:

• Moré Holstein farm B Corp™ certification (first in Europe, 2024)
• Farmer training and support for sustainable practices
• Chemical input reduction in farming systems
• Soil health improvement initiatives

2. Sustainable Sourcing Implementation:

• Sustainable Sourcing Policy (SSP) rollout in 2024
• Supplier environmental performance requirements
• Agricultural practice improvement programs
• Supply chain environmental monitoring

Resource Allocation:

1. Financial Investment:

• Capital allocation for environmental infrastructure
• Research & Innovation budget for pollution prevention technologies
• Partnership investments in environmental solutions
• Technology development funding for cleaner processes

2. Technology and Innovation:

• Biotech Open Platform investment with Michelin and partners
• Precision fermentation technology development
• Microsoft AI Academy for operational optimization
• Advanced analytics for environmental performance monitoring

3. Human Resources:

• Dedicated environmental teams at facilities
• Specialized expertise in pollution prevention
• Training programs for environmental management
• Cross-functional environmental working groups

Partnership and Collaboration:

1. Industry Partnerships:

• Ellen MacArthur Foundation strategic partnership on circular economy
• WWF collaboration on plastic pollution advocacy
• Global Methane Hub participation
• Industry consortium participation for environmental solutions

2. Supplier Engagement:

• Environmental requirements integration in supplier contracts
• Supplier training and support programs
• Collaborative pollution prevention initiatives
• Supply chain environmental performance monitoring

Monitoring and Measurement:

1. Environmental Performance Tracking:

• Regular monitoring of pollution prevention metrics
• Environmental impact assessment and reporting
• Third-party verification of environmental performance
• Continuous improvement program implementation

2. Technology Deployment:

• Environmental monitoring systems at facilities
• Automated pollution detection and prevention systems
• Digital technologies for environmental management
• Real-time environmental performance tracking

Regulatory Compliance Actions:

1. Legal and Regulatory Management:

• Comprehensive environmental law compliance programs
• Environmental permitting and authorization management
• Proactive regulatory engagement and advocacy
• Environmental risk assessment and mitigation

2. Standards and Certification:

• ISO environmental management system implementation
• Environmental certification program participation
• Best practice adoption from international standards
• Third-party environmental auditing and verification

Community and Stakeholder Engagement:

1. Local Community Programs:

• Environmental impact communication and engagement
• Community environmental protection initiatives
• Local watershed protection programs
• Environmental education and awareness programs

2. Transparency and Reporting:

• Environmental performance disclosure and transparency
• Stakeholder engagement on environmental issues
• Public reporting on pollution prevention progress
• External assurance of environmental data and performance

In 2024, we developed tools and data to manage the new EU Corporate Sustainability Reporting Directive (CSRD) requirements for reporting Substances of Concern. We also continued the work to ensure safe handling of chemicals at Neste to prevent hazardous exposure for workers.

New wastewater treatment units have been recently installed in Porvoo and Singapore. A new wastewater treatment unit is being completed at the Rotterdam refinery and will start operation with the expansion of the production unit.

Actions and Resources for Pollution

Water Treatment Infrastructure: We have established comprehensive water treatment systems for our manufacturing effluents, particularly for active pharmaceutical ingredients, ensuring compliance with all relevant regulations and pre-treatment standards before water returns to nature.

Sustainable Product Innovation: Sustainable product innovations have been implemented to reduce waste and emissions across our operations and value chain, minimising environmental impact throughout product lifecycles.

Compliance Monitoring: We have implemented monitoring systems to ensure compliance with water-related regulations and to address increased scrutiny on water usage. This includes additional measures, policies and programmes to meet regulatory requirements.

Investment in Pollution Prevention: Significant investments have been made in improving water efficiency and treatment infrastructure, particularly in water-stressed areas such as California, US, to minimise environmental impact.

Actions and Resources for Pollution Management:

Operational Actions:

• Implementation of best available techniques (BAT) across production facilities
• Continuous emission monitoring systems at all major sites
• Regular upgrades of pollution control equipment
• Process optimization to minimize pollutant generation

Technology Investments:

• Investment in clean production technologies
• Wastewater treatment facility upgrades
• Air emission control system improvements
• Implementation of closed-loop water systems where feasible

Chemical Management Actions:

• Substitution programs replacing hazardous chemicals with safer alternatives
• Enhanced chemical inventory and tracking systems
• Employee training on safe chemical handling
• Regular chemical risk assessments

Water Management Actions:

• Water efficiency programs reducing consumption
• Treatment system optimization for better water quality
• Monitoring of water bodies near operations
• Collaboration with local communities on water protection

Forest Management Actions:

• Sustainable forestry practices minimizing soil and water impacts
• Buffer zones around water bodies
• Selective harvesting techniques
• Restoration of sensitive areas

Resources Allocated:

• Capital investments in pollution control equipment
• Dedicated environmental management teams
• Regular environmental monitoring and testing
• Training and capacity building for environmental performance
• Collaboration with environmental experts and consultants

Compliance and Monitoring:

• Regular environmental audits and assessments
• Compliance with all applicable environmental regulations
• Third-party verification of environmental performance
• Transparent reporting of environmental metrics

Actions and resources related to pollution

Pollution prevention investments TKH has allocated significant resources to pollution prevention and environmental protection across our operations.

Operational pollution reduction measures

• Implementation of emissions and waste reduction programs
• Investment in cleaner production technologies and processes
• €15 million cost-saving measures including environmental optimization initiatives
• Facility consolidation to improve overall environmental efficiency

Environmental management systems

• Operation in accordance with ISO 14001 environmental management standards
• Regular environmental assessments and monitoring
• Implementation of environmental management systems across facilities
• Continuous improvement in environmental performance

Waste management initiatives

• Comprehensive waste reduction and recycling programs
• Achievement of 75.2% recycling rate in 2024
• Target achievement: 5.4% waste of most relevant raw materials (target < 5%)
• Investment in waste treatment and recycling infrastructure

Water management actions

• Water consumption monitoring: 116,821 m³ in 2024
• Implementation of water conservation measures
• Investment in water treatment and recycling systems
• Regular monitoring of water quality and usage efficiency

Supply chain engagement

• Supplier audits to assess sustainability-related risks, including pollution impacts
• 78.2% of copper suppliers assessed with 2024 risk management assessment
• Active dialogue with strategic suppliers to improve environmental practices
• Integration of environmental requirements in supplier selection and management

Technology and innovation investments

• €80.7 million R&D investment focusing on sustainable and cleaner technologies
• Development of environmentally friendly production methods
• Innovation in materials and processes that reduce pollution
• Design for environment principles in product development

Monitoring and reporting resources

• Regular environmental monitoring and assessment programs
• External assurance on environmental performance reporting
• Investment in environmental data collection and management systems
• Continuous improvement in environmental measurement and reporting

Pollution-Related Targets:

Danone has established specific targets for pollution prevention and reduction integrated within its Danone Impact Journey and environmental commitments.

Air Pollution Reduction Targets:

1. Renewable Energy Transition:

• 50% of energy from renewable sources by 2030
• Reduction of air pollution from fossil fuel combustion
• Decrease in scope 1 and 2 emissions contributing to air quality improvement
• Manufacturing process optimization for reduced air emissions

2. Transportation Efficiency:

• Logistics optimization reducing transportation emissions
• Supply chain efficiency improvements
• Alternative transportation methods deployment
• Carbon footprint reduction across distribution network

Plastic Pollution Reduction Targets:

1. Virgin Plastic Reduction:

• 30% reduction in virgin fossil-based packaging by 2030
• 50% reduction by 2040
• Continued progress from 21% reduction achieved (2018-2024)
• Alternative materials adoption and deployment

2. Circular Packaging Targets:

• 100% of packaging reusable, recyclable, or compostable by 2030
• Elimination of problematic plastic packaging
• Design for recyclability implementation
• Circular economy principles integration

3. Collection and Recovery Targets:

• Recover as much plastic as the Group uses by 2040
• Effective collection system development and leadership
• Extended producer responsibility enhancement
• Plastic circularity closing the loop

Water Pollution Prevention Targets:

1. Water Management:

• Water usage reduction across operations
• Wastewater treatment improvement targets
• Water quality protection in watersheds
• Zero discharge of untreated wastewater goal

2. Watershed Protection:

• Integrated water resources management in all operating watersheds
• Community water access improvement
• Water ecosystem preservation and restoration
• Local stakeholder engagement enhancement

Agricultural Pollution Reduction:

1. Regenerative Agriculture:

• Expansion of regenerative farming practices across supply chain
• Chemical input reduction in agricultural production
• Soil health improvement and contamination prevention
• Biodiversity protection and enhancement in farming systems

2. Sustainable Sourcing:

• Implementation of Sustainable Sourcing Policy (SSP) across supply base
• Supplier environmental performance improvement targets
• Agricultural practice transformation milestones
• Supply chain pollution prevention enhancement

Waste Reduction Targets:

1. Production Waste:

• Manufacturing waste minimization across facilities
• Zero waste to landfill goals at production sites
• Waste-to-energy and recovery system implementation
• Circular economy principles in production processes

2. Food Waste:

• Food waste reduction across value chain
• Supply chain loss minimization
• Consumer food waste reduction support
• Collaborative food recovery initiatives

Chemical Management Targets:

1. Substance Safety:

• Elimination of substances of concern from products and packaging
• Alternative substance development and deployment
• Chemical footprint reduction across operations
• Safer chemistry implementation in manufacturing

2. Product Design:

• Eco-design principles integration
• Life cycle assessment improvement
• Environmental impact reduction in product development
• Sustainable ingredient sourcing enhancement

Target Timeline and Milestones:

2025-2030:

• 50% renewable energy achievement
• 30% virgin plastic reduction
• 100% circular packaging implementation
• Sustainable sourcing policy full deployment

2030-2040:

• 50% virgin fossil-based packaging reduction
• Plastic recovery equivalent to usage
• Advanced regenerative agriculture implementation
• Zero waste to landfill achievement

Measurement and Monitoring:

1. Performance Tracking:

• Regular pollution prevention metrics monitoring
• Environmental impact assessment and reporting
• Third-party verification of pollution reduction progress
• Stakeholder transparency and communication

2. Continuous Improvement:

• Annual target review and adjustment
• Best practice adoption and scaling
• Innovation integration for enhanced performance
• Stakeholder feedback integration

Integration with Business Strategy:

• Pollution targets aligned with financial performance objectives
• Integration with Renew Danone strategic plan
• Resource allocation prioritizing pollution prevention
• Risk management integration for pollution-related risks

Other Emissions Targets

Hydro targets 50 percent reduction in material non-GHG emissions by 2030 against 2017 baseline, including:

• Sulfur dioxide (SO2) emissions: 50 percent reduction by 2030 against 2017 baseline
• Nitrogen oxide (NOX) emissions: 50 percent reduction by 2030 against 2017 baseline
• Particulate matter (PM) emissions: 50 percent reduction by 2030 against 2017 baseline

Hydro also has a fluoride performance target of 0.35 kg F / tonne aluminium for its fully owned smelters, by 2030.

Targets related to pollution

Waste reduction targets

Circular economy targets

Environmental management targets

Supply chain pollution reduction targets

Long-term pollution reduction goals

• Continuous reduction in waste generation across operations
• Improvement in recycling rates and circular economy implementation
• Enhancement of pollution prevention measures
• Integration of cleaner technologies in production processes
• Strengthening of supplier environmental requirements and assessments

Monitoring and improvement

• Regular review of pollution-related performance indicators
• Continuous enhancement of environmental management systems
• Investment in cleaner technologies and pollution prevention measures
• External verification of environmental performance and targets

Pollution of air, water and soil

Oil Spills

Total volume of oil spills (> 1 barrel): 2,815 barrels in 2024, compared to 12,719 barrels in 2023 and 5,628 barrels in 2022.

Breakdown by cause:

• Due to sabotage: 2,140 barrels in 2024, compared to 5,094 barrels in 2023 and 5,253 barrels in 2022
• Operational: 675 barrels in 2024, compared to 7,625 barrels in 2023 and 375 barrels in 2022

Air Emissions Data

Direct GHG emissions (Scope 1): 21.2 mmtonnes CO2eq. in 2024, representing direct air pollution from operations.

Direct methane emissions (Scope 1): 16.0 ktonnes CH4 in 2024, compared to 16.6 ktonnes CH4 in 2023 and 26.4 ktonnes CH4 in 2022.

Water Management

Freshwater withdrawals: 127 mmcm in 2024, compared to 109 mmcm in 2023 and 101 mmcm in 2022.

Re-injected production water: 51% in 2024, compared to 42% in 2023 and 43% in 2022.

Reuse of fresh water: 90% in 2024.

Pollution Prevention Measures

Eni is committed to protect the environment through the search for innovative solutions aimed at reducing the impact of its operations, ensuring efficient use of natural resources, the protection of biodiversity and water resources, and the promotion of development models based on regenerative principles of the circular economy.

Reporting Scope

KPIs refer to 100% of the operated assets, consolidated and unconsolidated, with reference to the operatorship criteria expressed in the standards of the Sustainability Statement. The 2023 and 2022 data are reported accordingly.

Pollution Management

SF6 Gas Replacement

The decarbonisation process continued with the reduction of Scope 1 and 2 (market-based) CO2 emissions mainly thanks to the progressive replacement of SF6 gas with a gas with a lower environmental impact.

Hexavalent Chromium Phase-out

Preparatory activities were started for the phase-out of hexavalent chromium from 84 production lines in line with the requirements of the European REACH regulation.

Waste Management

Target: % reduction in the amount of waste produced: -15% by 2030 (baseline 2019: 38,499 tons). Current progress: 32,555 tons (-15% vs baseline) - target achieved.

In 2024, we had 15 environmental permit violation cases at refineries (12), pre-treatment plants (1) and terminals (2) with limited local environmental impact. No serious environmental incidents occurred at Neste's refineries or terminals in 2024.

New wastewater treatment units have been recently installed in Porvoo and Singapore. A new wastewater treatment unit is being completed at the Rotterdam refinery and will start operation with the expansion of the production unit.

Detailed pollution data including air emissions, water discharges, and waste generation is provided in the Sustainability data package.

Other emissions (SO2, NOX and PM)

Target: 50 percent reduction in material non-GHG emissions by 2030 against 2017 baseline

A key driver for this improvement has been the replacement of heavy fuel oil with natural gas at the Alunorte alumina refinery.

Pollution of air, water and soil

Air pollution management TKH monitors and controls air emissions from our manufacturing operations as part of our comprehensive environmental management approach.

Air quality measures:

• Implementation of emission reduction programs across production facilities
• Regular monitoring of air emissions from manufacturing processes
• Investment in cleaner production technologies to minimize air pollution
• 70.3% reduction in CO2e footprint achieved, contributing to improved air quality
• Operation in accordance with ISO 14001 environmental management standards

Water pollution prevention Water quality protection is integral to our environmental management systems.

Water management initiatives:

• Water consumption monitoring: 116,821 m³ in 2024
• Implementation of water conservation and treatment measures
• Prevention of water contamination in manufacturing processes
• Regular monitoring of water usage efficiency and quality impacts
• Investment in water recycling systems where applicable

Soil protection measures TKH implements measures to prevent soil contamination at our operational sites.

Soil management approach:

• Assessment of soil impact risks at production facilities
• Implementation of prevention measures for soil contamination
• Proper handling and disposal of potentially harmful materials
• Regular environmental assessments at operational sites
• Compliance with local soil protection regulations

Pollution prevention through waste management

• 5.4% waste of most relevant raw materials (target < 5%)
• 75.2% recycling rate achieved in 2024
• Implementation of comprehensive waste reduction programs
• Focus on circular economy principles and design for recyclability

Integrated pollution prevention

• Operation in accordance with ISO 14001 environmental management standards
• Regular environmental monitoring and assessment programs
• Implementation of cleaner production technologies
• Continuous improvement in pollution prevention measures
• External assurance on environmental performance reporting

Substances of concern and substances of very high concern

ESRS E2-5 (Substances of concern and substances of very high concern) is not material for AMAG Austria Metall.

Materiality Assessment Result

As stated in the company's non-financial statement (p. 25):

"E2 - Pollution: microplastics, substances of (very) high concern" [are not reported for the 2024 financial year]

The company explanation (p. 25) notes:

"Substances of concern and substances of very high concern are not used in the main processes and for the manufacture of the main products."

Chemical Compliance and Management

Despite the non-materiality determination, AMAG has established comprehensive chemical management systems:

REACH Compliance: The company fulfils legal obligations under REACH and CLP Regulation through designated REACH officers at AMAG Ranshofen and environmental officers at AMAG components sites. Key activities include:

• Registration of metals contained in AMAG products
• Ongoing review of auxiliary and operating materials for changes to substance content
• Updates to the REACH candidate list, Annex XIV and Annex XVII
• Information transfer in the supply chain
• Provision of safety data sheets and technical data sheets via the AMAG website

Substance Exclusions: AMAG products do not contain:

• PFAS / PFAS compounds
• Microplastics
• Mercury (as an intentional substance; monitored as trace element)
• POPs / PFOA compounds
• Ozone-depleting substances (CFCs, halon)

RoHS Directive Compliance: Substances listed in Annex II are not manufactured, placed on market or used above specified maximum concentrations, with the exception of lead as an alloying element in aluminium up to 0.4% by mass (permitted under Annex III exception 6b). Small quantities of alloys with lead content >0.4% are produced on special customer request with appropriate safety information provided.

Conflict Minerals: No conflict minerals (tantalum, tin, gold, tungsten from DRC countries; extended: cobalt, micas) were purchased in 2024.

No quantitative data on total amounts of substances of concern or substances of very high concern has been disclosed, consistent with the non-materiality determination.

Substances of concern and substances of very high concern

Overview

Atos Group's manufacturing activities are primarily conducted by its Big Data and Security (BDS) Business Line, which produces supercomputers, servers, computing solutions, cybersecurity products (encryption solutions), and critical and embedded electronic and communication systems. The key manufacturing site is located in Angers, France, with some production in Aix-en-Provence.

Materials used in manufacturing

During 2024, BDS operations at the Angers plant used 1,421 tonnes of products and technical materials for manufacturing (845 tonnes with real data, 576 tonnes estimated). These materials include a range of substances, some of which are substances of concern.

The report identifies substances used in the manufacturing process, including:

Substances listed:

• Acids: Adipic acid, Azelaic acid, Benzoic acid, Citric acid, Dodecanoic acid, Formic acid, Hexanoic acid, Octadecanoic acid, Sebacic acid, Tartaric acid
• Metals and metal compounds: Aluminium oxide, Bismuth oxychloride, Bronze powder, Copper (Cu), Iron oxide, Lithium Manganese Oxide, Manganese dioxide, Silver (Ag), Tetramanganese tetraoxide, Vanadium, Zinc borate, Zinc compounds
• Organic compounds: Bisphenol A, Butanone, Dibutyl Sebacate, Epoxy resin, Hydrocarbons, Polyethylene glycol, Tripropylene glycol Diacrylate
• Other materials: Talc (containing no asbestiform fibers), Tetrahydromethylphthalic anhydride, Vanadium Phosphorus White

Regulatory compliance

The BDS activity complies with international regulations applicable to its manufacturing activities, including:

• European directives: Conformité Européenne (CE) standard
• REACH Directive: Registration, Evaluation, Authorization and Restriction of Chemicals, on eliminating pollutants
• RoHS Directive: Restriction of Hazardous Substances on eliminating hazardous substances
• Biocidal Products Regulation (BPR)
• ASHRAE standards: American Society of Heating, Refrigerating, and Air-Conditioning Engineers standards on maximum temperature and humidity for server functionality
• UKCA marking: United Kingdom Conformity Assessed marking (replaced CE marking on UK market since January 2023)

REACH and SCIP database compliance

From January 2021, in accordance with Article 33 of REACH regulations, companies are responsible for collecting information on the properties and uses of substances they manufacture or import above one ton per year. They must also assess the hazards and potential risks presented by the substance.

The reporting of substances of concern in the downstream supply chain is based on the list of declarable substances provided by the European Chemicals Agency (ECHA) and implemented in BOM (Bill of Material) check or Silicon Expert tools. This information is communicated to ECHA through a registration dossier (SCIP declaration in the ECHA SCIP database according to the EU waste framework directive) containing hazard information and where relevant an assessment of the risks that the use of the substance may pose and how these risks should be controlled. Atos complies with these regulations.

Conflict minerals

Since early 2013, Atos Group has embarked on a consultation process with its major suppliers on the origin of the raw materials they use, given the issue of "conflict minerals" and with the intention to prevent any use of these within the manufacturing process of BDS computers.

Supplier management

New partners are asked to disclose whether they have fundamental safeguarding practices in place regarding the protection of human rights within their own operations and supply chains during the onboarding process. This includes addressing health and safety risks related to raw material extraction or bad management of substances of concern.

The report notes: "Exposure of supply chain workers to health/safety risks related to raw material extraction or bad management of substances of concern" as a negative impact (ID 32) in the materiality assessment.

Packaging and plastic reduction

The BDS supply chain team tackles the reduction in the use of plastics in Atos packaging. Currently, Atos is investigating several solutions to reduce plastic usage in packaging. BDS clients are also offered services where packaging waste is collected upon delivery.

End-of-life management

Atos Group, as a producer, is responsible for the end-of-life of its products in accordance with the Directive 2008/98 (as modified by the Directive 2018/851) and the Directive 2012/19/EU (Waste Electrical and Electronic Equipment Directive – WEEE). This management is done at country level, according to local regulations.

In France, BDS supercomputer activity has joined, since 2013, a collective eco-organism certified by the French Ministry of the Environment (EcoLogic) to optimize the end of life of supercomputers sold to customers.

Data limitations

The report notes that data on materials used is only available for the Angers production site. Products manufactured in the Aix-en-Provence plant are not included in the calculation because this topic was not assessed as material until the double materiality conducted in 2024. The inclusion of data related to these products will be part of the action plan for 2025.

For 41% of products delivered to the Angers plant, no weight data was available from manufacturers or their transport providers; weight was estimated using an euros-per-kg ratio calculated from products where weight data was available.

Note: While the report provides extensive information on substances used in manufacturing and REACH compliance processes, it does not provide quantitative data on:

• Total tonnes of substances of concern (SoC) generated, used or procured
• Total tonnes of substances of very high concern (SVHC)
• Breakdown by hazard class (e.g. CMR, endocrine disruptor, PBT, vPvB)
• Amounts leaving facilities as emissions, products, or services

The disclosure focuses on regulatory compliance processes and the overall weight of input materials rather than specific SoC/SVHC tonnages.

Substances of concern and substances of very high concern

Management Approach

Barco actively manages environmental, health, and safety-regulated substances through a detailed Barco Regulated Substance List, which includes prohibited substances and those restricted to specific applications. This management process has been in place since 2014.

Product Compliance Requirements: Every component delivered by suppliers must meet Barco Product Compliance requirements, including compliance with worldwide regulations such as RoHS and REACH, ecodesign requirements, ERP, and SCIP. By implementing the Barco Substance List, the company goes beyond current legislation by restricting the use of specific chemicals or requiring declaration of specific substances.

Full Material Declarations (FMD): Barco collects applicable signed hazardous substance declarations of conformity for all active components, ensuring all components are covered by relevant compliance data. The collection of FMDs goes beyond what is required by regulation, allowing Barco to anticipate future regulations. In 2024, 84% of active components were covered by FMDs.

Do No Significant Harm (DNSH) - Pollution Prevention and Control: Since 2014, Barco has actively managed environmental, health, and safety-regulated substances by maintaining a detailed list of prohibited substances and those restricted in use to specific applications: the Barco Regulated Substance List. Barco has also implemented a management process for hazardous substances, ensuring compliance with relevant EU regulations and directives, thereby meeting the specified DNSH criteria.

Supplier Engagement: Barco provides training to suppliers on various sustainability areas, including environmental compliance and ecodesign. In 2024, the company focused on raising awareness about potential restrictions, current reporting obligations on PFAS/PFOS, and upcoming expiration of RoHS exemptions. The company actively discussed substitution plans and shared knowledge on where these substances may be present.

Circularity Context: The Technical Screening Criteria (TSC) for circular economy (CE 1.2) imply substitution requirements that are not realistic for Barco's industry. The company does not consider alignment with CE 1.2 for reporting year 2024 due to strict requirements concerning the use of hazardous substances.

Quantitative Data

Barco does not disclose total tonnages of substances of concern (SoC) or substances of very high concern (SVHC) generated, used, or procured in the reporting period.

Note

While Barco has established comprehensive processes for managing regulated substances and REACH compliance, including the Barco Regulated Substance List and FMD collection for 84% of active components, the company does not report quantitative tonnage data for substances of concern or substances of very high concern as expected under ESRS E2-5.

Substances of concern and substances of very high concern

Substances of concern or of very high concern may represent an integral component of the chemical raw materials used for production or of chemical products. To this extent, a portion of our products, which are key input products in further industrial or professional value creation or application, contain substances of concern or of very high concern. We address the safe handling and usage of chemical raw materials as part of our product safety. BASF understands product safety to be an integral part of all business processes, as an important element of our risk management and as an essential pillar of our commitment to Responsible Care®.

We continuously work on ensuring our products – including those that may contain substances of concern or very high concern – pose no risk to people and the environment when they are used responsibly and in the manner intended. A thorough safety and risk assessment enables us to serve markets with innovative and more sustainable products that meet regulatory requirements while still responding to trends.

We aim to comply with all relevant national and international laws and regulations. The guidelines, requirements, processes and responsibilities described above in this chapter under "Strategy and governance," also pertain to the handling of substances of concern and of very high concern.

We document and evaluate the safety, health and environmental information for our substances and products in a global database. We update this information on an ongoing basis. The database forms the basis for communicating this information via our safety data sheets, which we provide to our customers in around 40 languages. These include information on physicochemical, toxicological and ecotoxicological properties of products, potential hazards, first aid measures, measures taken in the case of accidental release and disposal. Our global emergency hotline network enables us to provide information around the clock. To ensure that people who buy, sell, use, transport or dispose of our products can quickly find information about the products and their associated hazards, we use the Globally Harmonized System (GHS) to classify and label our products around the world, provided this is legally permissible in the country concerned. We take into account national or regional adaptations within the GHS framework if applicable, such as the EU's regulation on the classification, labeling and packaging of substances and mixtures (CLP Regulation).

If necessary, we advise our customers on product safety. We set global requirements on the safe transport of dangerous goods for our logistics providers (see page 213). We also train our employees worldwide on the proper handling and usage of selected products with special hazard potential. In associations and together with other manufacturers, BASF supports the establishment of voluntary global commitments to prevent the misuse of chemicals. We are also involved at national and international level in various initiatives to further develop risk assessments, such as that of the European Centre for Ecotoxicology and Toxicology of Chemicals (ECETOC).

With such efforts, we aim to ensure that these substances or products containing these substances with very high hazard potential are safely handled and to ensure that impacts on human health and the environment can be prevented.

Substances of concern and of very high concern are subject to strict regulatory supervision, and the list of restricted substances with hazardous properties is continuously growing. When a substance is added to a regulatory list, this can change both the future availability of raw materials and the market behavior of customers and consumers. Normally, such changes are planned well in advance and transparently, allowing the industry to prepare by taking suitable measures, such as substitution planning or the implementation of derogations. Our proactive TripleS steering instrument, for example, makes a substantial contribution to planning a sustainable portfolio. A potential material risk for value chains, which would, however, not specifically affect BASF, could only arise in the event of an unforeseen proliferation of regulatory measures.

The substances of concern or of very high concern deployed by BASF in global value chains in the 2024 business year are stated in the following tables. As an integrated chemical company, BASF manufactures a broad portfolio of products, many of which are further processed by customers in the chemical industry. We handle the substances in our production appropriately and supply our customers with products that can be used safely if handled properly. As a B2B company, we market only a very small portion of our products directly to consumers and end users. The values listed in the tables also include multiple counts if several main hazard classes apply to a substance. The values therefore do not correspond to the total tonnages actually introduced into the downstream value chain.

Information about substances of concern (SoC) that are classified in one of the following hazard classes or hazard categories in Part 3 of Annex 4 of Regulation 1272/2008 (CLP Regulation)

Where components in a product/material are assigned to more than one main hazard class, the volume of components will be included in each hazard class, respectively. Emissions (separate reporting via environmental legislation) not included. Not yet implemented part of the EU regulation.

Information on substances of very high concern (SVHC) that correspond to the criteria pursuant to Article 57 and that have been identified pursuant to Article 59 (1) of the REACH regulation (EC) 1907/2006

Where components in a product/material are assigned to more than one main hazard class, as nominated in the candidate list, the volume of components in each hazard class will be included, respectively. Emissions (separate reporting via environmental legislation) not included.

Substances of concern and substances of very high concern

Material impacts

Beiersdorf has identified negative impacts related to substances of very high concern (SVHC) in the downstream value chain of the Consumer Business Segment. Some products such as deodorants may contain substances of very high concern. Use of such products may cause these substances to be released into wastewater and build up in the environment (medium-term potential negative impact).

Policies addressing SVHC

Beiersdorf has implemented several policies to manage substances of very high concern:

Standard Operating Procedure (SOP) Selection Criteria for Raw Materials (CBE.20003005.000.01)

This SOP outlines requirements for raw materials used in the manufacture of cosmetic and Over-the-Counter (OTC) products. Key provisions include:

• Raw materials must not contain substances prohibited by the EU Cosmetics Regulation or EU chemicals legislation (REACH)
• Unless exempted, raw materials must not contain substances listed in the "Candidate List of substances of very high concern for Authorization" published by ECHA
• The policy applies globally to raw materials intended for Beiersdorf cosmetic and OTC products, including those from third-party suppliers (excluding fragrance compounds, packaging materials, and La Prairie and Chantecaille products)
• Functions "Global Product Stewardship" and "Product Safety" within R&D are responsible for defining raw material requirements
• Progress is monitored through internal standard processes before final release and utilization of new materials in marketed products

Fragrance Restriction List

This policy ensures consumer safety by specifying allowed quantities of certain fragrance ingredients. Key features:

• Submissions must not contain substances listed in the ECHA "Candidate List of substances of very high concern for Authorization" at the time of the "Fragrance Briefing"
• Applies globally to all Beiersdorf AG fragrances and aromas used in products, including affiliates and contract manufacturers
• Managed by the internal Expert Team "Fragrances," led by the Manager for "Ingredient Compliance"
• Contractual agreements with fragrance houses ensure binding compliance
• Fragrance houses undergo intensive qualification processes and regular on-site visits to ensure compliance capabilities
• New fragrance creations require a "Fragrance Compliance File" with written and signed confirmation of compliance

Actions to reduce SVHC

Phase-out of cyclomethicone

• Cyclomethicone is a significant source of SVHCs (D5/D6) in the Consumer product portfolio, classified in the EU as very persistent and very bioaccumulative
• Phase-out was targeted by the R&D leadership team in April 2019
• Scope: entire Consumer Business Segment globally
• Timeline: completion for NIVEA and Eucerin products marketed in Europe by 2025, globally by 2030
• Progress: Compared to 2019, the annual volume of cyclomethicone has decreased by 64%

Environmental Performance Assessment Process

• Approved by R&D leadership team in February 2019 and in use ever since
• Includes ecotoxicological criteria and classifications for both new and existing cosmetic ingredients
• Ensures no new persistent ingredients enter the raw material portfolio
• Provides clear guidance for Environmental Assessment based on hazard data, with criteria including persistency, bioaccumulation, and aquatoxicity
• Scope: Consumer Business Segment, own operations globally
• The process has been actively used since 2019

Polymer reduction

• Beiersdorf evaluates all raw materials in terms of biodegradability based on Annex XIII of the European REACH Regulation and corresponding "Guidance on Information Requirements" (Chapter R.11)
• Goal: eliminate polymers that are not sufficiently biodegradable from European product formulations by the end of 2025
• Progress: In comparison with 2018, Beiersdorf used 69% fewer non-biodegradable polymers in European product formulations in the reporting year (base value 2018: 978 kt)

Assessment approach

The assessment of raw materials used at Beiersdorf covers both human and environmental toxicity as well as assessment in the context of applicable regulations. The main criteria for the identification of SVHC are evaluated in context with the requirements of the cosmetic product regulation and Beiersdorf's internal policies on human and environmental safety.

Quantitative disclosure

No quantitative data on total amounts of substances of concern (SoC) or substances of very high concern (SVHC) generated, used, or procured in tonnes is disclosed. No breakdown by hazard class is provided.

Substances of concern and substances of very high concern

The BMW Group has established processes to monitor and ensure legal compliance with prohibitions and limits relating to the use of chemical substances at the vehicle level. With regard to hazardous substances that fulfil the criteria of any of the classes or categories specified in Article 57 of the REACH Regulation (EC) 1907/2006 in accordance with the CLP Regulation (EC) 1272/2008 and which constitute at least 0.1% of the mass of the final product, the BMW Group has initialised a process to assess the extent to which these substances can be replaced with suitable alternatives.

Firstly, the points of the supply chain at which these substances are used were identified and assessed in a further step against the background of the state of the art and taking business, regulatory and technical concerns into account. If the use of these hazardous substances cannot be avoided, the BMW Group uses them under controlled conditions in accordance with hazardous material regulations.

Exclusion of problematic substances

All substances used by the BMW Group are in compliance with national and European laws. In addition, compliance with statutory prohibitions and limits on the use of chemical substances is monitored. Substitutes are sought for hazardous substances that are categorised as being of very high concern in accordance with Articles 57 and 59 of the REACH Regulation, provided they are used with a proportion exceeding 0.1% by mass in a mixture in the production processes, while taking factors such as economic and technical requirements into account. If such substances cannot be avoided, they are used under controlled conditions and in strict compliance with hazardous substance regulations.

To the extent possible, the BMW Group excludes the use of problematic substances right from the vehicle design stage and sets out corresponding stipulations for its suppliers. Guidance is provided in the form of the Global Automotive Declarable Substance List (GADSL).

Furthermore, the Company is committed to reducing exposure to emissions inside the vehicle to a minimum. All BMW, MINI and Rolls-Royce brand Automobiles are equipped as standard with interior air filters for pollutants and particles. Since 2020, the BMW Group has been using interior air filters equipped with nanofibre technology that not only trap fine dust, but also certain microbial particles and allergens.

Given that vulnerable people react particularly sensitively, the statutory requirements for potentially hazardous substances include children in particular. Therefore, complying with threshold values also regularly comprises the protection of children's health.

No quantitative data on total amounts of substances of concern or substances of very high concern in tonnes has been disclosed.

Substances of concern and substances of very high concern

E2-5 is assessed as not material by Cementir Holding and therefore no disclosure is provided in the 2024 sustainability statement.

As stated in the phase-in and materiality table (page 195), Cementir has determined that E2-5 (Substances of concern and substances of very high concern) is not material to its operations and has not disclosed quantitative or qualitative information regarding:

• Total amounts of substances of concern (SoC) generated, used or procured
• Total amounts of substances of very high concern (SVHC)
• Breakdown by hazard class
• Amounts leaving facilities as emissions, products, or services
• Narrative on monitoring and management (REACH compliance, etc.)

Substances of concern and substances of very high concern

Policies and Actions

Covestro uses chemical substances to manufacture products as starting materials for further processing in the value chain. Our products are used and transformed industrially in downstream processes. Their safe use and the provision of information to our customers are governed by law.

The reactivity and suitability of the substances are essential to achieving the desired product properties. The chemical substances used may result in properties which, in the context of sustainability reporting in accordance with ESRS, lead to classification as substances of concern (SoC) or substances of very high concern (SVHC). These properties also result in a potential negative impact in the downstream supply chain on people and the environment if employees are exposed to hazardous substances or if air, water, and soil are contaminated. Our actions to counter this potential negative impact are described in "ESRS S2: Workers in the Value Chain" under "Product Stewardship." The actions and policies described there comprehensively consider product-related hazards. This covers both the potential impacts of the substances of concern and substances of very high concern mentioned here and other potential hazards.

Apart from the above, Covestro does not have any dedicated policies to substitute and minimize the use of substances of concern and to phase out substances of very high concern, not even for essential societal purposes and in consumer products. This does not affect individual actions and optimization initiatives.

We identified a material risk for per- and polyfluoroalkyl substances (PFAS). PFAS are in the focus of public debate on account of their potential negative impacts on people and the environment. Covestro may be affected through the procurement of plant components and raw materials. We monitor the regulatory debate on PFAS and support proportionate, implementable, and enforceable regulations based on robust scientific results and a reliable risk assessment. To this end, we get involved in appropriate association activities and have established an internal interdisciplinary working group on this matter.

We include in our safety data sheets in the EU any PFAS that are classified as SVHC in accordance with REACH and are contained in our products at a concentration of more than 0.1% by weight.

Targets

In the future, we aim to produce and market more sustainable products. In this connection, it is essential to use SoCs or SVHCs on the basis of legal requirements. As described in "ESRS S2: Workers in the Value Chain" and in this section, we work continuously to provide information on the safe handling and use of our products in the value chain. Covestro does not set itself any specific targets for the procurement, use, manufacture, and placing on the market of SoCs and SVHCs in our production and products.

Metrics

The quantities shown below were recorded in a system-based approach. External procurement and sales volumes and the exact composition – including the hazard classification of the individual components at the reporting date – of our products and raw materials are documented in our IT systems. For the raw materials supplied externally, our internal information contains all the details on their composition available to us. The metrics reported here have been collated according to the best of our knowledge. To determine the quantities generated and used, we rely on the data from process orders or determine the reduction in inventories of the relevant materials compared to the previous reporting date. The metrics reflect SoCs/SVHCs carried in our inventory. This may lead to SoCs/SVHCs produced in situ not being recorded if they have been used up completely in the same production process and are not carried in our inventory. Due to the complex system and process landscape in the Group, specific micro quantities are not captured by the system-based calculation methods. They relate exclusively to quantities that have no influence on the figures presented in kilotons below. The volumes of emissions are likewise negligible and are therefore not included in the volumes reported.

The information contained in the table headed "Total quantity of substances of concern (SoCs) and substances of very high concern (SVHCs) in the reporting period" refer to the aggregate quantity of all quantities generated or used or procured by Covestro in the reporting period and to the quantities that left our facilities in the form of products, or parts of products.

"Allocation of substances of concern to the main hazard classes" includes exactly those substances in each hazard class which can be allocated to one of the hazard classes in accordance with the definition of SoC. As there are substances with more than one classification, i.e., they can be assigned to several hazard classes, some substances may be included more than once. As a result, the sum of the individual quantities may be larger than the total quantity.

Total quantity of substances of concern (SoCs) and substances of very high concern (SVHCs) in the reporting period

Allocation of substances of concern to the main hazard classes

Substances of concern and substances of very high concern

Policy and management approach

We avoid to the extent possible the use of substances of concern and substances of very high concern in our activities. This also applies to suppliers who work for us and throughout our value chain, for instance when we buy new trains.

The operation of diesel trains and the maintenance and preparation of trains are the activities primarily leading to consumption of substances of concern and very high concern.

Where avoiding the use of these substances is not possible, we seek to minimise the use. For this purpose, we have a process for approving chemical products to register and manage which chemicals are used in the company.

In addition, we carry out chemical risk assessments in relation to the activity for which the product is to be used, ensuring that we work in a structured manner to minimise our use of substances of concern and very high concern.

Quantities consumed

The consumption of substances of very high concern reflects DSB's consumption of refrigerants for trains (for engines – not air conditioning systems), and the consumption of substances of concern is related to DSB's consumption of diesel for traction operations, but also gear oil and refrigerants.

Table: Consumption of pollutants

Targets

We have developed processes to ensure that we assess and minimise the use of substances of concern and very high concern. Our diesel consumption, which is the primary driver of our emissions of substances of concern, is covered by our climate impact targets. We have no other targets for our efforts to limit the use of substances of concern and very high concern, nor do we expect to set targets for this.

Accounting policies

The calculation of substances of very high concern and substances of concern is based on extracts from DSB's chemicals database compared to extracts on purchased quantities of chemical products and consumption of diesel for train operations.

The calculation for substances of very high concern has been prepared for all relevant chemical products, whereas the calculation for substances of concern is based on a minimum consumption of 1,000 litres or 1,000 kilograms of the individual chemical products.

The calculation is made for January to September, and consumption in October, November and December is based on prior-year consumption.

Three selected suppliers have reported consumption of substances of concern.

Substances of concern and substances of very high concern

Approach and Methodology

Eramet has undertaken an initial mapping of raw materials and products used in its industrial processes, as part of its commitment to responsible management of the value chain and in compliance with the CSRD directive and ESRS standards. This approach focuses primarily on substances of concern (SoC) and substances of very high concern (SVHC), identified according to European regulatory frameworks.

The company, mindful of changing regulatory expectations and best practices in non-financial reporting, intends to expand this mapping in the coming years. The objective is to gradually expand its scope, in particular by integrating products outside the core business that could be used in secondary applications.

Substances of Concern (SoC)

A substance of concern (SoC) refers to any substance that may have negative effects on human health or the environment, and listed in Annex VI of the CLP Regulation. Appendix II of the ESRS, and more specifically Table 2, defines a substance as any chemical element and its compounds.

From a regulatory point of view, Eramet's finished products contain Nickel (Ni), which meets the criteria for a substance of concern (SoC). However, the Nickel ore present in the Group's operations is not a substance of concern as such, as it is a raw material integrated in a mineral matrix and not in an isolated chemical form. During the extraction phase, the Nickel ore has a low Nickel content (approximately 1%). Then, during the production phase, part of the ore is transformed into Ferro-Nickel (FeNi), used in various industrial applications. Another part of the ore is sold directly to customers in raw form, without further processing.

Nickel is a strategic metal with a wide range of industrial applications, including:

• Batteries and energy transition: A key element in Lithium-ion batteries used in electric vehicles and renewable energy storage. Demand for it is growing strongly with the global energy transition
• Stainless steel: Strengthens resistance to corrosion, essential for construction, infrastructure and automotive industries

As part of the CSRD requirements, Eramet assessed the amount of Nickel contained in ferroalloys and particularly in Ferro-Nickel (FeNi).

Nickel in Ferro-Nickel (SoC) - Quantitative Data

The data for the total quantities of Nickel that leave the Company's facilities in the form of discharge emissions are indicated in the previous section chapter on air and water pollution.

Substances of Very High Concern (SVHC)

Coal Tar Pitch is an essential component of electrodes used in silico-manganese, ferro-manganese and ferro-nickel production furnaces. When used in furnaces, Coal Tar Pitch breaks down, releasing hazardous substances, in particular Polycyclic Aromatic Hydrocarbons (PAHs), in industrial fumes.

Coal Tar Pitch (SVHC) - Quantitative Data

Management and Mitigation Measures

Coal Tar Pitch Management

Eramet is actively working on the continuous improvement of its filtration systems to minimize potential discharges, in particular by:

• Implementing strict measures to limit emissions related to the use of Coal Tar Pitch through advanced filtration systems that capture the emissions generated by the Group's furnaces
• Safely processing and storing dust from filtering to minimize any environmental impact

Aware of the challenges related to the use of Coal Tar Pitch, Eramet is also actively exploring more sustainable alternatives. Tests to replace Coal Tar Pitch-based electrodes with alternatives without this substance have begun in Norway. In 2024, 12% of our electrodes used are Coal Tar Pitch free.

Chemical Management Approach

Consistent with its commitments in terms of environmental and social responsibility, Eramet is committed to replacing substances of very high concern (SVHC) with less hazardous alternatives, while maintaining a high level of industrial performance and safety.

The Group's approach to chemical substances is based on:

• An analysis of the products used, ensuring a detailed understanding
• The proactive integration of regulatory requirements in terms of monitoring occupational exposures and assessing chemical risks, transforming them into a continuous improvement approach
• A life cycle analysis of products to improve understanding and limit the environmental and health impacts related to their transformation and end use

Data Limitations

Eramet acknowledges methodological limitations for substances of very high concern in its first-time ESRS application. The percentage of net turnover generated by products and services that are or contain substances of concern is compulsory for the 2027 reporting and is not yet disclosed.

Substances of concern and substances of very high concern

Policy and management approach

GN's Environmental Policy addresses pollution-related negative impacts in terms of substances used during both production in our own operations and outsourced manufacturing. Our policy commitments include compliance with all pollution-related legislation related to the use of substances of concern and very high concern, such as REACH and RoHS, and the substitution of substances with less harmful alternatives that can fulfil the same purpose, even when not legally required. This policy is supported by internal procedures on controlling and limiting the impact of incidents and emergency situations.

The implementation of these policy commitments is managed by senior management functions in our quality and legal functions. In support of achieving our policy intentions, we continuously evaluate and test performance to ensure compliance with legal requirements. Products that are manufactured in our own operations (hearing aids) are subject to medical regulatory requirements, which include obligations on material use. For products for which manufacturing is outsourced, all suppliers providing products or components to GN are required to complete a declaration of compliance to conform with our policies.

During 2024, all relevant suppliers have completed a declaration of compliance to show adherence to our policies in this area. This has enabled a better view of any high-risk areas in our value chain, as well as a better understanding of potential negative impacts relating to pollution of water, soil, and food, driven as a result of the use of hazardous substances.

Own operations actions

To support our policy objectives in this area, as well as moving beyond compliance with our internal policies through our health and safety processes, we phased out the use of dichloromethane as a cleaning agent in 2024, replacing it with a more effective and less harmful alternative.

As another action in 2024, at our manufacturing facility in Xiamen, we have significantly reduced our consumption of isopropyl alcohol (estimated annual reduction of 69% in liters consumed in 2024 versus 2023) by installing onsite recycling capability.

In 2025, we aim to work with stakeholders in our R&D, quality and legal functions to understand additional areas where we can take actions in substituting substances with less harmful alternatives throughout our production processes.

Value chain actions

As part of our policy objectives, a key focus is the continuous evaluation of compliance regarding the use of harmful substances by our suppliers. During 2024, all relevant suppliers have completed a declaration of compliance to show adherence to our policies in this area.

For products for which we depend on outsourced manufacturing, our focus is on phasing out halogens, specifically bromine, chlorine and fluorine. For Jabra products, we set requirements for suppliers and verify compliance through in-house testing. We expect to phase out bromine and chlorine in 2025 (where we have set a control limit that these substances cannot exceed 900 parts per million (ppm) individually or 1,500 ppm when combined) for flame-retardant parts, where phase out of these halogens in batteries will likely take longer. We have completed phase out of these substances for all other parts. We expect to phase out fluorine by 2026 for the same parts (where this substance cannot exceed 50 ppm).

Our current setup ensures compliance with our control limits but does not give us precise volumes of substances used in our value chain. With the aim of being able to report actual volumes in accordance with phased in data points in ESRS E2 for substance use in the value chain in future, we have commenced an action in 2024, running until 2026 to change our processes so that we obtain full material declarations from all suppliers for substances of very high concern.

Accounting policies

Total amount of substances of concern and substances of very high concern used in own operations

To report the total volume of substances of (very high) concern for production sites, we have collected usage or purchasing data for the substances that are in scope at our manufacturing sites in China, Malaysia, Denmark, and Spain. The total quantities used at these sites have been extrapolated to account for the remainder of our manufacturing sites where we have similar activities. Total amounts have been grouped by their respective hazard class as well as the level of severity within a given hazard class. All volumes are reported in litres. The metrics and use of substances of (very high) concern is externally verified at all sites and in accordance with local environmental legislation.

The hazard of a substance divides health, environmental and physical hazards into separate hazard classes such as reproductive toxicity, skin sensitization, carcinogenicity etc. The severity of the hazard within each class is described by the category. Some classes have five categories; other classes have only one category. Category 1 always represents the most severe hazard within that class. The higher the category number, the lower the severity of the hazard. Each substance can have more than one hazard class and several of the substances used will therefore be accounted for in more than one hazard class.

We include all substances used in the production process within our own operations, including any applicable substances which leave our facilities.

We will not report this metric for substances products or components for which manufacturing is outsourced, as these fall under the phase in provision given that these substances are added to components or products in our value chain. As such, our reported metric only includes substances added to products or components in our own operations, i.e., as part of manufacturing of hearing aids.

Quantitative data

Overview of substances of very high concern

*Refers to the REACH regulation and covers substances that have Persistent, Bioaccumulative and Toxic properties or substances that have very Persistent and very Bioaccumulative properties. Very small amounts of substances that has these properties, are used.

**Very small amounts of substances are used.

Overview of substances of concern

Substances of concern and substances of very high concern

The Group regularly monitors the legislative framework regarding substances of concern (SoC) and substances of very high concern (SVHC) to ensure compliance, minimize use, or phase out where applicable in own operations.

REACH Compliance

The Group ensures compliance with the REACH Regulation (EC) No 1907/2006 by utilizing only equipment designed and manufactured in alignment with EU safety and environmental regulations. All equipment used in the Group's transmission systems carries the 'CE' marking, which signifies conformity with applicable directives, including the RoHS Directive and REACH Regulation, which restricts SVHCs.

Polychlorinated Biphenyls (PCBs)

The Group does not use PCBs (polychlorinated biphenyls), which are banned in the EU under Directive 96/59/EC and classified as Substances of Very High Concern (SVHCs) under the REACH Regulation (EC) No 1907/2006. The Group ensures compliance by utilizing only equipment designed and manufactured in alignment with EU safety and environmental regulations. All equipment used in the Group's transmission systems carries the 'CE' marking, which signifies conformity with applicable directives, ensuring that SVHCs like PCBs are not present in any materials or components used in the Group's infrastructure.

Restricted Substances in Electrical and Electronic Equipment

The Group confirms that all equipment used to operate IT/OT data-driven solutions, which are limited to standard office equipment such as laptops and computers, does not contain the restricted substances listed in Annex II to Directive 2011/65/EU (RoHS Directive), except where the concentration values by weight in homogeneous materials do not exceed the maximum values listed in that Annex. All equipment bears the 'CE' marking, signifying conformity with EU safety, health, and environmental standards.

No quantitative data on total amounts of substances of concern or substances of very high concern generated, used, or procured is disclosed.

Substances of concern and substances of very high concern

Policies related to pollution

HUGO BOSS is dedicated to the conscious and safe use of chemicals, prioritizing both environmental and health considerations through its Chemical Management Policy. This policy outlines clear guidelines for the storage, use, and disposal of hazardous substances, aiming to minimize environmental impact and actively promote safer alternatives. It addresses key concerns such as preventing water pollution and reducing air and soil contamination by adhering to internationally recognized standards, including the Zero Discharge of Hazardous Chemicals (ZDHC) initiative, which HUGO BOSS joined in 2017. This initiative provides standardized tools to assess and enhance suppliers' chemical management practices.

A core element of this initiative is the ZDHC Manufacturing Restricted Substances List (MRSL), which identifies harmful chemical formulations that need to be phased out. The MRSL sets strict limits for critical process chemicals and supports efforts to monitor and mitigate water pollution. It forms an integral part of HUGO BOSS' supplier contracts, requiring all suppliers, including our own production facilities, to verify their chemical inventories against the MRSL.

To ensure that our products are free from harmful substances, we have established a Restricted Substances List (RSL) and Product Compliance Guideline. These comprehensive documents define product safety and marketability requirements, setting a clear framework for compliance throughout our supply chain. Our suppliers are required to adhere to our RSL, which strictly regulates substances in our products to ensure they meet the highest safety standards. It aligns with the recommendations of the Apparel and Footwear International RSL Management (AFIRM) Group, incorporating their substance lists, thresholds, and test methods for a structured approach to managing restricted substances.

HUGO BOSS extends the obligations of the MRSL and the RSL beyond its Tier 1 suppliers, mandating that upstream suppliers also comply with its standards, fostering collective commitment to product safety and sustainability.

Actions related to pollution

To reduce environmental impacts in production, we are collaborating closely with our suppliers and other businesses in the global apparel industry, including through initiatives such as the ZDHC. By adopting the ZDHC "Roadmap to Zero" framework, we have enhanced our ability to monitor and improve chemical management across the supply chain. Additionally, as a member of the AFIRM Group, we leverage their tools to maintain high standards of chemical compliance and product safety at every stage of production.

Recognizing the environmental risks posed by chemicals in products, HUGO BOSS eliminated the use of harmful per- and polyfluoroalkyl substances (PFAS) in production processes as early as 2018. This ban is now an integral part of our RSL and we remain committed to phasing out additional harmful substances and materials in the future.

To ensure our products are free from substances of very high concern (SVHC), we conduct regular monitoring through rigorous testing. Our Product Risk Database integrates third-party test reports for products, fabrics, and trimmings, enabling us to effectively track restricted substances and particularly focus on identifying and managing SVHCs. This proactive approach aims to ensure compliance with regulatory requirements while minimizing risks to consumers and the environment.

Targets related to pollution

HUGO BOSS is committed to ensuring that all Tier 1 and direct Tier 2 suppliers using wet processes meet the ZDHC MRSL reporting or an equivalent standard by 2030. We have set an interim target for all strategic Tier 1 suppliers using wet processes to meet the requirements by 2025. In 2024, 42% of the production sites in scope met the chemical inventory requirements (2023: 47%), including 65% of our strategic suppliers (2023: 67%). For wastewater tests, 62% of the production sites in scope complied with the specifications (2023: 58%), including 85% of our strategic suppliers (2023: 78%).

ESRS E2-5 status

According to the ESRS disclosure requirements index, ESRS E2-5 is marked as "not applied" in the company's reporting.

Substances of concern and substances of very high concern

Leonardo, whose business is at the end of the supply chain, is committed to managing chemicals and mixtures deemed harmful to human health and ecosystems through material procurement and supplier qualification stages. The management of such substances is complex both because of the stringent performance, safety and certification requirements of its products and because some hazardous substances are not universally identified as such in materials entering production processes.

Leonardo has identified the hazardous substances used in industrial processes, started a rationalisation of the substances purchased, in compliance with the restrictions and exceptions provided for by the REACH Regulation, and provided for mitigation plans for each division, as well as specific objectives for the reduction, and, where technically possible, the elimination of hazardous substances from products while also taking advantage of eco-design initiatives that make it possible to identify alternatives with lower impact right from the design phase. Substitution projects involve operating expenses that are incurred from essentially in-house sources. In addition, in some cases Leonardo collaborates, when useful, with third-party business partners to identify, develop and test together alternative solutions, including within the framework of national and European research and funding programs, and involves suppliers in the management of hazardous substances and compliance with REACH regulations through contractual clauses and training courses on the subject.

In compliance with the REACH Regulation and the RoHS Directive, Leonardo targets the reduction of the use of hexavalent chromium in processes for hard coatings of parts with high thermomechanical strength and a need for corrosion protection in very challenging environments. The Group has also started an analysis of PFAS (Per- and Polyfluoroalkyl Substances) in the supply chain, which are present in paints or insulation and elastic materials for a gradual reduction of their use in its processes and products. During 2024, the "Phase out of CrVI" project planned an investment of €mil. 6.86 for the complete substitution of hexavalent chromium with alternative substances in all of the Group's approximately 80 industrial processes by 2034, and the elimination or replacement of CrIV was achieved for some processes as early as in 2024.

Collaboration with stakeholders on the use of hazardous substances

ASD - Leonardo participates and leads the working group of the European Aerospace and Defence Association (ASD) on REACH and chemical substances, supporting the actions towards the European Commission and Parliament and the dialogue with the European Defence Agency (EDA).

AIAD (Italian Industry Federation for Aerospace, Defence and Security) - Leonardo also chairs AIAD's REACH Working Group to coordinate dialogue with the Italian Ministry of Defence and political counterparts.

MoD UK – Leonardo participates in the UK Ministry of Defence's Sustainable Procurement Working Group to share best practices in managing industry policies, including REACH regulations and GHG protocols.

ADCR - Leonardo participates in the Aerospace and Defence Chromium ReAuthorisation Consortium (ADCR), contributing to specific reports, including a socio-economic analysis in which it involved over 70 key suppliers that could be impacted by the substitution plans, in order to mitigate the risk of discontinuity in the business particularly linked to the substitution of some chromates with alternative solutions.

RINA-Centro Sviluppo Materiali – Within the working group on Critical Raw Materials, Leonardo has activated collaboration with RINA-Centro Sviluppo Materiali, one of the research and development partners, concerning alternative coating creation techniques, preferring chemical processes with reduced environmental impact.

Quantitative disclosure

Leonardo is equipped with specific tools for collecting and reporting information related to substances of very high concern (SVHC) and substances of concern (SoC) to ensure compliance with current regulations. In Leonardo, the use of these tools, combined with the strong working synergy, therefore allow a proactive assessment and management of the impacts on both health and environmental matrices, as well as, through appropriate mitigation plans, a minimisation of risks related to the use of these substances. Likewise, the Group requires its suppliers to comply with current regulations related to the use of these substances, enhancing these best practices towards end customers as well.

Substances of concern and substances of very high concern

E2-5 - Substances of concern and substances of very high concern

Substances of Concern (SoC) and Substances of Very High Concern (SVHC) represents the quantities of SoCs and SVHCs purchased for production processes and those leaving Lundbeck facilities as emissions or as product components. The majority of SoCs and SVHCs leave Lundbeck's facilities as emissions, including liquid waste, which are treated using either internal technologies or specialized external partners. Only about 1% of these substances that are purchased by Lundbeck exit the facilities as product components.

Lundbeck uses three substances as part of its products. Opadry contains titanium dioxide, which is classified as carcinogenic in its powdered form but is converted into a non-carcinogenic liquid form during tablet coating. An EU Court ruling is pending to provide further clarification on its status. Vortioxetine is classified as a skin sensitizer, though it does not come into direct contact with the skin due to its coating, and it has potential long-term impacts on aquatic ecosystems. Aripiprazole has properties that may affect fertility, pose risks to unborn children, and is suspected of being carcinogenic. Lundbeck remains committed to product safety and environmental responsibility, ensuring that all products and processes are managed responsibly.

Accounting policies

Substances of concern and substances of very high concern development

Substances of Concern (SoCs) at Lundbeck are defined based on the criteria outlined in the annex to the Commission Delegated Regulation (EU) supplementing Directive 2013/34/EU. A substance qualifies as an SoC if it meets any of the following criteria: (1) It is identified under Article 57 and Article 59(1) of Regulation (EC) No 1907/2006. (2) It falls within specified hazard classes, including carcinogenicity, reproductive toxicity, endocrine disruption, or persistent and toxic properties. (3) It negatively impacts the reuse and recycling of materials, as outlined in relevant ecodesign requirements. Substances of Very High Concern (SVHCs) are those that meet the Article 57 criteria of REACH and are identified under Article 59(1). SVHCs include carcinogenic, mutagenic, or toxic substances (CMRs) classified as category 1A or 1B, persistent bioaccumulative and toxic (PBT) substances, very persistent and very bioaccumulative (vPvB) substances, endocrine disruptors, or other substances of equivalent concern.

The scope of reporting includes all Lundbeck entities; however, the use of SoCs and SVHCs is specific to the production and R&D sites. The SoCs and SVHCs used in Lundbeck's production processes are collected from the internal chemical register, and the amounts of SoCs and SVHCs are gathered from the quantities of purchased substances recorded in SAP.

The SoCs and SVHCs used in production processes leave the company's facilities either as emissions or as part of products. The amount of SoCs and SVHCs that leave as emissions is estimated based on the assumption that the majority of hazardous substances exit as hazardous liquid waste, which is treated by external partners using advanced filtration technologies. Consequently, a 95% reduction factor is applied to the quantities purchased (i.e., used in production processes) to estimate the amount of SoCs and SVHCs leaving Lundbeck facilities as emissions. The amount of SoCs and SVHCs that leave as products or as part of products is estimated using an input-output approach, which assumes that the quantity purchased equals the quantity exiting as part of products.

Substances of concern and substances of very high concern

Metrics

Reporting principles

Chemical substances

The substance is a substance of concern (SoC) if it:

• Is a Substance of Very High Concern (SVHC) as identified in accordance with the EU REACH Regulation and added by ECHA to the candidate list for authorization (subsection i. in the definition of SoC in EC 2023/2772);
• Has harmonized classification in Part 3 of Annex VI to CLP Regulation with one of the hazard classes or hazard categories declared in the subsection ii. in the definition of SoC in EC 2023/2772;
• Has negative effects on reuse and recycling according to the EU product-specific ecodesign requirements. Ecodesign for Sustainable Products Regulation (ESPR) entered into force in July 2024, and it establishes a framework for setting ecodesign requirements on specific product groups.

Chemical substances are identified by the CAS/EC number that is declared in the SVHC list and in Annex VI to CLP. Neste has introduced CAS/EC numbers of the chemicals in the ERP systems so that substances of concern can be screened and amounts calculated.

None of the chemicals Neste supplies as feedstock or manufacturers is listed in the SVHC list by ECHA. However, many of the petroleum products are included in the Annex VI to CLP due to harmonized classification of health effects such as carcinogenicity. Majority of the reported amounts are from substances that are hazardous to health because there is no harmonized environmental classification in CLP Annex VI e.g., for petroleum products. However, petroleum products have properties that are hazardous to the environment and thus self-classified to indicate the environmental hazards. The self-classification is declared e.g., in the safety data sheets.

Emissions

Production sites shall evaluate SoC emissions that are identified as significant in accordance with their environmental permits or other authority or legal requirements. The main reference for the identification is the Annex II of the Industrial Emission Portal Regulation (EC) No. 2024/1244, which also covers the most significant SoC/SVHC polluting substances.

In 2024, Neste reports the total amount of substances of concern that leave its refineries as emissions to the environment and that can be identified with certainty, for example based on the CAS number. The reporting refers to the Annex II of the EU's Industrial Emissions Portal Regulation (2024/1244) and focuses on those substances that exceed the threshold values of the aforementioned Regulation for air, water and soil. In terms of air emissions, reported pollutants are carbon monoxide (over 95% of total reported SoC emissions) and benzene. Carbon monoxide is formed in the combustion processes, but upon entering the atmosphere, it oxidizes further into carbon dioxide, which is not classified as a SoC. Less than 0.1% of total SoC emissions (such as phenol, nickel and zinc) end up in water courses. These emissions have not been found to have a significant impact on, for example, the state of receiving water bodies.

Benzene has been identified and reported as the most significant SoC substance of NMVOC emissions at the Porvoo refinery. Neste is aware that other SoC substances can potentially also be present in NMVOC emissions. The total NMVOC of oil refineries is calculated as total carbon and the exact composition has not been reported. As the reporting definitions become more precise and the general knowledge base accumulates, the reporting of SoC emissions will be re-evaluated.

Validation by an external body other than the assurance provider

Neste is subject to annual environmental authority inspections and conducts emission reporting to competent authorities in the EU. Neste shall annually report to its competent authority data on the releases to air, water and land of any pollutant listed in IEPR Annex II for which the applicable threshold specified in that Annex is exceeded. The authorities assess the quality of the data, in particular the accuracy, completeness, consistency and credibility. This process is based on the requirements of the Industrial Emissions Portal Regulation (IEPR).

In Singapore the national water agency (PUB) regulates the sewerage system, as well as the treatment and discharge of industrial wastewater into public sewers. The industrial wastewater from the Singapore refinery is discharged to these sewers. If necessary, they must be treated to specified standards before being discharged into a sewer.

Management approach

Substances of concern are recognised and tracked in Neste's internal IT systems. There are a variety of existing regulatory requirements in place for notifying manufactured and imported chemicals and their yearly volumes to the national authorities. By managing these and many other EU and national requirements Neste has gathered depositories of data on hazardous chemicals. Reporting substances of concern as defined in the ESRS are managed together with the work related to these regulatory requirements. Neste continues to develop accounting of substances of concern for CSRD reporting.

Through the implementation of the Neste OEMS, the company aims to ensure that product compliance and chemical safety hazards are effectively managed in its operations. The OEMS includes the Neste Product & Chemical Safety Principle, which outlines mandatory chemical legislation requirements and their handling across its operations. It covers the mitigation of material risks related to Neste's use and processing of substances of concern. Neste is dedicated to product and chemical safety, ensuring compliance with regulations, minimizing risks, and fostering a sustainable approach to chemical management.

The Product & Chemical Safety Principle mandates the identification of substances of concern. Neste is actively working towards substituting chemicals with less harmful alternatives where possible and increasing the use of renewable raw materials and products. This shift towards renewable resources is key in gradually reducing the presence of substances of concern in Neste operations.

Neste carefully follows and takes due care in implementing various chemical compliance and safety regulations, like the EU REACH and CLP Regulations, that aim to ensure a high level of protection of human health and the environment. Part of Neste's revenue is based on manufacturing and selling products that contain substances of concern – chemicals like transportation and marine fuels.

Substances of concern and substances of very high concern

Management approach

Hydro's global procedures for health risk management and environment management require all operational sites that are fully owned or operated by Hydro, identify, risk assess, minimize, evaluate for substitution and appropriately manage all hazardous materials or substances, purchased or generated in its processes, that have the potential to cause ill health, or to negatively impact the environment.

Hydro's products are subject to compliance declarations according to different EU and U.S. legislations. This includes registration, evaluation, authorization and restriction of chemicals (REACH) and restriction of hazardous substances (RoHS) in the EU, and the Toxic Substances Control Act and California's proposition 65 in the U.S. This gives Hydro's customers assurance that its aluminium profiles do not contain the prohibited substances above the defined limits.

Stakeholders and potentially affected communities can use AlertLine as a communication tool to report environmental and social issues concerning Hydro operations.

Quantitative disclosure

There is significant uncertainty in the data reported. Hydro's interaction with SoC and SVHC are primarily as part of mixtures, such as paints and solvents used in surface treatment of extruded aluminium profiles, cold tar pitch used for anode production, and cryolite bath used in primary aluminium.

Substances are reported as the sum of mixtures containing SoCs and SVHC, by main hazard classes, based on the amount of the mixtures used in the reporting year. Data on contents per mixture is not available at a consolidated level, and many substances are classified in several hazard classes. The sum of the substances reported by hazard class, below, therefore does not reflect total mixtures containing substances that are generated or used in production activities.

Substances used in non-production activities, such as construction, maintenance and repair, research and laboratory, and other substances used in quantities below one tonne per year, are not included.

The majority of reported mixtures containing SoC and SVHC are procured for use. The majority of mixtures reported are used for anodizing, painting, powder coating and other surface treatment of extruded aluminium profiles, anode production, or manufacture of primary aluminium.

Substances of concern and substances of very high concern

Policies

Novo Nordisk's environmental policy states our commitment to handling chemicals safely and striving to avoid the use of harmful chemicals, when developing or designing new products and processes. Our screening of harmful chemicals applies to both in-house and outsourced product development processes. For treatments already on the market, we strive to minimise the use of these chemicals and substitute them where possible.

All of Novo Nordisk's production facilities are ISO 14001 certified for environmental management and thus mitigate, control, and prevent negative environmental impacts, including pollution-related incidents and emergency situations. We reuse chemicals where possible and ensure the best possible handling of hazardous waste and emissions. We also ensure compliance with the terms of the environmental permit for each production site. In case of breaches of regulatory terms, we register an environmental non-conformity, investigate, and implement corrective actions.

Actions

We work with several innovation projects in both our own and outsourced production processes to reduce the environmental impacts of our products on an ongoing basis.

Key action: Reducing chemicals in production and medicines - Recurring action to minimise the use of specific chemicals in production processes through substitution or purification for reuse, and to optimise efficacy of medicines with lower chemical use. Scope: In-house and outsourced production processes. The use of relevant chemicals is tracked through environmental assessments at production sites and during product design and development processes to monitor effectiveness.

Performance

We continuously track our use of chemicals through various internal KPIs and environmental assessments to ensure that we mitigate negative impacts on the environment or human health.

A total of 2,304 tonnes of SCs and SVHCs were procured in 2024. Most of their use is linked to solvents used in the production of our API. We are seeking to reduce the use of these chemicals through substitution initiatives or purification for reuse. During the production process, almost all of SCs and SVHCs are collected as waste and handled safely in accordance with our policies and any relevant regulations.

The remaining substances, leaving Novo Nordisk in the form of emissions or as part of products, were estimated to be 11 tonnes of SCs and SVHCs during 2024. SCs leaving our facilities as part of our products make up 5 tonnes, and originate primarily from one substance used as an excipient in extremely low concentrations to preserve our medicines. The remaining SCs and SVHCs leave our facilities as emissions to air and water. In 2024, this amounted to approximately 5 tonnes of SCs and 1 tonne of SVHCs, primarily linked to the production of API. The reported volumes of SCs and SVHCs leaving our facilities are within regulatory limits.

In addition to the disclosures above, we also report in accordance with the European Pollutant Release and Transfer Register.

Quantitative disclosure

Note: If a material belongs to more than one main hazard class, the weight of the substance is reported in both hazard classes. Consequently, the sum of the sub-categories exceeds the total.

Accounting policies

The figures reported are manually calculated from the available data and are subject to significant uncertainty. The weight of substances is calculated according to their concentration in the material. If information on concentration is not available, the assumption is that 100% of the material consists of substance(s) in scope. Consequently, certain metrics might be overestimated. The scoping of the materials included in the calculations may not be exhaustive.

Main hazard classes: Defined by chemical subject matter experts, based on the specific hazards they present and includes following hazard class codes: Human health hazard (hazard class code H3xx or EUH3xx), environmental hazard (hazard class code H4xx or EUH4xx or EUH059) and physical hazard (hazard class code H2xx or EUH2xx). If a material belongs to more than one main hazard class (human health and environmental hazard) the weight of the substance is reported in both hazard classes. Consequently, the sum of the sub-categories exceeds the total. Main hazard classes are not applicable to SVHCs.

Total weight of substances of concern/substances of very high concern: Comprise the total weight of substances procured into production, categorised into main hazard classes. Data sources include receipts of materials and purchase orders mapped against a chemical database indicating hazard class.

Amount of substances of concern and substances of very high concern that leave facilities as emissions: Total weight of SCs and SVHCs that leave production sites as emissions to air or water, split into main hazard classes. The estimated volumes of substances are based on available data for our API production and estimated for Chemistry, Manufacturing and Control (CMC) processes. Laboratories were deemed immaterial and are not in scope. Novo Nordisk Pharmatech A/S will be included from 2025.

Amount of substances of concern that leave facilities as products or part of products: Total weight of SCs and SVHCs that leave Novo Nordisk as products or part of products split into main hazard classes. Products or parts of products are defined as either excipients or devices. Data sources include production data (with final product quantities), bills of materials and purchase orders mapped against a chemical database indicating hazard class.

Substances of concern and substances of very high concern

Materiality assessment

[ESRS 2-IRO-2.58] Substances of concern and substances of very high concern are not material for OMV because of the low likelihood of incidents due to high process safety standards, prevention of contamination and strict regulatory requirements. This assessment is based on data and information such as incident data, as well as, taking EU legislation into account. Furthermore, regulatory conditions (e.g., permits, inspections) and mitigation measures are also in place and governed by Seveso requirements at all locations. All our produced and purchased products are certified, and safety datasheets are publicly disclosed on our website.

[ESRS 2-IRO-2.59] The first Sustainability Statement prepared in accordance with CSRD and ESRS includes the minimum disclosure requirements as specified by ESRS 2, as well as the mandatory reporting requirements for the initial year. Based on the materiality assessment results, we analyzed the materiality for all disclosure requirements. The detailed process is described under IRO-1-53a/b. Consequently, all disclosure requirements and data points related to topics and sub-topics identified as immaterial during the materiality assessment have been excluded from this statement.

Policy approach

[E2-1.15b] As part of our commitment outlined in the Code of Conduct, we are dedicated to substituting hazardous substances with less hazardous alternatives where reasonably practicable. To support this effort, processes should be designed, modified, and applied to minimize the production and use of hazardous substances, including the reduction of hazardous byproducts or waste, as well as minimizing quantities or concentrations for handling and storage.

The Environmental Management Standard stipulates that all OMV businesses and activities must understand the impacts of their air emissions on local and regional ambient air quality. The OMV Environmental Management Standard requires that all relevant OMV businesses and activities implement an Environmental Management System (EMS) consistent with ISO 14001.

Management of hazardous substances

The Management of Hazardous Substances Standard provides requirements for the management and treatment of waste, including hazardous substances. Where existing local, regional, or national waste management facilities are inadequate, OMV supports third parties in developing their capabilities.

All our produced and purchased products are certified, and safety datasheets are publicly disclosed on our website. The general principles for environmental management at OMV include complying with all applicable environmental laws and regulations, and observing internationally accepted best practice industry guidelines, for instance the International Standards Organization (ISO), the International Association of Oil & Gas Producers (IOGP) and the global oil and gas association for advancing environmental and social performance across the energy transition (Ipieca) best practices, among others.

Substances of concern and substances of very high concern

Pandora has not disclosed quantitative data on the total amounts of substances of concern (SoC) or substances of very high concern (SVHC) generated, used, or procured in tonnes for the reporting period.

Chemical management approach

Pandora's chemical management programme ensures adherence to global standards and compliance with local regulatory requirements, from raw materials to finished goods. The company is certified against ISO IEC 17025 (testing and calibration laboratories) and is the first company in Thailand, and one of the few globally within the jewellery manufacturing industry, to achieve this certification.

The chemical management approach is organised around three focus areas:

• Safer input: Safety data sheets are required, passed test certificates are obtained, and records of all substances are maintained. Non-compliant substances are discontinued after careful review.
• Safer process: Continuous progress is driven across four targets: zero accidents, zero health risks, zero waste and zero non-compliance, governed by ISO 45001 and 14001 certifications.
• Safer output: Wastewater is treated on-site before distribution to industrial treatment, with quality regularly monitored to meet or exceed local legal requirements. Hazardous waste is treated according to local legal requirements, including zero landfill.

REACH compliance and restricted substances

To help ensure regulatory compliance, Pandora applies comprehensive requirements for controlling and monitoring hazardous substances. The company's chemical requirements are based on its Restricted Substances List (RSL), which comprises substances restricted in usage pertaining to products and raw materials. The RSL is monitored by senior management in Crafting & Supply Quality and is aligned with regulatory requirements, including REACH (European Regulation (EC) No. 1907/2006 and its amendments REACH Annex XVII Item 63), and provides clear measures for chemical safeguards and workplace safety.

These safeguards extend beyond Pandora throughout the value chain and are communicated to suppliers as part of supplier contracts and sourcing documents. Suppliers must provide safety data for all substances, and test certificates are required as evidence of compliance. The health and safety impacts of products are continuously governed by the ISO 9001 certification of crafting facilities. As in previous years, there were no reported critical incidents of non-compliance concerning the health and safety impacts of products in 2024.

Future developments

Pandora continues to work in accordance with its "Together Towards Zero" campaign, focusing on zero accidents culture, zero health risks, zero waste and zero non-compliance. In 2025, the company will explore how to set targets to advance its chemical management programme. In 2024, Pandora updated its Global Environmental Policy, which guides work with all environmental topics, including chemicals, and serves as a foundation to develop future guidelines and frameworks.

Substances of concern and substances of very high concern

Roche disclosed narrative information regarding substances of very high concern (SVHC) in the context of process improvement and REACH compliance, but did not provide quantitative tonnage data for substances of concern or substances of very high concern.

Process improvement eliminating SVHC

In developing a novel antibacterial treatment, Roche optimised a complex, multi-step process (G2 process) that eliminated the use of three solvents on the REACH Candidate List of substances of very high concern for Authorisation:

• Dimethylacetamide (DMA)
• Dimethylformamide (DMF)
• 1,2-dimethoxyethane (DME)

This process optimization resulted in an increase in overall yield of 250%, while saving more than 90,000 kg of solvents required in the manufacturing of the drug substance. The improved process also reduced specific CO₂ emissions by 35% versus the previous (G1) process, which would avoid 14 kilotonnes of CO₂ emissions yearly based on current API forecast.

Risk assessment and compliance approach

Roche conducts environmental risk assessments to determine the impacts of particular chemicals and biomaterials on the environment and develops precautionary measures as a consequence.

Legislation calls for specific documentation for all chemicals and biomaterials handled at Roche sites. These documents include information such as hazard data and waste disposal guidance, and are made available online to employees, customers and the public.

Roche regularly performs safety, security, health and environmental protection (SHE) audits of its own business activities, supply chain and other service providers. The company expects that suppliers meet the same high SHE standards established for internal sites, checking their performance through audits at their facilities.

Substances of concern and substances of very high concern

Royal Schiphol Group references substances of very high concern (SVHCs) in the context of worker exposure risks and air quality impacts. The company states that it "remains highly focused on its impact on working conditions related to workers' exposure to emissions of UFPs and substances of very high concern." This impact extends to people working on platform, which is described as a small portion of RSG's own workforce.

The company has identified exposure to emissions of ultrafine particles (UFPs) and substances of very high concern as an actual negative impact (IRO 6) in relation to its own workforce. This is reflected in the strategy pillar Quality of Work and enabler Robust organisation.

RSG reports air pollution metrics including benzene, naphthalene and polycyclic aromatic hydrocarbons (PAHs), which are categorised as "zeer zorgwekkende stof" (ZZS) – the Dutch term for substances of very high concern as defined by RIVM:

The company notes that there are "additional pollutants in scope for ground operations due to health effects on our own workforce. This is due to the substances of very high concern reporting obligation."

RSG is working on initiatives to reduce exposure to emissions, including acquiring electric preconditioned air (PCA) units to reduce ground handlers' exposure to UFP emissions. By the end of 2024, 56 additional PCA units were operational.

The company also piloted a respiratory protection policy to minimise exposure to very dangerous materials and emissions for airside employees, though the pilot faced significant resistance from employees and supervisors.

No specific tonnages for total substances of concern generated, used or procured, or for total substances of very high concern, are disclosed.

Substances of Concern

Targets and Actions

• Tools deployed for efficient handling of product life cycle data
• Define and set target to minimise the use of "Target substances" (based on Product Compliance Programme outcome)
• Challenge to meet the targets in Scope 3 - use of products. Dependency on availability of Sustainable Aviation Fuel
• Phase out of substances of concern and substances of very high concern

Progress were made within "Substances of concern" however we did not accomplish internal targets. Saab will further focus on these areas in 2025.

Substances of concern and substances of very high concern

Policy and Management Approach

Our laboratory and manufacturing activities may require using some substances placed on the candidate list of substances of very high concern (SVHC) under the EU REACH regulation. All sites monitor compliance with emissions limits set in their respective operating permits. In all countries where we have business operations, we also seek to comply with applicable regulations regarding the use of these substances. A task force ensures a monitoring of SVHC-related regulatory developments, regular assessments of their impacts on our activities and develops plans to mitigate or prevent impacts. In line with our eco-design approach, we strive to reduce, minimize or replace the use of substances of very high concern by less hazardous substances when available and feasible, without compromising patients' access to medicines.

Targets

In line with our eco-design approach, we strive to reduce, minimize or replace the use of substances of very high concern by less hazardous substances when available and feasible, without compromising patients' access to medicines. No specific target has been set at global level. Substitution plans are engaged on a case by case basis in line with applicable regulations.

Quantitative Data

SVHC data reported here relate to our manufacturing operations and related activities and cover a list of 53 substances placed on the candidate list of substances of very high concern under the REACH regulation.

Methodology

A preliminary review of the candidate list of SVHC for authorization under the REACH regulation was done to identify those are the most likely used in Sanofi manufacturing activities. A list of 53 SVHCs was established based on the above mentioned review and was used as a basis for collecting and consolidating data from Sanofi manufacturing sites worldwide.

Amounts of SVHC procured and used cover SVHCs as such or in pre-identified mixtures in manufacturing operations and related activities (cleaning, quality control). Amounts of SVHC leaving facilities as part of products cover products for which the SVHC content is >0.1% (w/w). Amounts of SVHC that leave facilities as emissions (air / water) were calculated from regulatory monitoring data when applicable, or determined by mass-balance based on worst-case assumptions. For each category a reporting threshold of 1kg/y was applied.

For 2023, total amounts were consolidated from yearly figures provided by sites. For 2024, total amounts were determined from a consolidation of Q1 to Q3 figures provided by sites and an estimate of Q4 calculated as an average quarterly value from Q1 to Q3 data.

Substances of concern and substances of very high concern

Marketed products

Solvay decided to use the threshold value of 0.1% w/w for SoC as it is referenced in the REACH regulation for EU Substances of Very High Concern (SVHC).

The share of 2024 net sales made with:

Please refer to the next chapter for the full details of this entity specific disclosure.

Amount of SoC that are marketed as products or as part of products by hazard class category:

(*) Reference period for the analysis: January 1, 2024 - December 31, 2024.

(**) Category 1 as marketed products: 8,243 metric tons of substances referred to in Article 59(10) of the REACH Regulation (Candidate List) and 0.0 metric tons of substances referred to in Article 57 and Annex XIV of the REACH Regulation (Authorization List).

(***) Category 1 as part of marketed products: 0.0 metric tons of substances referred to in Article 59(10) of the REACH Regulation (Candidate List) and in Article 57 and Annex XIV of the REACH Regulation (Authorization List).

There is no amount of SoC that leaves Solvay's facilities as product or as part of product in the hazard class categories 3, 4, and 6.

Solvay - Substances Risk Monitoring (S-SRM) - Entity specific disclosure

Today, the "black list" and "red list" contain about 3,400 substances. In 2024, out of these 3,400 substances, 26 were present in Solvay-marketed products at a concentration of more than 0.1% w/w.

(*) According to the black and red S-SRM lists. S-SRMs manufactured by, or forming part of, the composition of products sold by Solvay worldwide. Reference period for the analysis: January 2023 - January 2024.

(**) Analysis of Safer Alternatives for potential substitution for black and red S-SRMs. A substance may be present in more than one product.

In 2024, Analysis of Safer Alternatives (ASA) was required and planned for a total of 20 combinations of products and applications. Of the 20 analyses of safer alternatives completed as of December 31, 2024, since the start of the program:

• Five have led to an effective replacement, either through a substitution, through a reduction below the required threshold, through a stop of production, or otherwise discarded as they became irrelevant to Solvay's activity.
• Three are ongoing, which means that an alternative has been identified and discussed with customers for implementation.
• 12 have resulted in no available alternatives, either because no substitute is available, because of regulatory obligations to use SVHC for some applications, or because an alternative has not been requested due to the application in the final product.

Raw materials

The perimeter of reporting this year is limited to raw materials labelled as SoC or SVHC and used in our European production plants. It excludes raw materials that are not labelled as SoC or SVHC but could contain SoC or SVHC.

We have been unable to reach a level of reasonable comfort to determine even a high-level estimate relating to such substances in our other locations outside Europe and with respect to raw materials which could partly include such substances, which would be relevant and useful to our readers in determining our full impact in tons, and which would adhere to the qualitative characteristics of information as prescribed in Appendix B of ESRS 2.

This is an area of significant management judgment, and we commit to improvements in our estimation process during 2025 when better data sources will become available with respect to substances of concern and very high concern, and which could result in a materially different outcome in 2025 with respect to substances of concern or very high concern data.

Amount of SoC procured products in 2024 by main hazard class category (European production plants perimeter only):

There is no amount of SoC that enters Solvay's European production facilities as a procured product in the hazard class categories 2, 3, 4, 5, 6 and 7.

Hazard class categories used for Marketed products and Raw materials

• Category 1:
  • Carcinogenicity, category 1
  • Germ cell mutagenicity, category 1
  • Reproductive toxicity, category 1
• Category 2: Chronic hazard to the aquatic environment, categories 1
• Category 3:
  • Endocrine disruption for human health, category 1
  • Endocrine disruption for the environment, category 1
• Category 4:
  • Persistent, Mobile, and Toxic or Very Persistent, Very Mobile properties
  • Persistent, Bioaccumulative, and Toxic or Very Persistent, Very Bioaccumulative properties
• Category 5:
  • Carcinogenicity, category 2
  • Germ cell mutagenicity, category 2
  • Reproductive toxicity, category 2
• Category 6:
  • Endocrine disruption for human health, category 2
  • Endocrine disruption for the environment, category 2
• Category 7:
  • Respiratory sensitization, category 1
  • Skin sensitization, category 1
  • Chronic hazard to the aquatic environment, categories 2 to 4
  • Hazardous to the ozone layer
  • Specific target organ toxicity, repeated exposure, categories 1 and 2
  • Specific target organ toxicity, single exposure, categories 1 and 2

Monitoring and management approach

Solvay identifies SoC and SVHC substances and runs risk monitoring processes to update risk studies and strive to substitute them with safer alternatives. In the supply chain, Solvay engages with suppliers to look for opportunities to prevent, reduce, and/or remediate pollution.

To ensure responsible stewardship over the life cycle of Solvay's products, the company takes actions focused on continuous improvement. Through Product Stewardship Management Systems, Solvay promotes the use of Solvay - Substances Risk monitoring (S-SRMs) to substitute substances whenever possible or reduce them below required levels, or halt production altogether. The internal list of SVHCs, S-SRMs, currently comprises approximately 3,400 substances identified as "black and red." In 2024, 26 of these substances were found in Solvay products at concentrations above 0.1% w/w, accounting for 4.7% of net sales.

Aside from the 26 products that are present on the black or red S-SRM lists, there is only one substance listed on the EU Candidate list: Bisphenol A. It appears on the black and red Solvay Substances Risk Monitoring (S-SRM) inventory because the analysis is done worldwide. However, it is neither marketed nor sold in the EU, and the global phasing out of Bisphenol A is effective from the end of 2024.

Solvay established its own reference list of substances of very high concern called "Solvay - Substances Risk Monitoring (S-SRM)" (previously called "Solvay - Substance of Very High Concern" (S-SVHC)) since 2015. This list is updated every year and includes two key categories:

• The so-called 'black list' includes all substances already undergoing a regulatory phase-out process with a known deadline in at least one country or zone across the world, or a restriction for uses relevant to Solvay.
• The so-called 'red list' includes all substances that could enter into a process of special authorization or restriction in the medium term.

The S-SRM methodology is part of the Global Policy - Health & Safety. It allows Solvay to control the potential risk of updates of hazard classification of substances in products, especially before they become Substances of Very High Concern (SVHC). S-SRM also allows Solvay to anticipate future regulatory expectations regarding SoC.

As part of the company's ambition, Solvay always strives to go beyond compliance with all relevant regional and national chemical regulations such as REACH (Registration, Evaluation, Authorization, and Restriction of Chemical Substances) or REACH-like regulatory frameworks all over the world. The ambition involves continuously lowering the presence of SVHC and SoC, whenever possible in all marketed products of the value chain. Solvay concentrates on SVHC from the EU REACH annex XIV and candidate list, while also monitoring S-SRM substances in marketed products for safer alternatives.

Substances of concern and substances of very high concern

TKH references hazardous substances in the context of supplier requirements. The Company's Code of Supply states that suppliers are expected to take all necessary actions to ensure consumer safety and that suppliers will ensure their products will not be made of hazardous substances as defined in EU Directive Restriction of Hazardous Substances (RoHS).

No quantitative data on the total amount of substances of concern (SoC) or substances of very high concern (SVHC) generated, used or procured has been disclosed. No breakdown by hazard class or amounts leaving facilities as emissions, products, or services has been provided.

The disclosure focuses on supply chain management and due diligence processes for copper and other materials, but does not include specific monitoring or management approaches for REACH compliance or SVHC tracking at the level required by ESRS E2-5.

Substances of concern and substances of very high concern

Policy and management approach

TotalEnergies monitors the use of substances of concern (SoC) and substances of very high concern (SVHC) across its operations, with particular focus on compliance with REACH regulations in Europe and equivalent frameworks in other regions.

Identification and listing

For operated sites:

• Hazardous products such as carcinogenic, mutagenic or toxic to reproduction (CMR) chemicals are listed and their risks identified as part of the One MAESTRO prevention framework
• In countries with no regulatory framework, criteria of minimum toxicity, minimum bioaccumulation potential and maximum biodegradability are used to select chemicals
• A documented chemical management procedure must be implemented to limit risks to the environment, taking into account selection, storage, transportation, use, possible associated emissions and disposal

For polymer production:

• The Company carries out continuous assessment of substances used, in compliance with the strictest local regulations for health and environmental protection, particularly REACH regulations in the EU where most operated production sites are located

For Marketing & Services products:

• Traceability of substances used and associated certifications are ensured from purchase to delivery of batches to customers
• Safety data sheets accompany petroleum and chemical products marketed by the Company
• Teams of regulatory experts, toxicologists and ecotoxicologists ensure preparation of safety documentation and REACH registration (or equivalent in other geographical regions)

Phase-out commitments

TotalEnergies is working to eliminate and/or replace, where possible, substances of concern and substances of very high concern. Action has been taken on operated facilities to:

• Eliminate asbestos: The Company prohibits the use of materials containing asbestos in new buildings and installations. These components are gradually being removed from plants as part of a comprehensive asbestos removal plan launched several years ago
• Eliminate PCBs (polychlorinated biphenyls): The Company prohibits the use of equipment containing PCBs. These components have been progressively eliminated from installations as part of a global PCB elimination plan launched several years ago
• Eliminate HFCs and HCFCs: In accordance with European Union regulations relating to fluorinated GHGs, the Company has banned since years the use of the targeted HFC and HCFC gases

Monitoring and reporting

Europe: In accordance with regulations, the Company's operated sites maintain an up-to-date list of substances of concern (SoC) and substances of very high concern (SVHC) present in their purchases and sales (with associated quantities).

Outside Europe: Regulations in force do not provide for similar monitoring. The Company has asked its operated sites located outside of Europe to engage in this process. Based on the data collected, it is not possible at this stage for the Company to publish an estimate of the quantities concerned in accordance with its quality assurance approach for published data.

Non-operated sites: The Company has questioned the operators of its non-operated sites to collect their information concerning SoC and SVHC. The operators of these sites are mainly located in countries not subject to European regulations and have no obligation to collect and make this information public. In 2024, less than 15% of third-party operated entities provided SoC and SVHC data, and the Company is therefore unable to publish this information. The Company has not identified any reasonable scientific basis for making estimates of these missing data at this stage.

Conclusion

TotalEnergies fully shares the desire to replace and/or minimize the use of substances of concern and to phase out the use of substances of very high concern in the industry. The Company regularly monitors product safety in order to eliminate and/or replace, where possible, substances of concern and extremely high concern that may be present in its industrial processes. However, quantitative disclosure of total SoC and SVHC tonnages is not yet available due to data collection challenges, particularly outside Europe and for non-operated sites.

Substances of concern and substances of very high concern

Analysis and prevention approach

In the field of chemical risk, the Group conducted an analysis on the issue of substances of concern and very high concern, through a prevention group dedicated to this subject, involving the main concerned departments (scientific and technical studies, business support, health and safety risks, procurement). After examining whether Veolia is affected by such substances, it appears to date that:

• With one exception detailed below, Veolia is not concerned with the production or marketing of these substances, and to our knowledge Veolia does not use them as input substances in technical processes;
• These substances may be involved in Veolia's operations in the form of input materials in the context of waste treatment activities, with the objective of eliminating them.

Regular investigations conducted by the chemical risk prevention group have identified the use of a substance of potential concern at one site. In order to preserve manufacturing secrets, Veolia wishes to keep precise information confidential.

As a precaution, Veolia is taking steps to replace this substance as soon as possible. Lastly, the process is designed not to discharge this substance and its residues into the site's environment.

Regulatory context

Veolia's activities are subject to comprehensive regulatory frameworks governing hazardous substances:

• REACH Regulation (EC) 1907/2006: Concerning the Registration, Evaluation, Authorization and Restriction of Chemicals. This regulation seeks to reduce the health and environmental risks associated with the manufacture and use of chemical substances and improve the management of these risks throughout the life cycle of chemical products. For the Group, as a user and producer of such substances, this involves greater cooperation and a better exchange of information with suppliers and customers.
• CLP Regulation (EC) 1272/2008: On Classification, Labeling and Packaging, harmonized the existing provisions and criteria concerning the classification, packaging and labeling of hazardous substances taking account of the adoption of the United Nations' Globally Harmonized System (GHS). As part of the Commission's strategy on sustainability in the area of chemical products, the CLP Regulation was amended by Regulation (EU) 2024/2865 of the European Parliament and of the Council of 23 October 2024.
• POPs Regulations: Regulation (EU) 2019/1021 of 20 June 2019 on persistent organic pollutants (Stockholm Convention) also has an impact on the Group's activities. Some PFAS are regulated under the REACH and POP regulations.

The relevant legal entities are in compliance with the schedule set by the REACH Regulation for chemicals requiring registration within the Group. After the systematic pre-registration of all substances that may be concerned, various deadlines are being monitored along with changes to the regulation and updates to its annexes.

Operational approach

Veolia's primary interaction with substances of very high concern occurs in the context of hazardous waste treatment activities, where the objective is to eliminate these substances. Veolia is the world leader in hazardous waste treatment, with extensive experience of all available techniques and the ability to operate them in a fully controlled manner.

No quantitative data on total amounts of substances of concern or substances of very high concern generated, used or procured has been disclosed in this report.

Anticipated Financial Effects from Pollution-Related Impacts:

Danone has assessed the financial implications of pollution-related impacts, risks, and opportunities as part of its comprehensive risk management and sustainability strategy.

Pollution-Related Risk Financial Impacts:

1. Regulatory Compliance Costs:

• Environmental regulation compliance across 151 production sites
• Packaging regulations requiring design changes and material costs
• Extended Producer Responsibility (EPR) fees and requirements
• Potential fines and penalties for environmental non-compliance
• CSRD and sustainability reporting compliance costs

2. Operational Impacts:

• Air pollution control system investments and maintenance
• Wastewater treatment infrastructure costs and upgrades
• Waste management system implementation and optimization
• Environmental remediation costs for historical contamination
• Production disruptions from pollution incidents

3. Raw Materials and Supply Chain:

• Premium costs for sustainable and non-polluting raw materials
• Agricultural pollution affecting raw material quality and pricing
• Supply chain disruption from environmental contamination
• Supplier environmental compliance support costs
• Alternative sourcing costs for pollution-affected materials

Pollution Prevention Investment Requirements:

1. Technology and Infrastructure:

• Renewable energy infrastructure (50% target by 2030)
• Wastewater treatment system improvements
• Air emission control technology deployment
• Waste management system optimization
• Environmental monitoring and control systems

2. Packaging Transformation:

• Alternative packaging material development costs
• Circular packaging design and implementation
• Collection and recovery system development
• Recycling infrastructure investment and partnerships
• Research & Innovation in sustainable packaging solutions

3. Agricultural and Supply Chain:

• Regenerative agriculture program investment
• Farmer training and support for pollution prevention
• Sustainable sourcing policy implementation costs
• Supply chain environmental compliance support
• Alternative ingredient development for reduced environmental impact

Pollution-Related Opportunities:

1. Market Differentiation:

• Premium pricing for environmentally superior products
• Market share gains from environmental leadership positioning
• B Corp™ certification competitive advantage
• Consumer preference for pollution-free products
• First-mover advantage in clean technology adoption

2. Operational Efficiency:

• Energy cost savings from renewable energy transition
• Waste reduction and resource efficiency improvements
• Process optimization reducing pollution and costs
• Circular economy cost savings and revenue generation
• Environmental management system efficiency gains

3. Risk Mitigation Benefits:

• Reduced environmental liability and insurance costs
• Lower regulatory non-compliance risk and associated costs
• Enhanced license to operate and community relations
• Supply chain resilience from environmental risk reduction
• Brand protection and reputation preservation

Financial Impact Quantification:

Investment Scale:

• Material costs represent 75% of cost of goods sold (€10 billion)
• Environmental investments integrated into capital allocation
• Research & Innovation budget allocation for environmental solutions
• Partnership investments in pollution prevention technologies

Cost Mitigation:

• Energy cost savings from renewable energy (50% by 2030)
• Material efficiency improvements reducing raw material costs
• Waste reduction saving disposal and management costs
• Regulatory compliance proactivity reducing penalty risks

Revenue Enhancement:

• Market opportunities from environmental product positioning
• New product categories addressing environmental concerns
• Partnership revenue from environmental technology development
• Circular economy business model revenue streams

Risk Management Integration:

Financial Planning:

• Environmental costs integrated into annual budgeting
• Capital allocation prioritizing pollution prevention projects
• Insurance and contingency planning for environmental risks
• Long-term financial planning incorporating environmental trends

Performance Monitoring:

• Regular assessment of environmental cost and benefit impacts
• ROI analysis of pollution prevention investments
• Financial materiality assessment of environmental risks
• Stakeholder value creation from environmental performance

Strategic Alignment:

• Environmental investments aligned with business strategy
• Pollution prevention integrated into value creation model
• Long-term financial resilience through environmental stewardship
• Competitive advantage development through environmental excellence

Financial Effects from Pollution-related Impacts

Compliance Costs: Reputational and legal fine/action risk due to non-compliance with water-related regulations or increased scrutiny on water usage leads to higher costs of compliance because of additional measures, policies and programmes, as well as costs to comply with updated regulations, or litigation costs, fines or penalties if not met or not compliant.

Revenue Impact: Non-compliance also leads to loss of revenue due to reputational damage and adverse reactions from customers.

Infrastructure Investment: Significant investments are required to improve water efficiency in water-stressed areas (e.g. improving and monitoring of water treatment where water is a constrained resource, particularly in California, US). This leads to increased operational costs due to new infrastructure investments needed.