If a topic other than climate change is deemed not material and its corresponding ESRS disclosures are omitted, a brief explanation of the materiality assessment conclusions may be provided.

If the company has determined that any of the ESRS topics below are not material, it must provide a clear and well-reasoned explanation based on the materiality assessment process. Each explanation should include: 1. Methodology for Materiality Assessment Describe the criteria and process used to evaluate the materiality of the ESRS topic. Specify whether the assessment covered: Impact materiality (effects on people and the environment). Financial materiality (effects on business, financial position, and cash flows). 2. Findings of the Materiality Assessment Explain why the specific ESRS topic is not considered material for the company. Provide evidence or justifications, such as: No significant business operations in sectors highly exposed to the topic. No significant impacts, risks, or opportunities identified through due diligence or stakeholder engagement. No regulatory or investor concerns indicating material exposure. Topic-Specific Considerations ESRS E2 – Pollution Justify why the company’s operations, products, or value chain do not generate significant air, water, or soil pollution. Confirm whether emissions, hazardous waste, or pollutants are below industry thresholds or well-managed. State whether sectoral regulations do not impose significant reporting obligations. ESRS E3 – Water and Marine Resources Explain why water usage or marine resource dependency is not material (e.g., operations are in low-water-risk areas, minimal water consumption, no marine impact). Confirm whether the company’s water withdrawals, discharges, or consumption do not pose a material risk or impact. ESRS E4 – Biodiversity and Ecosystems Justify the lack of material impact on biodiversity (e.g., no operations in biodiversity-sensitive areas, no direct contribution to deforestation or habitat destruction). Explain how existing measures (e.g., sustainable sourcing policies) mitigate potential risks. ESRS E5 – Circular Economy Explain why circular economy principles (e.g., waste reduction, recycling, resource efficiency) are not materially relevant to the company’s business model. Confirm whether the company’s waste generation or resource consumption is minimal or already aligned with sustainability best practices. ESRS S1 – Own Workforce Explain why workforce-related sustainability matters (e.g., fair wages, diversity, working conditions) are not material. Confirm whether employment policies, legal protections, and social risks are already well-managed or do not present a significant challenge. ESRS S2 – Workers in the Value Chain Justify why supply chain labor conditions do not pose material risks (e.g., no reliance on high-risk suppliers, strong due diligence, industry certifications). Confirm whether human rights risks, labor rights issues, or supplier dependencies are minimal. ESRS S3 – Affected Communities Explain why the company’s operations do not materially impact local communities (e.g., no land use conflicts, no significant social or environmental footprint). Confirm whether community engagement or social risks are limited due to business model, location, or industry characteristics. ESRS S4 – Consumers and End-Users Justify why consumer-related sustainability concerns (e.g., product safety, ethical marketing, data privacy) are not material. Confirm whether the company’s products/services do not pose significant health, safety, or ethical risks. ESRS G1 – Business Conduct Explain why corporate governance, anti-corruption, or ethical business practices are not material concerns. Confirm whether the company operates in low-risk regulatory environments or has strong governance frameworks that mitigate concerns. 3. Future Considerations & Monitoring Confirm whether the company will periodically reassess the materiality of the ESRS topics. If relevant, provide triggers for reassessment, such as regulatory changes, market shifts, or business expansion. https://xbrl.efrag.org/e-esrs/esrs-set1-2023.html#722